Adduco Media Group Limited – Privacy Policy

Adduco Media Group Limited (“Adduco”, “Us”, “We” or “Our”) is committed to safeguarding personal privacy. To provide Adduco Sites and Services, we must process information about individuals and organisations  (“you”, “your”, or “user”)  using these Sites and Services. The type of information that we collect depends on how you use our products. Adduco recognises that you, as a user of our Sites and Services, have a right to control how your personal information is collected and used. Providing personal information is an act of trust and is taken seriously. This Privacy Policy is effective as of July 14, 2018.

Personal Data We May Collect

Adduco collect two basic types of information: personal information and non-personally identifiable information. We may use personal and non-personally identifiable information to create aggregate information. We collect the following categories of information:

  • First name and surname, username and password, email address, contact information, country of residence, job title, and other information you provide us when you create an account on the Sites or Adduco Services, sign-up to receive communications or materials from us, or otherwise submit a form to us;
  • Transaction and payment information you provide when purchasing a product or service from us, whether on our Sites or elsewhere. This information may include the information listed above as well as payment information;
  • Content and information that you submit when using the Sites or the Adduco Services; this information includes, for example, information you provide in any blogs or forums on the Sites, comments you add on the Adduco Service, information you provide when you participate in any interactive features or surveys, and information you submit when filing a support ticket;
  • Usage, viewing, logs, metrics and other device and technical data collected when you visit our Sites, use the Adduco Service as an end user, or open or reply to emails we send. This may include information such as your web request, Internet Protocol (“IP”) address, device identifiers, device information (such as OS type or browser type), cookie IDs, referring / exit pages and URLs, interaction information (such as clickstream data), domain names, pages viewed, crash data, and other similar technical data;
  • Information about you and your company collected from third party or public sources or that we receive from companies that partner with us to provide products and services; this may include information about you and your company we receive from our advertising, integration and market research partners, who may provide us with information about your interest in and/or engagement with their services, advertisements or content; and
  • Location information when you visit our Sites or use our Adduco Service, including location information either provided by a mobile device interacting with one of our sites or applications or associated with your IP address.

 

How We Use Personal Data

Adduco processes your personal information for the following purposes:

A. Adduco Products, Services and Sites

We rely upon a number of legal grounds to ensure that our use of your Personal Data is compliant with applicable law. We use Personal Data to facilitate the relationships we have with our Users, to comply with our data management, financial regulatory and other legal obligations, and to pursue our legitimate business interests. We use Account Data to:

1. Manage Contractual and Pre-Contractual Business Relationships

We use Personal Data for the purpose of entering into business relationships with prospective Adduco Users, and to perform the contractual obligations under the contacts that we have with Adduco Users.

2. Conduct Legitimate Business Interests

We rely on our legitimate business interests to process Personal Data about you. The following list sets out the business purposes that we have identified as legitimate. We:

  • Provide Users with insights and statistics regarding their accounts;
  • Aggregate and provide Users with audience metrics to facilitate marketing platform insights;
  • Provide Users with brand partnership opportunities;
  • Allow Users to manage social media content including posts, comments, and interactions; and
  • Use Account Data to complete and support payment transactions and to provide payment-related services to, from and between our Users.

3. Uphold Legal and Regulatory Compliance

We use Personal Data to verify the identity of our Users in order to comply with fraud monitoring, prevention and detection obligations, laws associated with the identification and reporting of illegal and illicit activity and financial reporting obligations. Some obligations are imposed on us by the operation of law, industry standards, and by our financial partners, and may require us to report our compliance to third parties, and to submit to third party verification audits.

4. Keep our Services Safe

We use Account Data to verify accounts and activity, maintain the integrity of our Services, and to keep the Services safe and secure;

5. Communicate with our Users

We use Account Data to send you news, updates, promotions, product information, event announcements, and other marketing communications. To understand your choices around these communications please see the “Your Rights and Choices” section below;

6. Identify our Users

We use Account Data to identify you when you login to your account;

7. Support our Users

We use Account Data to process your requests and respond to your questions and concerns. For example, if you inquire about our services or contact an Adduco representative on our Sites, we may use your data to respond to and process these requests;

8. Contact our Users

We use Account Data to communicate with you about your account or transactions, and provide you with product-related communications, such as information about new features and policy updates;

9. Improve our Services

We use Account Data to operate, maintain, analyse, develop, update and improve our Sites, the Adduco Service, and other products and services we offer. For example, we may administer and track users’ activities on our Sites and Adduco Services to determine how to improve our content and features, or we may analyse trends and gather demographic information about our user base to better tailor our marketing efforts;

10. Detect Policy Violations

We use Account Data to detect, investigate and prevent activities that may violate our policies or applicable laws (such as fraud detection and prevention) or that may threaten the security, integrity or availability of our or another party’s products, systems and services; and

11. Process External Requests

We use Account Data to act pursuant to your consent for a specific purpose not listed in this policy.

