Privacy statement: SLPM
Limited, trading as SLPM Ltd and HomeAds ……..., and its related
entities (collectively, SLPM, us, we, our) are committed to
protecting the privacy of your personal information. SLPM Ltd is required to
comply with the Privacy Act 2020 (Privacy
Act) in New Zealand.
The purpose of this
privacy statement is also to inform you of your rights in relation to your
personal information. It covers the collection, processing and other use
of personal data under the General Data Protection Regulations (GDPR) 2018. Other
policies may apply instead of or in addition to this Privacy Policy in certain
circumstances.
By
using our websites (including our websites at www.homeads.co.nz, www.slpm.co.nz,
and any other website we may establish or operate from time to time), and/or
providing your personal information to us you consent to us handling your
personal information in accordance with this Privacy Policy.
We
reserve the right to update this privacy statement at any time and for any
reason, so we encourage you to make sure that you are familiar with the current
version of our privacy statement. Any change we make applies from the date the
updated Privacy Policy is posted on our website.
What
personal information do we collect?
The
kinds of personal information we collect and hold about you, and our use of
that information, is dependent on the products and services we provide to you.
The
products and services that we provide include real estate services for the
buying, selling, leasing, development and advertising of residential,
commercial and rural properties, providing services in connection with
arranging utility connection, removalists, cleaners, conveyancing, financing
and insurance.
Generally,
this personal information may include (but is not limited to) your name,
address, date of birth, telephone number, email address, details of the
products or services you have enquired about, property value, rental amounts,
insurance details, references (in relation to rental arrangements and job
applicants) and photo identification.
How
do we collect your personal information?
Generally,
we collect your personal information directly from you unless it is
impracticable or unreasonable to do so (for example where you deal with a third
party, rather than us). From time to time, we may collect personal information
about you from third parties (for example, from your representative, from
publicly available sources, from your referees where you apply for a position
with us, when you transact with our franchisees or if you apply to become a
franchisee).
If
you provide us with personal information about a third party, you represent,
and we collect it on the basis that, you have that person’s consent for us to
collect and handle their personal information in accordance with this privacy policy.
When
collecting your personal information, we will take reasonable steps to provide
you with certain information as required under the Privacy Act, including the
purpose of collection, who we may disclose your personal information to, any
law that requires or authorises us to collect the information and the main
consequences if we do not collect all of the personal information we require.
If we collect your personal information from another source, we will take
reasonable steps to ensure you are aware of the fact and the circumstances of
that collection.
Generally,
if we are unable to collect the personal information we require, we may not be
able to provide you with the products and services you seek. If the information
provided is incorrect or incomplete, this may also prevent, limit or otherwise
affect our ability to provide products or services to you.
How
is your personal information collected by the SLPM website?
Our
websites may use cookies. We do not use the information stored in those cookies
to collect information about you or your computer. The cookies are used for
statistical purposes and to assist with your use of the website. We may also
collect click-stream data when you use the website, such as the date and time
of your visit, the pages you accessed, your IP address, the type of browser and
operating system you are using and the websites you come from and move to. This
information is collected for statistical purposes to assist us to find out how
our website is used and navigated and to improve our website.
SLPM
websites may contain links to third party websites. SLPM is not responsible for
the privacy, security or handling of your personal information via those
websites. You should review the privacy policy and terms of use for those websites
each time you visit them.
Why
do we collect, hold and use your personal information?
We
will use and disclose your personal information for the purposes for which we
collected it, and for other related purposes that you would reasonably expect.
Generally,
these purposes include responding to your enquiries, providing you with
products and services such as those set out in the section above, providing you
with marketing information about our products and services, obtaining your
feedback on your customer experience, conducting promotional activities and for
our general business operations (for example, recruitment, maintenance of our
business records, compliance with our legal and insurance obligations and
statistical purposes).
By
providing us with your personal information, you consent to us using your
personal information for these purposes. You agree that we may send you such
information by post or by electronic means such as email. You can opt-out of
marketing and promotional communications at any time by contacting our Privacy
Officer via the details shown below.
How
do we disclose your personal information?
