Last Updated: 1 November 2014
At Mi9
New Zealand Limited (Mi9 NZ) we are committed to protecting and
maintaining your privacy. Mi9 NZ is bound by the Information Privacy Principles
(IPPs), which are contained in the Privacy Act 1993 (Privacy Act).
As part of our business operations we may collect your personal information.
This Privacy Policy describes the type of personal information we may collect
and how we use, store and disclose this personal information. If you have any
questions regarding this privacy policy, please contact our Privacy Officer
(using the contact details below).
As part
of Mi9 NZ’s normal business operations we may collect your personal
information. This Privacy Policy describes the type of personal information
that Mi9 NZ may collect and how we use, store and disclose this personal
information. It applies to your conduct on the Mi9 NZ websites, which includes
the online websites and mobile sites bearing the Mi9 NZ header and footer, as
well as any downloadable apps (the "Mi9 NZ Sites"). Where specified,
parts of this policy applies to the Mi9 NZ Sites together with the third party network
of websites, mobile sites, applications and other digital properties and
products on which Mi9 NZ sells advertising, including without limitation
Microsoft Products and our third party network of websites (which may include
partner advertising networks which will run advertising campaigns on a
blind-buy basis) (collectively, the “Mi9 NZ Ad Network”).
This
Privacy Policy is in addition to the general Terms of Use governing the Mi9 NZ Sites
and should be read in conjunction with such Terms of Use.
Microsoft
Products and Services
Where
the Mi9 NZ Ad Network incorporates leading global Microsoft products, services
and properties such as Outlook, Skype, Xbox, Bing and Windows Live (“Microsoft
Products”), personal information provided by you in connection with
Microsoft Products may be collected and used by Mi9 NZ (in which case this
Privacy Policy will govern our use and collection of your personal information)
and Microsoft Corporation (and its affiliates) (in which case the Microsoft Online Privacy Statement will
apply to Microsoft’s collection and use of your personal information).
Mi9 NZ
AND PRIVACY
Mi9 NZ’s
Commitment to Privacy
When you
deal with Mi9 NZ, whether online or otherwise, Mi9 NZ takes its privacy
obligations seriously. Generally, Mi9 NZ will handle personal information
collected online consistently with the way that it handles personal information
collected offline.
This Privacy Policy is designed to tell you about how Mi9 NZ uses and manages
personal information provided to, or collected by Mi9 NZ. We believe you should
be made aware of our practices so you can make informed decisions about how you
allow us to use your personal information.
Changes
to this Privacy Policy
In this
ever changing world Mi9 NZ may, from time to time, review and update this
Privacy Policy to take account of new laws, technologies and changes to Mi9 NZ’s
operations. All personal information held by Mi9 NZ will be governed by Mi9 NZ's
most recent Privacy Policy. The most recent Privacy Policy will always be
available on our website or by contacting the Mi9 NZ Privacy Officer (contact
details set out below).
WHAT
KIND OF PERSONAL INFORMATION DOES Mi9 NZ COLLECT AND HOW DOES Mi9 NZ COLLECT
IT?
The
type of information we collect
The
types of personal information we collect will vary depending on the nature of
your dealings with Mi9 NZ, Mi9 NZ Sites and the Mi9 NZ Ad Network. We only
collect personal information that we need for our business activities, or which
is volunteered to us. In general, the type of personal information Mi9 NZ
collects and holds could include (but is not limited to) your name, address
(postal and email), contact details, geographic location (including your suburb
or post code), gender, date of birth, transaction details relating to your use
of Mi9 NZ and/or Microsoft products and services and any preferences you tell
us about.
How we
collect your information
We may
collect your personal information over the internet, over the phone, when you
write to us, when you attend an event run by us or when you participate in a
survey, questionnaire, competition or other marketing campaign run by us or our
partners.
In order
to access some Mi9 NZ services and products, you may be asked to sign in with
an e-mail address and password, which we refer to as your Mi9 ID credentials.
As part of creating your credentials, you may also be requested to provide
questions and secret answers, which we use to help verify your identity and
assist in resetting your password, as well as an alternate e-mail address. Some
services may require added security, and in these cases, you may be asked to
create an additional security key.