B. Marketing and Communications

We may send you email marketing communications about Adduco products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing or account management purposes, provided that we do so in accordance with the consent requirements that are imposed by applicable law. When we collect your business contact details we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and, with your permission, include you on our marketing information campaigns.

C. Third Party Advertising

When you visit our Sites or online services, both Adduco and certain third parties collect information about your online activities over time and across different sites to provide you with advertising about products and services tailored to your individual interests (this type of advertising is called “interest-based advertising”). These third parties may place or recognise a unique cookie or other technology on your browser. Where required by applicable law, we will obtain your consent prior to processing your information for the purpose of interest-based advertising.

To learn how to opt out of behavioural advertising delivered by Network Advertising Initiative member companies, please see our section below detailed “Your Rights and Choices”. If you opt out from interest-based advertising, you may see advertising that is not relevant to you. At present, there is no industry standard for recognising Do Not Track browser signals, so we do not respond to them.

If we need to use your Personal Data in other ways, we will provide specific notice at the time of collection and obtain your consent where required by applicable law.

We also use non-personally identifiable information, such as usage data and aggregated data, for other lawful purposes, such as to create blog posts and content that others may find useful.

 

How We Store Personal Data

Your information may be stored and processed in – and we may transfer information to – United States and other countries where Adduco (including its sites, subsidiaries and affiliates) and our advertising partners and service providers maintain systems and facilities. In addition, information that we collect about you (including personal information) may be transferred to our affiliated entities and/or to other third parties across borders and/or from your country to other countries around the world.

By using our Sites and Services and submitting personal and company information, you acknowledge that the collection and processing of personal data necessarily involves the transmission of data on an international basis. Although we do our best to protect your personal information, the transmission of your data is outside our control and any such transmission is at your own risk. However, we protect all personal information collected through our Sites and Services in accordance with strict data protection standards.

 

How We Share Personal Data

We do not share your personal information outside of Adduco except in certain circumstances, including:

  • When you allow us to share the information, such as when you:
    • Elect to share your personal information with third party partners and providers listed on our Sites, so they can send you information, offers and promotions about their products and services;
    • Choose to share your personal information with third parties or their sites or platforms, such as when you share one of our blog posts to your social media feed; or
    • Use third-party features on our Site or the Adduco Service, such as commenting features run by third-parties;
  • Please note that once personal information is shared with another company, the information received by the other company becomes subject to its privacy policies and practices.
  • When we cooperate with other companies, such as our partners, to offer joint services to you in connection with the Adduco Services;
  • When our service providers are providing services on our behalf. For example, we may use an outside platform to host portions of our Sites or to provide certain features on the Adduco Service, or we may use a credit card processing company to bill you for services you purchase. Unless otherwise expressly noted, when acting as Adduco’s agents, these services providers are prohibited from using the personal information we have shared with them for purposes other than those requested by us or required by law;
  • To enforce our terms, agreements, policies or rules, to help protect the security, integrity and availability of our or another party’s products, systems and services; to exercise or protect the rights, property (including intellectual property), or safety of Adduco, our users, or others; to comply with legal requirements; or in other cases if we believe in good faith that disclosure is required by law (including in response to a lawful subpoena or other law enforcement request); and
  • In connection with a sale, divesture, or transfer of our company (including any shares in the company) or any combination of its products, services, assets, affiliates, and/or businesses. Your personal information (such as customer names and email addresses, and user information related to the Adduco Service) may be among the items sold or otherwise acquired in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

We may also share non-personally identifiable information and aggregate information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) for other business purposes. For instance, we may share aggregate reports with interested third parties to help them understand the usage patterns for certain Adduco Services or for our Sites or those of our partners.

 

Your Rights and Choices

You have the right to access and review your Personal Data that Adduco maintains and have the right to make choices regarding the use and disclosure of your Personal Data. Depending on your location and subject to applicable laws in such locations, you may have the following rights with regard to the Personal Data we control about you.

Data Access

You have the right to request confirmation of whether Adduco processes Personal Data relating to you, and if so, to request a copy of that Personal Data. You may also request that Adduco rectifies or updates your Personal Data that is inaccurate, incomplete or outdated. If you would like to review, correct, or update Personal Data that you have previously disclosed or provided to Adduco, You may do so by signing in to your Adduco account or by contacting us as indicated in the “How to Contact Us” section below.

For your protection, Adduco may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file.

Data Portability and Erasure

You have the right to request that Adduco erase your Personal Data in certain circumstances provided by law. You can do so by contacting us as indicated in the “How to Contact Us” section below.

