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Privacy Policy

Orionet Limited Site Visitor Privacy Policy

Welcome to the Customer Site Visitor privacy policy of Orionet Limited and its affiliates. This policy provides details of our processing of data that is collected from users of our websites.
Orionet Limited is a company that provides online services. Your privacy is our priority and for this reason on this page we have outlined what information we collect about you, how we use it and where we store it.
References to ‘you’ and ‘your’ are references to individual users and site visitors interacting with the customers/suppliers and affiliates of Orionet Limited websites.
We have tried to make everything which follows as clear and as simple as possible, but if you have questions you can contact us and we will be happy to help. Please find our contact details at the end of this policy.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. TRANSFERS OF DATA
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. LIMITATION OF LIABILITY
  11. GLOSSARY

1) IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy:
This policy will deal with the way that data is collected by our websites, through our use of cookies, identifiers and other technologies when an individual interacts with our Website.
This policy provides specific information regarding our processing of Visitor Information collected through the tracking of cookies and other technologies.
It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.
Processor
Orionet Limited is the processor on behalf of our Customers of the personal data collected in the circumstances described in this Privacy Policy. Orionet Limited is collectively referred to as “Company”. The Company is made up of different legal entities. This privacy policy is issued on behalf of the members of the Orionet Limited group of companies so when we mention Orionet Limited, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Orionet Limited group of companies responsible for processing your data.
Where we collect and process personal data relating to employees, agents, officers, workers and contractors of our customers, those of our commercial partners and visitors to our website (Individuals), we do so as a controller. For more information regarding how we collect and process Individuals, please see our Privacy Policy, here.

If you have any questions about this privacy policy, please contact us using the details set our below:

Contact details
Our full details are:
ATTN: Orionet Limited
Orionet Limited
15 Polaris Place
East Tamaki
Auckland 2013
New Zealand

Privacy@Orionet.nz

You have the right to make a complaint at any time to the Office of the Privacy Commissioner (https://www.privacy.org.nz/). We would, however, appreciate the chance to deal with your concerns before you approach the Office of the Privacy Commissioner so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We may change this policy from time to time. Although we will strive to ensure that any such changes are small, and we will inform our customers if we intend to materially change the way in which we use your data. We recommend that you consult this privacy policy regularly for updates.

2) THE DATA WE COLLECT ABOUT YOU

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different types of data about you, which we have grouped together below as follows:
• Personal Data: Email address, First name and Last name, Phone number, Address, Postal code and City
• Technical Data: Includes Internet Protocol (IP) address, browser information and preferences.
• Usage Data: Includes information about how you use any Customer Website, products and services.
• Cookies: We use “cookies” and similar analytics-driven technologies to track interaction with Customer Websites. Where a cookie is stored on your device, we assign a unique cookie ID to that device.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3) HOW IS YOUR PERSONAL DATA COLLECTED

Data collection through our Websites
Orionet Limited collects and records information about users’ visits to and use of our Websites through the use of industry-standard cookies and web beacons on our Websites. Cookies and web beacons exchange data between our servers and each user’s computer, based on instructions from our Customers.
In other words, we collect information regarding users only as enabled and permitted by our Customers. For example, at the direction of a Customer, when a user visits or purchases a product from a Customer Website, we generally collect and record such information as the user’s Internet Protocol (IP) address, the user’s browser and operating system, the website from which the user came, the pages on the Customer Website that the user visits and the date and time of the visit, the products and other information displayed on the pages the user visits, the links the user clicks, the search terms the user enters and information about other interactions between the user and Customer Website (such as what products the user adds to shopping carts and whether the user purchases the contents of shopping carts).
This information is not linked to any personally identifiable information and is not used by Orionet Limited to personally identify the user.
Visitor Information is collected through Customer Websites or by our Customers and their partners. We rely on Customers and such partners to ensure that appropriate information is provided to applicable users regarding our collection, use and disclosure of Visitor Information as set out in this policy and that each user is made aware of the lawful basis for such processing.
Website Analytics
We may use third-party Service Providers to monitor and analyse the use of our Service (such as Google analytics).

