YouPay NZ Limited and its subsidiaries and affiliates (“YouPay” or “we”) respect your preferences concerning the treatment of Personal Information that we may collect. This Policy (“Policy”) lets you know how we collect and use your Personal Information, how you can control its use, and describes our practices regarding information collected by YouPay.
We collect Personal Information from, and this Policy applies to:
individuals who visit and interact with YouPay sites (such as our websites, computer or mobile software applications, social media pages and HTML-formatted e-mail messages), as well as through offline sales and marketing activities (collectively, the “Channels”); and
our customers and those who engage directly with us to use our services and networks (the “Services”).
Personal and Other Information We Collect
Through your interaction with and use of the Channels and the Services, YouPay may collect Personal Information, which is information that identifies an individual or relates to an identifiable individual. Personal Information may include, but is not limited to:
your name and physical address, email addresses, and telephone numbers;
payment information and preferences;
behavioural or demographic attributes, when tied to personal identifiers;
past transactional behaviour on the Channels;
support queries and requests;
information obtained from third parties on your interests; and
information about your company such as the name, size and location of your company and your role within the company.
YouPay may also collect Other Information through your interaction with and use of the Channels and non- YouPay websites, which does not reveal your specific identity or does not directly relate to an individual. Other Information may include, but is not limited to:
unique IDs such as a cookie placed on your computer, mobile or device IDs;
internet Protocol address (“IP address”) and information derived from your IP address such as your geographic location;
information about your devices such as information contained in HTTP Headers (defined below) or other internet transfer protocol signals, browser or device type and version, operating system, user-agent strings and information about or from the presence or use of “apps” on your mobile devices, screen resolution, and your preferred language;
behavioural data about your usage of the Channels, such as webpages clicked, websites and content areas visited, date and time of activities; and
the web search you used to locate and navigate to the Channels.
In some instances, we may combine Other Information with Personal Information, such as deriving geographical location from your IP address and combining behavioural data about your usage of the Channels with your name. If we combine Other Information with Personal Information, we will treat the combined information as Personal Information.
How We Collect Information
YouPay and our third party service providers may collect both Personal Information and Other Information from a variety of sources that generally fall into three categories:
We collect Personal Information and Other Information provided by you when you engage us to provide Services to you or through your use of the Channels. This includes activities such as account creation, submission of registrations and forms, provision of sales, technical or consulting services by us, or sales inquiries and transactions.
The types of Personal Information we collect will vary depending on your use of the Services and the Channels. If you do not provide us with all information requested, we may not be able to provide you with the Services and products you have requested.
Wherever it is possible and practicable to do so, we will collect Personal Information directly from you. This may be in person, over the phone, by email or via the Channels. We will not collect Personal Information if it is not necessary to provide you with the Services or for you to use the Channels.
Publicly Available Data and Personal Information collected from Third Parties:
We may collect personal information about you from third parties only where you authorise us to do so, or where such information is publicly available.
When you use the Channels, we may collect general information about you through the use of technologies such as electronic communication protocols, cookies, or embedded URLs (“Automated Interactions”), so that we can provide effective Services and products to you.
Although YouPay’s use of Automated Interactions may change over time as technology evolves, the following descriptions are designed to provide you with additional detail about YouPay’s current approach to information collected from Automated Interactions.
Electronic Communications Protocols: As is true when you visit most websites and apps, YouPay may automatically receive information from you indirectly as part of the communication connection itself, which often consists of network routing information (where you came from), equipment information (browser type or device type), your IP address (which may identify your general geographic location or company), and date and time.
YouPay may also automatically receive and record information about your interaction with the Channels, such as clickstream information (when each YouPay webpage was visited and how much time was spent on the page), how often you access the Channel, performance data, aggregate usage, or general geo-location data.
Cookies: YouPay’s server will query your browser to see if there are “cookies” previously set by our electronic Channels. A cookie is a small piece of information sent by a Web server to store on a Web browser so it can later be read back from that browser. Cookies may collect information, including a unique identifier, user preferences, profile information, membership information, and general usage and volume statistical information. Cookies may also be used to collect individualised website use data, provide electronic Channel personalisation, or conduct and measure the effectiveness of advertising in accordance with this Policy. Some cookies may remain on users’ computers after they leave the website. While the majority are set to expire within 1-24 months of your last visit to the website that set the cookie, others may not expire because of their nature, such as cookies that remember opt-out preferences.
