This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.
Hadwin Jones collects, holds and processes personal information from clients, suppliers, employees, contractors and other individuals. We collect and hold this information when it is necessary for business purposes.
The main types of personal information Hadwin Jones collects, holds and processes relate to the contact details and organisational roles of our clients, suppliers and other business contacts. Typically, this information includes names, addresses, telephone numbers, e-mail addresses and job titles. In the course of providing professional services to our clients, we may collect and hold more detailed personal information (for instance financial details if we are engaged to perform financial services, or credit information).
We collect most information directly from individuals when we deal with them. The personal information we collect may be provided in forms filled out by individuals, face to face meetings, email messages, telephone conversations, when you use our websites or our social media, or by third parties. If you contact us, we may keep a record of that contact.
Because of the nature of our business, it is generally impracticable for us to deal with individuals on an anonymous basis or through the use of a pseudonym, although sometimes this is possible (for example, when seeking staff or client feedback generally).
The main purposes for which we collect, hold and process personal information are:
- to provide our services
- to respond to an individual’s request
- to maintain contact with clients
- to keep clients and other contacts informed of the services we offer and industry developments that may be of interest to them, and to notify them of service offerings, seminars and other events we are holding
- for general management and reporting purposes, such as invoicing and account management
for recruitment purposes - for purposes related to the employment of our personnel and providing internal services to our staff
other purposes related to our business.
We may keep a record of your Personal Information, correspondence or comments in a file specific to you. We will utilize, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by law.
If you choose not to provide us with personal information, we may be unable to do such things.
We may collect, hold and use personal information about individuals to market our services, including by email. However, individuals always have the opportunity to elect not to receive further marketing information from us by writing to the Privacy Officer at privacy.officer@hadwinjones.com . Please allow 20 working days for your request to be processed.
Alternatively, if we have contacted you by email, you may use the unsubscribe function in that email to notify us that you do not want to receive further marketing information from us by email.
If we collect, hold or use personal information in ways other than as stated in this policy, we will ensure we do so pursuant to the requirements of the Privacy Act.
Employee records are not generally subject to the Privacy Act and therefore this policy may not apply to the handling of information about employees by Hadwin Jones. For information about our practices relating to employee information, please contact us directly.
Hadwin Jones does not routinely disclose personal information to other organisations unless:
- use or disclosure is permitted by this policy
- we believe it is necessary to provide you with a product or service which you have requested (or, in the case of a partner, employee or contractor of Hadwin Jones, it is necessary for maintaining or related to your role at Hadwin Jones)
- to protect the rights, property or personal safety of any member of the public or a customer of Hadwin Jones or the interests of Hadwin Jones
some or all of the assets or operations of Hadwin Jones are or may be transferred to another party as part of the sale of some or all of Hadwin Jones’ business - you give your consent
- such disclosure is otherwise required or permitted by law, regulation, rule or professional standard.
We may also share non-personal, de-identified and aggregated information for research or promotional purposes. Except as set out in this policy, we do not sell to or trade personal information with third parties.
Hadwin Jones uses a range of service providers to help us maximise the quality and efficiency of our services and our business operations (including internal business requirements, such as recruitment and human capital requirements). This means that individuals and organisations outside of Hadwin Jones will sometimes have access to personal information held by Hadwin Jones and may collect or use it from or on behalf of Hadwin Jones. This may include, but is not limited to, independent contractors and consultants, travel service providers, mail houses, off-site security storage providers, information technology providers, event managers, credit managers and debt collecting agencies. We require our service providers to adhere to our privacy guidelines and not to keep, use or disclose personal information we provide to them for any unauthorised purposes.
If Hadwin Jones’ staff obtain products or services offered by a third party pursuant to an agreement or arrangement between that third party and Hadwin Jones, such as a credit card provider, we may provide your personal information to that third party, including information that relates to your use of such services.
We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place as appropriate to protect the data and to comply with our data protection, confidentiality and security standards.
In addition to disclosures permitted under this policy, we may disclose your personal information to other Hadwin Jones firms within the Hadwin Jones global network. For a list of where the Hadwin Jones firms are located, please contact privacy.officer@hadwinjones.com .
We may share personal data with other Hadwin Jones member firms where necessary for administrative purposes and to provide professional services to our clients (e.g. when providing services involving advice from Hadwin Jones member firms in different territories).
Hadwin Jones and other Hadwin Jones firms with which we exchange information may also use overseas facilities or contractors to process or back-up our information or to provide certain services to us. These Hadwin Jones firms, service providers and contractors may not be New Zealand entities or regulated by the Privacy Act, and may not be subject to privacy laws that provide the same level of protection as New Zealand’s. You consent to the disclosure of your personal information to such Hadwin Jones firms, service providers and contractors on this basis.
All service providers that have access to personal information held by us are required to keep the information confidential and not to make use of it for any purpose other than to provide services in accordance with their engagement. We will take all steps that are reasonably necessary to ensure your personal information is treated securely and in accordance with this Privacy Policy as well as applicable data protection laws, including, where relevant, by entering into EU standard contractual clauses (or equivalent measures) with the party outside the European Economic Area.
However, any such transfer of information does not change any of our commitments to safeguard your privacy and the information remains subject to existing confidentiality obligations.
