New Zealand Privacy Policy
Date: 29 January 2018
Verified NZ Limited (New Zealand Company Number) ("Verified NZ, our, we or us"), is a private entity who operates as a identity and background verification services provider for businesses and agencies.
Verified NZ is an entity within the Verified Global Pte Ltd Group of companies registered in the BVI.
Verified NZ is committed to protecting your personal information and complying with Privacy at the highest level whilst carrying out its business operations in accordance with the New Zealand Privacy Act 1993. We understands the importance of protecting the privacy of individuals. This privacy policy has been created to help you understand how we collect, use and protect your information when you visit our web sites and use our products and services.
This policy is provided for your information and doesn’t limit or exclude your rights under the Privacy Act 1993.
This Privacy Policy is divided into 5 principal sections:
- Section 1 – Visitors;
- Section 2 – Trial Users;
- Section 3 – Individual Users;
- Section 4 – Organisation Representatives; and
- Section 5 – General Provisions.
If you would like us to send you a PDF copy of this Privacy Policy (at no charge), please use the contact details at the end of this Privacy Policy to request a copy. If you require a copy of this Privacy Policy in a different format, Verified will use its reasonable efforts to comply with your request. If we cannot supply a copy of the Privacy Policy in the format you have requested, we will contact you to discuss your requirements and attempt to identify and agree an alternative format in which the copy of the Privacy Policy can be provided to you.
Verified NZ welcomes your comments on this Privacy Policy. If you would like to make a comment, you should contact us using the contact details set out in the Contact Details section of this Privacy Policy.
1. Visitors
A visitor is a person who visits our website or otherwise contacts us but to whom Verified NZ does not provide any goods or services or who does not undertake a trial of any products or services provided by us (Visitor).
We do not attempt to identify a Visitor when the Visitor is accessing the website or otherwise contacting Verified NZ except where the Visitor wishes to undertake a trial of any of our services (in which case, you should refer to section 2 of this Privacy Policy). Verified NZ will not collect personal information about any Visitor unless the Visitor expressly provides this to us (for example, by sending an email or completing an online registration form or online inquiry form).
If a Visitor wishes to undertake a Trial, the Visitor cannot undertake the Trial unless the Visitor provides an email address.
Where possible, our systems will allow a Visitor to communicate with Verified NZ on an anonymous basis or by using a pseudonym.
2. Trial Users
A trial user is a person who visits the Verified NZ website or otherwise contacts us and undertakes a trial of any products or services provided by Verified NZ or visits the public demonstration pages of our website (Trial User).
A Trial User will only be able to undertake a trial of products or services provided by us if the Trial User provides identifying details.
This section is divided into the following subsections:
- Why we collects personal information;
- What personal information Verified NZ collects;
- How Verified NZ collects personal information of an Trial Users;
- How Verified NZ collects personal information of Trial Users;
- How Verified NZ uses personal information of Trial Users; and
- Disposal or destruction of personal information of Trial Users.
2.1 Why we collect personal information
Verified NZ collects personal information of Trial Users:
- to confirm that the Trial User is a person who wishes to use the products and services of Verified NZ on a trial basis; and
- for the purposes of communicating with the Trial User.
2.2 What personal information Verified NZ collects
Verified NZ collects only the Trial User’s email address. It is not possible to undertake a trial of any products or services provided by Verified NZ or visits the public demonstration pages of Verified NZ’s website unless a user provides the user’s email address. Therefore, it will not be possible for a Trial User to communicate with Verified NZ on an anonymous basis or using a pseudonym.
2.3 How Verified NZ collects personal information of Trial Users
Verified NZ will collect information directly from each Trial User.
2.4 How Verified NZ obtains consent from Trial User
In most cases, either before or at the time of collecting the personal information, Verified NZ will obtain the consent of the Trial User to collect the personal information.
2.5 How Verified NZ uses personal information of Trial Users
Verified NZ will use the personal information to monitor usage patterns, to determine whether the Trial User is a genuine user of the trial products and services and to communicate with the Trial User including for the purposes of marketing.
Verified NZ will not disclose any personal information to any individual or entity without the express permission of the Trial User unless required to do so by law (refer clause 5.4).
