PRIVACY POLICY

1. This Privacy Policy covers the use or processing of your personal information by Dadelszen Ltd (New Zealand) and related companies, us / we.

“Personal Data” means personally identifiable information about an individual, such as a name, address, email address, phone number, or other identifier that permits direct or indirect identification of a specific individual, or as otherwise defined by applicable privacy and data security laws.

This Privacy Policyapplies to any type of data subjectsin their dealings with us, namely (i) visitors and users of our websites and online accounts and services (“Online Services”; visitors and users of it being referred to as “Online Services Users”), (ii) concerned individuals at customers, distributors, suppliers, vendors and other Customersof us (“Customers”), (iii) managers, employees, freelancers and other staff (“Employees”), and (iv) applicants for any positions with us (“Applicants”). Online Services User, Employees, Applicants and concerned individuals at Customers are collectively named “You”.

2. Information we collect

2.1 Online Services User

We process information about Online Services Userdirectly from you and automatically through your use of our Online Services.

2.1.1 Personal Data we collect directly from Online Services User

In general, you can visit our Online Services without identifying yourself or revealing any of your Personal Data. There are times, however, that you may choose to give us Personal Data. This is for example the case when you sign up to receive emails from us, open or respond to our emails, or if you participate in promotions or special events. In this case, we collect the following Personal Data:

your name;
your age/date of birth;
your home address, email address and phone number;
your marketing preferences, including any consents you have given us.
2.1.2 Personal Data we collect automatically through our Online Services from Online Services User

When you visit our Online Services, we automatically collect Personal Data through your use of our Online Services. This Personal Data may include, without limitation, the type of browser you use, the third-party web site from which your visit originated, the search terms you use on this Online Services, the specific web pages you visit on the Online Services and the duration of your visits, your IP address, device ID and other unique identifiers, information about your operating system, settings and system configuration.

2.2 Concerned Individuals of Customers

In the context of a business relationship, we may process the following Personal Data about concerned individuals of Customers:

contact information, such as full name, postal work address, work telephone number, work cell/mobile phone number, work fax number and work email address, and job title;
payment data, such as credit/debit card numbers, security code numbers, tax ID and other related billing information and data necessary for processing payments and fraud prevention;
further information necessarily processed in a project or contractual relationship with us or voluntarily provided by the concerned individuals of the Business Partner, such as Personal Data relating to orders placed or payments made;
personal Data collected from publicly available resources; and
other Personal Data, if such Information is required by us for compliance screenings of Business Partner in line with data protection law. This may include date of birth, ID numbers, identity cards and information about relevant and significant litigation or other legal proceedings against concerned individuals of Customers.

2.3 Employees

The data we may process related to you as an Employee includes:

name, homeaddress, private email address, privatetelephone number including mobile phone number;
salary and bank details, national personal ID number, national tax number and social security number where necessary for payment and taxation purposes;
marital status, beneficiaries’ details in relation to life insurance or other benefits, emergency contacts, information about family members (e.g. name, date of birth, gender and national personal ID number) where necessary for the provision of applicable benefits, guarantees or relocation assistance;
education and competence information, resume, qualifications and employment history outside Us;
citizenship, birth city, work permission, immigration status and copies of identity documentation, as permitted and required in order to verify your right to work;
background check information from employment screening agencies or publicly available registers (as allowed by law);
information about your performance or conduct from other employees, customers or suppliers you work with who may provide feedback about you;
any other information you submit to us (including during the course of any correspondence you may have with us): such as signatures, photographs, opinions, your location (if you choose to enable it on a company device) and any other information you provide.

2.4 Applicants

In the context of an application with us,the Personal Data we may process related to you as an Applicant includes:

information such as name, contact details, location address, gender, citizenship, eligibility to work in certain countries and notice period; as well as
additional information you may volunteer to further provide information on your application, such as work competencies, work experience, education and certifications, references, cover letter, job preferences, personal context in case of relocation, and related uploaded documents.

3. How we use Personal Data

We may collect and retain Personal Data during the course of our interactions in order to provide you with the services we offer. We may collect Personal Data that you choose to provide us via our websites, surveys, emails, business correspondence or personal meetings or phone calls between yourself and our personnel or agents.

You have the option of not disclosing Personal Data to us or to use a pseudonym instead, unless it is impractical, in our determination, for us to assist you or we are otherwise required by law or a court or tribunal to deal with you on an identified basis. If you choose to withhold any Personal Data, we may not be able to provide you with all or part of our services.

3.1 Online Services User

We use the Personal Data of Online Services User for the following purposes:

as required by us to enable our business and pursue our legitimate interests, in particular to communicate with you and respond to any comments or questions you may send us; to notify you of changes to the Online Services, our Terms and Conditions of Sale or this Privacy Policy; or to send you an email confirming your account registration. We use your data to help us improve and develop our products and services; and we will use your Personal Data for internal statistical or operational purposes, such as to measure and understand demographic, user, user interest, purchasing and other trends among our users;
to protect our rights and interests as well as the rights and interests of our users and any other person;
to comply with applicable legal or regulatory obligations, including, but not limited to, use in connection with legal claims, compliance, regulatory, investigative purposes (including disclosure of such information in connection with legal process or litigation).

