Privacy Policy

This Application collects some Personal Data from its Users.

Owner and Data Controller

HWR – 25 Esk Street 1104, Invercargill 9840, New Zealand Owner contact email: [email protected]

Introduction

• This Policy sets out how H W Richardson Group Limited (HWR, us, we, our) deals with your personal information or data and how we protect your privacy.
• We will only deal with personal information and data in accordance with the Privacy Act 2020 (Privacy Act). The Privacy Act provides a framework for protecting the right to privacy of personal information, including the right to access your personal information, while recognising that other rights and interests may also need to be taken into account.

Collection of Personal Information/Data

1. We will, from time to time, collect personal information or data from you or others that directly relates to our business.
2. We will collect personal information from you if you interact with us.
3. We collect personal information from job candidates, employees, contractors, customers, visitors, potential customers and people who use our website.
4. Where you interact with us, we will collect some or all of the following personal information/data:

• Your full name;
• Your contact details including your email address, phone number and/or postal address;
• Your written communications with us;
• Your credit card number, name on your card, expiry date, and CVC code;
• Your bank account details;
• Your IRD number;
• Your engagement with our website, our social media sites and/or services.

5. If you are a job candidate or an employee we may collect your personal information to assess suitability for employment and promotion, through screening, interviewing, medical checking, pre-employment vetting and reference checking, and for the efficient administration of our various business processes, such as payroll functions. If you are successful in your application for employment, we will retain the information collected in relation to that application on your personal file

Use, storage and security of personal information

• We will only collect, use and disclose personal information in accordance with the Privacy Act.
• We will not sell your personal information or use it for an unlawful purpose.
• We will only share your personal information if required by law or if we need to with trusted third parties (third parties) who provide services to our business, for example, IT support services, our legal representatives, financial advisors, our accountant etc.
• We will use cookies and web beacons to understand how an individual engages with our website and services so we can improve our services, increase engagement, and provide you with more targeted information.
• We keep your Personal Information for as long as it is required to provide you with the products or services you requested from us and to comply with legal requirements. If we no longer require your Personal Information for any purpose, including legal purposes, we will take reasonable steps to securely destroy or de-identify your Personal Information.
• We will take reasonable steps to ensure that your Personal Information is stored securely and is protected from misuse and loss and from unauthorized access, modification or disclosure. We have a range of systems and communication security measures. Access to your Personal Information is restricted to those properly authorized to have access.

Access to and correction of Personal Information

• We will make every effort to ensure that any personal information held by us is accurate, up to date, complete, and relevant to the purpose for which it was collected.
• We may contact you from time to time to clarify whether your personal information is accurate and to respond to any enquiries you have made.
• You have the right to ask for and access any personal information we hold about you, as required by the Privacy Act. If you consider any personal information we hold about you is incorrect, you can ask us to change it. Any queries about your personal information can be raised with us.
• Where we decline to correct the information held on you, we will ask you to provide us a statement of correction which we will attach to the personal information held.
• To view or change your personal information, please contact our Privacy Officer, Elliott Mitchell, GM People, Safety & Engagement on [email protected] or +64 3 217 1706.

Privacy Officer

• Our Privacy Officer is responsible for, amongst other things, encouraging and ensuring compliance with information privacy principles and dealing with Privacy Act requests. The Privacy Officer should be your first point of contact with any queries or concerns relating to your personal information or any matter relating to the Privacy Act.
• The Privacy Officer is also responsible for dealing with all complaints, providing training and liaising with the Privacy Commission where required.

Complaints Process

• If you are concerned that your privacy has been compromised or your rights under the Privacy Act have been breached, please immediately contact our Privacy Officer.
• For more information about your rights and the Privacy Act, you can contact the Privacy Commissioner’s office on 0800 803 909 or [email protected] or visit the Privacy Commissioner’s website https://www.privacy.org.nz/

Notifiable Privacy Breach

1. If there is a breach of this Policy or any other breach of Privacy which has caused (or is likely to cause) serious harm, we will notify the Office of the Privacy Commissioner and any affected individual as soon as practicable.
2. In considering whether a privacy breach is likely to cause serious harm, we will take into account the following:

• Any action taken by us to reduce the risk of harm following the breach;
• Whether the personal information is sensitive in nature;
• The nature of the harm that may be caused to affected individuals;
• The person or body that has obtained or may obtain personal information as a result of the breach (if known);
• Whether the personal information is protected by a security measure; and
• Any other relevant matters.

Failure to report a breach of privacy to the Privacy Officer may have serious consequences for HWR, its employees or clients and may result in disciplinary action up to and including dismissal.

Consent to Privacy Policy

By engaging with our website, social media sites and/or our services, and/or by applying for or accepting employment with us you confirm your acceptance of this Policy, and you agree to our collection, use and disclosure of your personal information in accordance with this Policy and the Privacy Act.

