Last updated: March 2014
1.1 Seebo will only collect Personal Information where the information is necessary for Seebo to perform one or more of its functions or activities. In this context, “collect” means to gather, acquire or obtain by any means information for the purpose of recording it.
1.2 Seebo collects Personal Information primarily to supply customers with the products and services ordered from it and related companies. Seebo also collects and uses Personal Information for secondary purposes, including:
(i) billing and account management;
(ii) business planning and product development; and
(iii) to provide individuals with information about promotions, as well as additional products and services, and the products and services of other Seebo companies and other organisations.
The type of information collected will depend on the goods or services Seebo is asked to provide, and may include, without limitation, names, addresses, telephone numbers and email addresses.
Examples of when Seebo may collect personal information is:
- when a product is registered with Seebo; and
- when an individual completes the ‘mandatory fields’, which will enable your specific request to be processed.
Seebo may collect data relating to internet traffic activity undertaken via its products and services using tracking technologies such as cookies. Seebo generally uses this information to report statistics, analyse trends, administer its services, diagnose problems and target and improve the quality of our products and services. To the extent this information does not constitute personal information, the Privacy Act does not apply and Seebo may use this information for any purpose and by any means whatsoever.
1.3 Unless it is obvious in the circumstances, Seebo will notify individuals (including, but not limited to, our customers) of the matters listed below, amongst other things, before collecting any Personal Information:
(i) the main reason that we are collecting Personal Information (this reason will be the Primary Purpose);
(ii) other related Uses or Disclosures that we may make of the Personal Information (Secondary Purposes);
(iii) our identity and how individuals can contact us;
iv) that individuals can access the Personal Information that Seebo holds about them;
(v) that individuals should contact our customer service department (even if they are not a customer) if they wish to access or correct Personal Information collected by us, or have any concerns in relation to Personal Information;
(vi) the organisations or types of organisations to whom we usually Disclose the Personal Information, including Related Bodies Corporate and contractors;
(vii) where applicable, any law that requires the Personal Information to be collected (for example, information that is required to be collected for the Integrated Public Number Database, which is used by directory publishers);
viii) the consequences (if any) for the individual if all or part of the Personal Information is not provided to Seebo;
ix) if Seebo is likely to disclose the personal information to overseas recipients.
1.4 Where it is not practicable for Seebo to notify individuals of all of the Collection Information before the collection of Personal Information, Seebo will ensure that individuals are notified of the Collection Information as soon as possible after the collection. Seebo will provide “post collection notification” in those circumstances where it is not practicable to notify individuals about the collection of their personal information before it is collected.
1.5 When collecting Personal Information over the telephone, it may not always be practicable to provide all the Collection Information at that time. In such circumstances, we will provide the individual with Seebo’s contact details, and then provide the balance of the Collection Information in a confirming letter.
1.6 Seebo will not collect Sensitive Information from individuals except with consent and only where it is necessary for Seebo to collect such information for an activity or function.
1.7 Seebo will only collect Personal Information via lawful and fair means.
1.8 While Seebo endeavours to collect personal information from the individual involved, in some instances it may also receive personal information from third parties. In the unlikely event where Seebo receives, (and retains) or uses personal information from third parties, it will attempt to contact the individual and advise that it holds this information.
2.1 Seebo will obtain an individual’s consent for Use of non-sensitive Personal Information for Secondary Purposes at the time of collection, unless the Use is a related Secondary Purpose that would be within the relevant individual’s Reasonable Expectations.
2.2 Seebo Uses Personal Information primarily for the purposes listed in 1.2 above.
2.3 Where Personal Information (other than sensitive information) is used for Direct Marketing, you can opt out of receiving this information at any time by notifying us.
2.4 Seebo will not use Sensitive Information for Direct Marketing except with consent.
2.5 Seebo may otherwise use your Personal Information if allowed by law, such as to avoid an imminent threat to a person’s life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.
2.6 Seebo will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
3.1 Seebo may Disclose Personal Information to related or unrelated third parties if consent has been obtained from the individual.
3.2 Seebo may Disclose Personal Information between Related Bodies Corporate. Where information is Disclosed to such a Related Body Corporate, that Related Body Corporate is bound by the original Primary Purpose for which the information was collected.
3.3 Seebo may Disclose Personal Information to unrelated third parties to enable outsourcing of functions (such as billing), where that is Disclosure or Use for a related Secondary Purpose and individuals have been notified, or where such Disclosure is within the individual’s Reasonable Expectations. Individuals will be notified of Seebo’s usual Disclosures via the Collection Information, as outlined in 1.3.
3.4 Seebo will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the Use and Disclosure requirements of the Privacy Act.
3.5 Seebo may Disclose Personal Information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.
3.6 Seebo may otherwise Disclose Personal Information where permitted by law, such as to avoid an imminent threat to a person’s life or to public safety.
