1. Introduction
1.1. At The 3rdDegree we take your privacy seriously. The purpose of this Privacy Policy is to inform you of how we manage your personal information when you interact with us, as a customer or potential customer of The 3rdDegree. If you are a candidate, employee or staff member who is/will be subject to verification checks, then your prospective employer/current employer’s Privacy Policy will apply.
1.2. The 3rdDegree refers to the background checking services provided by The 3rdDegree which is part of The Comprendé Systems Limited group of companies.
1.3. We are bound by this Privacy Policy and the requirements of the New Zealand Privacy Act 2020, which regulates how we may collect, use, disclose, and store personal information, as well as how individuals may exercise their rights or options regarding the personal information held about them.
2. Changes to this Notice
2.1. This Privacy Policy may be updated periodically. We advise you to check back frequently to see any updates or changes. The latest version and publication date will always be clearly marked.
3. We collect personal information:
4. As part of opening an account
4.1. We collect the applicant’s full name, role, contact phone number and email address (“Contact Information”), the full legal name of the applicant, suburb, physical and postal addresses, telephone numbers, the type of entity and the nature of the business that the applicant is associated with.
5. To create an account
5.1. We collect your name, email address and phone number and company or organisation’s name.
6. As part of delivering services and managing the service relationship
6.1. We collect the contact information of staff members who are involved in the service relationship.
7. Contact us via telephone
7.1. We collect your contact information, and the contents of the conversation, which may be recorded.
8. Contact us via email, webform or post
8.1. We collect:
a. your email address and any contact information provided. We will also collect the contents of your email.
b. any contact information provided, along with the contents of your webform query.
c. any contact information provided, along with the contents of your letter.
9. Visit, search for and browse our websites and self-service portals
9.1. We collect the internet protocol (IP) address used to connect your computer or device to the internet, your login information, data on your screen settings and device settings, such as the point and scroll settings of your mouse, web browser type and version, time zone settings, and operating system information.
9.2. We also collect information about your use or visit, including statistical information about visits to pages on the site, the products and services you viewed or searched for, page response times, duration of individual page view, page interaction information (such as scrolling, clicks and mouse-overs) and the paths taken by you through the site, plus the full uniform resource locators (URL) clickstream to, through and from our site (including date and time).
10. If you use our services (e.g., browsing our website) whilst logged into the following services, then they will collect information about your browsing as detailed in their privacy policies.
10.1. Facebook
10.2. Google+
10.3. Instagram
10.4. LinkedIn
10.5. Twitter
10.6. YouTube
11. We use Google Analytics to collect information about your browsing habits whilst using our services. As detailed within Google’s Privacy Policy, Google may share this information publicly and with their partners.
12. The information Google Analytics collects includes:
12.1. your IP address;
12.2. the search terms you use;
12.3. the pages you access on our website and the links you click on;
12.4. the date and time you visit the site;
12.5. the site that directed you to our website, if any;
12.6. your operating system (e.g., Windows, Mac); and
12.7. the type of web browser you use (e.g., Internet Explorer, Google Chrome, Mozilla Firefox).
13. A cookie is a piece of code that creates a file on your computer to track the pages that you view on our website. You may turn off cookies at any time. Most browsers have a feature that allows the user to refuse cookies, or issues a warning when cookies are being sent. However, turning off cookies may affect your ability to use some components of our sites.
14. We collect and use your personal information for a variety of purposes including:
14.1. Processing an account application;
14.2. Enabling the purchase of products and services from us, to process your orders, obtain payment and to recover debt owed to us;
14.3. Answering queries and providing customer service;
14.4. Maintaining and developing our business systems, processes, and infrastructure, including testing, and upgrading of these systems, route planning, product or service development, research, and quality control;
14.5. Keeping staff and visitors safe while on our premises, and to monitor access to secure areas within our premises;
14.6. Administering our websites for internal operations, including troubleshooting, data analysis, testing, research, security, statistical and survey purposes;
14.7. Providing information about products and services across The 3rdDegree
14.8. Undertaking research to understand our customers, and make improvements to our products, services, purchasing and customer support processes;
14.9. Measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
14.10. Investigating, assessing, and responding to any claims;
14.11. Meeting our various legal and contractual obligations;
14.12. Managing and resolving any legal or commercial complaints and issues;
14.13. Carrying out any activity in connection with a legal, governmental, regulatory requirement, or in connection with legal proceedings, crime or fraud prevention, detection, or prosecution.
