Last updated August 2023
This document outlines the Privacy Policy (Policy) of ManageMe Services Limited, referred to herein as “ManageMe,” “we,” “our,” or “us.” ManageMe is a registered company in New Zealand under company number 7638098. We commit to handling personal information in compliance with our privacy obligations, including those set forth in the Privacy Act 2020 (Act) and the Telecommunications Information Privacy Code 2020 (Code). This Privacy Policy elucidates the types of personal information we collect, how we utilise, disclose, and safeguard that information.
Modifications and Notice of Changes
We reserve the right to periodically review and amend this policy. Any revisions will be notified to users by uploading an updated version on our website. The amended policy will be in effect from the time of upload.
If there is any aspect of this Privacy Policy with which you disagree, your only recourse is to immediately leave our website.
Privacy and Confidentiality
At ManageMe, we uphold the utmost importance of protecting your privacy and confidentiality. We recognize that all visitors to our website have the right to ensure their personal data remains unused for unintended purposes and is not disclosed to third parties accidentally.
We are committed to maintaining the confidentiality of all the information provided to us.
Compliance with New Zealand Law
Our Privacy Policy is fully compliant with New Zealand law, as required.
Disclosure of Rights and Obligations
We are obligated to inform you about your rights and our obligations concerning the processing and control of your personal data. To fulfill this obligation, we request that you read the information provided at www.knowyourprivacyrights.org.
Non-Disclosure to Third Parties
Except as outlined below, we do not share, sell, or disclose any information collected through our website to third parties.
Information Collection and Use
The personal information we collect depends on your interaction with us and may include:
- Name, date of birth, email address, phone number(s), and address. For corporate and business customers, we may also collect information about nominated contacts, including name, title or position, date of birth, phone number(s), and email and business addresses.
- Purchasing patterns, consumer preferences, and attitudes for marketing purposes, including market analysis, developing marketing strategies, and identifying products and services of interest to customers.
- Payment details, such as credit or debit card, or direct debit information, provided during purchases.
- Employment applications from individuals applying for jobs with us.
When you become (or apply to become) a customer, we collect various information to assess your application and manage your account(s). This information may include:
- Proof of identity information, such as passport number, driver’s license number, or other government identifiers, required for identity verification and accurate customer records.
- Financial and credit information, including credit history, employment history, remuneration details, bank account, and credit card information, as well as information about assets, income, and relevant court judgments and bankruptcies, used to assess creditworthiness and financial suitability.
- Information about vulnerability or medical dependency, which is essential for providing support to customers who rely on power for critical medical assistance or are at risk of needing emergency services.
- Information relating to occupancy, required to establish a customer’s right to occupy the property for which services are provided.
- Information relating to change of name or status, which may include marriage certificates, death certificates, and other official documentation, requested in cases of account closure or transfer.
- Insurance information, including details about the persons or items to be insured, claims history, and previous insurance.
Failure to provide any of this information may result in our inability to provide products or services to you or may lead to limited or restricted services.
Additionally, we collect information about how you use our products and services, including:
- Service usage, such as energy consumption patterns, use of communication services, and internet usage.
- Responses to offers and promotions.
- Payment patterns and history.
- Inquiries and complaints, including notes and recordings from your calls or interactions with our customer service team.
Personal Information Collection
We collect information directly from you whenever possible and indirectly from related companies, agents, service providers, and third parties. The collection may occur through:
- Our websites, apps, and customer support platforms, including the use of cookies and other analytics tools.
- Social media platforms and third-party login providers, such as Twitter, Facebook, Instagram, and LinkedIn, when you interact with our social media accounts or use third-party login providers to sign in to our online services.
- Our call centers.
- Door-to-door sales activities.
- Network equipment, such as electricity smart meters.
- Wholesale service providers and wholesale customers and partners.
- Credit reporting agencies.
- Other service providers when you transfer (port) your services to us.
- Visits to our premises, where electronic sign-in systems may be in use.
- Inquiries at kiosks, dealers, or events operated by or on behalf of us.