Hadwin Jones may store personal information within services provided by offshore cloud service providers (CSP). Currently, Hadwin Jones only utilises the services of amazon.com.
This policy also applies to any personal information we collect via our websites, and applications including mobile applications. In addition to personal information you provide to us directly (such as where you make a request or complete a registration form).
In order to properly manage our websites and applications, we may log certain statistics about the users of the facilities, for example the users’ domains and browser types. None of this information specifically identifies an individual and it is used solely to ensure that our websites and applications provide the best possible navigational experience for users.
Cookies and web beacons are used on some Hadwin Jones websites.
Cookies are small text files that are placed on your computer by the websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. If you are uncomfortable with the use of cookies, you can manage and control them through your browser, including removing cookies by deleting them from your ‘browser history’ (cache) when you leave the site. In most cases, you can refuse a cookie and still fully navigate the Hadwin Jones websites. If you require more information on the type and use of cookies by Hadwin Jones, see our Cookies Information page.
A web beacon is a clear picture file used to keep track of your navigation through a website.
Along with cookies, web beacons help us gain an understanding of how users of Hadwin Jones websites navigate through and process the content contained in those websites. On occasion Hadwin Jones will advertise on third party websites. As part of the tracking process for advertising campaigns we may at times use web beacons to count visitors who have come to the Hadwin Jones websites after being exposed to Hadwin Jones advertising on a third party site.
We do not use this technology to access your personal information.
If you have registered an account with us, you will be identified by a user name and password when you log into our website or applications. The information we collect about members’ use of our websites may be used for measuring use and performance and in assisting to resolve any technical difficulties.
Because Hadwin Jones wants your user experience to be as informative and resourceful as possible, we provide a number of links to websites and embedded content operated by third parties that may also set cookies and web beacons. Hadwin Jones is not responsible for the privacy practices or policies of those sites. We encourage you to review each website’s privacy policy, especially if you intend to disclose any personal information via that site. A link to another non-Hadwin Jones website is not an express or implied endorsement, promotion or warranty of the products or services offered by or accessible through that site or advertised on that site.
Depending on the purpose for which we have collected personal information (for example, registration for a Hadwin Jones event or a request for particular information or material), we may store some of the information electronically in Hadwin Jones’ customer relationship management system. Some or all of this personal information may be available to partners and authorised staff of Hadwin Jones for use in accordance with this policy.
Hadwin Jones will endeavour to take all reasonable steps to keep secure any information which we hold about you, whether electronically or in hard-copy, and to keep this information accurate and up to date. We also require our employees and data processors to respect the confidentiality of any personal information held by Hadwin Jones.
Hadwin Jones aims to achieve industry best practice in the security of personal information which it holds. It is our policy not to retain personal information once there is no longer a legal or business need for us to do so.
We will provide access to personal information upon request by an individual, except in the limited circumstances in which it is permitted for us to withhold this information (for instance, where granting access would infringe another person’s privacy).
When you make a request to access personal information, we will require you to provide some form of identification (such as driver’s licence or passport) so we can verify that you are the person to whom the information relates. In some cases we may also request an administrative fee to cover the cost of access.
If at any time you want to know what personal information we hold about you, you may contact us by email the Privacy Officer at privacy.officer@hadwinjones.com .
If you are a resident in the European Economic Area, you have the following rights in relation to your personal information (where applicable):
Access – You have the right to request a copy of the personal information we are processing about you. For your own privacy and security, at our discretion we may require you to prove your identity before providing the requested information.
Rectification – You have the right to have incomplete or inaccurate personal information that we process about you rectified.
Deletion – You have the right to request that we delete personal information that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
Restriction – You have the right to restrict our processing of your personal information where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
Portability – You have the right to obtain personal information we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal information which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you.
Objection – Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing Withdrawing Consent. If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge. This includes cases where you wish to opt out from marketing messages that you receive from us.
To make a request to exercise any of these rights in relation to your personal information, please email, call or write to us using the contact information listed below in the “Introduction” and “Correction and Concerns” sections.
We are generally controllers for the personal data we process, however, we may provide some services, such as payroll services, as a processor (in which case our client is the controller). If you have any questions about this privacy statement or how and why we process personal data, please contact us at:
Privacy Officer: email at privacy.officer@hadwinjones.com .
If you believe that information we hold about you is incorrect or out of date, or if you have concerns about how we are handling your personal information, please contact us and we will try to resolve those concerns.
If you wish to have your personal information deleted, please let us know and we will take reasonable steps to delete it (unless we need to keep it for legal, or internal risk management reasons, or compliance with our professional obligations).
If Hadwin Jones becomes aware of any ongoing concerns or problems concerning our privacy practices, we will take these issues seriously and work to address these concerns. If you have any further queries relating to our privacy policy, or you have a problem or complaint, please contact our Privacy Officer. If you are not satisfied with our handling of your problem or complaint you may make a complaint to the Office of the Privacy Commissioner (https://www.privacy.org.nz/about-us/contact/).
Hadwin Jones operates in a dynamic business environment and we aim to review this policy annually to keep it current.
Hadwin Jones may update this privacy policy at any time by publishing an updated version on this website.
The amended policy will apply between us whether or not we have given you specific notice of any change.
This policy was last updated September 2018.