This policy sets out how Smartstaff (Pvt) Ltd. (Company Registration Number: 8151691, NZBN: 9429048909808) collects, uses, discloses, retains and manages your personal information and the personal information for Clients it works for and how we comply with our obligations under the Privacy Act 2020.

Personal information means identifiable information about an individual, such as their name, email, image, address and telephone number etc. Sensitive information means a special category of personal information containing information regarding racial or ethnic origin, political opinions, religious beliefs, genetic data, health information etc.

Unless you advise us otherwise, you acknowledge and consent to us using your personal information as set out in this Privacy Policy or as otherwise permitted under the Privacy Act or other law.

1) What personal information do we collect?

1.1 When we are contacted or we provide our services, the personal information we collect may include a person’s name, contact numbers, email address, residential or business address, financial details, insurance details, credit card details and other personal data. This may include sensitive information (as that term is used in the Privacy Act).

1.2 When our server/cloud storage is accessed, it automatically records information the browser sends when it connects to our website. This information may include:

• The accessing party’s Internet Protocol (IP) address, domain name, browser type and language
• Information about usage and online activities (for example, by way of cookies) including when our website is accessed, other sites accessed from our website, content upload and download and usage of the services available on our website
• Information provided through use of any downloading facilities on our website.

1.3  Our website uses cookies. Cookies do not identify you personally, but they may link back to a database record about you. With most Internet browsers you can erase or block cookies or receive a warning before a cookie is stored. Refer to your Internet browser instructions for guidance on this.

2. How do we collect personal information?

2.1 We collect personal information:

• From the individual
• From you, our clients when we provide services to them. This includes personal information about your customers and clients (Your Clients)
• Via a file-sharing arrangement with a client and when a client provides access to their customer relationship management (CRM) and software systems and third party websites to enable us to provide the services; VA Platinum Privacy Policy April 2018
• When sent to us by email or other communication from third parties
• From publicly available sources of information
• When we are required to do so by law
• From our own records

2.2  We are committed to ensuring the information we have is accurate and up to date. We update personal information when we are advised there has been a change and at other times as necessary.

3. How do we use your personal information?

3.1 Generally, we will collect, use and hold personal information to:

•  Provide our services, including services involving Your Clients
• Facilitate our internal business operations, including the fulfilment of any legal requirements
• Advise you of additional services or information which may be of interest
• Provide your contact details to our partners who have agreed to provide you with any services
• Analyse our services and customer needs with a view to developing and improving existing and new products and services
• Maintain and update our business infrastructure and systems;
• Compile statistical data
• Promote and advertise our business, products and services

3.2 If we do not collect the personal information we will not be able to provide the services or provide any assistance requested.

3.3  If the personal information provided to us is incomplete or inaccurate, we may be unable to provide our services or our services may be adversely affected.

4. When do we disclose your information?

We can disclose personal information we have about you to third parties in certain circumstances including:

• If you or Your Client agree to the disclosure;
• To employees, contractors and service providers, who assist us in operating our business and providing our services and those service providers of yours that you require us to work with;
• If you or Your Client would reasonably be expected to consent to information of that kind being passed to a third party;
• Using it for the purposes we collected for which it was (e.g. to provide our services or respond to a query);
• Where disclosure is required or permitted by law;
• To our related entities;
• If disclosure will prevent or lessen a serious and imminent threat to someone’s life or health; or
• Where it is reasonably necessary for the enforcement of the criminal law, a law imposing a pecuniary penalty or for the protection of public revenue.

5. Storage and Security of your information

We are committed to protecting the security of individuals personal information and we take all reasonable precautions to protect it from unauthorised access, modification or disclosure.

We implement and maintain security measures designed to provide reasonable protection against the loss, interference or misuse of personal information and to prevent unauthorised access, modification or disclosure of that information.

6. Accessing, correcting or deleting personal information

An individual may request access to their personal information, or request we update or correct any personal information we hold about them, or ask us to restrict or cease processing the personal information or even delete personal information.

Individuals should set out their request in writing and send it to us at damien@smartstaffnz.co.nz. We will review such requests as soon as reasonably practicable to comply with our legal obligations (our target response is 20 working days). If we are unable to grant the individual request, we will give the reasons for this decision in writing.

7. Contact us

If an individual has any concerns about privacy or the use or collection of personal information by us please contact our Privacy Officer at lakshan@sas.co.nz and include any concerns. We will respond as quickly as possible (our target response is 20 days) and handle all complaints in a way that is fair and consistent. However, if you remain dissatisfied, you can make a formal complaint with the Office of the Privacy Commissioner at investigations@privacy.org.nz or phone 0800 803 909.