The Trusts Privacy Policy

Overview

West Auckland Trust Services Limited, Portage Licensing Trust and Waitakere Licensing Trust (together, and referred to in this Privacy Policy as The Trusts, we, our or us) are committed to protecting your personal information in accordance with this privacy policy (Privacy Policy) and the Privacy Act (as amended and replaced from time to time).  If you have any questions, please contact us using the details in the “Contact Us” section below.

When does this Privacy Policy apply and can it be updated?

1.   Application of this Privacy Policy

This Privacy Policy applies to any personal information that we collect collected by us, including the personal information of our customers, our business partners, our suppliers and service providers and recipients of grants.

We also use CCTV at our sites.  For information on our use of CCTV and how we collect, use, and disclose personal information from our use of CCTV, please see our CCTV Systems Privacy Policy.

2.   Updates to this Privacy Policy

We may need to update this Privacy Policy in future to reflect changes to applicable law or changes to our Programmes and services. If we update this Privacy Policy, we will provide at least two weeks’ prior notice of the change by publishing our updated Privacy Policy on our Websites. We may also take additional steps to bring the changes to your attention, including by notifying you directly.

3.   Additional rights and obligations

This Privacy Policy applies in addition to, and does not limit:

(a)      our rights and obligations under the Privacy Act and any other applicable law; and

(b)      any additional information or authorisation provided by you or us in connection with your membership or use of a particular Programme.

What personal information do we collect?

4.   Overview

In this section, we describe the personal information that we collect.  You do not have to provide us, or authorise us to collect, any information that we request.  However, if you do not do so it may affect our ability to assist you, including providing you with our products and/or services.

5.   Types of information that we collect

The types of personal information we collect about you depends on the circumstances in which that information is collected, which may include:

(a)      your contact details (such as name, email address, address, phone number);

(b)      age and gender;

(c)       if you are a customer of ours, details of the programmes you have joined and used, including any rewards you have earned through your membership of our loyalty programmes and information you provide to enter a promotion;

(d)      record of communications we have with you;

(e)      your billing information;

(f)        video footage of you on our in-store CCTV in accordance with our CCTV Systems Privacy Policy; and

(g)      any other information that you authorise us to collect or provide to us.

How do we collect personal information?

6.   Overview

In this section, we describe how we collect personal information directly from you and, in some cases, from other sources.

7.   Collection of personal information from you

Generally, we only collect personal information directly from you. For example, when you:

(a)  register for and use a Programme, such as PlusPoints;

(b)  visit one of our Websites, social media platforms or use one of our Apps;

(c)   participate in a survey, promotion or competition;

(d)   communicate with us or contact us for any other purpose;

(e)  enquire about, or request, any of our services;

(f)   enquire about job vacancies or apply for job vacancies; and

(g)  when we otherwise provide information or services to you.

How do we use personal information?

8.   How we use personal information

We may use your personal information to:

(a)      process your registration and administer your Programme membership, including to send you rewards and vouchers applying to PlusPoints;

(b)      provide services to you;

(c)       send you direct marketing, by post and electronic means, including by email, phone and text/SMS.  This may include information about special offers, discounts, promotions and other information relating to our products and services, or the products and services of group companies and selected third parties, that we think may be of interest to you – you can opt out of receiving direct marketing by telling us in writing, by email (refer to the “Contact Us” section)

(d)      understand your shopping habits and likely preferences, in order to enhance The Trusts products and services (for example, in order to offer you a better, more personalised and tailored service, send you information about goods and services that are likely to be of most interest to you and show you advertising and information that is most relevant to you and your interests);

(e)      enter you in a prize competition and administer the prizes – please be aware that, in some cases, you may be automatically entered into a competition by purchasing an eligible product and swiping your PlusPoints;

(f)        improve our Programmes, including our range of Programmes and offerings generally and to ensure that they remain relevant and of interest to users.  For example, we may contact you to request that you respond to market research and surveys and if you contact our call centre we may record your call for quality and training purposes;

(g)      assist you to access new channels for delivery of, and access to, our services, for example mobile applications and payment methods;

(h)      assist us in investigating your claims and complaints;

(i)        to reply to your queries or requests, including when you make an enquiry;

(j)        facilitate the provision of our products and/or services that we may offer from time to time;

(k)       work with and procure goods and/or services from our suppliers and service providers;

(l)        facilitate recruitment and selection of prospective personnel;

(m)     provide and manage charitable assistance and community grants;

(n)      to comply with relevant laws and regulations;

(o)      for our administrative purposes and any other purposes in relation to the operation of our business; and

(p)      for any other purpose that you authorise.

Who do we share personal information with?

9.   Overview

In this section, we describe who we share personal information with.

10.    Service providers

In providing and managing our services, community grants, Programmes, Websites and Apps, we contract with other businesses to provide services to us and we may disclose personal information to them to enable them to provide those services. We require these service providers to adhere to our confidentiality requirements and to the requirements of the Privacy Act.