- Referrals of details from other customers or third parties.
- Purchase of marketing lists, databases, and data aggregation services.
- Other public sources, including public registers.
- We handle any unsolicited personal information received from you in accordance with our obligations under the Act.
Use of Personal Information
We use personal information for legitimate business purposes, including but not limited to:
- Processing customer applications and verifying customers’ identities.
- Providing products and services to customers.
- Conducting credit checks.
- Billing and collecting payments from customers, including processing credit card transactions.
- Responding to customer communications, inquiries, and complaints.
- Marketing our products and services, which may include electronic communications, unless you have unsubscribed from such messages.
- Improving our products, services, and customer service.
- Managing and securing our systems and networks, including monitoring network security or integrity.
- Improving or personalizing customers’ website experience, including targeted advertising.
- Conducting research and statistical analysis on an anonymized basis.
- Protecting and enforcing our legal rights and interests, including defending against claims.
- Other purposes authorized by the Act or the individual concerned.
Personal Information Disclosure
We may disclose personal information to related companies and third-party agents, service providers, and partners engaged in relation to our products and services. This includes, but is not limited to:
- Sales & marketing agents, representatives and partners for marketing our products and services.
- Organisations that process banking and payment transactions, including credit/debit card and direct debit payments.
- Wholesale service providers, such as telecommunications network operators, local fiber companies, and electricity lines companies, for service, account, and network management.
- Other service providers involved in verifying and completing the transfer (port) of services between us and other service providers.
- Printers, mail distributors, couriers and dispatch centres for communicating with customers and delivering products.
- Third party call centres handling our customer service or marketing operations.
- IT service providers and data managers
- Public directories (e.g. White Pages)
- Credit reporting and debt collection agencies for credit checking, reporting, and recovering overdue debt.
- Professional advisors, including legal, accounting, insurance, and business advisory consultants.
We may also disclose personal information to:
- Government agencies to assist in the government’s response to a national emergency and to establish or verify eligibility for concessions and entitlements.
- Dispute resolution agencies (e.g. TDR) for complaint management and dispute resolution.
- Emergency services to aid in quickly locating people at risk of harm.
- Law enforcement (e.g. Police) for law enforcement or security purposes.
- Third parties in the event of a merger, acquisition, reorganization, bankruptcy, or insolvency of our business.
- Third parties to prevent fraud and as allowed or required by law.
Certain businesses supporting our products and services may be located overseas, which means personal information may be transferred to, or accessed from, countries other than New Zealand. We take reasonable steps to ensure that we only disclose personal information to overseas entities or persons if we believe, on reasonable grounds, that the recipient is subject to privacy laws (or is otherwise required to protect the information) that provide comparable safeguards to those in the Act. The Act also provides other limited grounds for us to disclose personal information overseas.
Protection of Personal Information
We acknowledge the criticality of protecting your personal information and ensuring it remains complete, accurate, up-to-date, and relevant.
When you contact us regarding your account or service, we conduct an ID check to verify your identity and the accuracy of your details. For safety-critical information, such as medical information required for maintaining secure power supply or priority assistance, we conduct regular checks.
We have processes for verifying personal information collected for specific transactions, such as proof of occupancy, change of occupier, and priority assistance. Our staff are trained to handle different types of information, especially sensitive information, and we have quality assurance measures to monitor adherence to our processes.
While some personal information is held in hardcopy form, most is stored in electronic databases.
We have robust security safeguards in place to protect our information systems and files from loss, unauthorized access, use, modification, disclosure, or other misuse. We also have documented procedures governing our response in the event of an actual or suspected privacy breach.
Data Breach (GDPR & NDB)
In the event of a data breach, ManageMe is obligated to notify its Customers without undue delay after becoming aware of the breach. We will cooperate with our customers to investigate and remediate the breach, as well as cooperate with any supervisory authorities and law enforcement, and assist with any necessary notifications.
Accessing and Correcting Personal Information
You have the right to request access to your readily retrievable personal information and to request correction of your personal information. Before granting access or making corrections, we will need evidence to confirm your identity as the individual to whom the personal information relates.
