We are committed to protecting your privacy. This is our Privacy Policy. A reference to “Talentpay”, “we”, “us” or “our” is a reference to Talentpay NZ Ltd, Company No: 9429041246085. Our affiliates as referred to herein, include Talentpay Pte Ltd (Singapore) and Talentpay Pty Ltd (Australia) as referred to herein, have their own Privacy Policies available on their respective websites. This Privacy Policy applies to the information and data we collect when you interact with us on the sites owned and operated by us including talentpay.co.nz (“Website” or “Websites”), or any other channels, and when you use our services. This Privacy Policy describes how we collect, receive, use, store, transfer, share and process your Personal Data. It also describes your choices and rights with respect to your Personal Data. In this Privacy Policy “Personal Data” has the meaning given to “personal data” or “personal information” respectively under Applicable Data Protection Law; and “Applicable Data Protection Law” means applicable legislation relating to data protection and privacy including the Privacy Act 2020 (NZ). We use the information we collect about you to maximize the services we provide to you. We respect the privacy and confidentiality of the information provided by you. Customers may collect and manage Personal Data when using  any software based services offered by us on or through our Websites pursuant to applicable terms.  We process such data as a processor under the direction of the relevant data controller as may be applicable, unless otherwise specified in writing. As we plan to ensure our Privacy Policy remains current, this Privacy Policy may be updated from time to time. Please return periodically to review our Privacy Policy. By providing us with Personal Data and using our Websites and services, you  agree to the terms of this Privacy Policy as updated.

Information we collect

We may collect three types of information about you when you visit our Website or interact with us, submit an enquiry, request customer support, sign up for an account with us, set preferences, create or modify user information, or use our services:

1. Personal Data (such as your name, address, telephone number, e-mail address, identification details, customer history information, or professional details), and;
2. nonpersonal, aggregate information that (such as information regarding the pages on our Website you have visited). This information is aggregated and cannot be used to identify you personally.
3. ’Sensitive’ or ‘Special categories of Personal Data’ (such as health, racial origins or religious beliefs).

Use of your information

Your Personal Data will only be used if it is necessary for a legitimate interest. In general, the processing of your Personal Data is based on our legitimate interest in delivering our services to you. Personal Data may not be processed for the purposes of a legitimate interest if, in individual cases, there is evidence that the interests of the data subject merit protection, and that this takes precedence. We may use your Personal Data for the following legitimate interests: –

• To complete any transaction or service requested by you, including to create your account, for billing, account management, administrative, security, or customer support purposes, or to send you updates regarding our legal agreements.
• To deliver requested information to you, such as sending you newsletters or legal alerts or information regarding educational seminars or other events that we believe may be of interest to you.
• To notify you about a material change to this Privacy Policy or the Terms of Use, if necessary.
• Where we need to comply with a legal or regulatory obligation.

We may use Personal Data collected for the purpose of providing you with direct marketing material, updates regarding our Websites and information in the form of a newsletter. This will only apply if you have registered or subscribed to such publications by your registering your details with us. However, if you wish to cease receiving any such information you may let us know either by email or unsubscribing at any time and your request will be actioned as soon as possible. We respect the privacy of our visitors. We may collect information on or through our Websites that can personally identify you. For example, we collect personally identifiable information which you volunteer to us to respond to visitor questions and comments about us and our products and services, and to mail enewsletters. We will use all reasonable means to protect the confidentiality of your Personal Data while in our possession or control. We may use in a general sense without any reference to your name, your information to create marketing statistics, identify user demands and to assist it in meeting customer needs generally. In addition, we may use the information that you provide to improve our Websites and services. Any non-personal information, communications and material you send to our Website or to us by other means, or which we obtain from third parties without promises of confidentiality, may be kept, used and disclosed by us on a non-confidential basis. We are free to use and reproduce any such information freely, and for any purpose whatsoever. Specifically, we will be free to use any ideas, concepts, know-how or techniques contained in such information for any purpose, including developing, manufacturing or marketing products.

Storage of your information

We receive and store information you enter on our Websites or give us in any other way from time to time. You may provide basic contact information such as your name, phone number, address, and email address to enable us to send information or process your order and we may also collect additional information at other times, including but not limited to, when you provide feedback, change your content or email preferences, respond to a survey, communicate with our customer support or submit queries. We hold your data only for as long as necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our lawful business purposes.

Cookies

A cookie is a small file placed in your web browser that collects information about your web browsing behaviour. Our legitimate interest pursued is the provision and/or promotion of further products and/or services to you. Use of cookies allows a website to tailor its configuration to your needs and preferences. Cookies do not access information stored on your computer or any personal information (e.g. name, address, email address or telephone number). Most web browsers automatically accept cookies, but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of a website. Our website uses cookies to analyse website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google AdWords. These ads may appear on this website or other websites you visit. If you do not wish for cookies to be installed on your device, you can change the settings on your browser or device to reject cookies. Our website may contain content and links to other sites that are operated by third parties that may also operate cookies. We don’t control these third-party sites or cookies and this Privacy Policy does not apply to them. Please consult the terms and conditions and Privacy Policy of the relevant third-party site to find out how that site collects and uses your information and to establish whether and for what purpose they use cookies.

