1 What is this Privacy Statement about?
Clever Core respects your rights to privacy. We know your privacy is important to you. That’s why we protect it and are clear and open about what we do with it.
This Privacy Statement applies to all our businesses and their interactions with you. It describes how we collect, use and manage your personal information. We collect the personal information we need to provide our products, services, work with our customers and conduct our business operations. Credit information will be dealt with in accordance with this Privacy Statement and our Credit Reporting Policy applicable at the time of your application for commercial credit.
2 What is your personal information?
“Personal Information” is a term defined in New Zealand and Australian Privacy Acts. In general terms, it is any information that can be used to personally identify you. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.
3 What kinds of personal information do we collect and hold?
The personal information that we may collect and hold includes the following:
- name, address and contact details (such as telephone numbers and email addresses);
- date of birth;
- employment history, educational qualifications and income details;
- government related identifiers (eg. IRD and tax file number and driver’s licence information);
- financial information;
- details of the products and services provided to you by us; and
- other personal information you voluntarily provide to us during the course of interacting with us.
We may also collect sensitive information, such as membership of a trade union or professional association, and health information (for example for the purposes of contact tracing related to Covid-19, or if you access our sites or operate our equipment). We will only collect this type of personal information with your consent.
In your interactions with us, we may include links to various third party websites. If we do that, the third parties will be responsible for their content and what they do with any personal information they collect.
4 How do we collect your personal information?
We usually collect personal information directly from you unless it is unreasonable or impracticable to do so or unless otherwise expressly authorised by you. When we collect personal information, we may do so when you communicate or interact with us, such as when you:
- engage with us via correspondence such as purchase orders, requests for quotes, telephone conversations and emails;
- make inquiries about us, our products and services or contact us for any other reason so that we can process, deal with and respond to your queries or other issues including any complaints;
- contact, register with, post to, like or follow any of our social media websites, pages, forums or blogs;
- answer a survey or question we ask;
- apply for commercial credit;
- use or register on any of our websites;
- register a product you have purchased or subscribe to any of our services (including rebates or loyalty programmes);
- register for or attend any of our events;
- attend any of our sites or locations;• make applications for prospective employment and contracting opportunities with us; or
- subscribe to a newsletter, fill out a form or survey, enter or participate in any competitions or promotions.
The collection of personal information on our website, via promotions or our social media pages will be clear from the context (e.g. request to complete information fields) or will state that personal information is being collected at the point of collection.
In addition we may collect information through click tracking (in relation to your use of one of our websites including the content you access and any services you utilise) and through log files or cookies (as further detailed below).
In some instances, we may collect personal information about you from third parties, such as wholesale and retail suppliers of home building, renovating and design related products or services, where you have made inquiries about our products or services to the third parties. Also, we may collect personal information about you from recruitment agencies, marketing agencies, labour hire providers, your employer or from third party medical service providers (which provide medical reports, medical or other services like legal or financial services to us) or credit rating or similar services. In such circumstances, we are relying on the third party to have obtained your consent. We may also collect your personal information from publicly available resources.
5 What happens if you do not provide your personal information to us?
If you choose not to provide personal information that we request in connection with our business functions and activities, we may not be able to provide some or all of our products or services to you, engage with you as intended or be able to respond and assist in the manner required. We also may not be able to provide you with information about products and services that you may want or otherwise respond to you in the way we would otherwise have liked.
6 How we hold your personal information?
All personal information you provide to us is stored securely. We store most of our personal information in New Zealand or in Australia. We store personal information electronically and physically. We may use a variety of security techniques, including encryption and authentication, to help with the protection and to maintain the availability, security and integrity of your personal information.
We are committed to protecting your information through the following measures:
- restricting access to your personal information to only those who need to use it for the relevant purpose;
- preventing unauthorised access to IT systems by using firewalls; and
- regular monitoring of IT systems to detect and stop misuse of personal information.
When we transfer information outside Clever Core, our contract with that recipient will require them to protect your personal information.
As our websites are linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
7 Why do we collect, use, hold and disclose your personal information?
We collect, use, hold and disclose your personal information to operate our businesses, including the following:
- to design and provide our products and services to you, including information and all services relating to our products and services;
- to confirm your identity or your authority to engage with us on behalf of another person;
- to record information regarding products or services purchased from us and to provide further products or services to you, such as product warranties and guarantees, and repair or replacement of products;
- to assist in providing better products and services to you by tailoring them to meet your needs;
- to provide you with access to protected areas of our website;
- to assess the performance of our websites and to improve the operation of our websites;
- to keep our websites and other online presence relevant and of interest to you, for direct marketing including promotions, newsletters and competitions, to show you advertising and information that is most relevant to you and your interests, and to carry out analysis of market activity, market research and surveys;
- for promotional and industry activities and functions (including training seminars)
- to conduct credit checks for invoicing and billing purposes;
- to provide you with further information about us or other websites or goods or services offered by us or our related companies or which we consider may be of interest to you;
- to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
- to contract with you and assess you for employment and contracting purposes;
- to manage access to our sites, equipment and locations;
- to manage the health, safety and wellbeing of you and our workforce;
- to meet our reporting obligations;
- to update our records and keep your contact details up to date;
- to process and respond to any complaint made by you;
- to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country (including those relating to tax, fraud, or other illegal activities); and
- any other purpose which is stated to you at the time of collection or that you otherwise authorise.
