Blinder Limited (we, us, our) complies with applicable privacy laws, including in Australia the Privacy Act 1988, and in New Zealand the Privacy Act 1993 (in each case, the Act), and the General Data Protection Regulation of the European Union (GDPR) when dealing with personal information.
Personal information is information about an identifiable individual (a natural person), and includes personal data, personally identifiable information and equivalent information under applicable privacy and data protection laws.
This policy was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal information. We are happy to provide any additional information or explanation needed. Any request for further information should be sent to firstname.lastname@example.org.
CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION
This policy was last updated on 05/06/2019
|Blinder Call||a phone call transmitted using the Blinder Service, and made by or to a Customer.|
|Customer||a person who accesses and uses the Blinder Service as a customer of Blinder, and/or, where that access and use is on behalf of another person (e.g. an individual for whom that person acts), that other person.|
WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT
We collect the following general types of personal information in connection with the use of the Blinder Service:
- information that you provide to us directly, e.g. during Registration or in the course of your other dealings with us (Customer Information), including:
- name, email, address, phone numbers and other contact details
- local addresses, where these are required by a third party to allocate a local phone number to you
- your preferences and instructions relating to the management of your calls as part of the Blinder Service
- call-related data (other than Call Content) for Blinder Calls (Call Data), including:
- the phone number from where the call is initiated
- the phone number to which the call is sent or diverted
- time and duration of the call
- call briefing notes
- the contents of Blinder Calls, which we may record and/or transcribe strictly on behalf, and in accordance with the preferences and instructions, of the relevant Customer (Call Content)
- the Customer Information, Call Data, Call Content and any other information collected directly from Customers is collectively known as the Customer Data.
We only process Customer Data as authorised by our customers in our Blinder Terms of Service. Unless required otherwise under applicable law, if we receive any request or enquiry relating to Customer Data, we will forward this request to our relevant customer.
WHO WE COLLECT PERSONAL INFORMATION FROM
We may collect personal information:
- from you, when you provide that personal information to us, including via the Website and any related service, through Registration, through any direct contact with us (e.g. phone call or email, where Blinder is a party to the communication), or when you buy or use the Blinder Service or any of our other services and products
- that is included in any Call Data, from you or the other party to the call, where you are a party to a Blinder Call
- that is included in any Call Content, on behalf of the relevant Customer
- from third parties where you have authorised this or the information is publicly available (including third party service providers who specialise in collecting and providing publicly available information)
- which is generated by us in our interactions with you, e.g. your User ID.
If you have concerns about the collection of personal information by us, contact us at email@example.com.
HOW WE USE PERSONAL INFORMATION
We use your personal information in the following ways:
- where you are a Website user and/or Customer, to market our services and products to you, including contacting you electronically (e.g. by text or email for this purpose)
- to verify your identity, where it is reasonably necessary to do so
- to undertake credit checks of you, if necessary
- where you are a Customer, to bill you and to collect money that you owe us, including authorising and processing credit card transactions
- to respond and deal with communications from you, including to resolve complaints or issues with the Blinder Service
- to provide the Blinder Service to you, where you are a Customer, including:
- to manage Blinder Calls in accordance with your preferences and instructions
- to transcribe and provide Call Content to you in accordance with your instructions
- to monitor, maintain and improve the Blinder Service and its Underlying Systems, but to the extent that we use Call Data or Call Content for this purpose we do so only as is strictly necessary
- (other than Call Content) to conduct research and statistical analysis (on an anonymised basis)
- to protect and/or enforce our legal rights and interests, including defending any claim
- for any other purpose authorised by you, the Act or any other applicable law.
We may transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition.
DISCLOSING YOUR PERSONAL INFORMATION
We may disclose your personal information:
- to another company within our group
- to telecommunications carriers, for the purpose of enabling the transmission of Blinder Calls
- to any other business that supports our services and products, including any person that hosts or maintains any Underlying Systems or data centre that we use to provide the Blinder Service or Website, for the purpose of enabling us to provide them, but to the extent that we use Call Data or Call Content for this purpose we do so only as is strictly necessary
- to a credit reference agency for the purpose of credit checking you
- where you are a Customer, to our payment processer for the purpose of processing payments from you
- collected as Call Data, to the Customer on whose behalf we transmitted the relevant Blinder Call
- collected as Call Content, to the Customer on whose behalf we recorded and/or transcribed the relevant Blinder Call
- (other than Call Content) to other third parties (on an anonymised basis)
- to a person who can require us to supply your personal information (e.g. a regulatory authority)
- to any other person authorised by the Act or another law (e.g. a law enforcement agency)
- to any other person authorised by you.
A business that supports our services and products may be located in the United States or other locations outside Australia or New Zealand. This may mean your personal information is held and processed outside your location.
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
A business that supports our website, products and services may be located outside of New Zealand (the country where we are incorporated) and also outside of the country where you are located. This means that the personal information we collect may be transferred to, and stored in, a country outside of New Zealand and the country where you are located.
