TROLLEY SERVICES AUSTRALIA PTY LIMTIED – PRIVACY POLICY

1. “IPP” means the Information Privacy Principles as set out in the Privacy Act.
2. “TSA” means Trolley Services Australia Pty Limited, trading as Trolley Tracker™.
3. “Personal Information” is as defined in section 7 of the Privacy Act 2020, which includes any information which can be used to identify an individual.
4. “Privacy Act” means the Privacy Act 2020 as amended or substituted by Act of Parliament and includes any regulations thereunder.

5. Trolley Tracker™ takes phone, online and app submissions from members of the public who wish to report the location of wayward shopping trolleys so they can be collected and returned to stores.

6. In the performance of its business activities, TSA may collect, use and/or disclose Personal Information such as contact details, telephone and facsimile numbers, address details (including email address), login details, IP address details and GPS coordinates.

7. This Privacy Policy sets out guidelines to assist TSA and its personnel comply with the requirements of the Privacy Act, including the IPP, as they concern the collection, storage, use and disclosure of Personal Information.

8. This Privacy Policy applies to the collection, storage, use and disclosure by TSA (or on behalf of TSA) of Personal Information in New Zealand.

9. TSA may collect Personal Information for a lawful purpose relevant to and connected with a function or activity of TSA (the “Primary Purpose”) including, without limitation:
   a. maintaining a database of existing and previous customers;
   b. maintaining a database of members of the general public who have enquired about, or reported a lost trolley;
   c. maintaining a database of persons eligible to receive a prize for the reporting of a lost trolley in order to notify the persons if they win a prize;
   d. preparing market research and analysis;
   e. conducting, and assessing the results of, marketing and promotional activities;
   f. receiving and responding to enquiries, feedback and complaints;
   g. providing training;
   h. preparing reports for customers; and
   i. fulfilling statutory and legal requirements including obtaining any necessary licenses from statutory bodies.

10. TSA shall not collect Personal Information in a manner which is unreasonably intrusive.

11. Any person who collects Personal Information for or on behalf of TSA shall comply with this Privacy Policy and the requirements of the Privacy Act.

12. Where relevant, TSA will only assign a unique identifier to an individual for use in TSA’s operations in the event that the unique identifier is necessary to enable TSA to perform any of its functions in an efficient manner. TSA shall take, in such circumstances, any reasonable steps to ensure that the risk of a unique identifier being misused by any person is kept to a minimum and that a unique identifier is assigned only to an individual whose identity is clearly established. TSA will all times comply with IPP13 in respect of any unique identifier it may use.

 13. TSA may be required to disclose Personal Information to third parties in connection with the Primary Purpose, such as disclosing Personal Information to advertising agencies who assist TSA with its promotional, marketing and research activities or as required by third parties to enable TSA to provide its services, such as accountants, lawyers, IT management, payment processing, customer support, cloud storage, retail partners, fulfilment and shipping. In such event, those third parties are not permitted to use Personal Information for anything other than the purpose for which TSA supplied that information to them.

14. TSA will not disclose Personal Information to third parties for the purpose of allowing them to direct market their services. However, TSA may join its customers (or retailers) in joint marketing of their services to other customers and to the general public. Prize winners’ contact details will be shared with retail partners of TSA solely for prize delivery.

15. TSA may disclose Personal Information to its related entities, such as any subsidiary company of TSA.

16. TSA will not use or disclose Personal Information about an individual for a purpose (“the Secondary Purpose”) other than the Primary Purpose, and for directly related purposes (including those required by law) unless the use or disclosure is consistent with the requirements of the Privacy Act, and:
     a. the individual has consented to the use or disclosure; or
     b. the source of the information is a publicly available information and, in the circumstances, it would not be unfair or unreasonable to use or               disclose the information; or
     c. the use or disclosure of the information for the Secondary Purpose is required by law; or
     d. if in an emergency situation it is necessary or desirable to disclose the information to a civil defence or Government organisation, or another             emergency service; or
     e. the use or disclosure is authorised or required by the Privacy Commissioner under section 30 of the Privacy Act or otherwise under New                     Zealand law.

17. TSA will not sell, lend, or trade Personal Information to any third party.

18. Should TSA disclose Personal Information outside of New Zealand, it shall ensure that the recipient is subject to safeguards (whether through privacy laws and/or binding contracts) that provide a level of protection comparable to the New Zealand Privacy Act
2020.

19. TSA will take reasonable steps to ensure any Personal Information it collects, uses or discloses is accurate, up to date, complete and not misleading.

20. TSA will take reasonable steps to protect the Personal Information it holds from misuse, loss, unauthorised access, modification and/or disclosure. TSA takes the security of Personal Information seriously, and ensures that all its personnel comply with their legal obligations to protect Personal Information, except in the limited number of circumstances required by law.

21. TSA will only retain Personal Information for as long as is required for the purpose(s) for which it may be lawfully used. Once Personal Information is no longer required, TSA will securely destroy it.

22. TSA shall maintain generally accepted standards of technology and operational security in order to prevent the misuse, loss, alteration or destruction of Personal Information. TSA has taken reasonable steps to ensure the safety of Personal Information stored in both electronic and hard copy format.

23. Neither TSA nor its employees, contractors or agents shall transfer Personal Information to a recipient without first establishing the identity of that recipient via cross check and/or personal identifier.

24. TSA stores Personal Information on secure servers in Australia in a manner that ensures the safeguards in place provide a level of protection comparable to the New Zealand Privacy Act 2020.

25. This policy can be found at www.trollleytracker.co.nz. TSA shall ensure that this policy will be made available to anyone who requests it.

26. Any individual about whom TSA holds Personal Information is entitled to ask for a copy of that Personal Information, and to ask for it to be corrected if that individual thinks there is an error. To ask for a copy of your information, please contact us at info@trolleytracker.co.nz.

27. TSA will provide reasons for denial of access to or a refusal to correct Personal Information, in accordance with the Privacy Act.

28. In the event that an individual requests TSA to correct information held by TSA about that individual and TSA is not willing to make the requested correction, TSA shall, at the request of that individual, take any steps as may be reasonable to ensure that a statement by the individual detailing the correction sought shall be so attached as to always be read together with the information.

29. If Personal Information is involved in a privacy breach which TSA reasonably believes has caused or is likely to cause serious harm to an individual (a “Notifiable Privacy Breach”), TSA will (where appropriate) inform the affected individual(s) and recommend what steps should be taken in response. TSA will also report a Notifiable Privacy Breach to the Office of the Privacy Commissioner. In respect of a Notifiable Privacy Breach, TSA will comply with the Privacy Act.

30. TSA will use Personal Information in accordance with the privacy policy under which that information was collected. TSA may update this policy from time to time, including to reflect changes to its practices or for other operational, legal, or regulatory reasons. In such event, TSA will post the revised Privacy Policy on its website, update the ‘last updated’ date and take any other steps required by applicable law.

31. Please direct any questions or concerns about TSA’s privacy policy to its Privacy Officer who can be contacted as follows:
     a. info@trolleytracker.co.nz; and
     b. (+61) 2 4926 2755.

32. To enable TSA to more easily address any questions or concerns, it is preferable if contact is made in writing.

33. The Privacy Officer will investigate any complaints that are received and respond as soon as possible.

34. If you are not satisfied with how TSA has handled your complaint, you can contact the Office of the Privacy Commissioner on 0800 803 909 or via www.privacy.org.nz.