2.6 Disposal or destruction of personal information
Verified NZ will delete all personal information at the conclusion of the trial arrangement except in those cases where Verified NZ is required to maintain a record.
3. Individual Users
An Individual User is a person who visits Verified NZ’s website or otherwise contacts Verified NZ and to whom Verified NZ provides products or services.
Verified NZ’s identity verification service is a service which verifies the identity of an Individual User thereby allowing the Individual User to prove that the Individual User is who the individual says he or she is including to allow the Individual User to electronically present himself or herself to a trusted independent entity with whom the Individual User may already have a relationship.
This section is divided into the following subsections:
- Why Verified NZ collects personal information;
- What personal information Verified NZ collects;
- How Verified NZ collects personal information of Individual Users;
- How Verified NZ uses personal information of an Individual User;
- Access to personal information;
- Disposal or destruction of personal information.
3.1 Why Verified NZ collects personal information
Verified NZ collects personal information of Individual Users:
- to provide identity verification services to the Individual Users;
- for the purposes of communicating with the Individual User;
- for the purpose of providing information to specific organisations with whom an Individual User has authorised Verified NZ to communicate;
- for the purpose of providing information to government, law enforcement or statutory bodies when ordered to do so; and
- to provide services related to the services and purposes described above.
To provide the Verified NZ’s identity verification service, the information collected by Verified NZ is compared against an information database.
Verified NZ also collects such personal information of Individual Users as is reasonably necessary to undertake a necessary function or activity (for example, to manage and administer Verified NZ and conduct its business).
3.2 What personal information Verified NZ collects
Verified NZ collects the following information about Individual Users:
- Name;
- Date of Birth;
- Latest Address;
- Previous Addresses;
- Gender;
- Home phone number;
- Mobile phone number;
- Email address;
- Driver's Licence Details;
- Pasport and Visa Details;
- Current Occupation
- Previous Occupation
- time and date of use of Verified NZ;
Additional information may be required depending on the services which the Individual User wishes to acquire from Verified NZ and Verified NZ will, notify the Individual User of the requirement to collect this additional information as specified in section 3.4 of this Privacy Policy.
Where possible, Verified NZ’s systems will allow an Individual User who wishes to communicate with Verified NZ on an anonymous basis or by using a pseudonym. However, it will not be possible for an Individual User to communicate with Verified NZ on an anonymous basis or using a pseudonym if the Individual User requires assistance in relation to its account or the information which it has provided to Verified NZ for the purposes of establishing or using its account.
3.3 How Verified NZ collects personal information of Individual Users
Verified NZ will collect information directly from each Individual User, from third parties whom the Individual User has authorised Verified NZ to contact, from our subscribers (who are banks, finance houses and other credit providers), or from public sources.
We may also use information from publicly available publications such as the Mercantile Gazette and public register databases, as well as social media feeds such as Facebook and Twitter.
3.4 How Verified NZ obtains consent from an Individual User
In most cases, either before or at the time of collecting the personal information, Verified NZ will obtain the consent of the Individual User to the collection of the personal information. If Verified NZ cannot obtain the consent of the Individual User before or at the time of collection, it will obtain consent as soon as practical after the collection.
3.5 How Verified NZ uses personal information of an Individual User
The Verified NZ service enables an Individual User to use the Individual User’s personal information for the Individual User’s own purposes. Verified NZ uses the personal information of an Individual User as required to provide products and services to the Individual User. This may include disclosure of personal information to persons whom the Individual User has authorised Verified NZ to contact or provide the personal information for the purposes of providing the verification service to the Individual User.
Verified NZ will not disclose any personal information to any individual or entity without the express permission of the Individual User unless required to do so by law (refer clause 5.4).
3.6 Access to personal information
Individual Users may access all the personal information they have provided to Verified NZ or which Verified NZ has collected and may update or delete it except in those cases where Verified NZ or an organisation to which Verified NZ has provided the personal information as part of Verified NZ’s provision of the verification services is required to maintain a record. This includes retention of records for compliance with the Anti-Money Laundering and Countering Financing of Terrorism Act 2014 or other laws or regulations.
