LAST UPDATED: 15-07-2021
Maintaining the privacy of your information is of paramount importance to us as it helps foster confidence, goodwill and stronger relationships with you, our customers. If, at any time, you have questions or concerns about our privacy practices, please feel free contact us at contact [at symbol] spotzee.com.
U.S.-EU data transfers
Spotzee adheres to the core privacy of data protection compliance regarding the collection, use, and retention of personal information from European Union member countries and Switzerland.
Conduct an independent risk assessment into whether the proposed data transfer will provide an adequate level of protection for the rights of the data subjects; and
If we do not find that there is an adequate level of protection, we put into place adequate safeguards to protect the rights of the data subjects. This is ensured by way of a contractual agreement with any applicable data controller or data processor to whom data is transferred, where possible using the European Commission model clauses in respect of transfers from controller to controller and in respect of transfers from controller to processor.
We only engage in transfers of personal data outside the EEA to a country whose data protection laws have not been approved by the European Commission as providing adequate protection for data subjects’ rights if there is an adequate level of protection for the rights of data subjects.
In assessing adequacy, we consider general adequacy criteria and legal adequacy criteria. If our assessment of the ‘general adequacy criteria’ reveals that, in the particular circumstances of the case, the risk to the rights of data subjects associated with the transfer is low, we may consider that an exhaustive analysis of the ‘legal adequacy criteria’ may not be necessary. If a high risk is identified (for example, in the event that the data is particularly sensitive) then a more comprehensive investigation of the legal adequacy criteria would be carried out.
The criteria we consider in making the assessment is as set out below:
- The nature of the personal data;
- The purposes for which the data is intended to be processed;
- The period during which the data is intended to be processed;
- The country or territory of origin of the information contained the data;
- The country or territory of the final destination of the information;
- Any security measures taken in respect of the data in the country or territory of destination.
Legal adequacy criteria
- The law in force in the country or territory in question;
- The international obligation of the recipient country or territory;
- The rules or codes of practice which govern the processing of personal data in the third country.
If adequacy is established by way of our assessment, then we would proceed with the transfer of the data. If adequacy is not established by way of our assessment, then we would seek to enter into a contractual relationship with the data controller or data processor in question to ensure that the security of the data is maintained to our required standards before any transfer takes place.
Information Collection and Use
Spotzee collects information that personally identifies you (“personal information”) in some circumstances, for example when you apply for our services or our customers provide your personal information to us so that we can help them communicate with you by email. The types of personal information we collect include name, contact details, identification information, organisation, title, information submitted in forms, payment details and enquiry/complaint details. We also collect personal information about your interactions and transactions with us, including any through monitoring and recording any contact we have with you by telephone, email or online for purposes including security, dispute resolution and training. We collect personal information directly from you as well as from third parties including public sources, our related companies, information service providers and the parties with whom we exchange information as described here.
We collect, use and disclose your personal information to provide, administer, improve and personalise our products and services, maintain and update our records, manage our relationship with you and our customers and deal with your enquiries and concerns. We may also collect, use and disclose your personal information in connection with suspected fraud, misconduct and unlawful activity.
If you are our customer, your personal information is used to create your personal access to our email marketing product, and to contact you in the course of using this product. Financial information that is collected is used to verify, identity and to bill either you or your company for products and services, as applicable. Demographic and profile data collected by Spotzee may be used to tailor this web site or any requested email communications, and to display information that is more relevant to you. Spotzee also compiles demographic and product use information, but in the aggregate only, and may make that aggregate information publicly available. Under no circumstances will Spotzee make any personal information about an individual user available publicly in this manner.
Your email address is used to only send you information that you have requested. As part of your use of our email marketing software, Spotzee allows you to elect to receive, or not receive, certain information from Spotzee. Spotzee adheres strictly to permission-based email policy. Except as mentioned above, Spotzee will not send you unsolicited email information, commercial offers or advertisements. Spotzee will not sell, rent, or loan our contact lists or our customer’s contact lists (including customer data) to any outside firms not involved in the provision of Spotzee services, nor will Spotzee use customer contact lists for our own marketing purposes. All emails that you have requested will have an option to unsubscribe. Unsubscribe requests are fulfilled within minutes and no further communications will be sent to users who have stated that they do not wish to receive the specified information.
We may not be able to do the things described above without your personal information. For example, we may not be able to communicate with you and deal with your enquiries.