8 Who will we disclose your personal information to?
We may disclose personal information to our related companies and other third parties, including:
- our employees, other personnel, related companies and affiliates;
- third party contractors and providers of goods and services, such as courier and delivery companies, marketing and promotion companies, training and training certification agencies, web analytics services, business support services, travel agencies and information technology service providers;
- parties with whom we are in joint venture or otherwise doing business with who need that information to conduct our business;
- market research companies who undertake customer surveys for us;
- industry bodies or buying groups of which you may be a member;
- insurance and finance companies;
- professional service firms providing services to us, such as legal or accountancy services;
- authorised third party providers of information assurance services;
- law enforcement agencies or regulatory agencies where required or authorised;
- any entity where required or authorised by or under a law or a court or tribunal;
- third parties as set out in the credit reporting policy applicable at the time of opening your trading account; and
- any other recipient which is notified to you at the time of collection or that you otherwise authorise.
9 Do we disclose personal information overseas?
We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.
We may disclose your personal information to the following overseas recipients for some of the purposes listed in section 7:
- our employees, other personnel, related companies and affiliates;
- third party service providers of data storage and processing services;
- joint venture partners and contractors;
- third party contractors and providers of goods and services;
- entities we work with in delivering or managing our business;
- companies and individuals you’ve given us permission to share information with; and
- foreign governments or regulating bodies if we are required to.
These recipients may be located in Australia, New Zealand, USA, China, Singapore, United Kingdom, Europe, the Pacific Islands & South Africa. This may change from time to time, including as a result of change of provider, changes in data protection practices and processing efficiency.
You can disable your web browser from accepting cookies if you wish. If you do so, you can still access our websites, but not all services may be available.
We may automatically collect general statistical information on our websites about visitors to them, such as IP addresses, browsers used, dates visited, pages visited and number of visitors. However, such information does not refer to you by name or your contact details. We use this data in aggregate to improve our websites. We may provide such aggregated data to third parties, but in so doing, we do not provide personal information without your consent.
11 Direct marketing
We may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications may be sent using various methods including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Unsolicited Electronic Messages Act 2007. You consent to us sending you those direct marketing communications by any of those methods. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us (see the details below) or by using opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list.
We do not provide your personal information to other organisations for the purposes of direct marketing.
12 Dealing with us anonymously or by using a pseudonym
You may deal with us on an anonymous basis or by using a pseudonym when making inquiries through our website or social media pages, or when you make general inquiries by telephone and do not require a further response from us. However, we may need certain contact details from you to respond to inquiries. Generally, we will require your personal information in order to transact with you.
13 What we do if there’s a breach?
If we believe there’s been a privacy breach, we’ll identify the issues and take steps to minimise any harm.
If we believe the breach has caused, or is likely to cause, serious harm, we’ll contact the relevant Privacy Commissioner and we may also contact the individuals who may be affected.
If you believe there has been a privacy breach affecting you, please contact us as soon as possible.
14 Access and correction of your personal Information
You have the right to access your personal information which we hold about you, subject to some exceptions. You can only request information about yourself. Before we provide you with access to your personal information, we may require some proof of identity. We may charge a reasonable fee for giving access to your personal information if your request requires substantial effort on our part. However, we will not charge you for simply making a request. If you wish to access the personal information we hold about you, please contact us using the details provided in section 18.
You also have the right to request that we correct any inaccurate personal information we hold about you, subject to some exceptions. If you wish to correct the personal information we hold about you, please contact us using the details provided in section 18.
If we do not agree to your request to provide you with access to your personal information or to amend your personal information, we will inform you of our decision within a reasonable period. If you wish to complain about this outcome or to attach a statement to your record that you believe the personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, please see our complaints procedure in section 15.
You may request further information about the way we manage your personal information or lodge a complaint by contacting our Privacy Officer using the contact details in section 18.
We will deal with any complaint by investigating it, and providing a response to you within a reasonable time, provided that we have all necessary information and have completed any investigation required. In some cases, we may need to ask you to put your complaint in writing so that we are sure that we understand it, and may also need to ask you for further information or to verify your identity. In cases where further information, assessment or investigation is required, we will seek to agree an alternative timeframe with you.
While we always try to work with you to solve your issue directly, you may take your complaint to the Privacy Commissioner at the Office of the Privacy Commissioner (NZ). The contact details for the Privacy Commissioner are available from its website at www.privacy.org.nz
16 Change of ownership
In the event of a change of ownership of all or a portion of our business or the website, your personal information may be transferred to the new owner so that the business and/or website can continue operations.
We may amend this Privacy Statement at any time. Amendments to this it will be posted on our website and will be effective when posted.
Please check our website for the current version of our Privacy Statement.
18 Contact details
If you have any questions about this Privacy Statement, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please contact our Privacy Officer using the details set out below.
You can write to:
Privacy Officer – Clever Core
Private Bag 76514
Alternatively you can email us at FBPrivacy@fbu.com or call us on +64 (0)9 525 9000.
Date of issue: November 2020.