3.7 Disposal or destruction of personal information
Verified NZ will delete all personal information at the conclusion of the Individual User’s arrangements with Verified NZ except in those cases where Verified NZ is required to maintain a record.
4. Organisation Representatives
An Organisation Representative is a person who is dealing with Verified NZ in his or her capacity as the representative of an organisation who has appointed Verified NZ as its Intermediary for the purposes of the New Zealand Identity Information Confirmation Service and who is authorised to act on behalf of the organisation.
This section is divided into the following subsections:
- Why Verified NZ collects personal information;
- What personal information Verified NZ collects;
- How Verified NZ collects personal information of an Organisation Representative;
- How Verified NZ uses personal information of an Organisation Representative;
- Access to personal information;
- Disposal or destruction of personal information.
4.1 Why Verified NZ collects personal information
Verified NZ collects personal information of an Organisation Representative:
- to provide services to the organisation which the Organisation Representative represents;
- for the purposes of communicating with the Organisation Representative and the organisation which the Organisation Representative represents;
- for the purpose of managing Verified NZ’s contract with the organisation which the Organisation Representative represents; and
- to provide services related to the services and purposes described above.
Verified NZ also collects personal information of Organisation Representatives which is reasonably necessary to undertake a necessary function or activity (for example, to manage and administer Verified NZ and conduct its business).
4.2 What personal information Verified NZ collects
Verified NZ collects the following information about Organisation Representatives:
- name;
- address;
- birth date;
- email;
- telephone number;
- fax number; and
- name of the organisation which the Organisation Representative is representing and other information which is required to identify the organisation including Incorporation Number, NZBN, address, telephone number; fax number and website.
Where possible, Verified NZ’s systems will allow an Organisation Representative to communicate with Verified NZ on an anonymous basis or by using a pseudonym. However, it will not be possible for an Organisation Representative to communicate with Verified NZ on an anonymous basis or using a pseudonym if the Organisation Representative requires assistance in relation to Verified NZ’s arrangements with the organisation which the Organisation Representative represents or the Organisation Representative’s account.
4.3 How Verified NZ collects personal information of an Organisation Representative
Verified NZ will collect information directly from each Organisation Representative.
4.4 How Verified NZ obtains consent from an Organisation Representative
In most cases, either before or at the time of collecting the personal information, Verified NZ will obtain the consent of the Organisation Representative to the collection of the personal information. If Verified NZ cannot obtain the consent of the Organisation Representative, it will obtain consent as soon as practical after the collection.
4.5 How Verified NZ uses personal information of an Organisation Representative
Verified NZ does not anticipate disclosing the personal information of an Organisation Representative to enable Verified NZ to provide products and services to the organisation which the Organisation Representative represents.
4.6 Access to personal information
Organisation Representative may access all the personal information they have provided to Verified NZ or which Verified NZ has collected and may update this information and update it or delete it except in those cases where Verified NZ is required to maintain a record.
4.7 Disposal or destruction of personal information
Verified NZ will delete all personal information:
- at the conclusion of the arrangements between Verified NZ and the organisation which the Organisation Representative represents except in those cases where Verified NZ is required to maintain a record; or
- when the Organisation Representative notifies Verified NZ that it is no longer the representative of the organisation; or
-
when the organisation which the Organisation Representative represents notifies Verified NZ that it is no longer the representative of the organisation,
except in those cases where Verified NZ is required to maintain a record.
5. Provisions applicable to all persons from whom Verified NZ collects personal information
This section is divided into the following subsections:
- Unsolicited personal information;
- Usage patterns;
- Cookies;
- Disclosure of personal information by Verified NZ;
- Transfer of personal information outside Australia;
- Data security and data storage;
- Government related Unique Identifiers;
- Concerns about personal information;
- Response to request for access to personal information;
- Process for accessing personal information;
- Refusing access to personal information;
- Quality of personal information and correction of personal information;
- Complaints;
- Changes to Privacy Policy; and
- Contact details.
5.1 Unsolicited personal information
There may be situations in which Verified NZ receives personal information about a person even though Verified NZ has not requested any personal information about an individual or has not requested the particular information which has been received about an individual (unsolicited personal information).