How we
store your personal information
Mi9 NZ
may hold your personal information in electronic or hard copy format or a
combination of both. This personal information may be combined or linked with
other information held about you, including information that we receive from
third parties. We have taken a number of physical, electronic and procedural
steps to protect your personal information from misuse, interference, loss,
unauthorised access, modification or disclosure.
Mi9 NZ
protects the personal information it collects in a secure database stored by
our third party data storage provider. It is in proprietary data format, which
can only be read using proprietary tools.
Mi9 NZ
also employs firewalls, intrusion detection systems and virus scanning tools to
protect against unauthorised persons and viruses from entering our systems.
Mi9 NZ
employees are required, as a condition of their employment, to treat personal
information held by Mi9 NZ as confidential, and to maintain the confidentiality
of that personal information.
Collection
of information which is not ‘Personal Information’
We also
collect additional information about your interaction with the Mi9 NZ Ad
Network websites, services and products (including the Microsoft Products)
without identifying you as an individual. For example, we use website analytics
tools on our websites to retrieve information from your browser, including the
website you came from, the search engine(s) and the keywords you used to find
our site, the pages you view within our site, your browser add-ons, and your
browser's width and height. We also use technologies, such as cookies and web
beacons (described below), to collect information about the pages you view, the
links you click and other actions you take on our sites and services.
Additionally, we receive certain standard information that your browser sends
to every website you visit, such as your IP address, browser type and language,
access times and referring Web site addresses. We also deliver advertisements
(see the Display of Advertising section below) and provide website
analytics tools on non-Mi9 NZ and Microsoft websites and services, and we
collect information such as page views on these third party sites as well.
Anonymous
data which we collect about you via your interaction with the Mi9 NZ Ad Network
may be used by Mi9 NZ for the purposes described in this Privacy Policy or may
be sold or otherwise provided by us to third parties including our partners,
clients and service providers for purposes including (but not limited to)
data-matching, campaign analysis, selling aggregated anonymous data via
advertising exchanges, conducting launch surveys, and modelling.
When you
receive newsletters or promotional e-mails from Mi9 NZ, we may use web beacons
(described below), customised links or similar technologies to determine
whether the e-mail has been opened and which links you click in order to
provide you with more focused e-mail communications or other information.
ANONYMOUS
TRANSACTIONS
Mi9 NZ
will not make it mandatory for you to provide Personal Information unless such
Personal Information is necessary in order for Mi9 NZ to provide a
product/service or otherwise achieve the desired outcome. Mi9 NZ may however
request that you provide Personal Information voluntarily to Mi9 NZ (for
example, as part of a competition or questionnaire).
Mi9 NZ
will allow you to transact with it anonymously wherever that is reasonable and
practicable.
Information
we collect from other sources
In order
to offer you a more consistent and personalised experience in your interactions
with Mi9 NZ, information collected through one Mi9 NZ service may be combined
with information obtained through other Mi9 NZ services. We may access
information about you from our Related Bodies Corporate and third-party sources
and platforms (such as social networking sites, databases, online marketing
companies, Microsoft Products, third party websites on the Mi9 NZ Ad Network
and ad targeting companies) and supplement the information we collect with
information obtained from those third party sources. For example:
*
we may use services from other companies that enable us to
derive a general geographic area based on your IP address in order to customise
certain services to your geographic area.
*
we may collect anonymous information provided to Microsoft through
your Windows Live ID account; and
*
we may obtain third party information relating to your
advertisement interaction and viewing data, such as ad click-through rates and
information about how many times you viewed a particular advertisement.
HOW Mi9
NZ USES PERSONAL INFORMATION
Generally,
we only use personal information for the primary purpose for which we have
collected it, or for another closely related secondary purpose. For example, if
you provide us with your personal information in order to enter a competition
promoted by Mi9 NZ, we will use this personal information for the purpose of
facilitating the competition and for related secondary purposes only. Our
potential usages of personal information which Mi9 NZ collects (and for which
you consent to us using your personal information for) may include the
following purposes:
*
operating and improving our websites, products and services
*
providing you with news and information about our products and
services (including newsletters, product surveys and special offers);
*
providing you with more effective customer service;
*
enabling us to conduct customer research;
*
performing research and analysis aimed at improving our
products, services and technologies;
*
displaying content and advertising that are customised to your
interests, preferences and experiences.
