Titan Industries Ltd (we, us, our) is committed to complying with privacy laws, including the New Zealand Privacy Act 2020 (the Act) when dealing with personal information.
This policy sets out how we will collect, use, disclose and protect your personal information.
In this policy, all references to you or your are to an individual who is the subject of the personal information.
CHANGES TO THIS POLICY
We may modify or amend this policy from time to time. The change will apply from the date that we revise this policy. You should periodically review this policy for the latest information about our privacy practices.
This policy was last updated in June 2021
WHAT IS PERSONAL INFORMATION?
In this policy, all references to personal information are to information or an opinion about an identified individual, or an individual who is reasonably identifiable.
Personal information may include things like your name, your age or gender, your contact details (including phone numbers and email addresses), your location, biometric data about you, or a picture of you. It may also include information about your health, employment, finances, payments, opinions, preferences or beliefs.
If any information we collect personally identifies you, or enables you to be identified, then it will be personal information.
WHAT PERSONAL INFORMATION DO WE COLLECT?
We may collect personal information about you in the course of operating our business.
We may not be able to provide you with products or services, or information requested by you, if you choose not to provide us with this personal information.
The types of personal information we may collect are:
- your name and contact details (including addresses, phone numbers and email addresses) – we may collect this information whenever we deal with you, for example when you order products or services from us, request information from us, or deal with our staff or customer services representatives or other agents
- your age or date of birth – you may be required to provide this information to us for identity verification purposes, or where required to verify that you are legally entitled to access certain products or services
- your image, sound or biometric details – we may collect this information when you enter any of our premises (i.e. via CCTV or video or audio recordings)
- details about your finances or employment status – we may collect this information where necessary to better direct our products or services to your specific needs, or where you are seeking credit or finance from us
- payment details – we may collect payment details from you whenever you order products or services from us
- supporting information – in certain circumstances we may also request additional personal information from you to enable us to provide you with specific information about our products or services, to tailor our products or services to your specific needs, or to provide you with support or assistance in relation to products or services you have already purchased
- passwords or user-names – we may collect passwords or user-names from you when you establish a user or customer account with us
- other information you provide – during the course of our dealings with you, we may collect your personal information in circumstances other than the ones described above. These circumstances may include where you provide us with personal information in the course of interacting with us through online forums, live chats or social media.
In many cases we will collect this personal information directly from you. But in some circumstances we will collect personal information about you from our contractors, agents or service providers in the course of their providing services to us or assisting us with the provision of products or services to our customers. These may include IT services providers, couriers and delivery service providers, call centres, finance providers, collection agencies or professional advisers.
We may also collect personal Information about you from other users or customers of our products or services. For example, we may collect personal information about you when a customer gives us your contact details in relation to particular products or services, or orders products or services tailored to your requirements.
HOW WE USE YOUR PERSONAL INFORMATION
We will use your personal information:
- to provide services and products to our customers
- to provide our customers and suppliers with information about our products and services
- to market our services and products to our customers, including contacting you electronically (e.g. by email for this purpose)
- to improve the services and products that we provide to our customers
- to provide support and assistance in connection with products or services purchased or ordered from us, for example to manage warranty issues or to provide support in the event of an issue with our products or services
- to maintain our internal records
- to verify your identity
- for product development, planning or research purposes
- for strategic planning or development purposes in connection with our business, including assessing the ongoing needs and requirements of our business
- to evaluate customer satisfaction and the performance of marketing activities
- to undertake credit approval, establish creditworthiness and credit limits, and administer your credit account with us
- to invoice customers and to collect money that they owe us, including authorising and processing credit card transactions
- to respond to communications from you, including complaints
- to help prevent unlawful activity
- to investigate and take action in connection with any suspected unlawful activity, or suspected breaches of any agreement between you and us
- to protect and/or enforce our legal rights and interests
- as otherwise reasonably necessary to enable us to undertake our legitimate business activities
- as otherwise specified in this policy
- as otherwise required or permitted by any law (including the Act, and the Privacy Act 1988 (Australia)).
DISCLOSING YOUR PERSONAL INFORMATION
We may disclose your personal information to:
- our employees or agents and any other person, in the ordinary course of business
- any business that supports our services and products, including any person that hosts, supports or maintains any of our IT systems
- a credit reference agency for the purpose of credit checking
- our solicitors and external debt collection agencies
- our directors, shareholders, financiers, investors, and key stakeholders in our business
- other third parties (for anonymised statistical information)
- a person who can require us to supply your personal information (e.g. a regulatory authority)
- any other person authorised by the Act or another law (e.g. a law enforcement agency)
- any other person authorised by you.
TRANSFER OF PERSONAL INFORMATION
We may transfer your personal information to or from other countries where necessary to achieve any of the purposes specified in the “How we use your personal information” section above.
If you are New Zealand-based and we transfer your personal information outside New Zealand, we will ensure that appropriate safeguards are in place with the recipient of that personal information, as prescribed by the Act, before we transfer that personal information.
If you are Australia-based and we transfer your personal information outside Australia, we will take such steps as are prescribed by the Australian Privacy Principles in relation to that personal Information.
We may transfer your personal information to another entity in connection with a sale of our business or assets, or a merger or consolidation or restructuring of our business or company.
If we transfer any of your personal information in such circumstances, we will ensure that the recipient of that personal information agrees to be bound by privacy practices and obligations that are consistent with our own under this policy.
HOLDING PERSONAL INFORMATION
We will not hold your personal information for longer than is reasonably required for the purposes for which it was collected.
Personal information may be held for longer periods where extended retention periods are required by law or regulation, or as necessary in order to enforce or defend our legal rights.
PROTECTING YOUR PERSONAL INFORMATION
We will take reasonable steps to keep your personal information safe from loss, unauthorised activity, or other misuse. If you suspect any loss, unauthorised access, use, modification or disclosure of your personal information, please let us know immediately.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
You may request access to any personal information we hold about you, or seek to have that personal information corrected if you believe that it is incorrect, at any time. All access or correction requests will be dealt with in accordance with applicable law, including the Act.
If you wish to make an access or correction request, please contact our Privacy Officer (see below) and he/she will tell you how to make a request. If you make a request, we may ask you to verify your identity.
If there is a breach of privacy involving your personal information, we will comply with our legal obligations under the Act and will (if required under the Act) notify the Office of the Privacy Commissioner as soon as possible.
For any queries or further information about our policy, or about our privacy or data practices, please contact our Privacy Officer. This person’s contact details are as follows:
Titan Industries Privacy Officer
Address: 36 Honan Place, Auckland 1026, New Zealand
PO Box 19097, Avondale, Auckland 1746, New Zealand
Phone: 09 828 1079