If Verified NZ receives any unsolicited personal information, it will, within a reasonable period of receipt of the unsolicited personal information, review the unsolicited personal information to determine if it is reasonably necessary for its functions. If it is, Verified NZ will handle the information in the same way as it handles the information we collect from a person. If Verified NZ does not need the information, Verified NZ will destroy the information or de-identify it.
5.2 Usage Patterns
Verified NZ’s web server collects information on the usage patterns of people visiting Verified NZ’s website. The information is collected each time a user visits Verified NZ’s website. Except in relation to a Trial User, it is not used to identify browsing activities of any individual user but is collected for statistical purposes. The information collected consists of:
- the date and time of visits;
- number of users who visit the website;
- traffic patterns and pages viewed.
This data will be used to research Verified NZ’s website and product and to evaluate, develop and improve its usability.
5.3 Cookies
Verified NZ’s website uses session based cookies to keep Individual Users and Organisation Representatives logged in during a session. No other cookies or trackers are used.
5.4 Disclosure of personal information by Verified NZ
Verified NZ will not disclose information that identifies an individual, or enables an individual to be identified except as:
- specified in this Privacy Policy;
- authorised by the individual;
- as required under applicable laws; or
- as directed by courts, tribunals or other bodies having authority over Verified NZ.
5.5 Transfer of personal information outside New Zealand
In providing verification services to an Individual User, Verified NZ will be required to transfer personal information of an Individual User outside New Zealand if the Individual User provides verification information from a country other than New Zealand. In this instance, personal information will be transferred by Verified NZ to the country from which the verification information provided by the Individual User originates. By giving Verified NZ your personal information, you consent to such transfer and disclosure. In addition, we believe that the recipients of such information are subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the applicable New Zealand information privacy laws.
5.6 Data security and storage
All personal information held by Verified NZ is protected from unauthorised access through the use of secure passwords and user logons and other forms of biometric verification.
Verified NZ stores all personal information that it collects securely in a manner that is sufficient to prevent misuse and loss, unauthorised access, modification or disclosure of personal information. Verified NZ maintains a high level of data security by implementing:
- physical security to prevent unauthorised entry to our premises, by installing systems to detect unauthorised access and secure containers for storing paper-based personal information;
- computer and network security to protect computer systems and networks for storing, processing and transmitting personal information;
- communications security to protect communications via data transmission and to prevent unauthorised intrusion into our computer network
- personnel security, through Verified NZ’s personnel security measures and background checking procedures to limit access to personal information only by authorised staff and for only approved purposes.
5.7 Government related identifiers
Verified NZ does not use or disclose any government unique identifier or unique identifier issued by another person or agency.
5.8 Concerns about personal information
Users can contact Verified NZ to address any concerns that they have about their personal information.
If you would like access to the personal information which Verified NZ holds about you or a person whom you are authorised to represent, please contact Verified NZ using the contact details set out in the Contact Details section of this Privacy Policy. Your request should specify the format in which you wish to be provided the personal information (for example, in person, by email, by telephone, hard copy or other electronic record). This application is free of charge. However, Verified NZ may make a reasonable charge for providing access to you in the event that there is a cost to Verified NZ in relation to labour and materials required to make the information available to you, or any cost incurred as a result of your request being treated as urgent. If Verified NZ wishes to charge you to access the personal information, Verified NZ will notify you of this charge prior to making the personal information available to you.
5.9 Response to request for access to personal information
If you make a request to access personal information, Verified NZ will respond to your request as soon as reasonably practicable and in any case within 20 working days of receipt of your request. If Verified NZ cannot respond within this period, Verified NZ will notify you of the delay, the reasons for the delay and the date by which Verified NZ will provide a response.
5.10 Process for accessing personal information
If Verified NZ agrees to give you access to your personal information, the following process will apply:
- No charge for access – Verified NZ will notify you of its decision and (where you have requested that the information be provided to you by email, hard copy or other record that can be delivered to or sent to you), Verified NZ will also provide the personal information to you at the same time (except as set out below)
- Access charge – Verified NZ will notify you of its decision and the proposed charge for giving you access and the payment terms and method of payment. If you wish to discuss the proposed charge with Verified NZ, you should contact the Verified NZ representative nominated in the notice. Once you have paid the access charge), Verified NZ will provide the personal information to you (except as set out below).
