Reviewed February 2023
About this policy
Bartercard Exchange Ltd (‘we’, ‘us’, ‘our’) of Building 3, Level 3, Candida Office Park, 61 Constellation Drive, Mairangi Bay, Auckland, understands the importance of, and is committed to, protecting your personal information. We comply with the Privacy Act 1993 (Privacy Act) and we adhere to the privacy principles detailed in the Act.
This policy applies solely to individuals, i.e. living human beings, and not to other legal entities such as companies, trusts, or incorporated societies.
- clearly communicate to you how we deal with personal information
- enhance the transparency of our operations
- give you a better and more complete understanding of the sort of personal information that we hold, and the way we handle that information
Privacy Officer: Scott Hayden
Information we collect about you
We collect information about you for our business functions and activities and information which is required by law. Our business functions and activities include:
- Providing you with products and services– these are described generally on our website, our corporate brochures, advertising, our letter and emails, and communications to customers
- activities in support of those functions including but not limited to administration, management, marketing, online and mobile marketing, IT, legal, security, customer support, finance (including credit control), and human resources
- activities we plan for the future, including new ways of communicating, new products and services, new business models, and new businesses.
- your name
- your contact details including residential or business address, telephone number, and email address
- date of birth
- financial information such as bank account and credit card details, employment details, and information about your credit
- worthiness and credit history
- proof of identity
- publically available information;
- we collect details related to your transactions with us or our business partners including products and services, retailer (or service provider), payment details, and other details;
- if your business or employer supplies us with products or services, or if your business or employer distributes, sells, or services our products, we collect information about your trading with us (for example the products you buy or sell or the services you provide), your trading history and account history
- if you apply for a position with us, we collect information to help us decide your application, including your date of birth, tax file number, work history, and similar details
- if you request information from us (for example about a product or service) or register a complaint, we collect information about your request or complaint
- if you enter a promotion or competition, visit us at an event, or enquire about us, we may collect your contact details so that we can follow up on your enquiry or interest by sending you marketing material.
How we collect information about you
We collect personal information directly from you. We may record your contact details when you call us, when you fill out an application form, when you purchase our products or services, when you participate in a transaction with us or our business partners, when you provide your contact details via the web, mobile or email or when you ask us for information or request something from us, among other interactions. Sometimes we collect personal information about you from another person or business, or from a publicly available source. For example:
- A retailer or business partner may give us your details in relation to a product or service;
- if you are an employee of one of our business partners, we may be given your name and contact details by your employer
- if you enter a networking event, promotion, or competition organised by us, we may be given your name and contact details by the promoter of the event
- our service providers may provide us with your personal information from websites, social media sites, mobile, and other technology-based sources
- credit reporting bodies may provide us with information if we request a credit history
We use lawful and fair means to collect your information. We will collect personal information about you from another person or from a publicly available source only if it is unreasonable or impracticable to collect it directly from you, and we will take reasonable steps to inform you that we have collected your personal information. Those reasonable steps may include informing you through this statement.
If we receive personal information about you that we have not requested, it will be subject to the same protection methods, access, and disclosure standards as any information that we have requested.
Do I have to provide you with my personal information?
You can deal with us anonymously (without giving us your name and contact details) or by using a pseudonym (a name that does not include your real name, for example, an email address or a user name that you use in an online forum (nickname)).
If you choose to deal with us anonymously or using a nickname, we can give you general information about our products and services, and you may be able to participate in any online forum we provide, but there are some things we cannot do, for example:
If you do not give us your personal information we cannot give you information about transactions you may have made with us, deal with a complaint you may have, provide you with a service or deliver a product to you at an address. You cannot attend one of our networking events, or enter into one of our promotions anonymously or using a nickname.
You can deal with us using a nickname together with your real name and contact details. If you choose to deal with us in this way, we may collect your personal information together with your nickname. When you identify yourself to us using your nickname only, we can deal with you only as described above. We may ask you to provide proof of your identity if you use a nickname.
Why we collect personal information about you (purpose of collection)
We collect and record personal information about you so that we can carry out our functions and activities described above. The primary purposes for which we collect your personal information include:
- so that we can provide our services to you and to our business partners and suppliers
- so that we can administer our dealings with you, provide you with information, and respond to any requests that you may have (for example, so that we can provide you with marketing and sales opportunities or introduce you to our business partners)
- so that we can function as a business, for example, we may collect your personal information for research, and marketing so that we can offer new products, and reconcile transactions, or if you are a supplier we can record your dealings with us
- so that we can comply with agreements we have entered into with our suppliers and business partners
- so that we can comply with legislative requirements.