15. If you choose not to provide certain personal information you should be aware that we may not be able to provide you with products and services.
16. We may send you marketing or promotional communications about our products, services, or brand. If you do not wish to receive such communications, please contact us and we will respect your request and cease future communications.
17. Legal
17.1. The 3rdDegree, inclusive of its variations and domains are the intellectual property of Comprendé Systems Limited.
17.2. The 3rdDegree is the trade name owned by Comprendé Systems Limited.
17.3. For all purposes the Client of The 3rdDegree is the party in which services are provided to, being the Applicant and Client.
17.4. The Parties submit to the exclusive jurisdiction of the laws of New Zealand.
WHO DO WE SHARE YOUR INFORMATION WITH?
18. We use a number of organisations within The 3rdDegree, as well as organisations outside The 3rdDegree to enable the provision of services to you. Personal information may be provided to these organisations as part of delivery of the services. These organisations are contractually required to only use your information for the purpose of supporting the services that we provide to you.
19. Information may also be disclosed to:
19.1. Other entities within The 3rdDegree in order to optimise the design and delivery of products and services across The 3rdDegree. You can find out more information about entities within The 3rdDegree here;
19.2. People who you specifically request we share your personal information with;
19.3. Candidates in order to inform them of your request to complete checks;
19.4. The prospective seller or buyer in the event that we buy, sell, reorganise, merge or dissolve businesses or assets;
19.5. Law enforcement, regulatory bodies, legal advisors, or similar third parties where we are under a legal duty to disclose or share personal information in order to comply with a legal obligation;
19.6. Enforce or apply our website terms and conditions and other agreements; and
19.7. Protect our rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
20. We do not disclose your personal information to any third party other than those described previously or when we are legally required to do so.
21. Your personal information is held in a controlled and secure environment. We use appropriate technical, organizational, and administrative security measures to protect any information we hold from loss, misuse, and unauthorised access, disclosure, alteration, and destruction. Among other practices, accounts are protected by a password for your privacy and security.
22. We use various technologies on our websites to appropriately secure transactions and process online orders. You should, however, be aware that there is always an inherent risk in transmitting personal information via the Internet.
23. We only keep your personal information for as long as it is required. We will keep your personal information:
23.1. Until we no longer have a valid reason for keeping it; or
23.2. For as long as required by law e.g., we keep invoice information for 7 years to fulfil our tax obligations.
23.3. Whilst we may keep commercial information as required by law, we are provided with the absolute right and authority to delete all Applicant information.
23.4. Both the Client and Applicant confirm and request that the Applicant’s data will automatically be deleted after 21-days, other than Name, Address and Date of Birth.
24. If you have any questions or concerns or would like to exercise your right to obtain a copy of the information that we hold about you (or to have this information corrected), please get in contact with us directly at admin@comprende.net.nz
25. Alternatively, you can contact The 3rdDegree Privacy Officer via:
25.1. Email: admin@comprende.net.nz or
25.2. Post: PO Box 10363
Wellington Central
Wellington 6140
26. If you consider your query or privacy concerns have not been resolved satisfactorily by us, or you wish to obtain more information on privacy requirements, you can contact the New Zealand Office of the Privacy Commissioner via their website www.privacy.org.nz or free phone at 0800 803 909.
27. Further information about how to lodge a complaint is available on the Privacy Commissioner’s website.
Published June 2023