- Form of access if different from format requested – If Verified NZ concludes acting reasonably, that it is not possible or practicable for Verified NZ to provide the personal information in the format you have requested (for example because of the volume or nature of the personal information or your needs), Verified NZ will contact you to agree a format in which Verified NZ can give you access to the personal information. If you have requested access by in person or by telephone, Verified NZ will contact you to arrange the time and place at which you may access the personal information.
5.11 Refusing access to personal information
Verified NZ is entitled to refuse a request for access in the circumstances specified in Part 4 of the New Zealand Privacy Act. If Verified NZ decides to refuse your request, Verified NZ will notify you of its reasons (except where it is permitted to refuse to provide reasons). Verified NZ will consult with you to identify an alternative means of giving you access to the personal information which may include reducing the scope of request or giving you access through an agreed intermediary.
If you disagree with Verified NZ, you may make a complaint as described in the Complaints section of this Privacy Policy.
5.12 Quality of personal information and correction of personal information
Verified NZ makes reasonable efforts to ensure that the information that it collects is accurate, up-to-date, complete and relevant both at the time of initial collection and during the period that Verified NZ holds the personal information.
If you consider that any personal information that Verified NZ holds about you is inaccurate, out-of-date, incomplete, irrelevant or misleading and you wish to have the information corrected, you should contact Verified NZ using the contact details set out in the Contact Details section of this Privacy Policy. Verified NZ will respond to your request within 20 working days of the date of receipt of the request. This application is free of charge.
If Verified NZ accepts the request, it will take such steps as are reasonable in the circumstances to correct the information to ensure that, having regard for the reasons for which the information is held, the information is inaccurate, out-of-date, incomplete, relevant and not misleading.
If Verified NZ refuses the request:
- Verified NZ will send you a written notice explaining the reasons for the refusal (except where it is unreasonable to provide an explanation), the complaint mechanism which you may follow and other matters which Verified NZ is required to include; and
- you may request that Verified NZ associate with the personal information a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading. Verified NZ will take reasonable steps (given the circumstances) to associate the statement in such a way to make it apparent to users of the information.
5.13 Complaints
If you wish to make a complaint about:
- this Privacy Policy;
- the manner in which Verified NZ has implemented this Privacy Policy; or
- any other matter relating to the personal information Verified NZ holds about you or your dealings with Verified NZ in relation to your personal information,
please contact Verified NZ using the contact details set out in the Contact Details section of this Privacy Policy. All complaints will be considered by Verified NZ’s privacy officer who may contact you to obtain further details of your complaint and to better understand your complaint so that it resolved as quickly as possible.
Verified NZ aims to resolve all disputes in a manner which is satisfactory to both you and Verified NZ. There may be circumstances where you are not satisfied with the manner in which Verified NZ has resolved your complaint. If you are not satisfied with the manner in which Verified NZ deals with your complaint, you may complain to the New Zealand Office of the Privacy Commissioner (see http://www.privacy.org.nz).
5.14 Changes to this Privacy Policy
Verified NZ reserves the right to change this Privacy Policy as required to maintain compliance with the New Zealand Information Privacy Principles and other applicable laws, to comply with changes in technology or to facilitate changes in its business. Verified NZ will, if possible, give prior notice of its intention to change this Privacy Policy. If Verified NZ considers it necessary, it will consult with the New Zealand Office of the Privacy Commissioner or other appropriate government representatives and other representative groups before implementing any change to this Privacy Policy. However, there may be circumstances where Verified NZ considers that prior notice or prior consultation is not required or where it is not possible for Verified NZ to give prior notice of a change to this Privacy Policy or undertake consultation before changing this Privacy Policy.
When this Privacy Policy is updated, those updates will appear on this page. Verified NZ will ensure that changes to this Privacy Policy are identified in each update. Verified NZ will also ensure that prior versions of the Privacy Policy can be accessed.
5.15 Contact details
If you have any questions or comments about this Privacy Policy, would like to request a copy, request access to personal information held about you or make a complaint, please contact:
The Privacy Officer
Verified NZ Limited
PO Box 76103
Christchurch
New Zealand
e-mail: [email protected]
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