3.2 Concerned Individuals of Customers

We process Personal Data of concerned individuals of Customers in the context of a business relationship with Customers for the following purposes:

to communicate with you about products and services, or to respond to your queries or requests;
to establish and fulfill a contract with you, a request for quotation or a purchase order. This may include performing transactions and orders verifying your identity, communicating with you, providing customer services, processing payments, performing accounting, auditing, billing and collection, as well as arranging the shipment or other provision of products, goods or services;
to enable our business and pursue our legitimate interests, in particular to respond to any comments or inquiries you may send us;
to administer and perform marketing campaigns, surveys, market analysis, contests, sweepstakes or other promotional activities or events; or
to comply with applicable laws (such as record keeping obligations), export control and customs, compliance screening obligations (e.g. to prevent white-collar or money laundering crimes), and to protect our legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, especially regulatory or investigative purposes (including disclosure of such information in connection with a legal process or litigation).

3.3 Employees

We process Personal Data of Employees in the context of an employment relationship with them for the following purposes:

as required for administration, evaluation and developing of the employment relationship, to establish and perform the employment contract, to maintain or terminate the employment relationship and to enable you to perform your job (e.g. for payroll, benefit, pension administration, absence and compensation purposes, as part of general personnel record keeping, internal recruitment and selection processes, the purposes of performance and talent management, staff development, succession and career planning);
as required by us to enable our business and pursue its legitimate interests, and where its interests are not overridden by your data protection rights, e.g. to provide access to offices, manage IT systems and infrastructure, collate directories and provide communication services such as e-mail, telephone and internet access, managing and developing personnel (e.g. succession planning, training and leadership development, award recognition, employee surveys and marketing to employees) or to analyze our workforce in accordance with applicable laws;
compliance with applicable laws and protection of our legitimate business interests, legal rights and obligations, including, but not limited to, use in connection with planning, budgeting, calibration, headcount, database administration, diversity metrics, surveys, evaluations, reports, performance reviews, development assessments and career plans or legal claims, compliance, regulatory, audit, investigative and disciplinary purposes;
where you have given consent regarding your photograph, for example, we may ask for your permission to use your image in a company publication. Where we ask for consent, you are free to withhold or revoke it;
sensitive Personal Data about Employees such as data relating to health and union affiliations are processed in relation to absence management, sick pay, and in order for us to otherwise perform our obligations or exercise our rights under employment, tax, social security and similar laws. Where sensitive Personal Data of Employees is collected, we will ensure that any additional legal requirements are complied with.
In addition to information about Employees, you may also provide us with information about your dependants, relatives and friends for health and other insurance policies and for use in case of an emergency. You must tell those people that you have provided their data to us and that we store and use their data for the purposes for which you provided it in the manner set out in this Privacy Policy.

3.4 Applicants

We process Personal Data of Applicants in the context of recruitment for the following purposes:

as required exclusively to administer, process and evaluate the application of the concerned Applicant or to assess their suitability for available roles based on their profile created;
if an Applicant provides the details of a reference or any other third party e.g. educational institution as part of the Applicant’s application, this authorizes us to contact the said person or organization to verify any information provided and related to the relevant work experience and qualifications of the Applicant.

4. Legal Bases for the Processing

We need to hold, process and transfer your Personal Data but solely for legitimate business purposes, and it is only disclosed on a need-to-know basis to those who are authorised to use it for these purposes.

We process the Personal Data listed above for the following purposes:

As required to establish and perform contractual relationship, to maintain or terminate it and to enable us to manage your account and our Products and Services applicable to you.
As required by us to enable our business and pursue our legitimate interests, and where our interests are not overridden by your data protection rights.
Compliance with applicable laws and protection of our legitimate business interests, legal rights and obligations.
Where you have given consent.

5. Cookies when using Online Services

Cookies are small text files which are transferred to your computer or other storage device. Cookies can identify your internet browser but not you. You can adjust your web browser to restrict, limit or deny cookies, but then parts of our websites may not functional correctly.You can learn more about how to manage your cookies by visiting www.aboutcookies.org.

Your consent is not required for us to send and utilise the necessary cookies (Session Cookies) that maintain the continuity of your browsing session while you move around the website(s), enable you to access secure areas, or allow you to save items to an online list or “basket”.

We will ask for your consent before sending your device any cookies that collect information about which of our webpages are most visited and what errors are experienced on those webpages, so that we can improve our website design and layout, and improve the effectiveness of our platforms and software applications.

We will ask for your consent before sending your device any cookies (Persistent Cookies) that enable our websites to recall the selections you made in order to provide a personalised experience in terms such as language and city or country location.

We will ask for your consent before sending your device any advertising cookies that enable the delivery of advertising content related to your browsing history.