*
occasionally sending marketing and promotional material about
our products and/or services (or the products and/or services of our Related
Bodies Corporate) that we believe you may be interested in.
*
providing to entities whom Mi9 NZ or its Related Bodies
Corporates have a shareholding in (“Associated Entities”) for the
purpose of such entities providing data matching and targeted advertising
services;
*
conducting competitions or promotions on behalf of Mi9 NZ and
selected third parties;
*
verifying your identity;
*
to allow you to log in or otherwise access products and/or
services owned or operated by Mi9 NZ or its Related Bodies Corporate;
*
communicating with you, including by email, mail or telephone.
*
investigating any complaints about or made by you, or if we have
reason to suspect that you are in breach of any of our Terms of Use or that you
are or have been otherwise engaged in any unlawful activity; and/or
*
using personal information as otherwise required or permitted by
any law (including the Privacy Act).
Mi9 NZ
may state a more specific purpose at the point we collect your personal
information.
You
acknowledge and agree that any personal information submitted by you on the Mi9
NZ Ad Network may be provided by Mi9 NZ to its related bodies corporate and
Associated Entities and used by those organisations for any of the purposes
disclosed in this Privacy Policy.
Please
contact the Mi9 NZ Privacy Officer via email at privacyofficer@mi9.co.nz if you
wish to request that Mi9 NZ (or any of its related bodies corporate) cease
using your personal information for any or all of the purposes described under
this Privacy Policy.
DOES Mi9
NZ DISCLOSE PERSONAL INFORMATION TO THIRD PARTIES?
Except
as described below in this Privacy Policy, Mi9 NZ will not disclose your
personal information outside of Mi9 NZ and its Related Bodies Corporate and
Associated Entities without your consent.
Mi9 NZ
may disclose personal information it collects about you to third parties for a
variety of purposes in connection with Mi9 NZ providing its products, services
and special offers to you (including to our agents, related bodies corporate
and contractors). Personal information may be disclosed to third parties by Mi9
NZ in the following circumstances:
a.
Service Providers
We occasionally engage other companies to provide limited
services on our behalf, such as handling the processing and delivery of
mailings, data-matching, providing customer support, hosting websites,
providing debt recovery services, processing transactions, or performing
statistical analysis of our services. Personal information collected by Mi9 NZ
may be disclosed to these third parties to whom Mi9 NZ contracts out
specialised functions. For example, Mi9 NZ may disclose your personal
information to a business that provides competition management services to Mi9
NZ where that business needs your personal information to contact you in
connection with your participation in the competition. If Mi9 NZ does need to
disclose personal information to third party contractors under outsourcing or
contracting arrangements, Mi9 NZ's policy is to take reasonable steps to ensure
that those third parties:
i.
comply with the IPPs when they handle your personal information;
ii.
preserve the confidentiality of the personal information; and
iii.
are authorised only to use personal information in order to
provide the services or to perform the functions required by Mi9 NZ.
b.
Clients/Partners of Mi9 NZ
Personal information collected by Mi9 NZ from an individual may
be disclosed to a specified third party client or partner of Mi9 NZ if the
individual has consented to such disclosure.
For example, if an individual provides personal information to Mi9
NZ and the individual expressly checks a box prior to providing that personal
information which confirms they agree to have their personal information
provided to the third party partner (e.g. for the purpose of receiving
marketing communications directly from that third party partner), Mi9 NZ will
disclose this individual’s personal information to the specified third party
partner for this purpose only. Any subsequent communications received by the
individual from that third party partner will be subject to that third party
partner’s privacy policy.
c.
Disclosures required by law or Mi9 NZ policies.