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: email address, Cookies, Usage Data, phone number, first name, last name, company name and website. Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application. Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available. Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located. Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data. Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data. If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: User database management, Remarketing and behavioral targeting, Backup saving and management, Advertising, Interaction with external social networks and platforms, Analytics, Managing support and contact requests, Tag Management, Interaction with live chat platforms, Contacting the User, Managing contacts and sending messages and Platform services and hosting. Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Advertising

This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on this Application, possibly based on User interests. This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below. Some of the services listed below may use Cookies to identify Users or they may use the behavioural retargeting technique, i.e. displaying ads tailored to the User’s interests and behaviour, including those detected outside this Application. For more information, please check the privacy policies of the relevant services. In addition to any opt out offered by any of the services below, the User may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.

Bing Ads (Microsoft Corporation)

Bing Ads is an advertising service provided by Microsoft Corporation. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy – Opt Out.

• Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behaviour.

Facebook Ads conversion tracking (Facebook, Inc.)

Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Application. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy.

Google AdWords conversion tracking (Google Inc.)

Google AdWords conversion tracking is an analytics service provided by Google Inc. that connects data from the Google AdWords advertising network with actions performed on this Application. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy – Opt Out.

Backup on Google Drive (Google Inc.)

Google Drive is a service to save and manage backups provided by Google Inc. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: US – Privacy Policy.

• Contacting the User

Phone contact (this Application)

Users that provided their phone number might be contacted for commercial or promotional purposes related to this Application, as well as for fulfilling support requests. Personal Data collected: phone number.

Contact form (this Application)

By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header. Personal Data collected: company name, first name, last name, phone number and website.

• Interaction with external social networks and platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of this Application. The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

LinkedIn button and social widgets (LinkedIn Corporation)

The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy.

AdWords Remarketing (Google Inc.)

AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of this Application with the Adwords advertising network and the Doubleclick Cookie. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy – Opt Out.

Facebook Custom Audience (Facebook, Inc.)

Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network. Personal Data collected: Cookies and email address. Place of processing: US – Privacy Policy – Opt Out.

Facebook Remarketing (Facebook, Inc.)

Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy – Opt Out.

Remarketing through Google Analytics for Display Advertising (Google Inc.)

Google Analytics for Display Advertising is a remarketing and behavioral targeting service provided by Google Inc. that connects the tracking activity performed by Google Analytics and its Cookies with the Adwords advertising network and the Doubleclick Cookie. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy – Opt Out.

• Tag Management

This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion. This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.

Google Tag Manager (Google LLC)

Google Tag Manager is a tag management service provided by Google LLC. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy.

• User database management

This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Application, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that the Owner can display and use for improving this Application. Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application.

ActiveCampaign (ActiveCampaign, Inc.)

ActiveCampaign is a User database management service provided by ActiveCampaign, Inc. Personal Data collected: email address and various types of Data as specified in the privacy policy of the service. Place of processing: US – Privacy Policy.

Personal data capture - HWR recruitment campaign channels

Personal contact data capture for the purposes of recruitment to via a recruitment campaign to contact prospective job-seekers to arrange a follow up interview for future employment opportunities.

Channels utilised:

• Chatbot.com - Privacy Policy
• Modica Group - Privacy Policy
• META advertising and Messenger (Facebook and Instagram) - Privacy Policy
• TikTok advertising - Privacy Policy

Anyone who has submitted their details consents to being contacted in future by HWR about potential/available roles and recruitment updates. Data will either be emailed to HWR's HR team or exported by the HWR HR team into a secure server/holding location.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

This Application uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Application does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Application as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies

Small sets of data stored in the User’s device.

Web developer support

As Plato Creative can also access website data, we have provided the below information for inclusion also.As we carry out marketing on your behalf we may need to access your website from time to time to verify the quality of leads. We have provided the below blurb for your legal team to review and insert in your privacy policy outlining when and why we would access the site. We also recommend you list all tracking services that we use, and link to their privacy policies.

Google Tag Manager
Google Analytics

Plato Creative Design Limited (“we”, “us”), is committed to complying with our privacy obligations and respects and values the information that you share with us.

Our approach is set out in our privacy policy (which can be found on platocreative.co.nz) and can be summarised as follows:

• We only collect information that we really need
• We only use it for the purpose for which it was provided
• We take reasonable precautions to protect it from loss, misuse or unauthorised alteration
• We ensure that it is only accessed by members of our team that have a legitimate need to access it.

We may collect or access information as a result of administering your website and may use it to:

• Diagnose and resolve issues
• Market products and services, where the individual has opted in
• Analyse and improve our services
• To facilitate our internal business operations, including fulfilment of any legal requirements.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This privacy policy relates solely to this Application, if not stated otherwise within this document.

Latest update: 1/9/2023

HWR hosts this content and only collects the Personal Data strictly necessary for it to be provided.