We generally respond to access/correction requests within 20 working days, but we will inform you if the process is expected to take longer. If there are justifiable grounds under the Act for refusing your request, we will explain these reasons. For correction requests, we will make the correction if reasonable and reasonably feasible. If we cannot make the correction, we will take reasonable steps to note your request for correction on the personal information.
Reasonable costs may apply if you request copies of your personal information or corrections.
Retention Period for Personal Data
We retain your personal information only as long as necessary:
- To provide you with requested services.
- To comply with other laws, including the period demanded by tax authorities (typically 7 years).
- To support a claim or defense in court.
If you have not purchased or used any of our services, your personal information may be deleted by deleting your account.
New Zealand Hosted Products and Services
All of ManageMe’s customer data and infrastructure are hosted and based in New Zealand, primarily at our data centers in Auckland. This includes our databases, web services, and payment systems. Backups are also hosted in New Zealand, ensuring personal customer data remains within the country. While ManageMe operates a voice proxy service in Australia for phone-specific data, this service does not include account information or personal data, limited only to data required for phone connectivity and authentication.
Internationally Hosted Products and Services
For services originating overseas, such as the provision of international phone numbers, ManageMe may transfer customer data outside of New Zealand as required by the authorities in those jurisdictions, such as the USA, UK, and European Economic Area (EEA). By using our International Products and Services, you consent to any such transfer of your information outside your country.
Communications and Notifications
As part of our service, we may send you messages related to your account and the services you use, such as invoices, payment receipts, low balance alerts, technical notifications, and other relevant issues. These messages are mandatory and essential to our services. If you wish to stop receiving them, you must cancel your services. When you contact us via telephone, website, or email, we collect the data you provide to respond appropriately.
We maintain records of your requests and our replies to enhance the efficiency of our business. We keep personally identifiable information associated with your messages, such as your name and email address, to ensure high-quality service and track our communications with you. If you contact our sales or support teams, we will respond via live chat, email, or telephone. We may periodically contact you to provide updates on our services, including new products, campaigns, promotions, and payment methods.
You can unsubscribe from promotional messages by following the instructions included in such communications.
Internet Use and Cookies
While we take reasonable steps to maintain secure internet connections, providing personal information over the internet is done at your own risk. If you post personal information in a public area of our websites or social media pages, you acknowledge and agree that the information you post is publicly available. When you follow links on our websites or social media pages to other sites, please review the privacy policies of those sites before providing personal information.
We may use:
- Cookies: These are alphanumeric identifiers transferred to your computer’s hard drive to recognize your browser and monitor website use. Two types of cookies may be stored on your device, “first-party” (from our digital properties) and “third-party” (from advertisers and analytics organizations). You can disable cookies through your browser settings, but this may limit certain website features.
- Testing Tools: To serve different content and advertising, we use Google cookies and may update information stored in existing website cookies for consistent content display.
- Tracking and Optimization Tools: We use tools to understand customer interactions with our digital properties, including clicks, mouse movements, time spent on pages, and interactions with sign-up forms and fields.
- Property Data: We may use property data based on the address you provide during the sign-up process to determine certain characteristics of the address, such as size and location, to tailor services.
- Local Storage: When signing up for products or services on our digital platforms and adding items to your cart, we may store this data locally in your browser’s local storage. This helps complete transactions and allows you to resume your order if needed. This data may also be used for remarketing activities.
Complaints
If you are dissatisfied with our Privacy Notice or have any complaints, please inform us by email at support@manageme.co.nz. If the dispute remains unresolved, we encourage you to engage in good faith with us in mediation or arbitration.
Complaints to Data Protection Commissioner
If you remain dissatisfied with how we process your personal information, you have the right to lodge a complaint with the Data Protection Commissioner.
This is intended to provide clear and formal information about our Privacy Policy, complying with legal requirements and setting forth our obligations and your rights. If there are any questions or concerns about this policy, please do not hesitate to contact us.
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