Lightwire Limited and Lightwire Australia Proprietary Limited (we, us, our) complies with the New Zealand Privacy Act 2020 and the Australian Privacy Act 1988 collectively referred to as (the Act) when dealing with personal information. Personal information is information about an identifiable individual (a natural person).
This policy sets out how we will collect, use, disclose and protect your personal information.
CHANGES TO THIS POLICY
We may change this policy by uploading a revised policy onto the Website. The change will apply from the date that we upload the revised policy.
This policy was last updated on 02/11/2020
WHO DO WE COLLECT YOUR PERSONAL INFORMATION FROM
We collect personal information about you from:
- you, when you provide that personal information to us, including via the Website and any related service, through any registration or subscription process, through any contact with us (e.g. telephone call or email), or when you buy or use our services and products
- third parties where you have authorised this or the information is publicly available.
If possible, we will collect personal information from you directly.
HOW WE USE YOUR PERSONAL INFORMATION
We will use your personal information:
- to verify your identity
- to provide services and products to you
- to market our and our group’s services and products to you, including contacting you electronically (e.g. by text or email for this purpose)
- to improve the services and products that we provide to you
- to undertake credit checks of you (if necessary)
- to bill you and to collect money that you owe us, including authorising and processing credit card transactions
- to respond to communications from you, including a complaint
- to conduct research and statistical analysis (on an anonymised basis)
- to protect and/or enforce our legal rights and interests, including defending any claim
- for any other purpose authorised by you or the Act.
- for general administrative and business purposes
DISCLOSING YOUR PERSONAL INFORMATION
We may disclose your personal information to:
- another company within our group
- any business that supports our services and products, including any person that hosts or maintains any underlying IT system or data centre that we use to provide the Website or other services and products and upstream suppliers
- other network operators to enable you to make and receive calls through other networks, and so we can transfer numbers from one operator to another
- a credit reference agency for the purpose of credit checking you
- debt collection agencies
- other third parties (for anonymised statistical information)
- any wholesale or channel partner of Lightwire providing services to you
- any channel partner of Lightwire receiving rebates for services provided to you
- 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
A business that supports our services and products may be located outside New Zealand or Australia. This may mean your personal information is held and processed outside New Zealand and Australia.
Where the Australian Privacy Act 1988 (Cth) applies, unless we have your consent, or unless an exception under the Australian Privacy Principles applies, we will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to your personal information.
Under New Zealand Privacy Act 2020 principles if a jurisdiction does not offer similar protections to New Zealand, the individual concerned we be fully informed that their information may not be adequately protected and must expressly authorise the disclosure.
PROTECTING YOUR PERSONAL INFORMATION
We will take reasonable steps to keep your personal information safe from loss, unauthorised activity, or other misuses.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
Subject to certain grounds for refusal set out in the Act, you have the right to access your readily retrievable personal information that we hold and to request a correction to your personal information. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.
In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the personal information, we will make the correction. If we do not make the correction, we will take reasonable steps to note on the personal information that you requested the correction.
If you want to exercise either of the above rights, email us at email@example.com Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information, or the correction, that you are requesting).
We may charge you our reasonable costs of providing to you copies of your personal information or correcting that information.
While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.
If you post your personal information on the Website’s [message board/ chat room/ forms or chat bot, you acknowledge and agree that the information you post is publicly available.
To improve our Website and services, we may use patterns and other meaningful information gathered from website analytics tools. This may include the timing and frequency of your use of the Website, your IP address, page requests, form requests, mouse click activity and other information that you voluntarily enter into the Website.
In addition, we may use third party cookies from third party services such as Google Analytics and/or Microsoft Application Insights. These services give us insight into behavioural information relating to users interests in our services, on an anonymous and aggregate level. This helps us to understand browsing behaviour to give a better experience whilst using our services.
You may make a complaint about privacy to the Privacy Officer at the contact details set out below.
NZ: 0800 534 576
AU: 1300 016 678
Attention: Privacy Officer
Postal Address: PO Box 9361, Hamilton 3240, New Zealand
The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint and will generally respond to your complaint within a week.
If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
If you are not satisfied with our response to your complaint, or you consider that we may have breached the Act, a complaint may be made:
- in respect of New Zealand laws, to the Office of the Privacy Commissioner (contacted by telephone on 0800 803 909 or by using the contact details on the Website www.privacy.org.nz); and
- in respect of Australia, to the Office of the Australian Information Commissioner (contacted by telephone on 1300 363 992 or by using the contact details on the Website www.oaic.gov.au).