We also collect your personal information for secondary purposes that are related to the primary purposes outlined above. Secondary purposes may include so that we can run our business efficiently – for example, so our advisors can provide us with customer research so that we can use technology to automate our business, to understand how our business is performing, to allow us to operate efficiently and to lower costs by outsourcing services (such as collecting or paying money). Other secondary purposes may include so that we can sell or transfer our business or merge with another business.
- a purpose you would reasonably expect
- a purpose required or permitted by law
- a purpose otherwise disclosed to you to which you have consented
- service providers, including management, repairers, contractors, IT, security, legal, accounting, research, credit, credit reporting bodies, marketing, insurers, financial institutions, and others
- affiliate companies and related companies, Bartercard franchisees and companies that we may merge with or who may acquire ownership of us
- government, regulatory, and law enforcement authorities, where we are required to or permitted to by law
- your employer, if you are an employee of a supplier
- to prevent or investigate any fraud or crime (or suspected fraud or crime)
personal information. We take reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations with respect to the protection of your personal information.
We may disclose your personal information to an overseas service provider, for example, a cloud data centre or a customer information call centre. Our overseas service providers may be located in:
- Europe: United Kingdom
- North America: United States
- Asia: Singapore, Thailand, Philippines, Hong Kong
- Other: Australia or another jurisdiction.
Access to Personal Information
You may request access to the personal information that we hold about you by using the contact details provided above. We will deal with your request for such access within a reasonable time.
If we refuse access, we will provide you with a written notice which sets out the reasons for the refusal and the relevant provisions of the Privacy Act that we rely on to refuse access. We may recover reasonable costs in relation to a request for access to personal information.
Accuracy and correction
We take reasonable steps to make sure that the personal information we use or disclose is accurate, up-to-date, complete, and relevant before utilising that information. Where we believe that the personal information we hold is inaccurate, out-of-date, incomplete, irrelevant, or misleading, we will take reasonable steps to correct that information.
You may request that we correct the personal information that we hold by contacting us using the contact details provided above. We will take reasonable steps to correct the information to ensure that it is accurate, up-to-date, complete, relevant, and not misleading.
We will deal with your request to correct your personal information within a reasonable time. If we do not agree with the corrections you have requested, we are not obliged to alter your personal information accordingly. However, where we refuse to correct any personal information as requested by you, we will give you a written notice which sets out the reasons for our refusal.
We hold your personal information in paper-based and electronic files.
We will take reasonable steps to ensure that your personal information which is kept in our files is protected from:
- misuse, interference, and loss
- unauthorised access, modification, or disclosure
We may assign a unique identifier to you as this is necessary in the provision of our services. This unique identifier will not, to the best of Bartercard’s knowledge and ability, be the same as unique identifiers that may have been assigned to you by any other agencies.
This section explains how we handle personal information collected from our websites (including social media site(s) and mobile site(s) if relevant). If you have any questions or concerns about transmitting your personal information via the internet, you may contact us using the contact details provided above, as there are other ways for you to provide us with your personal information.
Visiting our website
If you access an unsecured part of our websites, that is, a public page that does not require you to log on, we (or our service providers) will collect information about your visit, such as:
- the time and date of the visit
- any information or documentation that you download
- your browser type
- your IP address
When we receive emails, we may retain the content of the email and our response to you where we consider it necessary to do so. Your email address will only be used or disclosed for the purpose for which is was provided. It will not be added to any mailing lists or used for any other purpose without your consent.
We make reasonable efforts to ensure that the most up-to-date security measures are used on our website to protect your personal information. Any data containing personal information which we transmit via the internet is encrypted. However, we cannot guarantee that any information transmitted via the internet by us, or yourself, is entirely secure. You use our website at your own risk.
We may use your personal information, including your contact details, to provide you with information about products and services, including those of third parties, which we consider may be of interest to you. We may do this, even if you are on the Do Not Call Register.
We may also provide your details to other organisations for specific marketing purposes. You may opt-out at any time if you no longer wish to receive marketing information. In order to do so, you will need to request that we no longer send marketing materials to you or disclose your information to other organisations for marketing purposes. You can make this request by using the contact details provided above, or by “unsubscribing” from email or other marketing messages.