We may access or disclose information about you, including the
content of your communications, in order to: (a) comply with the law or respond
to lawful requests or legal process; (b) protect the rights or property of Mi9
NZ or our customers, including the enforcement of our agreements or policies
governing your use of the products or services; or (c) act on a good faith
belief that such access or disclosure is necessary to protect the personal
safety of Mi9 NZ employees, customers or the public.
We may also disclose personal information as part of a corporate
transaction such as a merger or sale of shares or assets.
Otherwise, Mi9 NZ will only disclose personal information if you
consent, or if it is otherwise permitted under the Privacy Act.
OPTING
IN AND UNSUBSCRIBING
Opting
In
At the
point Mi9 NZ collects information from you, you may be asked to “opt in” to
consent to us using or disclosing your personal information other than in
accordance with this Privacy Policy or the Privacy Act. For example, you may be
asked to opt-in to receive further information or communications from our
advertisers and partners which do not fall into one of the categories described
above.
Opting
Out / Unsubscribing
You will
be given the opportunity to “opt out” from receiving communications from us or
from third parties that send communications to you in accordance with this
Privacy Policy. For example, you will be given the option to unsubscribe from
newsletters, emails and other marketing or promotional material sent by us. You
may “opt out” from receiving these communications by clicking on an unsubscribe
link at the end of an email.
If you
receive communications purporting to be connected with us or our services that
you believe have been sent to you other than in accordance with this policy, or
in breach of any law, please contact the Mi9 NZ Privacy Officer (contact
details set out below).
THIRD
PARTY WEBSITES COMPRISING THE Mi9 NZ AD NETWORK
Other
than Mi9 NZ Sites, the Mi9 NZ Ad Network is comprised of sites that are not
owned or operated by Mi9 NZ and that are operated by third parties. Such third
party sites are not controlled or maintained by Mi9 NZ. We may collect
information from such third party sites in connection with serving or targeting
advertising. However, we are not responsible for the privacy practices of those
companies that are in fact responsible for these third party sites. These third
party sites may collect personal information from you that may be shared with Mi9
NZ. This Privacy Policy will apply to any personal information we obtain in
this manner.
SECURITY
AND MANAGEMENT OF PERSONAL INFORMATION
Mi9 NZ
understands that the security of your personal information is important. Mi9 NZ's
policy is to ensure all our employees understand and take reasonable steps to
keep personal information secure from unauthorised access, misuse, loss and
interference.
We take
physical, electronic and managerial steps to ensure that the personal
information we hold is secure from unauthorised access, destruction, use,
modification or disclosure. We only permit your details to be accessed by
authorised personnel. Mi9 NZ has also appointed a Privacy Officer to oversee Mi9
NZ’s management of personal information in accordance with this Privacy Policy
and the Privacy Act.
Additionally,
we take reasonable steps to destroy or permanently de-identify personal
information when we no longer need it. We also impose strict requirements of
security and confidentially on all third parties as to how they store, handle
and deal with personal information.
In
striving to ensure that the security, integrity and privacy of personal
information submitted to our site is maintained to the highest level, Mi9 NZ
regularly reviews and updates its security measures in light of current
technologies. Unfortunately, no data transmission over the internet or
publically available website can be guaranteed to be totally secure and you
need to be aware of this when using any Mi9 NZ Sites.
Personal
information collected on the Mi9 NZ Ad Network may be stored and processed both
in Australia and/or overseas countries including (but not limited to) the
United States, Singapore and any other country in which Mi9 NZ or its
affiliates, subsidiaries or service providers maintain facilities. Some of Mi9
NZ’s third party contractors and service providers may perform some of their
services overseas. For instance, a third party contractor may utilise a server
hosted overseas as a method to send emails to Mi9 NZ customers. In all
instances where this occurs, Mi9 NZ takes reasonable steps to ensure that third
parties overseas handle all personal information in accordance with the APPs
and this Privacy Policy.
USE OF
COOKIES
What is
a cookie?
A
“cookie” is a small text file that is placed on your hard disk by a Web server.
Cookies contain information that can later be read by a Web server in the
domain that issued the cookie to you. Cookies cannot be used to run programs or
deliver viruses to your computer.
