Privacy policy

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 individuals 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 partners 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 NZs 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 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 Advertisementssections 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 Australias collection of data, use of cookies or to access Nielsen//Netratings Australias 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 advertisers 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 NZs 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 NZS Privacy Officer.

Mi9 NZ Pty Limited is a Mi9 company

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