The Warranty Group Australasia Pty Ltd (“TWG”) (a company incorporated in Australia and registered as carrying on business in New Zealand under Company Number 2367681), with offices in New Zealand at Suite 3, Level 2, 73 Manchester Street, Christchurch, 8011, New Zealand, acts as Administrator to VSC and, in such role, has access to all information collected by VSC.
TWG also, in its own name, and including in connection with its secondhand dealer licence issued under the Secondhand Dealers and Pawnbrokers Act 2004 (“SHD Act") or otherwise, operates certain device trade-in and related programs in New Zealand. This Policy describes how TWG collects, holds, uses and discloses personal information in compliance with and pursuant to the Act and in connection with its activities in New Zealand.
Both VSC and TWG are part of Assurant, Inc (NYSE: AIZ), a global provider of risk management solutions.
In this Policy the terms “We”, “Us”, “Our” each refer to VSC and/or TWG and related companies which handle personal information collected by VSC and/or TWG in New Zealand, as applicable. Further, the terms “You” and “Your” refer to, as applicable, Our customers and policyholders or persons who enter into a trade-in contract or arrangement with Us or with Our business partner and who have provided their personal information to Us.
We collect and use Your personal information, which You have directly provided to us or that we have obtained from other sources, for purposes of administering the insurance product or extended warranty, service contract, master policy or similar product which You have obtained from Us directly or through Our business partners (“Product”) or in connection with a trade-in contract or arrangement with Us or with Our business partner. The information collected is held by Us and is used by Us and our respective contractors and agents to administer the Product which You have obtained from Us or in connection with a trade-in contract or arrangement with Us or with Our business partner.
If You do not provide this information, We may decline Your application to take out a Product (“Product”) or we may not agree to enter into a trade-in contract or arrangement with Us or with Our business partner. You have the right to request access to, and correction of this information, subject to the provisions of the Act.
This Policy also serves as notification to individuals of the matters required to be notified by the Information Privacy Principles under the Act (“IPPs”). An individual who provides personal information to Us, either directly or through a business partner, distributor or referrer, agent or service provider who sells or is involved with selling Our Products or who enters into a trade-in contract or arrangement with Us or with Our business partner, is given access to this Policy. By providing personal information to Us and having access to this Policy an individual consents to Us collecting, holding, using and disclosing personal information in accordance with this Policy.
If You do not wish for Us to process Your personal information, as set forth in this Policy, do not provide Your personal information to Us.
The personal information We collect:
Personal information We collect, from time to time, will include: first, middle and last names; phone numbers; home and postal addresses; e-mail addresses; information contained in or on identification documents (including, without limitation, passport, driver’s licence and student ID documents) and copies of such documents, date of birth; gender; personal history (including criminal, insurance and claims history; information about individuals from financial institutions; credit card details; bank account details and IMEI/serial number information for devices. We may, in connection with certain Products only, also collect sensitive information, a category of personal information, including medical and health information and history.
How We collect and store personal information:
We collect the personal information of individuals directly from those individuals when selling Products to those individuals or in connection with trade-in contracts or other arrangements with Us or with Our business partner, as well as from Our business partners, distributors or referrers, agents, or service providers who sell or who are involved with selling the Products or are involved with our trade-in programs. In connection with Products, We collect personal information from other parties such as financial institutions and medical and health professionals in connection with claims made by individuals. We also collect personal information directly from an individual when the individual makes an inquiry or claim about a Product.
We will, from time to time, receive and store personal information You enter onto Our website, or an app or provide to Us directly or via Our business partners or given to Us in other forms. We may collect additional information at other times, including but not limited to, when You provide feedback, when You provide information about Your personal or business affairs, change Your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with Our customer support or when we supply devices or accessories, including SIM cards to You. This may include details which enable the device to be identified with You.
Additionally, We may also collect any other information you provide while interacting with Us or our business partners.
Personal information received by Us is held electronically on Our information technology systems, which are password and access-level protected and may only be accessed by Our authorised employees and contractors who require access in connection with the purposes described in this Policy. Some personal information is held in hard copy such as files created when a claim or complaint is made relating to Products, which are accessible to Our claims and complaint-handling employees, their managers and the organisation which is contracted by Us to store and secure that information. Other hard copy personal information may be held for internal purposes and administration of Our business.