Disclosure of your information

We do not and will not sell or deal in your Personal Data. We will never disclose your Personal Data to a third party except as expressly permitted herein or in other relevant terms. We may disclose Personal Data:

• Where you have consented;
• to our service providers who assist us in providing the information and/or services we are providing to you;
• where such disclosure is necessary to achieve the purpose for which it was submitted;
• to our affiliates when it is necessary to provide you with the services you have requested; or
• as required or authorised by law.

To the extent that we do share your Personal Data with a service provider, we would only do so if that party has agreed to comply with our stringent privacy compliance standards.

Overseas Disclosure

Personal Data that we collect and hold is stored by us or our affiliates. Some service providers who we use for specific functions (for example cloud based data storage and software providers) may store certain information on our behalf on servers based in Canada, USA and Singapore. Some of our service providers overseas may not be subject to the Applicable Data Protection Laws of New Zealand. Please contact us if you require specific details. For UK and EU residents, this means that your data may be transferred outside of the European Economic Area (“EEA”) or UK when it is provided to us. Where your personal data is transferred by us to anyone else, we will ensure that this is only done with appropriate safeguards in place to protect Personal Data in compliance with Applicable Data Protection Law. Such measures may include (without limitation) transferring the data (i) to a third party in a country that has been identified as providing adequate protection for EEA or UK data, or (ii) to a third party which has entered into standard contractual clauses adopted or approved by the European Commission or the Information Commissioner’s Office (UK). Should you require more detailed information as regards transferring your Personal Data outside the EEA or UK (e.g. the names of the recipients and the exact legal basis for any such transfer), please contact us on the contact details below.

Third Parties

We may from time to time need to disclose certain information, which may include your Personal Data, to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, during a legal proceeding or in response to a law enforcement agency request. We may use your Personal Data to protect the rights, property or safety of Talentpay, its customers or third parties. Finally, if there is a change of control in one of our businesses (whether by merger, sale, or otherwise), or a sale or transfer of its assets, customer information, which may include your Personal Data, could be disclosed to a potential purchaser under an agreement to maintain confidentiality, or could be sold or transferred as part of that transaction. And finally, we would only disclose your information in good faith and where required by any of the above circumstances.

Your Rights

You may request that Personal Data about you be accessed, corrected or deleted by contacting us via email at  team@talentpay.co.nz.  This is part of our commitment to take all reasonable steps to ensure that the information we hold about you is accurate, complete and up-to-date. UK and EU residents also have the following additional rights:

• the right to request that we erase their Personal Data (right to be forgotten);
• the right to obtain a copy of their Personal Data on request;
• the right to transfer their Personal Data to another person or entity (right of data portability);
• the right to restrict or object to processing, or withdraw consent to processing; and
• the right to lodge a complaint with a supervisory authority (see below).

Security

We strive to ensure the security, integrity and privacy of Personal Data submitted to us, and periodically update security measures considering current technologies. We will endeavour to take all reasonable steps to protect the Personal Data you may transmit to us and to ensure its security on our systems. In addition, our employees and the contractors who provide services related to our systems are obliged to respect the confidentiality of any Personal Data held by us. While we take all appropriate measures to safeguard against the unauthorised disclosure of Personal Data, no responsibility can be accepted for the conduct of third parties outside of our control. We have appropriate security measures in place in our physical facilities to protect against the loss, misuse, disclosure or alteration of your Personal Data. We follow strict security procedures as to how your Personal Data is stored and used, and who sees it, to help stop any unauthorised person getting hold of it. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. All information we receive from our customers, is protected by our secure servers. Credit card information is not stored by us on our servers.

Links

The Websites may contain links to other websites for convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. We are not responsible for the privacy practices of other websites. We encourage our users to be aware, when they leave our Websites, to read the privacy policies of each and every website that collects personally identifiable information. This Privacy Policy applies solely to information collected by us or our Websites.

Further privacy information and complaints

If you have any questions about this Privacy Policy, wish to no longer receive information or communications from us, or if you would like further information about the way we manage your Personal Data, please contact us at team@talentpay.co.nz and we will respond to you within 48 hours. If you have a complaint in relation to a privacy matter, please contact us pursuant to our Complaint and Disputes Policy on privacy@talentpay.co.nz. We take such matters very seriously and shall respond to any such concerns with you directly in a prompt fashion. If you are dissatisfied with the response to your complaint in relation to a privacy matter, you also have the option of contacting the relevant data protection supervisory authority, which is:

• for New Zealand, the NZ Privacy Commissioner, on either privacy.org.nz or +64 0800 803 909

For more information about privacy issues and protecting your privacy, visit the above data protection supervisory authority.