Privacy Policy

The scope of this privacy policy

1. This privacy policy applies only to the actions of OSACO Group and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
2. For purposes of the applicable Data Protection Laws, OSACO Group is the “data controller”. This means that OSACO Group determines the purposes for which, and the manner in which, your Data is processed.

Data collected

We may collect the following Data, which includes personal Data, from you:

1. 1. name;
   2. job title;
   3. contact information such as email addresses and telephone numbers;
   4. an IP address (automatically collected);
   5. web browser type and version (automatically collected);
   6. operating system (automatically collected);

in each case, in accordance with this privacy policy.

How we collect Data

We collect Data in the following ways:

• data is given to us by you;
• data is collected from other sources; and
• data is collected automatically.

Data that is given to us by you

1. OSACO Group will collect your Data in a number of ways, for example:

• 1. when you contact us through the Website, by telephone, post, e-mail or through any other means;
  2. when you elect to receive marketing communications from us;
  3. when you use our services;

in each case, in accordance with this privacy policy.]

Data collected from other sources

1. In some cases we may collect your Data from a source other than you (for example, from your employer or organisation when they register you for one of our training events, or from publicly available sources). Where we collect your Data indirectly, we will take reasonable steps to ensure that you are made aware, as soon as reasonably practicable, that your Data has been collected, the purpose of the collection, and the intended recipients, unless an exception under the Act applies.

Data that is collected automatically

1. To the extent that you access the Website, we will collect your Data automatically, for example:

• 1. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content;
  2. we will collect your Data automatically via cookies, in line with the cookie settings on your browser and the consent you provide. For more information about cookies, and how we use them on the Website, see the section below headed “Cookies”.

Our use of Data

1. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

• 1. internal record keeping;
  2. improvement of our products/services;
  3. transmission by email of marketing materials that may be of interest to you;
  4. contact for market research purposes, which may be done using email, telephone or mail. Such information may be used to customise or update the Website;

in each case, in accordance with this privacy policy.

2. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
3. For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft opt-in:

• 1. soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt out;
  2. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide;
  3. if you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.

Who we share Data with

1. We may share your Data with the following groups of people for the following reasons:

• 1. any of our group companies or affiliates — when you agree to receive our newsletters or attend our workshops and seminars;
  2. our employees, agents and/or professional advisors — to obtain advice from professional advisers and to operate our business;
  3. third-party service providers who support the operation of this Website and our business (for example, website hosting and email providers) — to provide our services to you;
  4. relevant authorities — to facilitate the detection of crime or the collection of taxes or duties, or when required by law;

in each case, in accordance with this privacy policy.

Keeping Data secure

1. We will use technical and organisational measures to safeguard your Data, for example:

• 1. where access to systems or services is provided, access is controlled by credentials that are unique to you;
  2. we store your Data on secure servers.

2. Technical and organisational measures include measures to deal with any suspected privacy breach. If we become aware of a privacy breach that has caused, or is likely to cause, serious harm, we will notify the Office of the New Zealand Privacy Commissioner and affected individuals as required by the Act, and any other regulator where required by applicable Data Protection Laws. If you suspect any misuse or loss of, or unauthorised access to, your Data, please let us know immediately by contacting us via this e-mail address: info@osacogroup.com.
3. If you want detailed information from “Get Safe Online” on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit https://www.ncsc.govt.nz, supported by the New Zealand governmen

Data retention

1. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.
2. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

1. You have the following rights in relation to your Data:

• 1. Right to access — the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive”. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why;
  2. Right to correct — the right to have your Data rectified if it is inaccurate or incomplete;
  3. Right to erase — the right to request that we delete or remove your Data from our systems;
  4. Right to restrict our use of your Data — the right to “block” us from using your Data or limit the way in which we can use it;
  5. Right to data portability — the right to request that we move, copy or transfer your Data;
  6. Right to object — the right to object to our use of your Data, including where we use it for our legitimate interests.

2. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: info@osacogroup.com.
3. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority:

• in New Zealand, the Office of the Privacy Commissioner (www.privacy.org.nz);
• in the United Kingdom, the Information Commissioner’s Office (https://ico.org.uk);
• in the European Union, the supervisory authority in the member state where you live or work.

4. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

International transfers of Data

1. Data which we collect from you may be stored and processed in, and transferred to, countries outside of New Zealand, the European Economic Area (EEA) and the United Kingdom. For example, this could occur if our servers are located overseas or one of our service providers is situated overseas. We also share information with our group companies, some of which are located in other countries.
2. We will only transfer Data internationally where the transfer complies with applicable Data Protection Laws and adequate safeguards are in place. Depending on the destination, these safeguards may include:

• 1. transfer to a country that has been recognised as providing an adequate level of data protection (New Zealand, for example, is recognised by the European Commission as providing adequate protection for personal data transferred from the EU);
  2. a data transfer agreement incorporating the standard contractual clauses adopted by the European Commission in June 2021 (or, for transfers from the UK, the UK International Data Transfer Agreement or UK Addendum);
  3. for transfers to the United States, transfer to an organisation certified under the EU-U.S. Data Privacy Framework (and, where relevant, its UK Extension).

3. To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.

Links to other websites

1. 1. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes in business ownership and control

1. OSACO Group may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of OSACO Group. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part, and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
2. We may also disclose Data to a prospective purchaser of our business or any part of it.
3. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies

1. This Website may place and access certain Cookies on your computer. OSACO Group uses Cookies to improve your experience of using the Website. OSACO Group has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
2. All Cookies used by this Website are used in accordance with applicable Cookie Laws.
3. Before the Website places non-essential Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling OSACO Group to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
4. This Website may place the following Cookies: