(a) The Comvita website at www.comvita.co.nz (“Website”);
(b) Any other Comvita website, page or application used to gather your details or send you email notifications relating to Comvita and its products; or
(c) Any other social media website or page, containing pages or content established by or associated with Comvita, including but not limited to:
(i) Facebook and
(ii) Twitter (“Social Media”)
(each of (a), (b) and (c) are collectively referred to as the “Internet Sites”).
2. TERMS AND CONDITIONS
4. INFORMATION WE MAY COLLECT AND HOW WE USE IT
4.1. Comvita collects the following information about you when you use the Internet Sites:
4.1.1. Information that you provide to us. We may collect personal information (for example your name, email address and postal address) when you enter these into our website to buy a product or register for our newsletter;
4.1.2. Limited financial information that you provide when placing orders through the Website (we receive card type, last 4 digits of the card number and expiry date from our third-party payment provider);
4.1.3. Information transmitted by your computer when you use the Internet Sites. This may include your IP address browser data and information we receive from cookies (please see section 9 below).
4.1.4. From time-to-time we may request information via surveys or competitions. Participation in these surveys or competitions is completely voluntary. Information requests may include contact information (such as your name and email address), and demographic information (such as your postcode and age). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of the Website.
4.1.5. Comments, reviews and posts on social media. Comvita may collect personal information (for example, your name, email address, social media identifier and the contents of your comment, review or post) when you leave a comment, post a review or send a post via Social Media or otherwise provide information on Social Media.
4.2. We may use this information in the following ways:
4.2.1. to provide our service(s) to you as a user of the Internet Sites, including enhancing your user experience;
4.2.2. to process and fulfil your orders for our products;
4.2.3. to provide you with newsletters and other information about special offers or features of the Internet Sites which we think may be of interest to you and for related marketing purposes, if you have submitted your contact details to us for these purposes or otherwise provided your consent for us to do so;
4.2.4. for marketing third party products and services to you, if you have provided your consent for this;
4.2.5. to ensure that content from the Internet Sites is presented in the most effective manner for you and your computer;
4.2.6. to notify you about changes to our products and/or the Internet Sites;
4.2.7. to notify you about product recalls; and
4.2.8. when managing and maintaining the Internet Sites.
4.3. We do not collect any ‘Special Categories of Personal Data’ about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) unless you voluntarily provide this (e.g through a Social Media post). Nor do we collect any information about criminal convictions and offences.
5. FURTHER COLLECTION
Comvita also reserves the right to collect more extensive information where it deems such action is appropriate, such as in the case of any security concerns which may arise. Where possible, information will be obtained directly from you. However, you acknowledge that by accessing the Internet Sites information may be collected from you as a result of the workings of the Internet Sites and the attached systems and software. In addition, to the extent Comvita deems it necessary to make any credit enquiries about you, you authorise Comvita to make such enquiries and authorise any person to provide Comvita with such information as Comvita reasonably requires in response to its credit enquiries.
6. SOCIAL MEDIA
6.1. We work with trusted third parties, including social network sites like Facebook, Twitter, YouTube, Google+, and with application developers who specialise in social media so we can connect to your social networks. All these companies operate third party sites. We provide access to our Social Media to third parties and business partners so we can generate interest in our products and services among members of your social networks and to allow you to share product and service interests with friends in your network.
6.2. We cannot control how your data is collected, stored, used or shared by third party sites or to whom it is disclosed. Please be sure to review the privacy policies and privacy settings on your social networking sites to make sure you understand the information they are sharing. If you do not want a third-party site to share information about you, you must contact that site and determine whether it gives you the opportunity to opt-out of sharing such information. Comvita is not responsible for how these third parties may use information collected from or about you.
7. INFORMATION DISCLOSURE TO THIRD PARTIES
7.1. We may disclose your personal information as follows:
7.1.1. for marketing purposes, provided your consent has been given and has not been withdrawn, with the third parties mentioned when we seek consent;
7.1.2. to Social Media partners for identifying other people like you, who may also be interested in our products, provided your consent has been given (for further details, please see the section 6 “SOCIAL MEDIA” above).
7.1.3. to service providers who manage aspects of our operations and make them more efficient (for example third parties who provide support services to the Internet Sites, payment providers and delivery agents;
7.1.4. to our insurers, brokers and external auditors;
7.1.5. to our related companies within the “Comvita” group;
7.1.6. to debt collection and credit reference agencies and other parties deemed necessary in relation to providing you access to the Internet Sites, for any services you access or goods you purchase from the Website, to recover any money you owe Comvita, and to exercise any lawful right Comvita or its related companies may have.
7.1.8. if we are under a duty to disclose or share your personal data to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other agreements, including the terms and conditions of use of any social media platform;
7.1.9. to protect the rights, property, or safety of Comvita or Website and/or Social Media users (this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
7.2. We only allow third parties to handle your personal data if we are satisfied that they take appropriate measures to protect your personal data. One way we achieve this is by placing contractual obligations on third parties governing the use of personal data that we provide them with.