4) HOW WE USE YOUR PERSONAL DATA

Although the actual practices by our Customers will be set out in their privacy policies, our Customers may typically use and disclose the Visitor Information for the following purposes:
• To analyse trends relating to Customer Websites;
• To better understand how users interact with Customer Websites;
• To monitor aggregate usage by users on Customer Websites;
• To monitor web traffic routing on Customer Websites;
• To improve Customer Websites and to create web properties and applications that are easier to use and are more appealing to users;
• To enable third party contractors to assist such Customers with the foregoing;
• To assist Customers in using and understanding Visitor Information, including by providing Customers with related reports and data summarizing;
• To improve the quality of our services and other services that Orionet Limited provides to its Customers.
Except as described in this policy, Orionet Limited does not rent, sell, share, distribute or disclose Visitor Information to parties other than our Customers except when we have express permission from the applicable Customer or when we reasonably believe that we are required to do so by law or to establish or exercise our legal rights or defend against legal claims.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, collected on behalf of our Customers, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity Type of data Lawful basis for processing including basis of
legitimate interest
To estimate the number of unique users interacting with a Customer Website
1. Such processing is necessary for our legitimate
interests (to assist our customers in understanding approximately how many end users interact with their websites); or 2. Where our Customers have obtained your consent to our processing of your personal data, on the basis of such consent.
To improve the user’s experience on the Customer Website
(a) Technical (b) Cookies (c) Usage
1. Such processing is necessary for our legitimate
interests (to assist our clients in providing more relevant search and navigation pages, product suggestions, automatic search phrase completion); or 2. Where our Customers have obtained your consent
to your processing of your personal data, on the basis of such consent.
To track the user’s browsing activity, patterns and preferences to enable our customers to understand how users interact with their website.
(a) Technical (b) Cookies (c) Usage
1. Such processing is necessary for our legitimate interests (to assist our clients in providing a (a) Technical
personalized search experience, malicious and (b) Cookies
web spider detection); or (c) Usage
2. Where our Customers have obtained your consent to our processing of your personal data, on the basis of such consent.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5) DISCLOSURES OF YOUR PERSONAL DATA

We may disclose your data to third parties such as:
• Other members of our group of companies;
• Authorised third-party service providers who provide IT and administration services to us to help us to provide our services;
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services; and
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

6) TRANSFERS OF DATA

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside New Zealand and choose to provide information to us, please note that we transfer the data, including Personal Data, to New Zealand and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
We share your personal data with other companies within our group. This will involve transferring your data outside the European Economic Area (EEA). Some of our external third-party service providers are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data adequate protection.

7) DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Orionet Limited takes reasonable precautions to protect personal data relating to Individuals which is processed and collected by Orionet Limited. Orionet Limited follows generally accepted industry standard security measures to secure such personal data and protect it from unauthorized access or against loss, misuse or alteration by third parties. Orionet Limited maintains personal data behind a firewall.
Although we make good faith efforts to store personal data in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of personal data during its transmission or its storage on our systems.
Further, while we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information.
Links to other sites
Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
We do not warrant or represent that personal data will be protected against, loss, misuse, or alteration by third parties.

8) DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9) YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
• Request access to your personal data: this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. This is commonly known as a “data subject access request”.
• Request correction of your personal data: this enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data: this enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You can also ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
• Object to processing of your personal data: where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we
have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing your personal data: this enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request transfer of your personal data: we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. (Note: this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.)
• Children’s Privacy – our Service does not address anyone under the age of 18 (“Children”).We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
If you wish to exercise any of the rights set out above, please contact us.
Please note, where we process your information for statistical purposes, certain of the above rights will not be available to you. Please contact us for further information on which of the above rights will not apply to our processing of personal data for statistical purposes.
What we may need from you
Where we are not able to determine with any degree of certainty whether the information requested by you relates exclusively to you, our disclosure of such information to you may pose a privacy risk to a third party (for example, where a cookie is associated with a device used by more than one person). We will assess each request to exercise any of the rights listed above individually on its merits and will disclose the requested information where we are satisfied that such disclosure does not represent a privacy risk to any third party.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10) LIMITATION OF LIABILITY

By using our website, you agree to:
In no event shall Orionet Limited, its affiliates or any of their respective directors, officers, employees, agents, or content or service providers be liable for any indirect, special, incidental, consequential, exemplary or punitive damages arising from or directly or indirectly related to the use of, or the inability to use, the site or the content, materials and function related thereto, including, without limitation, loss of revenue, or anticipated profits, or lost business, data or sales, or cost of substitute services, even if Orionet Limited or its representative or such individual has been advised of the possibility of such damages. Some jurisdictions do not allow the limitation or exclusion of liability so some of the above limitations may not apply to you. In no event shall the total liability of Orionet Limited to you for all damages, losses, and causes of action (whether in contract or tort, including, but not limited to, negligence or otherwise) arising from the terms of your use of these sites exceed, in the aggregate, $200.

11) GLOSSARY

Lawful Basis
Legitimate Interest means the interest of Orionet Limited in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties
Other companies in the Orionet Limited Group and who are based [in the United Kingdom, the United States, New Zealand, Japan, Singapore and Australia] and provide IT and system administration services and undertake leadership reporting.
External Third Parties
• Service providers acting as processors based in the UK, USA, Australia, Japan, Singapore and New Zealand who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Changes to this Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:
• By email: Privacy@Orionet.nz