How we
use cookies
The Mi9 NZ
Ad Network uses cookies to enable you to sign in to our services and to help
personalise your online experience. One of the primary purposes of cookies is
to store your preferences and other information on your computer in order to
save you time by eliminating the need to repeatedly enter the same information
and to display your personalised content. The Mi9 NZ Ad Network also use
cookies as described in the What kind of personal information does Mi9 NZ
collect and how does Mi9 NZ collect it? and Display of Advertisements
sections of this Privacy Policy.
Cookies
and Windows Live IDs
When you
sign in to a website using your Windows Live ID credentials, your unique ID
number is stored in an encrypted cookie on your hard disk. This cookie allows
you to move from page to page at the site without having to sign in again on
each page. Cookies are also used to improve the sign in experience. For
example, your e-mail address may be stored in a cookie that will remain on your
computer after you sign out. This cookie allows your e-mail address to be
pre-populated, so that you will only need to type your password the next time
you sign in. If you are using a public computer or do not otherwise want this
information to be stored, you can select the appropriate radio button on the
sign-in page, and this cookie will not be used.
Declining
cookies
You have
the ability to accept or decline cookies. Most Web browsers automatically
accept cookies, but you can usually modify your browser setting to decline
cookies if you prefer. If you choose to decline cookies, you may not be able
use interactive features of the Mi9 NZ Ad Network websites and services that
depend on cookies, and some advertising preferences that are dependent on
cookies may not be able to be respected. If you choose to accept cookies, you
also have the ability to later delete cookies that you have accepted. If you
chose to delete cookies, any settings and preferences, including advertising
preferences, controlled by those cookies will be deleted and may need to be
recreated.
USE OF
WEB BEACONS
What is
a web beacon?
The Mi9 NZ
Ad Network may contain electronic images known as “web beacons” - sometimes
called single-pixel gifs - that may be used to assist in delivering cookies on
our sites and allow us to count users who have visited those pages and to
deliver co-branded services.
How we
use web-beacons
Mi9 NZ
may include web beacons on all webpages on the Mi9 NZ Ad Network in order to
determine whether messages have been opened and acted upon. We may also employ
web beacons from third parties in order to help us compile aggregated
statistics regarding the effectiveness of our promotional campaigns or other
operations of our websites. We prohibit web beacons on our websites from being
used by third parties to collect or access your personal information.
Finally,
we may work with other companies that advertise on the Mi9 NZ Ad Network to
place their Web beacons on Mi9 NZ sites in order to allow us to gather
statistics and better target advertisements on the Mi9 NZ Ad Network website
that may result in a purchase or other action on the advertiser's site.
NIELSEN//NETRATINGS
Mi9 NZ
utilises the Nielsen//Netratings Australia auditing system on the Mi9 NZ Ad
Network. Nielsen//Netratings Australia collects data and uses cookies on the Mi9
NZ Ad Network. For further information about Nielsen//Netratings Australia’s
collection of data, use of cookies or to access Nielsen//Netratings Australia’s
opt-out tool, please visit nielsen-online.com
DISPLAY
OF ADVERTISEMENTS
Advertising
on the Mi9 NZ Ad Network
Many of
the websites and online services we offer, as well as those of our partners,
are supported by advertising. Through the Microsoft Advertising Platform, we
may display advertisements on the Mi9 NZ Ad Network (which includes the sites
of our advertising partners including the Mi9 third party ad network).
How we
personalise our advertising
When we
display online advertisements to you, we will place one or more persistent
cookies on your computer in order to recognise your computer each time we
display an advertisement to you. The cookies we use for advertising have an
expiry date of no more than two years. Because we may serve advertisements on
many different websites, we are able to compile information over time about
where you, or others who are using your computer, saw and/or clicked on the
advertisements we display. We use this information to make predictions about
your characteristics, interests or preferences and to display targeted
advertisements that we believe may be of interest to you. We may also associate
this information with your visit, purchase or other activity on participating
advertiser’s websites in order to display targeted advertisements or to determine
the effectiveness of the advertisements.
