OUR PRIVACY POLICY
Last updated: October 2020
General
This website together with our related social media accounts that link to this policy (the ICL Sites) are each owned and operated by Ivanov Consulting Limited (New Zealand company number 4874440) (ICL, us, we or our).
We are committed to respecting your privacy and ensuring the security of any personal information you provide to us. Any personal information you provide to us, whether via any of the ICL Sites or otherwise, will be collected, held and used by ICL in accordance with this policy and all applicable privacy laws. This policy covers our data processing activities as an "agency" (under the Privacy Act 2020 (NZ) of New Zealand (Privacy Act)) and/or "controller" (under the EU General Data Protection Regulation (GDPR)), as applicable.
When this policy refers to our "processing" your personal information, it covers all activities relating to our use of that personal information, from its collection through to its storage and disposal and everything in between. For the purposes of this policy ‘personal information’ means identifiable information about you, for example your name, email, address, telephone number, bank account details, payment information, support queries, community comments and so on. If you cannot be identified (for example, when personal information has been aggregated and anonymised) then this policy doesn’t apply. Check out our terms of use for more information on how we treat your other data.
We may need to update this policy from time to time, including when necessary to reflect changes to the ICL Sites, updates to our services or to reflect any changes in law. When we update this policy, we will revise the "Last updated" at the top of the policy. Where the changes are material, we will use reasonable endeavours to notify you – usually by prominently posting a notice of those changes on the ICL Site or by sending you an email.
We encourage you to read this policy carefully. If you have any questions, please contact us using the details available here.
How we collect your personal information
Information you provide to us directly
We collect personal information that you submit when using the ICL Sites, including by filling in any of the online forms available on the ICL Sites or subscribing to any of our mailing lists. The personal information you provide to us may include information such as your name, addresses, email, phone numbers and/or payment account information as well as any additional information you otherwise choose to provide us from time to time.
Where you provide us with any third party personal information, you must have that third party's consent to do so. By providing us any third party personal information, you warrant that you have that third party's permission to provide that information to us.
Information collected automatically
To make the ICL Sites more useful to you, our servers may collect information from you, including your browser type, operating system, Internet Protocol (IP) address, domain name, and/or a date/time stamp for your visit.
Furthermore, in order for you to access certain functionality of any ICL Site, a cookie or cookies may need to be installed on your device. Cookies are small text files that are placed on your device by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
Most internet browsers give you the option to reject all cookies, accept all cookies, erase cookies stored on your device or be notified before a cookie is stored on your device. However, if you reject or erase the cookies referred to above some features or services of the ICL Sites will not function properly or may not be fully available. Please refer to your internet browser instructions if you want to find out more about rejecting or erasing cookies.
If we don’t collect your personal information, we may be unable to provide you with all our services, and some functions and features on our ICL Sites may not be available to you.
How we use your personal information
If you choose to provide us with personal information, we will primary use your information to operate the ICL Sites, to provide you with any goods and/or services you have requested and otherwise to support our relationship with you.
We may also use your personal information for other purposes, which may include the following:
· to support your use of ICL goods and/or services, this may include assisting with the resolution of product issues or other issues relating to the ICL Sites, whether by email or otherwise;
· to improve and enhance our services and the design and style of the ICL Sites;
· to monitor, respond to and/or keep records of our e-mail communications and other correspondence with you;
· to analyse the use of any of the ICL Sites to ensure that content from the ICL Sites is presented in the most effective manner for you and for your device;
· if you opt-in to receive information about our promotional offers and/or newsletters from us, we may use your personal information to contact you by email and/or post with the information you have opted-in to receive.
· Apart from sending you marketing communications, we shall not use your personal information to display targeted third party advertising to you online, whether through the ICL Sites or through third party websites and their platforms. We may however use your personal information to display targeted advertising for other ICL products or platforms;
· to produce aggregated and anonymised analytics and reports, which we may share publicly or with third parties;
· in order to detect and/or prevent any illegal activity that may threaten any ICL Site; and
· in order to comply with any applicable laws and/or regulations.
We will not keep your personal information for longer than is reasonably necessary to fulfil the purposes outlined in this policy and to allow us to comply with our legal obligations.
How we may share your personal information
There will be times when we need to share your personal information with third parties. Where we do disclose your personal information to third parties, we do so in connection with the purposes outlined above and will use reasonable efforts to make those third parties aware of the terms of this policy.
We may disclose your personal information to:
· any related company of ICL;
· third party service providers who assist and enable us to use your personal data to support delivery of our products to you or provide functionality on the ICL Sites, for example, these third party service providers may include:
o payment processors engaged by us to securely store or handle payments information, such as credit or debit card details;
o providers of appointment / meeting scheduling software;
o providers of services that provide aggregated reports on website activity;
o providers of email management and distribution tools; and
o web-hosting companies;
· regulators, law enforcement bodies, government agencies, courts or other third parties where we think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights;
· an actual or potential buyer (and its agents and advisers) in connection with an actual or proposed purchase, merger or acquisition of any part of our business; and
· other people where we have your consent.
These service providers may be granted access to some or all of the personal information you provide or we collect, but will be restricted from using your personal information you provide other than as is reasonably necessary to perform their services for us. The third parties to whom we disclose your personal information may be located within or outside New Zealand.
Where any disclosure is to a third party located outside New Zealand we will only make that disclosure in accordance with the requirements for overseas transfers of personal information as set out in the Privacy Act and any other applicable privacy laws. You may request more information about the safeguards that we have put in place in respect of transfers of Personal Information to jurisdictions outside of New Zealand by contacting our data privacy officer.
Your rights in connection with your personal information
Under certain circumstances, by law you have certain rights in connection with your personal information, including rights to:
· request access to your personal information;
· request correction of your personal information; and
· request erasure of your personal information.
If you wish to exercise any of the rights described above, please contact our Privacy Officer (details below). Please note that, if you are located in New Zealand, there are some statutory exceptions (contained in Part 4 of the Privacy Act) where your request for access to your personal information may be denied.
If you are unsatisfied with the handling of your complaint, you may contact us further here to advise us of your concerns and, if we are unable to reach a satisfactory resolution, you may wish to take your complaint to the Office of the Privacy Commissioner in New Zealand (or your local data protection authority, if you are located in the European Economic Area (EEA)) for a review of your complaint.
If you have any questions about what personal information we hold about you or you have a question or feedback for us on this policy or any of the ICL Sites, please get in touch with our privacy officer using the contact details set out below.
If you would like any further information about our handling of personal information or to make a complaint about something you believe breaches the Privacy Act (or, as applicable, the GDPR), please lodge a written complaint addressed to our Privacy Officer using the email address below. Once we receive your complaint, we will respond to your complaint within a reasonable period of time, usually within 20 working days (or, for customers in the EEA, in any event in accordance with any applicable requirements of the GDPR).
Please note that we may keep a record of your communications to help us resolve any issues that you raise.
Privacy officer
Andrey Ivanov