Third parties may use cookies and other technologies such as web beacons, Adobe Flash technology (including Flash Local Stored Objects also known as “Flash Cookies”) and JavaScript on our websites and platforms in connection with online services like banner advertising, internet site analytics, maps, social sharing and surveys. This may allow them to collect information about your use of our website or platform (including your device’s internet protocol address) which they may store domestically or in other countries, including the United States. The use of these technologies allows these third parties to deliver customised advertising content, measure the effectiveness of their advertising, evaluate users’ use of our websites and provide other services relating to internet site activity and internet usage. Those third parties may also transfer the information they collect to others if required to do so by law, or if those others process the information on their behalf.Please note that setting the Flash Player to restrict or limit acceptance of Flash Cookies may limit the functionality of internet sites using Flash, which our websites may do from time to time.

You can find more details in the privacy policies of those third-party services, including information on how to restrict or deny these cookies or technologies.

6. To whom may we disclose your information?

Most Personal Data will remain with us, but we may share your Personal Data for the abovementioned purposes with affiliates, service providers (eg.payroll service providers, IT service providers, banks, credit card companies, data hosting providers), government authorities / law enforcement officials

7. Trans-border transfer of your Personal Data

Where information is transferred out of your country, including out of the European Economic Area(E.E.A.), it is transferred into New Zealand, which the E.U. Commission has determined is a country in which your data is adequately protected.

8. Security of Personal Data

We consider the confidentiality of Personal Data collected from you to be of utmost importance. To prevent unauthorised access, disclosure, interference or misuse, we have procedures and equipment to safeguard the security and confidentiality of your Personal Data. We ensure we are doing what is reasonably and technically feasible to protect your Personal Data, however, since no system is completely secure or error-free, we cannot guarantee that your Personal Data is totally protected, for example, from hackers or misuse.

You should exercise due care to safeguard any user names, passwords, identification numbers, or other special access features associated with your use of our websites or platforms or services.

9. Direct marketing to Customers

We do not provide Personal Data of concerned individuals of Customers to other entities or organisations for the purposes of direct marketing, without your consent. We may issue direct marketing communications subject to your express consent. By providing us with your consent, we may use that Personal Data to issue direct marketing communications that include promotions and information about our products and services. These communications may be sent in various forms, principally email or mail, but also by telephone, or SMS.

At any time you may opt-out of receiving our marketing communications by contacting us or by using any “unsubscribe” facility provided in the marketing communications you receive, and we will then take steps to remove your Personal Data from the direct marketing database from which your Personal Data was sourced.

10. Your Rights in Relation to their Personal Data

You can request information from us at any time as to whether and how we process your Personal Data and request that we give you access to your Personal Data or send you a copy of it.
If you believe that the Personal Data we hold about you is incorrect or incomplete, you can ask us to correct or complete it.
You may also have the right to object to the processing of your Personal Data and may ask us to restrict our use of your Personal Data and to delete it.
If we process your Personal Data based on your consent, you have the right to withdraw your consent at any time. You can withdraw your consent by emailing us or, in case of electronic direct marketing, by following the instructions in the communication. Your withdrawal will not affect the lawfulness of the processing carried out before you withdrew your consent.
With regard to the Personal Data we process based on your consent or based on a contract, you may request a copy of this Personal Data from us in a structured, commonly used and machine-readable format.
With regard to these rights some restrictions apply. For example, we cannot delete Personal Data if we are obliged to store it by law or if we retain it based on a contract with you. In addition, information about and access to Personal Data may be denied if Personal Data about another person would be disclosed with the provision of the information or if it is not possible for us to disclose the concerned Personal Data for legal reasons.

If Personal Data is required by us to fulfil a legal or contractual obligation, providing this information is mandatory: If this information is not provided, we cannot perform the contract or fulfil our obligations. In all other cases, the provision of the requested Personal Data is voluntary.

You may always lodge a complaint with a privacy authority in the country or state in which you reside.

11. How Long We Retain Your Personal Data

In principle, we will keep Personal Data for as long as it is necessary for our relationship with you or otherwise allowed or required under applicable law. If we are processing a specific request you send us, we will generally keep the concerned Personal Data for as long as is necessary to process this request. Afterwards, we may retain Personal Data for an appropriate period to protect ourselves from legal claims, to administer our business, or to the extent permitted by applicable law, which may require us to hold the concerned Personal Data for specific periods. If we process Personal Data based on consent, we will delete this Personal Data upon withdrawal of the consent. Any deviating retention period will be specified when we collect the Personal Data (ie. when we ask for consent).

Once the purpose for which the Personal Data was initially collected is achieved and the retention period ended, we will delete or anonymize it in a secure manner without unreasonable delay.

If we cannot entirely delete Personal Data due to statutory retention obligations or billing and accounting obligations, the Personal Data will be blocked until the respective retention period expires or until the billing or accounting purpose has been fulfilled, meaning that the Personal Data is excluded from further use.

13. Data Controller and Contacting Us

We request that complaints about breaches of privacy be made in writing to assist our investigations. We will respond and try to resolve your complaint within a reasonable timeframe or within the timeframe required by the laws of your location. To contact us, please use the contact details at www.dadelszen.com