3.7 If a Disclosure is not for a Primary Purpose; is not for a related Secondary Purpose; or upfront consent has not been obtained, Seebo will not Disclose Personal Information otherwise than in accordance with the exceptions set out at 3.5 to 3.6 above.
3.8 Seebo does not generally sell or share its customer lists on a commercial basis with third parties but if it did, it would only do so if it had the appropriate consent of the individual involved. If the consent provided is conditional, Seebo will take steps to ensure (by contract) that the use of its customer list by third parties does not exceed the scope of the consent.
4. Information quality
4.1 Seebo will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
4.2 Seebo will take steps to destroy or de-identify Personal Information after as short a time as possible once it is no longer required and after a maximum of seven years, unless the law requires otherwise.
5. Information security
5.1 Personal information is stored electronically, on paper, or both. Seebo has physical, electronic and procedural safeguards for personal information and takes reasonable steps to ensure that personal information is protected.
5.2 Electronic records are stored within our electronic database that requires passwords for access.
5.3 Paper records are stored within secure premises. Externally, the premises have several barriers to unauthorised entry, including secured entry and monitored alarms. Internally, steps are taken to ensure access to personal information is limited, including filing in a locked cabinet within a secured office.
5.4 Seebo requires employees and contractors to perform their duties in a manner that is consistent with Seebo’s legal responsibilities in relation to privacy.
5.5 Seebo will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within Seebo who have a genuine “need to know” as well as a “right to know”.
5.6 Seebo will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.
6. Access and correction
6.1 Seebo will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.
6.2 Seebo will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.
6.3 Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting Seebo Customer Service, as per the details on the back of this document. While some requests for access may be handled by Customer Service, it may be necessary for your request to be escalated to the Seebo Customer Relations Group.
6.4 Seebo will not normally charge a fee for processing an access request unless the request is complex or is resource intensive. Seebo does, however, reserve the right to charge a $25.00 administration fee if an individual requests access to their Personal Information more than once in a three-month period.
6.5 Where Seebo offers on-line account management facilities, customers can use this capability to control aspects of their account, including amending or updating certain Personal Information.
7. Openness and Complaints
7.1 Seebo’s Customer Service representatives will be the first point of contact for inquiries about privacy issues. Individuals wishing to make an inquiry or complaint regarding privacy should do so by contacting Seebo Customer Service as per the details on the back of this document.
7.2 Privacy complaints will be managed in accordance with Seebo’s Complaint Handling Policy, which complies with the C628:2007 Telecommunications Consumer Protections Industry Code (as amended from time to time).
8. Anonymous transactions
8.1 Seebo will not make it mandatory for visitors to its web sites to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service. Seebo may, however, request visitors to provide Personal Information voluntarily to Seebo (for example, as part of a competition or questionnaire). Where you are registering a Product, the provision of some personal information will be mandatory.
8.2 Seebo will allow its customers to transact with it anonymously or use a pseudonym wherever that is reasonable and practicable.
9. Transferring personal information overseas
9.1 Seebo will take reasonable steps to limit the amount of Personal Information it sends to unrelated organisations overseas.
9.2 If Seebo must send Personal Information overseas for sound business reasons, Seebo will take reasonable steps to ensure that the overseas recipient complies with the Privacy Act.
At the time of drafting this Policy, Seebo expects that personal information may be disclosed to parties, such as its retailers, in New Zealand. However, individuals will be notified of usual overseas Disclosures via the Collection Information as outlined in clause 1.3.
Collection Information means the information outlined in 1.3 notified to individuals prior to, or as soon as practical after, the collection of their Personal Information.
Direct Marketing means the marketing of goods or services through means of communication, including written, verbal or electronic means. The goods or services that are marketed may be those of Seebo or a Related Body Corporate, or those of an independent third-party organisation.
Disclosure means the release of information outside Seebo, including under a contract to carry out an “outsourced function”.
Seebo means all companies in the Seebo group, including Seebo Networks Pty Limited, SNA Mobile Pty Limited and SNA Administration Pty Limited.
Personal information, as distinct from business information, is information, or an opinion about a person that is identified or reasonably identifiable.
Primary Purpose means the dominant or fundamental reason for information being collected in a particular transaction.
Reasonable Expectation means a reasonable individual’s expectation that their personal information might be Used or Disclosed for the particular purpose.
Related Body Corporate means that where a body corporate is:
(a) a holding company of another body corporate;
(b) a subsidiary of another body corporate; or
(c) a subsidiary of a holding company of another body corporate,
(d) the first mentioned body corporate and the other body corporate are deemed to be related to each other.
Sensitive Information means:
(a) information or an opinion about an individual’s:
(i) racial or ethnic origin; or
(ii) political opinions; or
(iii) membership of a political association; or
(iv) religious beliefs or affiliations; or
(v) philosophical beliefs; or
(vi) membership of a professional or trade association; or
(vii) membership of a trade union; or
(viii) sexual preferences or practices; or
(ix) criminal record that is also personal information; or
(b) Use means the handling of Personal Information within Seebo.