If you are located in the European Economic Area (EEA), your personal information may be transferred outside of the EEA. Under the GDPR, the transfer of personal information to a country outside the EEA may take place where the European Commission has decided that the country ensures an adequate level of protection. In the absence of an adequacy decision, we may transfer personal information if other appropriate safeguards are in place.
Where we transfer personal information outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data, or to a third party where approved transfer mechanisms are in place to protect your personal information (e.g. to organisations in the United States under the EU-U.S. Privacy Shield framework or by entering into the European Commission’s Standard Contractual Clauses. For further information, please contact us at firstname.lastname@example.org.
Some of the personal information we collect is processed in New Zealand. New Zealand is recognised by the European Commission as a country that has an adequate level of data protection and we rely on this decision in transferring personal information to New Zealand.
PROTECTING YOUR PERSONAL INFORMATION
As required by applicable law, we will take reasonable steps to keep your personal information safe from loss, unauthorised activity, or other misuse. We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks inherent in processing personal information.
You play an important role in keeping your personal information secure by maintaining the confidentiality of any password and accounts used in relation to our products and services. You should not disclose your password to third parties. Please notify us immediately if there is any unauthorised use of your account or any other breach of security.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
Subject to certain grounds for refusal set out in the Act and/or any other applicable laws (e.g. laws governing the collection and use of data relating to telecommunications services), you have the right to access your personal information that we hold and to request correction to your personal information. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.
In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the personal information, we will make the correction. If we do not make the correction, we will take reasonable steps to note on the personal information that you requested the correction.
If you want to exercise either of the above rights, email us at email@example.com. Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information, or the correction, that you are requesting).
Subject to applicable law, we may charge you our reasonable costs of providing to you copies of your personal information or correcting that information.
Subject to applicable law, we may refuse to allow you access to your personal information where to do so may identify, or involve unwarranted disclosure of information about, another individual.
While we take reasonable steps to maintain secure internet connections and other communications systems, if you provide us with personal information over the internet or other networked systems, the provision of that information is at your own risk. You acknowledge that no system is 100% secure and that our obligations do not provide a guarantee that your personal information will be secure against unauthorised access or loss (including hacking).
DATA RETENTION POLICY
The personal information that we collect and use will not be kept longer than necessary for the purposes for which it is collected, or for the duration required for compliance with applicable law, whichever is longer.
The name and contact details of our Data Protection Officer for the purposes of the GDPR are:
|Phone number||+64 9 888 9222|
GDPR ADDITIONAL TERMS
LAWFUL BASIS FOR PROCESSING PERSONAL INFORMATION
Our lawful basis for processing (as that term is defined in the GDPR) personal information that we collect, use and disclose depends on the personal information collected and the context in which we collect it.
Generally, we collect personal information from you where we have your consent, where processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, or where processing is necessary for the purposes of our legitimate interests (except where such interests are overridden by your interests or fundamental rights and freedoms).
Where we process personal information based on your consent, you may withdraw your consent at any time.
Despite the above, we may process your personal information where such processing is necessary for compliance with applicable laws.
If you have any question about the legal basis on which we process personal information or need further information, please contact us at [insert email address].
YOUR RIGHTS UNDER THE GDPR
If you are located in the European Union, your rights in relation to your personal information include:
- right of access - if you ask us, we will confirm whether we are processing your personal information and provide you with a copy of that personal information
- right to rectification - if the personal information we hold about you is inaccurate or incomplete, you have the right to have it rectified or completed. We will take reasonable steps to ensure inaccurate personal information is rectified. If we have shared your personal information with any third party, we will tell them about the rectification where possible
- right to erasure – when your personal information is no longer needed for the purposes for which you provided it, we will delete it. You may request that we delete your personal information and we will do so if deletion does not contravene any applicable law. If we have shared your personal data with any third party, we will take reasonable steps to inform those third parties that they must delete your personal information
- right to withdraw consent - if the basis of our processing of your personal information is consent, you can withdraw that consent at any time
- right to restrict processing - you may request that we restrict or block the processing of your personal information in certain circumstances. If we have shared your personal information with any third party, we will tell them about this request where possible
- right to object to processing - you may request that we stop processing your personal information at any time and we will do so to the extent required by the GDPR
- rights related to automated decision-making, including profiling - you have the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such automated decision-making is necessary for entering into, or the performance of, a contract with you, is authorised by applicable laws or is based on your explicit consent. We do not undertake automated individual decision-making
- right to data portability - you may obtain your personal information from us that you have consented to give us or that is necessary to perform a contract with you. We will provide this personal information in a commonly used, machine-readable and interoperable format to enable data portability to another data controller. Where technically feasible, and at your request, we will transmit your personal information directly to another data controller
- the right to complain to a supervisory authority - you can report any concern you have about our privacy practices to your local data protection authority.
Where personal information is processed for the purposes of direct marketing, you have the right to object to such processing, including profiling related to direct marketing.