We
may disclose your personal information to:
·
Our licensees, agents and contractors
for the purposes set out above, and for the purposes of those parties providing
services to us or performing business services or functions on our behalf;
·
other companies or individuals who
assist us in providing services or who perform functions on our behalf (such as
mailing houses, hosting and data storage providers, specialist consultants and
legal advisers);
·
other companies or individuals who
perform checks (such as but not limited to compliance reviews and audits) that
are necessary or desirable under law on our behalf;
·
other companies, agencies or individuals
that maintain databases against which your identity may be verified, which may
include (but is not limited to) the New Zealand Department of Internal Affairs,
and New Zealand Transport Agency;
·
courts, tribunals and regulatory
authorities (such as the Real Estate Authority, and Ministry of Justice in New
Zealand);
·
Office of the Ombudsman, where a
complaint relates to official information;
·
any person or agency we believe could
assist in responding to a serious privacy breach;
·
Office of the New Zealand Privacy
Commissioner, where a complaint relates to breach of the Privacy Act 2020;
·
Human Rights Commission, where a
complaint relates to discrimination;
·
CERT NZ, where appropriate to assist
with the management of a voluntarily notified privacy breach
·
overseas privacy regulator, where a
complaint relates to the actions of an overseas agency; and
·
anyone else to whom you authorise us
to disclose it.
Apart
from the above instances, we may also use and disclose your personal
information with your consent and as otherwise required or permitted by law.
Storage
of personal information
We
may hold your personal information in electronic formats or in hard copy, at
our offices at at 88 McCormacks Bay Road or at premises outside our offices,
including data storage facilities or online storage located within or outside
New Zealand, which may be operated by independent service contractors.
Where
your personal information is transferred outside New Zealand, we will ensure
the intended recipient has provided appropriate safeguards and that requisite
rights and remedies in relation to the personal information remain available,
or we will obtain your explicit consent for the transfer.
Management
of personal information
We
take reasonable steps to securely store your personal information to ensure it
is protected from unauthorised access, modification and disclosure, and from
other types of misuse, interference and loss. This includes electronic and
physical security measures and procedures, staff training and use of password protection
software.
We
will take reasonable steps to destroy or permanently de-identify your personal
information when we no longer require it for any purpose for which it was
collected. We may retain your personal information for as long as necessary to
comply with any applicable law, for legal, insurance and corporate governance
purposes, for the prevention of fraud and to resolve disputes. Your personal
information may also be retained in our IT system back-up records.
The
transfer of data over the Internet is inherently insecure. We cannot guarantee
the security, during transmission, of any personal information provided to us
via our websites. Please bear this in mind when transmitting information by
this means to us.
Your
right to access and correct your personal information we hold
The
Privacy Act and the GDPR give you the right to access information held about
you by us. You may lodge a request to access and correct personal information
that we hold about you if you believe it is inaccurate, incomplete,
out-of-date, irrelevant or misleading by contacting our Privacy Officer via the
contact details shown below.
You
may request that we provide you with access to the personal information we hold
about you. Generally, we will provide you with access, except in limited
circumstances where the Privacy Act permits us to deny access. Any such
requests must be made in writing and directed to our Privacy Officer via the
details shown below. We will respond to your request within 20 working days of
the day on which the request is received.
Under
the Privacy Act, we may be permitted to charge you a reasonable fee for
providing access to your personal information. Please note that no fee will be
incurred for requesting access, and if your request for access is accepted, we
will inform you of the fee (if any) that will be payable for providing access
if you proceed with your request.
You
may ask us to inform you of the source of any personal information about you
that we have collected from a third party. We will provide this at no cost,
except in limited circumstances where laws permit us to withhold this
information.
You
have the right to change the permissions that you have given us in relation to
how we may use your data. You also have the right to request that we cease
using your data or that we delete all personal data records that we hold
relating to you. You can exercise these rights at any time by writing to our
Privacy Officer at the address detailed below.
Making
a complaint
You
may lodge a complaint with us if you believe we have handled your personal
information other than in accordance with the Privacy Act. To do so please
contact our Privacy Officer via the contact details below. We will confirm
receipt of your complaint and set out the time frame we require to investigate
your complaint and provide you with a response. We will endeavour to respond as
quickly as possible, which will typically be within 14 days of receiving your
complaint.
You have the right
to make a complaint to the New Zealand Privacy Commissioner. This can be done
through the Privacy Commissioner online complaint form here: https://privacy.org.nz/your-rights/making-a-complaint/complaint-form/
Contact
us
If
you would like further information about the way we manage your personal
information, or if you have a privacy-related complaint, please contact our
Privacy Officer by telephone on 0800 884422, by mail at 88 McCormacks Bay Rd,
Mt Pleasant, Christchurch 8081 or by email at info@slpm.co.nz
For
the purpose of the GDPR, we are the data controller and any enquiry regarding
the collection or processing of your data should be addressed to our Privacy
Officer at the contact details above.
Office
of the Privacy Commissioner
More information
about your rights and our obligations in connection with your personal
information are available from the Office of the Privacy Commissioner at www.privacy.org.nz
Last
updated: 20/09/2022
