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      We.EV Privacy Policy

       

      1. Scope and Application 

      This Privacy statement applies to We.EV, a business unit within WEL Networks Limited (WEL).  WEL is committed to ensuring that the collection, use, correction, disclosure and disposal of personal information complies with the principles of the Privacy Act 2020, (the Act). 

      2. How to contact us 

      We have appointed a Privacy Officer for We.EV. If you have an enquiry about this Privacy Statement or a complaint about the way we handle your personal information, or if you would like to ask for a copy of your information, or to have it corrected, please contact us at privacy@we-ev.co.nz, or 0800 800 935, or PO Box 925, Hamilton, Attention: Privacy Officer. 

      3. Purpose 

      We collect personal information which helps us interact with you, set up and manage your account, supply our products and services in accordance with your preferences and respond to your enquiries. We also collect information for the purposes of marketing if you have consented, personalising your website experience, product registration and licensing and technical support and repairs. 

      4. How we collect information 

      Generally, WEL collects information from you when you give it to us, for example when you set up your account, or contact our Call Centre. Information will also be created by us, or through a technical process when you use our products or services, or interact through our website www.we-ev.co.nz, our enterprise cloud service CP Link (Website) and through our mobile app (App).  

      Cookies and similar technologies let us remember your preferences and tailor our content to your interests. They are usually enabled by default.  Most web browsers and mobile device settings will allow you to disable them or set limits on how they work, manage settings for advertising preferences and manage opt-outs.   

      Sometimes We.EV may need to get information from other sources - such as public registers, your references, or 3rd parties. We only collect data from trusted providers if it’s lawful or they confirm they have permission to share it. 

      5. What information we collect  

      The personal information we collect depends on how you use our products and services and our relationship with you. It may include any of the following information about you: 

      • name; 
      • contact information; 
      • location; 
      • computer or network or device information specific to you, including model, software, unique device and service identifiers, and technical and performance related settings; 
      • interactions with us including usage; 
      • billing or purchase information; 
      • copy of your driving licence, passport and your visa/work permit status; 
      • content of your communications including pictures you send us; 
      • technical and performance information related to our products, services, equipment or networks and how they are performing for you. 
      6. Location information 

      We may collect information generated about your location. This may be generated automatically as we supply our products and services to you (e.g.  when your device connects to cell towers and GPS satellites.)  It may also be generated when you share your information with us through a website, app or other digital platform and may be optional.  

      7. CCTV Footage 

      Our products may be monitored by CCTV for the safety and security of the public and installed equipment, and to detect and deter criminal behaviour and acts. All CCTV cameras will be installed in alignment with the Privacy Commissioner’s publication: Privacy and CCTV; A guide to the Privacy Act for businesses, agencies and organisations. 

      Any data from CCTV cameras in our control, unless required for the purposes above, will only be stored on a dedicated self-overwriting disk. This usually means that no more than about 35 days of video data is stored. 

      8. How we use your information  

      We only use your personal information in connection with the original purpose for which it was collected, for a directly related purpose, with your authorisation (including under this policy), or for another purpose which is lawfully authorised (such as for public safety). 

      We may share your personal information with people who you ask us to share it with.  We may also share your personal information with trusted third parties like service providers, business partners, agents, and advisors. We require such recipients to take appropriate measures to protect the information and restrict their use of it.  We may also be required to share your information with government agencies, or if required by law. 

      Common reasons we share your personal information with these recipients include:  

      • managing the supply of products and services to you 
      • when they are providing services to us, such as technology and business process services, market research, advertising placement, product development and business intelligence 
      • for the purpose of using your personal information in accordance with this policy 
      • to comply with legal obligations that we have 
      • when we sell a business or asset, or to comply with other contractual obligations that we have or accept.  
      9. How we store and safeguard your information  

      We apply security measures and follow industry standards to keep your personal information secure. If we do need to store your information online and/or in the cloud, we carefully select trusted data centre providers and take all reasonable precautions to ensure the safety and integrity of your information.  Currently, Personal Data may be stored on Amazon Web Services (AWS) servers in the United States via a data processing agreement we have with HubSpot . We also use Stripe New Zealand (Stripe) to process payment transactions. Some of your information, including credit card details, will be shared with Stripe and may be transferred, processed and stored outside of New Zealand.  To better understand how a data centre provider uses and stores the data shared with them, check their privacy policies directly: 

      If, despite our efforts, we become aware of a data breach that we think could compromise your security, we’ll tell you as soon as we can. We may also report the breach publicly, if we consider it appropriate, or if we’re required to by law.   

      10. How long we keep your information  

      We usually only keep your personal information for as long as it’s needed in connection with its original purpose. After that, we delete it or anonymise it.   

      Some personal information may be retained for longer for purposes directly connected to the original purpose or to comply with our legal and regulatory obligations. For example, we generally keep:   

      • Contact centre recordings for about two months, in-app chat messages for approximately one year and live chat messages for up to three years, or more to help with coaching, fraud investigation and complaint investigation.  
      • Billing records for seven years, even after you stop being a customer, to comply with our legal obligations, to help reconnect you and to improve our credit, fraud management controls and decision-making/credit scoring models.  

      In some circumstances we may need to keep some information longer when necessary for a lawful purpose. For example, to investigate and resolve an issue or to assist with law enforcement. 

      11. What you can do 

      You have the right to request a copy of the personal information we hold about you. We will be as open as we can with you, but please note that your right to request personal information may be limited if it breaches another person’s right to privacy or is subject to an overriding national security legislation. We may occasionally need to withhold personal information under sections 27-29 of the Privacy Act, for example where the information requested is legally privileged. However, we will only ever withhold information where necessary. 

      You may request a correction of personal information that you consider is inaccurate. Where the correction requested is not able to be made or we dispute the accuracy of the correction, we will make a note on your personal information. 

      To help with our efforts to keep your personal information safe, we ask you to:  

      • Keep unique account information such as your account number, PIN and password secure. Don’t share them with anyone.  
      • Always select strong, unique passwords or PINs. Don’t re-use them from other services or platforms now or in the past, and don’t re-use them on other services or platforms in the future.  

      We may assume that any verbal or online request or instruction we receive is authorised by you, if it’s accompanied by suitable verification such as your WE.EV account number, personal identification number or password. 

      12.Limitation of Liability

      Nothing in these Terms and Conditions limits or excludes any rights You may have, or obligations we may have, under the Energy Complaints Scheme provided by Utilities Disputes Ltd.