1. We respect your privacy
- 1.1. Vine Digital Limited respects your privacy and is committed to safeguarding the privacy of our customers and website visitors. We adhere to the New Zealnd Privacy Principles contained in the Privacy Act 1993 (Privacy Act). This policy sets out how we collect and treat your personal information.
- 1.2. “Personal information” is information we hold which is reasonably identifiable as being about you.
- 1.3. In addition to New Zealand laws, individuals located in the European Union (EU) may also have rights under the General Data Protection Regulation 2016/679 (GDPR). Sometimes, we assist clients that need to comply with the GDPR by agreeing to comply with the GDPR solely as their processor. Appendix 1 provides an overview of how we process the personal information of individuals located in the EU when we have agreed to act as a processor for a client, in accordance with the GDPR.
2. Collection of personal information
- 2.1. Vine Digital Limited will, from time to time, receive and store personal information you enter onto our website, provided to us directly, which we request or given to us in other forms.
- 2.2. You may provide basic information such as your name, phone number, address and email address to enable us to send information, provide updates and process your product or service order. We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.
- 2.3. Additionally, we may also collect any other information you provide while interacting with us.
3. How we collect your personal information
4. Use of your personal information
- 4.1. Vine Digital Limited may use personal information collected from you to provide you with information, updates and our services. We may also make you aware of new and additional products, services and opportunities available to you. We may use your personal information to improve our products and services and better understand your needs.
- 4.2. Vine Digital Limited may contact you by a variety of measures including, but not limited to telephone, email, sms or mail.
5. Disclosure of your personal information
- 5.1. We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Policy. Personal information is only supplied to a third party when it is for internal business purposes (such as invoicing) or for the purpose of the delivery of our services.
- 5.2. We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.
- 5.3. We may also use your personal information to protect the copyright, trademarks, legal rights, property or safety of Vine Digital Limited, vinedigital.co.nz, its customers or third parties.
- 5.4. Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of New Zealand. Where the disclosure of your personal information is subject to New Zealand privacy laws, you acknowledge that some third parties may not be regulated by the Privacy Act and the New Zealand Privacy Principles in the Privacy Act and if any such third party engages in any act or practice that contravenes the New Zealand Privacy Principles, it would not be accountable under the Privacy Act and you will not be able to seek redress under the Privacy Act.
- 5.5. If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.
6. How we treat personal information that is also sensitive information
- 6.1. Sensitive information is a sub-set of personal information that is given a higher level of protection under the New Zealand Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation, sexual practices or sex life, criminal records, health information or biometric information.
- 6.2. We do not currently collect sensitive information. However, if we do require sensitive information:
- if we collect the sensitive information directly from you we will not collect this sensitive information about you without first obtaining your consent; or
- when providing services to our clients, if we collect sensitive information about you from our clients, we will always require that they have obtained your consent.
- 6.3. Provided you consent, your sensitive information may only be used and disclosed for purposes directly related to the primary purpose for which the sensitive information was collected.
- 6.4. Sensitive information may also be used or disclosed if required or authorised by law.
7. Security of your personal information
- 7.1. Vine Digital Limited is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
8. Access to your personal information and correction of your personal information
- 8.1. You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act . A small administrative fee may be payable for the provision of information. If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at email@example.com. 8.2. We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act.
9. Complaints about privacy
- 9.1. If you have any complaints about our privacy practices, please feel free to send in details of your complaints to our Head Office at 8 Help St, Chatswood, New South Wales 2067, Australia. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.
- 11.1.When you visit our website
- When you come to our website (vinedigital.co.nz) we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.
- 11.4. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website.
- 11.5. Third party sites
- Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Vine Digital Limited is not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.
For any questions or notices, please contact our Privacy Officer at:
Address: 8 Help St, Chatswood, New South Wales 2067, Australia
Last update: 26 November 2019
APPENDIX 1 – HOW WE PROCESS PERSONAL INFORMATION AS A PROCESSOR UNDER THE GDPR
Under the GDPR individuals located in the EU have extra rights which apply to their personal information. Personal information under the GDPR is often referred to as personal data and is defined as information relating to an identified or identifiable natural person (individual).
If we are asked to comply with the GDPR by a client, we may agree to do so, but solely as a processor.
What personal information is relevant?
How we process personal information
If we are acting as a processor, we are handling information solely on the instructions of the controller. If we have agreed to act as a processor and we have received your personal information from our client or on behalf of our client, our client is in control of that information. To understand how your personal information is processed, please contact the relevant controller.
Where we agree to act as a processor, we will only retain your personal information for the duration of the processing activities we are carrying out on behalf of the relevant client (controller), or as long as necessary for the purposes of satisfying any legal, accounting, or reporting requirements.
In some circumstances we may anonymise your personal information (so that it can no longer be associated with you) for analytics, research or statistical purposes in which case we may use this anonymised information indefinitely without further notice to you.
Extra rights for EU individuals
If your information has been provided to us by one of our clients or collected by us on behalf of one of our clients, to exercise any privacy rights you may have under the GDPR, please contact the relevant controller. You may ask them to stop processing your information, restrict the processing of your information, allow you to access, erase or port your information, or rectify any of your information. We will provide reasonable assistance to the controller where we have agreed to act as a processor and where requested to do so by the controller.