Respecting your privacy

Smart Loyalty New Zealand (“We”, “Our” and “Us”) (operators of the GetGenuine GetRewards, SmartTrade, Hirepool Rewards, Fuso Performance Rewards, Daimler Performance Rewards, Subaru Rewards, Luxaflex Inspire Rewards, AutoPlay Rewards, Ateco Rewards, Honda Rewards, Metro Rewards, Smart Partner Rewards and Farm Source Rewards programmes (“Program”)) is committed to respecting the privacy of our Members and Partners and adhering to the principles and policies contained in the Privacy Act 2020 which set clear standards for the collection, access, storage and use of personal information which we obtain as part of our business operations.

Our respect for your right to privacy of your personal information is paramount. We have policies and procedures to ensure that all personal information, no matter how or where it is obtained, is handled sensitively, securely, and in accordance with the Privacy Act 2020.

This Privacy Policy sets out:

Matters of which you should be aware regarding information we may collect about you

Our policies on the management of personal information, and generally, what sort of information we hold, for what purposes, and how we collect, hold, use and disclose that information

Terminology

In our Privacy Policy, “personal information” refers to information about a person whose identity is apparent or can reasonably be ascertained from the information or opinion.

What personal information do we collect and store?

So that we can provide services to you, we may collect personal information such as your name, address, telephone number, e-mail address and reward redemption information, to the extent that it is necessary for one or more of the following purposes:

• to provide our services to you or to other parties that are related to you;

• market, advertise or otherwise promote our services;

• to undertake market research in relation to our services;

• to improve our website and our services; and

• to comply with our obligations under any applicable laws.

• Some examples of where we may need these details are to seek your feedback on the Program or to seek your participation (on a purely voluntary basis) in advertising campaigns, launches, customer testimonials and focus groups. Privacy law requires us to collect personal information about you only from you if it is reasonable and practical to do so.

We take reasonable measures to ensure your personal information is protected from unauthorised access, loss, misuse, disclosure or alteration. We also take measures to destroy or permanently de-identify personal information when it is no longer required. The types of measures we take vary with the type of information, and how it is collected and stored.

Generally, you have no obligation to provide any information requested by us. If you choose to withhold requested information however, we may not be able to provide you with the goods and services that depend on the collection of that information, particularly if the collection of that information is required by law.

How do we collect personal information?

• directly from you when you provide information to us over the Internet using our website, email or any other form of electronic communication, over the telephone or facsimile, on forms, questionnaires or surveys, and through correspondence posted by you to us;

• directly from you when you transact with our Participating Merchants and redeem rewards from the Rewards Shop;

• from third parties, such as our related companies, credit reporting agencies or your representatives;

• from publicly available sources of information;

• from our service providers identified below; and

• when legally required to do so.

We only collect personal information by lawful and fair means and not in an unreasonably intrusive manner. To the extent reasonable and practicable, we only collect personal information about a person directly from that person.

We may collect “de-identified information” through the use of our website, including the dates and times you access our website, the domains from which you visit our website, your activity on our website and Internet Protocol addresses. This information is referred to as “click stream data” and we may use this data to analyse trends and statistics in order to improve our website and services. We collect this data using various technologies, including “cookies”. A “cookie” is a text file that this website sends to your browser which is then stored on your computer as an anonymous tag identifying your computer, but not you, to us. You can set your browser to disable cookies. However, some parts of our website may not function properly, or at all, if cookies are disabled.

Some pages on our website and emails created by our website may also contain a “web beacon”. A web beacon is a clear-pixel image which enables us to monitor your Internet activity. When you view a page containing a web beacon, a de-identified notice of your visit is generated which we may process. A web beacon generally works in conjunction with a cookie. If a person disables cookies, a web beacon will be able to generate an anonymous notice of the visit but which cannot be associated with the information contained in a cookie.

How is personal information used?

The personal information that we ask for is generally used to provide goods or services to you. For example, we need your contact details to provide you with special offers relevant to you and in the case of a competition, so that we can contact you if you win.

We may also use your personal information in other ways to provide you with superior service. This may include using your personal information to advise you of new products and services.

We may disclose your personal information to third parties for the purpose of completing our obligations owed to you under any agreement between us and you, or as required by law.

We may also disclose your personal information to third parties for the purpose of those third parties providing information to you regarding their products and/or services.

You have the right to tell us that you do not want us to send information to you other than for the main purpose for which we have collected your personal details. Where possible, we try to ensure that our disclosure of information to other organisations (for example market researchers, and others with whom we have commercial arrangements) is in a way which does not personally identify individuals.

Data Security

We will take reasonable steps to protect the personal information which we hold from misuse and loss and from unauthorised access, modification or disclosure. When using our website, you should be aware that no data transmission over the Internet can be guaranteed to be totally secure. We do not warrant the security of any information transmitted over the Internet, although we strive to protect such information. By using our website, you accept that your information will be transmitted to and from our website at your own risk.

Access to and correction of your personal information

We will provide you with access to any of your personal information we hold (except in the limited circumstances recognised by privacy law). If you wish to access your personal information please write to us at Smart Loyalty New Zealand Ltd, South Bloc Building, Level 1, 140 Anglesea Street, Hamilton 3204. or email us at privacy@smartloyalty.co.nz. Of course, before we provide you with access to your personal information we will require some proof of identity. If you need to update your information (e.g. if you change your address), please contact the relevant part of the Smart Loyalty New Zealand Limited group to which you supplied that information so we can make the change.

Transfer of personal information outside New Zealand

We may transfer personal information held about you to third parties outside New Zealand but solely for the purpose of ensuring any agreement between us and you is performed. We will take all reasonable steps to ensure that those third parties hold, use and disclose your personal information in accordance with laws equivalent to the Privacy Act 2020. Please contact us in accordance with the manner set out in this privacy policy if you withdraw your consent to us transferring your personal information to third parties outside New Zealand.

Privacy Policy changes

We may change our privacy policy from time to time. Any changes to this privacy policy will be published on our website. You may obtain a copy of our current privacy policy from our website or by contacting our privacy officer using the contact details set out above.

More information

More information about Privacy law and the Privacy Act is available from the Office of the Privacy Commissioner at www.privacy.org.nz