Your browser may provide you with information and control over cookies. You can set your browser to alert you when a cookie is being used, and accept or reject the cookie. You can also set your browser to refuse all cookies or accept only cookies returned to the originating servers. Users can generally disable the cookie feature on their
browser without affecting their ability to use the site, except in some cases where cookies are used as an essential security feature necessary for transaction completion. Cookies, however, are important to the proper functioning of a site, and disabling them may degrade your experience and interfere with website features and customisations.
YouPay has engaged one or more third party service providers to track and analyse both individualised usage and volume statistical information from interactions with electronic Channels. The service provider(s) may set cookies on behalf of YouPay. YouPay also uses other third party cookies to provide advertising and personalisation services in accordance with this Policy, and to track the performance of YouPay advertisements on our Channels and YouPay e-mails.
Embedded URLs: YouPay may use a tracking technique that employs embedded URLs to allow use of the electronic Channels without cookies. Embedded URLs allow limited information to follow you as you navigate the electronic Channels, but are not associated with Personal Information and are not used beyond the session.
Physical Location: We may collect and share the physical location of your device for purposes consistent with this Policy, such as to provide you with personalised location-based services or content. In some instances, you may be permitted to allow or deny such use of your device’s location, but if you choose to deny such use, we may not be able to provide you with the applicable personalised services or content.
How We Use and Process Information
YouPay uses and processes the Personal Information it collects (unless otherwise restricted by applicable law) in the following ways:
Provide the Services. YouPay may use Personal Information to provide the Services to or engage in transactions with you.
Process Transactions. YouPay may use Personal Information, including financial and payment information, to process your transactions.
Provide Support or Other Services. YouPay may use your Personal Information to provide you support or other services you have ordered, administrative messages, technical notices, security alerts as well as product updates, product patches and fixes and other similar operational communications.
Tailor Marketing to Your Needs. In accordance with your marketing preferences, YouPay may use your Personal Information and Other Information to notify you about new product releases and service developments, and to advertise YouPay’s products and services in accordance with this Policy. Your website visit, marketing experience, and communications may be tailored to your interests based on your Personal Information. With your consent, YouPay may pass your contact information to the appropriate YouPay distributor or reseller for further follow-up related to your interests.
Respond to Your Requests. YouPay may also use Personal Information in order to respond directly to your information requests (including newsletter registrations or other specific requests) or other enquiries.
Post Testimonials. We post testimonials on our Channels that may contain Personal Information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update or delete your testimonial, please request a change and be sure to include your name, testimonial location, and contact information.
Select Content, Improve Quality and Facilitate Use of the Channels. YouPay may use your Personal Information to help create and personalise content on our Channels, facilitate your use of the Channels (for example, to facilitate navigation and the login process, avoid duplicate data entry or enhance security), improve quality, track marketing campaign responsiveness (including online advertising and e- mail marketing), and evaluate page response rates.
Improve Products, Services, and Experiences. YouPay may use your Personal Information to evaluate and improve our products, services, marketing, and customer relationships, and to perform analytics and conduct research.
Comply with Legal Requirements and Corporate Transactions. YouPay may disclose your Personal Information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes; (d) to enforce our terms and conditions; and (e) to allow us to pursue available remedies or limit the damages that we may sustain. Additionally, in the event of a reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we may transfer the Personal Information we have collected to the relevant third party.
We may use, transfer, and disclose Other Information we collect for any purpose, except where applicable law requires otherwise. If we are required to treat Other Information as Personal Information under applicable law, then we will only use it in the same way that we are permitted to use and disclose Personal Information.
Disclosure of Personal Information
In the course of providing our services and products, we may need to disclose your Personal Information to certain third parties, including:
any of YouPay’s subsidiaries and affiliates;
third party services providers who assist and enable us to use the Personal Information, for the purposes set out in this policy and
to such persons that you may have agreed to provide your Personal Information to.
We may disclose your personal information if required to do so by law. We may also disclose information about someone whose activities could cause harm to themselves or others (i.e. fraud). Where possible and appropriate, we will notify you of this type of disclosure.
Registration and Privacy Choices <
E-mail Marketing. YouPay enables you to opt out of marketing communications. You may opt out of e-mail marketing by using our general unsubscribe automated link that is included in YouPay marketing e-mails.
Cookies and Do Not Track. YouPay enables you to opt out of cookies that are not required to enable core site functionality. YouPay uses its cookies preferences tool to process Internet advertising and tracking preferences but does not respond to any other Do Not Track signals.