11.    Prize competitions

Generally, we will never disclose your personal information to our suppliers who supply products for our stores and venues. The one exception to this is that we may provide your contact details to a supplier to enable them to contact you if you have won a prize. Please be aware that this may include providing your contact details to a supplier if you have won a prize competition that you were automatically entered into by purchasing an eligible product.

12.    Anonymous information

We may share anonymised and aggregated information (which is not capable of identifying you) with our contractors, affiliates, business partners and other third parties.

13.    New partners

We are focused on continually enhancing The Trusts’ products and services and providing new products and services, which may involve new partnerships with other companies.  We will only disclose your personal information in connection with new or enhanced products and services if the use or disclosure is for one of the purposes described in or otherwise permitted by our Privacy Policy, or after you have given us express authorisation.

How do we store personal information?

14.    Storage of personal information

Personal information that we collect is either held by us or on our behalf.  Our physical address is 3044 Great North Road Auckland 0600, New Zealand.  Some information we hold will be stored in “the cloud” in secure databases on our behalf by third parties based overseas.  The use of these services will not relieve us of our obligations under the Privacy Act and this Privacy Policy.

15.    Security standards

We will take reasonable technical and organisational safeguards, including complying with generally accepted industry standards, to protect personal information against loss, unauthorised access, disclosure, modification, or use.

16.    Your responsibilities

You are responsible for ensuring your Internet browser and computer system are secure (including, but not limited to, free and secure from viruses) and can support any security measures we use to protect your information.

You are also responsible for complying with any security requirements that we notify you of.

17.    Updates to your personal information

We rely on you to update us if your contact details change (please refer to the Contact Us section).

18.    Access to and correction of your personal information and preferences

You are entitled to request confirmation of whether we hold any personal information about you, and to access any such personal information.

If we hold personal information about you, you are also entitled to request us to correct the information.  If we do not agree to make the correction sought, you may request that we attach a statement of correction sought but not made to such information.

We will make reasonable efforts to respond promptly to access/correction requests in accordance with applicable laws.

19.    Access fee and ID requirements

We may charge a reasonable fee for giving you access to your information if your request requires substantial effort on our part.  Before we provide you with access to your information, we may require some proof of identity.

20.    Retention of your personal information

We will take reasonable steps to make sure that we keep your personal information for as long as it is necessary for us to provide you with the Programme, our services or achieve other purposes set out in this Privacy Policy, unless otherwise required by law.

21.    Cookies and anonymous information

We may collect information about you using “cookies”, when you visit our Websites or social media pages, use our Apps, or click on our advertisements on the online media of other companies. For information about cookies and how to switch them off, see www.allaboutcookies.org.

A cookie is a small data file that our Websites, or social media pages, our Apps, or our advertisements send to your browser, which may then store it on your system for later retrieval. Cookies record information about your online preferences and allow us to tailor the websites to your interests. Information supplied by cookie and session information can help us to analyse the profile of the Website’s and social media platform’s visitors and the profile of the App’s users, and help us to provide you with a better user experience.

We use Google Analytics to collect analytical information, such as the number of visitors to our Websites per day or the number of pages requested per day. This non-personal information is aggregated by Google Analytics and enables us to measure activity within our Websites, which in turn is used to continually improve our Websites and our service to our customers. To opt-out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.  You can see how Google uses data when you access our Websites https://policies.google.com/technologies/partner-sites.

22.    Anonymous information

We also use aggregated and anonymous information (where identifiable characteristics are removed, so that you will remain anonymous).  Where we do this, we may use that information to determine preferences, shopping habits and other metrics related to our customers’ access to and use of our Programmes.

23.    Contact Us

Our contact details

We are committed to protecting your personal information. If you have any questions about this Privacy Policy, please contact us using the details set out below.

You can contact us at any time by emailing us at or calling us on 09 826 2620.  Alternatively, you can write to us at:

 

Privacy Officer

The Trusts

Private Bag 93 016, New Lynn

Auckland 0640

New Zealand

The Trusts CCTV Policy

Overview

West Auckland Trust Services Limited, Portage Licensing Trust and Waitakere Licensing Trust (together, The Trusts, we, our or us) have a duty of care under relevant legislative responsibilities to take robust precautions to safeguard the security, safety, wellbeing and privacy of The Trusts team members, customers, contractors and members of the public working in or visiting The Trusts sites.

The protection of individual privacy is a fundamental responsibility for The Trusts when using technology such as CCTV and CCTV recording systems.

This CCTV Systems Privacy Policy (Privacy Policy) outlines how The Trusts collect, use, store and disclose personal information, including how you can access and request amendment to your personal information, from The Trusts’ use of Closed-Circuit Television (CCTV) security cameras and electronic recording systems (known as CCTV Systems) in operation at its sites.

How we collect personal information

We may collect personal information via our CCTV Systems and other cameras installed in at our sites and The Trusts will openly display signage advising CCTV cameras are operating on site.

We may also collect personal information about you from any person or entity sharing information with us for anti-social behaviour prevention and for law enforcement purposes.

