GrowPay NZ Limited Privacy Policy
V 1.1 – Last Updated: October, 2022
GrowPay NZ Limited and its subsidiaries and affiliates ("GrowPay" 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 GrowPay.
We collect Personal Information from, and this Policy applies to:
individuals who visit and interact with GrowPay 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”).
The Channels may provide links to or the ability to connect with non-GrowPay websites, services, social networks or applications. Clicking on those links or enabling those connections may allow the third party to collect or share information about you. Those third-party websites or services are beyond our control. We encourage you to check the privacy policies and terms of use of any non-GrowPay websites or services before providing your Personal Information to them.
Personal and Other Information We Collect
Through your interaction with and use of the Channels and the Services, GrowPay 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:
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.
GrowPay may also collect Other Information through your interaction with and use of the Channels and non-GrowPay 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
GrowPay 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:
(a) Direct Interactions:
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.
(b) 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.
(c) Automated Interactions:
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 GrowPay's use of Automated Interactions may change over time as technology evolves, the following descriptions are designed to provide you with additional detail about GrowPay's current approach to information collected from Automated Interactions.
Electronic Communications Protocols: As is true when you visit most websites and apps, GrowPay 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.
GrowPay may also automatically receive and record information about your interaction with the Channels, such as clickstream information (when each GrowPay 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: GrowPay'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.
GrowPay 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 GrowPay. GrowPay also uses other third party cookies to provide advertising and personalisation services in accordance with this Policy, and to track the performance of GrowPay advertisements on our Channels and GrowPay e-mails.
Embedded URLs: GrowPay 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.
Contact Lists: We may access your contact list and use those details for purposes consistent with this Policy and to enhance your user experience of GrowPay including for example, populating lists of your favourites or to search when you want to do a P2P transfer. In most instances, you will be prompted for access which you can accept or deny, you can select which contacts are saved within GrowPay and your other contacts’ information is not retained by GrowPay. You consent to GrowPay accessing your contact lists and collecting Personal Information from the same for the purposes of this Policy.
How We Use and Process Information
Personal Information
GrowPay uses and processes the Personal Information it collects (unless otherwise restricted by applicable law) in the following ways:
Provide the Services. GrowPay may use Personal Information to provide the Services to or engage in transactions with you.
Process Transactions. GrowPay may use Personal Information, including financial and payment information, to process your transactions.
Provide Support or Other Services. GrowPay 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, GrowPay may use your Personal Information and Other Information to notify you about new product releases and service developments, and to advertise GrowPay'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, GrowPay may pass your contact information to the appropriate GrowPay distributor or reseller for further follow-up related to your interests.
Respond to Your Requests. GrowPay may also use Personal Information in order to respond directly to your information requests (including newsletter registrations or other specific requests) or other enquiries.
Interact with You on Third Party Social Networks. GrowPay may use your Personal Information to interact with you on third party social networks. GrowPay's interactions with you on a third party social network would be subject to that network's privacy policies and terms of use.
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. GrowPay 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. GrowPay 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. GrowPay 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.
Other Information
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 GrowPay’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. GrowPay 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 GrowPay marketing e-mails.
Cookies and Do Not Track. GrowPay enables you to opt out of cookies that are not required to enable core site functionality. GrowPay 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, GrowPay may use third-party lists to send communications about GrowPay 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 GrowPay. When we use such lists, the communications will include mechanisms to opt out of receiving GrowPay marketing communications.
Advertising
GrowPay uses third parties to administer GrowPay 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.
GrowPay may also use advertising technologies and participate in advertising technology networks that collect Other Information from GrowPay and non-GrowPay websites, as well as from other sources, to show you GrowPay-related advertisements on GrowPay’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 GrowPay. It means that you will stop receiving ads from GrowPay 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 privacy@growpay.io or write to us at the following address:
Chief Privacy Officer, GrowPay Limited, 20A Redbrook Drive 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
GrowPay 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, GrowPay 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 GrowPay. 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, GrowPay will also notify you by e-mail or mail. GrowPay 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
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 GrowPay transferring your Personal Information to its affiliates globally and to third party entities that provide services to GrowPay.
Complaints
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.
Contact Us
GrowPay 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
GrowPay Limited
20A Redbrook Drive
RD 1 Taupiri 3791
New Zealand
Email: privacy@growpay.io
Policy Updates
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: October 2022