If you would like to exercise any of your above rights, please contact us at firstname.lastname@example.org. If you are not satisfied by the way we deal with your query, you may refer your query to your local data protection authority.
By continuing to use our website and related services, you indicate your agreement for us to use the cookies described below.
WHAT ARE COOKIES
Cookies are text files containing small amounts of information which are downloaded to your browsing device, e.g. a computer or smartphone, when you visit a website. Cookies can be recognised by the website that downloaded them, or by other websites that use the same cookies. This helps a website know if the browsing device has visited that or other websites before.
Cookies can be used to collect information relating to your use of a website or your device, let you navigate between pages effectively, help to remember your preferences and generally improve your browsing experience. Cookies can also help ensure advertising you see online is more relevant to you and your interests.
Cookies can be session or persistent cookies. Session cookies are temporary and only stay on your browser until you stop browsing. Persistent cookies stay on your device until they expire or are deleted.
The cookies used on our website may be first party cookies (i.e. set by us) or third party cookies (i.e. cookies set on our website by a person other than us). The third party companies that place cookies on our website will have their own privacy policies.
WHAT TYPES OF COOKIES DO WE USE
The types of cookies used by us, and most websites, can generally be categorised as follows.
Strictly necessary cookies
These cookies are essential for the full functionality of our website and related services. They enable you to navigate around our website and services and use their features e.g. accessing secure areas and enabling services that you have asked to receive. If you opt out of these cookies, you may not be able to access all the functions of our website and some services that you have asked to receive.
These cookies do not track where else you have been on the internet and do not remember your preferences beyond your current visit. These cookies are generally first party session cookies which will expire when you close your browsing session. These cookies do not collect information that could be used for marketing purposes.
These cookies allow a website to remember choices you make and provide enhanced, more personal features. e.g. these cookies allow us to remember the settings you have applied to the website (such as font size, preferences or colours), identify whether you are a returning website visitor and present you with a personalised version of the website, or eliminate the need for you to re-enter your login details. The information these cookies collect is generally anonymous and they do not track your browsing activity on other websites. These cookies may be first or third party, session or persistent cookies.
These cookies collect information about how you use a website, e.g. which pages are the most visited and if you receive any error message from any page. This information helps us improve the way our website and related services work and helps us manage the performance and design of the website and services. These cookies do not gather information that identifies you. All of the information these cookies collect is aggregated and anonymous. These cookies may be first or third party, session or persistent cookies.
Targeting cookies are used to present advertising that is relevant to you and your interests. These cookies collect information about your browsing habits e.g. the pages you have visited and the links you have followed across the internet. They may also be used to limit the number of times you see an advertisement and help measure the effectiveness of advertising campaigns. These cookies will usually be persistent but time-limited and may be placed on our website by third party service providers or advertising partners with our permission.
We use targeting cookies to present interest-based advertising on our website and for retargeting. This is a form of interest-based advertising that enables our advertising partners to build a profile of your interests and show you advertising based on your browsing activity across the internet, including to allow us to advertise to people who previously visited our website.
We use Google Analytics to collect information about visitors to our website. Google Analytics collects information related to your device, browser, IP address, network location, and website activities to measure and report statistics about your interactions on our website. We use this information to help us manage the performance and design of our website and to improve our website.
We use Google Analytics Advertising Features, including[Remarketing with Analytics, Demographic and Interests reporting in Analytics, Campaign Manager integration (formerly known as DoubleClick), Display & Video 360 integration, Google Display Network (GDN) Impression Reporting and Segment]. We also use Google Ads.
HOW TO CONTROL OR OPT OUT OF COOKIES AND TARGETED ADVERTISING
You can control and/or delete cookies as you wish. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. However, if you do this, you may have to manually adjust some preferences every time you visit our website and attempt use our services, you may not be able to access certain parts of our website or services, and some functionalities may not work.
You can find out more information about how to change your browser cookie settings at www.aboutcookies.org.uk.
To learn more about how to control cookie settings through your browser:
- click here to learn more about the Private Browsing setting and managing cookie settings in Firefox
- click here to learn more about Incognito and managing cookie settings in Chrome
- click here to learn more about InPrivate and managing cookie settings in Internet Explorer
- click here to learn more about Private Browsing and managing cookie settings in Safari.
You may opt out of targeted advertising at http://www.youronlinechoices.eu/. You can learn more about interest-based advertising and opt out of interest-based advertising from participating online advertising companies at the following links.
- Network Advertising Initiative (NAI) – http://optout.networkadvertising.org/
- Digital Advertising Alliance (DAA) – http://optout.aboutads.info/
- Digital Advertising Alliance EU (EDAA) – http://www.youronlinechoices.com/
- DAA AppChoices page – http://www.aboutads.info/appchoices
Please note that opting out of interest-based advertising does not mean you will no longer be served advertising. You will continue to receive generic ads.
THIRD PARTY WEBSITE COOKIES