You have the right to request that we export to another company, where technically feasible, your Personal Data that we hold in order to provide Services to you. The export of non-personally identifiable and aggregated information regarding your account may be reviewed on a case-by-case basis.

Adduco reserves the right to restrict the export, disclosure and erasure of non-personally identifiable and aggregated information. This information may be stored indefinitely and requests for export, disclosure and erasure of such data may be reviewed on a case-by-case basis.

Data Processing

You have the right to request that Adduco restrict the use of your Personal Data in certain circumstances including having your account on an Adduco Site or Service temporarily disabled. In doing so, you acknowledge that your use of Adduco Sites and Services may also be restricted or disabled. Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time. You may also have the right to object to the processing of your Personal Data on grounds relating to your particular situation.

Electronic Communications

If you no longer want to receive marketing-related emails from Adduco, you may opt-out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our Services.

 

Security and Retention

Adduco is conscious about the security of your data. We have implemented technical and organisational security measures that are designed to help protect your information from unauthorised access, disclosure, use and modification. From time-to-time, we review our security procedures to consider appropriate new technologies and methods.

Please be aware, though, that despite our efforts, no security measures are perfect or impenetrable. We cannot ensure, and do not warrant or guarantee, that the information you transmit to Adduco will remain secure, nor do we guarantee that this information will not be accessed, disclosed, altered, destroyed or used in an unauthorised manner.

If we learn of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on the Site or Adduco Services if a security breach occurs. Depending on where you live, you may have a legal right to receive a notice of a security breach in writing.

How long we keep the personal information we collect depends on the type of information, the purpose for which it is used, how sensitive it is, and similar factors. In general, we will retain your personal information for the length of time reasonably needed to provide you with products and services, unless a longer retention period is required or permitted by law. We will also retain and use your information for as long as necessary to resolve disputes and/or enforce our rights and agreements. We retain your account information for the Adduco Services for as long as you or your company’s account is active and thereafter unless you or your company requests deletion. Non-personally identifiable and aggregated information may be stored indefinitely.

 

International Data Transfer

Adduco is a global business and operates Sites and Services on an international platform. Personal Data collected in accordance with this Privacy Policy may be stored and processed in any country where Adduco has operations or where we engage service providers. We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected, including to the United States and New Zealand. Such countries may have data protection rules that are different from those of your country and the country from which the data was originally collected within. However, Adduco will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Policy.

In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data and Adduco may comply with such agencies and authorities if required by law.

If you are located in the European Economic Area (“EEA”) or Switzerland, we comply with applicable laws to provide an adequate level of security for the transfer of your Personal Data to New Zealand and/or the United States. Where applicable, one or more of the following data transfer mechanisms will gover the international transfer of Personal Data: verification that the recipient adheres to the EU-US and Swiss-US Privacy Shield Framework, verification that the recipient has implemented Binding Corporate Rules, or EU Standard Contractual Clauses with a data recipient outside the EEA.

 

Use By Minors

Protecting the privacy of young children is especially important and we encourage guardians to spend time with their children to educate on online behaviours and be fully familiar with the sites that their children are visiting. For that reason, Adduco does not knowingly collect or solicit personal information from anyone under the age of 13. Adduco’s Sites and Services are not directed to individuals under the age of 13, and we request that they not provide Personal Data through the Sites and Services. In the event that we learn that we have collected personal information from a child under age 13, we will delete the information we have stored as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us as indicated in the “How to Contact Us” section below.

 

Links To External Websites

Adduco Sites and Services may provide the ability to connect to other websites and may refer to external Sites and Services where applicable. These websites may operate independently from Adduco and may have their own privacy notices or policies, which we strongly suggest you review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website or the privacy practices of the operator of the website. Inclusion of links to external websites not owned or controlled by Adduco cannot be taken to imply any endorsement or validation by us of the content of the external website. Adduco is not responsible, nor does it accept any liability, for the conduct of companies linked to or from our Sites and Service.

 

Updates To This Privacy Policy

Adduco may change this Privacy Policy from time to time to reflect changing legislation, new Sites and Services, changes in our data practices or relevant laws. Adduco reserves the right to revise to this Privacy Policy at any time without notice. The “date of last revision” legend at the bottom of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes to this Privacy Policy are effective when we post the revised Privacy Policy on relevant Adduco Sites and Services. We may provide you with disclosures and notifications regarding the Privacy Policy or Personal Data collected by posting them on our Sites and, if you are a User, by contacting you through contact information obtained in accordance with this Privacy Policy. Adduco encourages you to check this Privacy Policy regularly.

 

How To Contact Us

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to support@adduco.media or sent physically to:

Adduco Media Group
Attn: Adduco Legal
146 Bridge Street
Nelson, 7010
New Zealand

Date of last revision: 14 July 2018