If information or consent is not provided:
Without all of the required personal information being provided or consent being given, We may not be able to provide the Products or to enter into a trade-in contract or arrangement with You, and may not be able to administer claims or handle inquiries in connection with Products.
Personal information will be collected, held, used and disclosed for the purposes of:
- providing the Product for an individual;
- handling inquiries about the Product;
- checks to verify the identity of an individual;
- administering claims under Products;
- handling complaints;
- completing matters as related to trade-in contracts or arrangements with Us or with Our business partner;
- administering the information technology systems used by Us;
- as required by law (including, without limitation the SHD Act) or a court or tribunal order;
- providing you with information and updates about our Product and our services or to make You aware of new and additional products, services and opportunities available to You; and
- any related, secondary or ancillary purposes.
We may use Your personal information to improve Our products and services and better understand Your needs.
We will hold personal information for as long as necessary in order to meet the purposes described in this Policy and as required by law. For example, personal information in connection with Products will be held for at least the life of the Product which includes the period when claims may be notified or made after the Product expires.
We may contact you by a variety of measures including, but not limited to telephone, email, sms or mail for purposes related to the administration of any Product which you have obtained from Us or in connection with a trade-in contract or arrangement with Us or with Our business partner.
Disclosure of personal information (including overseas recipients):
We may disclose personal information to Our business partners who provide services for Us and third-party service network providers including, claims handlers, call centres, repairers, assessors and loss adjusters to perform activities in connection with the purposes described in this Policy. We may disclose Your personal information to any of Our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors and third parties with whom We have agreements insofar as reasonably necessary for the purposes set out in this Policy.
We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.
We may also use your personal information to protect copyright, trademarks, legal rights, property or safety of Us, Our customers or third parties.
Also, as We are a member of the Assurant group of companies, a member of the group may share and access personal information in connection with the purposes described in this Policy and in accordance with IPP 12 of the Act.
Some of the organisations to which We disclose personal information are located outside New Zealand. They are located in the U.K, U.S.A, South Africa, China, Singapore, Japan, India, South Korea, the Philippines and Australia, which may not have data protection regimes equivalent to New Zealand. By purchasing a Product or entering into a trade-in contract or arrangement with Us or with Our business partner you consent to Us managing personal information in this way and in accordance with this Policy.
We will take reasonable steps to ensure that overseas recipients do not breach the IPPs in relation to the information and when we disclose information outside New Zealand we will do so in accordance with the IPPs.
If there is a change of control in our business or a sale or transfer of business assets, We reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.
Accuracy and protection of personal information:
An individual will need to ensure that the personal information which is provided to Us is accurate, complete and up-to-date at the time it is provided and must notify Us of any changes. We will take reasonable steps to protect the personal information that We hold from misuse and loss and from unauthorised access, modification or disclosure.
Access to personal information:
An individual may exercise their privacy rights by contacting Us. You may request access to and/or a copy of Your personal information that We hold. If an individual is able to establish that their personal information is not accurate, complete and up-to-date, then on request We will take reasonable steps to correct it. If We are unable to agree whether personal information is accurate, complete or up-to-date, then an individual may ask Us to place with the information a statement claiming that particular information is not accurate, complete or up-to-date. An individual who seeks to exercise their privacy rights of access and correction may contact Us as set out below.. If We decline an individual’s access request or do not amend the personal information, We will provide Our reasons together with details about how the individual can access Our complaints process.
Questions and complaints:
If You have any questions about the information collected about You, please contact Us at [email protected].
If you would like to make a complaint about the way your information has been handled, please contact our Privacy Officer directly:
by phone, 0800 443 881;
by email, [email protected].; or
by post, PO Box 355 Christchurch New Zealand
Assurant Global Privacy Office, 260 Interstate North Circle SE, Atlanta, Georgia 30339, USA or send Us an email at [email protected].
You also have the right to file a complaint directly with the Office of the New Zealand Privacy Commissioner under applicable local data protection law.
Acknowledgement and Consent
By purchasing a Product, or entering into a trade-in contract or arrangement with Us or with Our business partner, the individual consents to the collection, handling, use and disclosure of personal information by Us in accordance with this Policy.
Please be aware that We may change this Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon Our posting of the modifications on our website or notice board. If We make a material change to Our Policy, we will communicate such change to you by email or other appropriate means as required by applicable data protection legislation. Please check back from time to time to review Our Policy.
Third party sites. Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that We are not responsible for the privacy practices of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.