The kind of personal information we collect

Personal information is information that identifies you or from which you may reasonably be identified. The types of personal information that The Trusts’ may collect about you from its CCTV Systems include images and other biometric data from our CCTV Systems.

We may also collect, use, store and disclose other forms of personal information outlined in our Privacy Policy.

Why we use CCTV Systems

The Trusts operate CCTV Systems to:

  • actively deter crime against The Trusts people and property;
  • mitigate the risk of criminal incidents including Robbery, Theft or Assault against The Trusts team members, customers, contractors, and members of the public attending sites;
  • utilise technology and openly promote the security of The Trusts sites to ensure the safety, wellbeing, and privacy of people, in or visiting a site, while creating a more secure working environment;
  • capture factual evidence of crime, mal-practice or incident involving harm to any person, loss or damage to any property and to assist in any investigation; and
  • support Operational Procedures, Health & Safety and Security programmes and support the execution of any process pursuant to NZ legislation lawfully utilised by The Trusts, e.g. identification of trespassed individuals, identification of self-excluded persons.

The Trusts do not use CCTV Systems:

  • by directing cameras at or positioned in ablution blocks / showers, toilet facilities, changing rooms, first aid rooms or lunchrooms;
  • as part of a routine team member work time or attendance monitoring programme;
  • to monitor the general movement of team members or contractors while going about their normal duties / activities;
  • to monitor buildings, premises, or occupants unrelated to The Trusts business purposes; or
  • to gather information to intentionally intrude on the privacy of individuals.

How we use, and may share, your personal information

The information gathered by The Trusts CCTV Systems pursuant to this Privacy Policy will be used for business purposes only and the purposes for which it was intended.

The Trusts’ business purposes include to:

  • operate CCTV Systems as a deterrent to ‘would be’ offenders committing crime and to gather evidentiary material confirming criminal acts or events;
  • gather information to:
    • assist investigations into crime, mal-practice, employee or customer actions, or incidents involving harm to any person and loss or damage to property; and
    • support any procedural, employment or legislative process related to requisite policies or procedures;
  • secure evidentiary information for inclusion onto crime reporting platform AUROR;
  • assist us in ensuring security, health and safety and customer protection at The Trusts’ sites, and record information independently at each site to provide necessary assurance to mitigate safety, security, and compliance risks;
  • assist us, our service providers and any other persons or entities with whom we agree to share information relevant to monitoring anti-social behaviour and law enforcement purposes, in investigating and preventing any potential, suspected or actual breaches of law or anti-social behaviour;
  • to comply with relevant laws and regulations;
  • for any specific purpose which we notify you of at the time your personal information is collected; and
  • for our administrative purposes.

We may disclose information about you:

  • to our service providers (including our hosting providers);
  • if we are requested to do so during legal proceedings or other investigations;
  • with your authorisation;
  • to law enforcement agencies, government agencies or other third parties, where required by law;
  • to third parties where necessary to assist us in investigating and preventing any potential, suspected or actual breaches of law or anti-social behaviour; and
  • to third parties with whom we agree to share information relevant to monitoring anti-social behaviour and for law enforcement purposes, in investigating and preventing any potential, suspected or actual breaches of law or anti-social behaviour.

CCTV System information security

The Trusts will ensure that information collected through the CCTV Systems is protected by such security safeguards as are reasonable in the circumstances to protect against loss, misuse and unauthorised access, use, modification, or disclosure.

This includes the CCTV Systems operating and recording information independently at each site to mitigate safety, security and compliance risks with gathered information stored on digital electronic storage media (NVR). CCTV Systems and NVR storage media will be:

  • access / password protected;
  • secured in cabinets or secure office; and
  • under the management and control of a Trusts Site Manager.

How you can access/amend your personal information

If you wish to obtain confirmation that we hold personal information about you and to access that information, or you wish to request a correction to your personal information that we hold, please contact us at

If you request access to, or a copy of, your personal information, we will provide you with a copy of the personal information we keep about you. However, we reserve the right to charge you a reasonable amount for providing copies of any personal information you request, to take into account the time, cost and effort involved.

If you request a correction to your personal information and we agree that your personal information needs correcting, an amended record of your personal information will be provided back to you. If we do not agree to your request for a correction, you may request that we take reasonable steps to attach to the information a statement of correction sought but not made.

How long we hold personal information

We will determine how long we hold your personal information, except that we will not keep your personal information for longer than is necessary to achieve the purposes for which we may lawfully use it.

Who you can contact for further information

If you have any queries about this Privacy Policy or personal information we have collected about you, you can contact us at any time by emailing us at or calling us on 09 826 2620.  Alternatively, you can write to us at:

Privacy Officer

The Trusts

Private Bag 93 016, New Lynn

Auckland 0640

New Zealand

 

This Policy may be reviewed and updated by The Trusts. If we update this Privacy Policy, we will provide at least two weeks’ prior notice of the change by publishing our updated Privacy Policy on our Websites. We may also take additional steps to bring the changes to your attention, including by notifying you directly.