Spotzee will not use or disclose your personal information without your consent, except:
- where required or authorised by law;
- to implement the terms of any agreement we have with you;
- to assist the lawful investigation of a law enforcement authority;
- to protect the rights, property or personal safety of another Spotzee customer, any member of the public or Spotzee;
- We may exchange your personal information with our related bodies corporate, your representatives and with our service providers that assist us with archival, auditing, accounting, customer contact, legal, business consulting, banking, payment, delivery, data processing, data analysis, information broking, research, investigation, website or technology services. Third parties to whom we disclose personal information may be located in New Zealand, the United States of America and other countries.
Subscriber Lists, Campaign Content and Campaign Reports
Spotzee employs a range of measures to protect the privacy and confidentiality of personal information in subscriber lists, email content and reports. Spotzee may scan the content of your campaigns to ensure it complies with our Terms of Service — to protect against defamatory, inaccurate, abusive, obscene, profane, or threatening material that is racially or ethnically offensive.
Communications from the Site
Special Offers and Updates
We send all new users a welcoming email to verify their new account and confirm their password and username. Established users will occasionally receive information on products, services, special deals, and a newsletter. Out of respect for the privacy of our users we present the option to not receive these types of communications. Customers can unsubscribe via the unsubscribe mechanism at the bottom of each email.
If a user wishes to subscribe to our newsletter, we ask for contact information such as name and email address. Out of respect for our users privacy we provide a way to opt-out of these communications via the unsubscribe mechanism at the bottom of each email.
On rare occasions it is necessary to send out a strictly service related announcement. For instance, if our service is temporarily suspended for maintenance we might send users an email. Generally, users may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature.
We communicate with users on a regular basis to provide requested services and in regards to issues relating to their account we reply via email or phone, in accordance with the user’s wishes.
Website Usage Information
We use your IP address to help diagnose problems with our server, and to administer our website. We do not link your IP address which accesses our website to any personal information. We use tracking information to determine which areas our site users visit based on traffic to those areas. Spotzee does not track what individual users read, but rather how often each page is visited. This helps us maintain a superior and informative website for you.
In providing email campaign services for our customers, we may link cookies and IP addresses with records of emails received and links accessed to help our customers monitor the effectiveness of their email campaigns and manage their relationships with subscribers.
Our website may contains links to other sites. We are not responsible for the privacy practices or policies of those sites.
Data supplied for verification: You may also supply data to Spotzee as a part of the verification process. Information about how we keep this information secure in both transit and in rest will be sent upon request. Please send an email to contact [at] emailverifierapp.com to request a copy of Spotzee’s Data Security document.
Behavioral targeting We partner with a third party to either display advertising on our Web site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests.
Social media widgets Our website includes Social Media Features, such as the Facebook Like button, and Widgets, such as the Share This button or interactive mini-programs that run on our website. These Features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy statement of the company providing it.
Spotzee has made a substantial investment in server, database, backup and firewall technologies to protect our information assets. These technologies are deployed as part of sophisticated security architecture. All data resides in a tightly controlled, secure data center. These investments mean that information about the identity and preferences of individual members is strongly protected by Spotzee against unauthorised access. We will maintain safeguards to protect the security of these servers and your personal information.
Spotzee may process, store and back up its information with the assistance of those providers.
If you apply for a position with us, we may also collect information about your experience, qualifications, skills, character and screening checks (including identity, eligibility to work, health, reference, background, directorship, financial probity, vocational suitability and criminal record checks). We collect, use and disclose your personal information to assess your application, conduct screening checks and consider and contact you about other positions. We may exchange your personal information with screening check providers, recruiters, academic institutions, health service providers, professional and trade associations, law enforcement agencies, referees and your current and previous employers. Without your personal information we may not be able to progress considering you for positions with us.
We may also disclose your personal information as required by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
If Spotzee is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.
Contacting Spotzee about Privacy
If you have any questions about our privacy statement, the information we have collected from you online, the practices of this website, or you wish to access or correct the personal information we hold about you, please contact us:
Level 17/11-19 Customs Street West,
Auckland - 1010
+64 9 870 5777
contact [at symbol] this domain
In the case of access and correction requests, please provide as much detail as you can about the particular information you seek, in order to help us locate it. We will comply with any applicable legal requirements to provide reasons if we deny any request for access or correction, or to make a requested note of your desired correction with the information.
We take your privacy concerns seriously. Where you express any concerns that we have interfered with your privacy, we will respond to let you know who will be handling your matter and when you can expect a further response.