While we
may use some of the information we collect in order to personalise the
advertisements we show you, the Microsoft systems we use are designed to select
advertisements based only on data that does not personally and directly
identify you. For example, we may select the advertisements we display
according to certain general interest categories or segments that we have
inferred based on:
*
demographic or interest data, including any you may have
provided when creating a Windows Live ID account (e.g. age, postal code,
gender), demographic or interest data acquired from other companies, and a
general geographic location derived from your IP address;
*
the pages you view and links you click when using the Mi9 NZ Ad
Network and its advertising partners’ and clients’ websites and services;
*
the search terms you enter when using Microsoft Internet search
services, such as Bing; and
*
information about the users you most frequently interact with
through social networking services.
Your
advertising choices
When we
display personalised targeted ads, we take a number of steps designed to
protect your privacy. For example, page views, clicks and search terms used for
ad personalisation targeting are stored separately from your contact
information or other data that directly identifies you (such as your name,
e-mail address, etc.). We also give you the ability to control your preferences
to receive this type of advertising via the Mi9 NZ opt out tool. For more
information or to use our opt-out tool, you may visit www.youronlinechoices.co.nz which
offers a single location to opt-out of ad targeting from member companies.
Third
party personalised advertising and YourOnlineChoices
Online
advertisements on the Mi9 NZ Ad Network are primarily served by Microsoft
Advertising Platforms. We also serve advertising campaigns via other ad serving
networks, to display advertisements on our sites. These companies currently
include, but are not limited to Sizmek, Double Click, Facilitate and Eyewonder.
These
companies may offer you a way to opt in or opt-out of ad targeting based on
their cookies. You may find more information on these companies’ websites or by
visiting www.youronlinechoices.co.nz.
ACCESS
TO PERSONAL INFORMATION
Under
the Privacy Act, you have the right to request access to the personal
information which Mi9 NZ holds about you. There are some limitations to this
right set out in the Privacy Act, which mean that we can refuse to provide you
access to that information in limited circumstances, including where granting
you access might have an unreasonable impact on the privacy of other
individuals, if the request is frivolous or vexatious; or if the information
relates to anticipated legal proceedings. If you wish to exercise your right
under the Privacy Act to seek access to the personal information that Mi9 NZ holds
about you, we ask that you contact Mi9 NZ using the contact details for the
Privacy Officer set out below. We will assume (unless you tell us otherwise)
that your request relates to our current records about you. These current
records may include personal information about you which is included in our
databases and in paper files (and which we may use on a day to day basis), or
in tapes of programs which we have broadcast.
Generally,
Mi9 NZ will endeavour to acknowledge your request for access within 7 days, and
to provide you with access within 30 days of the date of receipt of your
request. We will notify you if we consider it will take longer than 30 days to
provide you with access.
Therefore,
if you seek access to records held by Mi9 NZ which are not current records, our
Privacy Officer will need to contact you to discuss your request. If your
access request to archived records is granted, please be aware that it may take
a longer period of time to locate these records and that we may charge you for
the cost of providing access.
CORRECTION
OF PERSONAL INFORMATION
Mi9 NZ
endeavours to ensure that the personal information it holds is accurate,
complete and up-to-date.
You have
the right to ask us to correct information about you which is inaccurate, incomplete,
out of date, not relevant or misleading. Mi9 NZ is required to take such steps
(if any) as are reasonable in the circumstances to correct the information. You
are able to seek correction of your personal information that we hold about
you, by notifying our Privacy Officer. Mi9 NZ’s policy is to respond to your
request for correction within 30 days of receipt.
HOW TO
CONTACT THE Mi9 NZ PRIVACY OFFICER
If you
have any questions regarding this Privacy Policy, complaints regarding how we
handle your personal information or would like to make an access request,
please contact Mi9 NZ via e-mail privacyofficer@mi9.co.nz. All
complaints received will be assessed by the Privacy Officer and all reasonable
steps (if any) will be taken to remedy the complaint. Mi9 NZ will endeavour to
respond to your complaint within 30 days of receipt of the complaint by Mi9 NZ’S
Privacy Officer.
Mi9 NZ
Pty Limited is a Mi9 company.