7.3. We will share personal information with law enforcement or other authorities if required by applicable law.
8. YOUR RIGHTS – MARKETING
8.1. You will only receive marketing communications from us and/or third parties if you have consented to this when you provided your contact details to us (or if you have otherwise submitted your consent to us for these purposes).
8.2. You have the right to ask us not to use your personal data for marketing purposes. You can request that you stop receiving information from us at any time by contacting us at the address set out below (please see section 20 “QUERIES”)
9. IP ADDRESSES AND COOKIES
9.1. We may collect information about your computer including your IP address, operating system and browser type for system administration and to report aggregated information. This is statistical data about your browsing actions and patterns and does not identify you individually.
11. DATA TRANSMISSION
Unfortunately, no data transmission over the internet can be guaranteed as totally secure. Whilst Comvita strives to protect such information, we do not warrant, and cannot ensure complete security of any information which you transmit to us. Accordingly, any information which you transmit to us is transmitted at your own risk. Nevertheless, once we receive your transmission, we will take reasonable steps to preserve the security of such information.
12. ACCESSING & AMENDING INFORMATION
You are entitled to access any information which Comvita may hold about you and Comvita is obliged to provide this information to you as long as it has such information and such information can be readily retrieved. You are also entitled to request Comvita correct any inaccuracies in any information which Comvita holds about you. Comvita is entitled to charge you for the reasonable costs of retrieving, providing this information, and as applicable, correcting this information.
13. DELETING INFORMATION
You are entitled to require us to delete your personal information where there is no good reason for us to continue to hold it or where you have successfully exercised your right to object to processing (see clause 14 below). Please note however that we may not always be able to comply with your request for specific legal reasons which will be notified to you if applicable at the time of your request.
14. PROCESSING RIGHTS
14.1 You are entitled to require us to restrict processing of your personal information in the following scenarios:
(a) if you want us to establish the accuracy of the data;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish or defend legal claims;
(d) you have objected to our use of the data but we need to verify whether we have overriding legitimate grounds to use it.
14.2 You have the right to object to your personal information being processed for direct marketing or profiling.
14.3 You have the right not to be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly effects you.
14.4 Where we are relying on your consent to process your personal data (e.g for marketing purposes) you have the right to withdraw your consent to that process at any time. This will not impact the lawfulness of any processing before you withdraw consent.
14.5 If you wish to exercise any of the rights referred to in clauses 14.1 to 14.4 above please contact us at the details provided in clause 20 below. Please note you may be asked to provide proof of your identity and address (e.g a copy of your passport and a recent utility bill).
15. COMBINING INFORMATION
Comvita may combine any information which it collects from you with information collected by its related companies.
16. DATA STORAGE – WHERE YOUR PERSONAL DATA IS HELD
16.1. All information you provide to us is stored on our secure servers and those of our group of companies, service providers and agents.
16.2. Where we have given you (or where you have chosen) a password or other data which enables you to access certain parts of our Website, you are responsible for keeping this password and any other identifier confidential and we strongly recommend that you do not share your password or other identifier with anyone. Furthermore, we strongly recommend that you do not use the same password for any other service or website.
16.5. We use strict procedures and security features to prevent unauthorised access. Agents or contractors who, while providing services to Comvita, have access to information which you give to us are required to keep that information secure and confidential and are not permitted to use it for any purpose other than to carry out the services which they are performing for Comvita. However, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk.
17. FOR HOW LONG WILL WE KEEP YOUR PERSONAL DATA?
17.1 If you choose to create an account, we will keep your personal information for as long as your account is open. If you don’t have an account, or choose to close your account, we will keep some of your information until 8 years have passed since we last provided product to you. We consider 8 years to be an appropriate retention period because it is as long as is necessary for us to:
17.1.1. respond to any questions, complaints or claims made by you or on your behalf;
17.1.2. show that we treated you fairly;
17.1.3. keep records required by law; and
17.1.4. satisfy any accounting or reporting requirements.
17.2. We will not retain your personal information for longer than necessary for the purposes set out in this policy.
17.3. When it is no longer necessary to retain your personal information, we will delete or anonymise it.
17.4. In some circumstances you can ask us to delete your data: see section 13 “DELETING INFORMATION”.
20. PRIVACY ACT
This Policy does not affect your rights under the Privacy Act 1993.
21. QUERIES & COMPLAINTS
We will do our best to resolve any concerns you may have directly with you and encourage you to contact us with details of your concerns. If we are unable to resolve your concerns you have the right to make a complaint to the NZ Privacy Commissioner. For further information on making a complaint visit www.privacy.org.nz/your-rights/making-a-complaint
Last updated: 28th September 2018
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