Please remember that if you delete your cookies, or use a different browser or computer, you will need to set your cookies preferences again. You may access or change your cookie preferences at any time.
Third Party Permission-Based Lists. On occasion, YouPay may use third-party lists to send communications about YouPay products and services. These lists, which are maintained by third parties, include users eligible under applicable law to receive e-mails from other companies such as YouPay. When we use such lists, the communications will include mechanisms to opt out of receiving YouPay marketing communications.
YouPay uses third parties to administer YouPay advertisements on third party electronic channels. Other Information, such as user community or implied or inferred interests, may be used in the selection of advertising to make sure that it has relevance to the user. Some ads may contain embedded pixels that may write and read
cookies or return session connection information that allows advertisers to better determine how many individual users have interacted with the ad.
YouPay may also use advertising technologies and participate in advertising technology networks that collect Other Information from YouPay and non-YouPay websites, as well as from other sources, to show you YouPay- related advertisements on YouPay’s own and third-party websites. These advertisements may be tailored to your perceived interests using retargeting and behavioural advertising technologies, a set of practices collectively referred to as “Interest Based Advertising” in this Policy. Any retargeted or behavioural advertisements served to your browser will contain information on or near it that informs you about the advertising technology partner and how to opt-out of viewing such advertisements. Opting out does not mean that you will stop receiving ads from YouPay. It means that you will stop receiving ads from YouPay that have been targeted to you based on your visits and browsing activity across websites over time.
Access and Correction
You may request a copy of, or to review, correct, update, suppress, or otherwise modify any of your Personal Information that you have previously provided to us through the Channels or by using our Services, or object to the use or processing of such Personal Information by us. If you have privacy concerns regarding access to or the correction of your Personal Information, please contact us at email@example.com write to us at the following address:
Chief Privacy Officer, YouPay Limited, Level 16, 55 Shortland Street, Auckland 1010, NZ.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information that you have provided to us.
While the majority of questions and issues related to access can be handled quickly, complex requests may take more research and time. In such cases, issues will be addressed, or you will be contacted regarding the nature of the problem and appropriate next steps, within thirty days.
Retention and Deletion
YouPay will only retain your Personal Information for:
as long as is needed to provide you products or Services;
as needed for the purposes outlined in this Policy or at the time of collection;
as necessary to comply with our legal obligations (e.g., to honour opt-outs), resolve disputes, and enforce our agreements; or
to the extent permitted by law.
At the end of the retention period, YouPay will delete your Personal Information in a manner designed to ensure that it cannot be reconstructed or read.
Security and Breaches
The security of your Personal Information is very important to YouPay. We use physical, electronic, and administrative safeguards that are designed to protect your Personal Information from loss, misuse and unauthorised access, disclosure, alteration and destruction. While we cannot ensure or guarantee that loss, misuse or alteration of Personal Information will not occur, we use our best efforts to prevent this.
In the event of an unauthorised privacy breach in relation to your Personal Information where it is reasonable to believe that such breach has caused or is likely to cause serious harm, we are required to report the breach
to the relevant authority as soon as possible. In such circumstances, YouPay will also notify you by e-mail or mail. YouPay will give you notice as soon as possible, so that you and we may take appropriate action to protect your Personal Information.
Cross Border Transfers
YouPay subsidiaries and affiliates are global corporations with operations in multiple countries and have developed global data security practices designed to ensure that your Personal Information is appropriately protected. Please note that Personal Information may be transferred, accessed and stored globally as necessary for the uses and disclosures stated above in accordance with this policy. However, we may only disclose your Personal Information to overseas third parties if we are sure that the third party is subject to laws that provide comparable safeguards as those in the Privacy Act 2020 (New Zealand), or they agree to protect your Personal Information in such a way. By providing your Personal Information you consent to YouPay transferring your Personal Information to its affiliates globally and to third party entities that provide services to YouPay.
If you have any complaints regarding our compliance with this policy, you should first contact us. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of your Personal Information in accordance with this policy.
YouPay has appointed a Chief Privacy Officer. If you believe your Personal Information has been used in a way that is not consistent with this Policy or your specified preferences, or if you have further questions related to this policy, please contact the Chief Privacy Officer by emailing the address below or by written enquiry, addressed to:
Chief Privacy Officer YouPay Limited
Level 16, 55 Shortland Street
Auckland 1010 New Zealand
We may update this Policy from time to time. In the event we make material or significant changes, we will post a prominent notice in notifying users when it is updated.
Last Updated: January 2021