EziBuy’s Privacy Policy

Our privacy commitment
Our obligations
Why EziBuy collects your personal information
What kind of personal information EziBuy holds
How EziBuy uses your personal information
When do we disclose your information?
Who do we disclose your information to?
Direct Marketing
Remarketing with Google Analytics and others
Cookies
Overseas recipients
Use of Government Identifiers
Data Quality & Security
Website usage
Links to third party sites
How you can access and edit your information
How you can contact us about this Privacy Policy

Our privacy commitment

EziBuy is committed to protecting the privacy of your personal information. We manage your personal information in an open and transparent way.

EziBuy will only use your personal information when it is necessary for us to deliver you a service or perform other necessary business functions and activities.

EziBuy will not use or disclose your personal information for purposes unrelated to our business activities and the services we provide, unless we first obtain your consent.

‘EziBuy’ refers to EziBuy Limited, EziBuy Australia Limited, EziBuy Operations Limited, Mosaic Brands Ltd and its subsidiaries.

Our privacy obligations

This privacy policy sets out how we comply with our obligations under the:

• Privacy Act 1988 (Australia); and
• Privacy Act 1993 (New Zealand).

EziBuy is bound by the requirements of these laws, which regulates how we may collect, use, disclose and store your personal information. These laws also specify how individuals may access and correct information held about them.

“Personal Information” means information or an opinion about an identifiable individual (or an individual who is reasonably identifiable), whether true or not, or recorded in a material form or not. For example, this type of information could include your name, contact details, age and address.

In this policy ‘we’, ‘us’, ‘our’ and ‘EziBuy’ refers to (and this policy applies to) EziBuy Limited (NZBN: 9429039761811), EziBuy Australia Limited (NZBN:9429036208371), EziBuy Operations Limited (NZBN:9429035680604), Mosaic Brands Ltd (ACN:003 321 579) and its subsidiaries.

If you have any questions regarding EziBuy’s Privacy Policy, please call us on 0508 500 500 or email us at mail@ezibuy.co.nz. If you would like EziBuy to send you a hard copy of this policy, please contact us and we will do so.

We may review this policy from time to time and will notify you of any changes by posting an updated version on our website. Your use of our website following any updates constitutes acceptance of this policy as amended. We recommend you regularly review the policy when you visit our website. This document represents our privacy policy as at September 2015.

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How and why does EziBuy collect and hold your personal information?

EziBuy will only collect your personal information by lawful and fair means, and not in an unreasonably intrusive manner.

It is EziBuy’s usual practice to collect information directly from you when you:

• become an EziBuy customer;
• register with any of our other marketing programs;
• place an order with us or complete any online form on one of our websites or online payment gateways;
• arrange the collection of an item through our ‘Click & Collect’ service (which will require you to verify your identity);
• establish an account;
• visit or use an EziBuy website, including any forums, (this may include the address of your Internet service provider, the name of the web page directing you and your clicks and activity on our website);
• subscribe to marketing and sales material or communications;
• complete an online form on one of our social media channels (for example, Facebook);
• complete a survey;
• enter a trade promotion or competition;
• register a gift card;
• complete an online form on one of our online advertisements that is placed on a third party website;
• complete a hard copy form or provide information in one of our stores;
• complete and return to us a hard copy form that is provided with one of our products;
• request delivery of products;
• make a purchase, return or exchange a product where we request you to verify your identity;
• provide feedback via phone, e-mail, chat or social media;
• speak with us, or one of our representatives directly during a product or sales enquiry; or
• contact us directly by telephone, via mail, e-mail or online (inbound and outbound calls to the EziBuy Call Centre will be recorded).

We may collect information about you from a third party or a publicly available source, but only if you have consented to such collection, or would reasonably expect us to collect your personal information in this way.

Where we can, we will allow you to deal with us anonymously or by using a pseudonym. For example, if you wish to review a product or make a comment about our service, you are able to do this anonymously.

However, in some circumstances, EziBuy may need to collect your personal information to provide you with a delivery or other service. In some cases, if you do not provide the required personal information we will not be able to provide you with that service.

If we receive information about you from a third party and it is not information we need in respect of our business activities, we will destroy or de-identify that information (provided it is lawful to do so). If we receive information in error (e.g. via social media) we will act promptly to remove the content.

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What kind of personal information does EziBuy collect and hold?

Any personal information that you provide via our websites or directly is collected and managed by EziBuy.

If you provide your personal information to a third party via a link from an EziBuy website, that information is collected and managed by those third parties. You should familiarise yourself with their privacy policy prior to deciding whether you wish to provide them with your information.

The types of personal information EziBuy may collect includes your:

• name;
• date of birth;
• gender;
• marital status and family details (this may include the name of a child if a personalised product is ordered);
• residential, business and postal address;
• email address;
• contact telephone numbers;
• identification details;
• password for online access;
• testimonials or opinions;
• photos of you;
• financial information, such as credit card details;
• written or verbal contact with EziBuy, including voice recordings of telephone conversations you have had with our employees;
• information relating to your access to our website;
• information provided to NZ Post;
• activities, including but not limited to lifestyle and other interests.

EziBuy also collects personal information (which may include sensitive information) from its employees (past, current and future) in order to provide a range of employment related services.

EziBuy collects personal information directly from job applicants (and their referees) or from recruitment agencies and related service providers. The information we collect may include your name, address contact details, employment and education history, the names of your referees and other relevant information. This information we collect about you will be used for recruitment purposes and may be disclosed to third party service providers who provide recruitment related services to us.

Whilst you may opt not to provide us with your personal information, you should be aware that without this personal information, we may not be able to provide you with some of the services and/or products you are seeking.

If you provide us with information about any third party, you must obtain that person’s permission to give us the information and inform them that you have given the information to us.

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How does EziBuy use your personal information?

We use your personal information for a variety of reasons including to:

• contact you in relation to one of our loyalty, survey or marketing programs;
• provide services and products to you;
• send you an abandoned online shopping cart or ‘shopping bag reminder email’;
• answer your inquiries and deliver customer service to you;
• tell you about other products that we think may be of interest to you;
• enable us to undertake a credit assessment;
• maintain and improve customer services;
• manage your gift card balance;
• meet our legal obligations;
• consider making offers for employment purposes;
• manage and resolve any legal, consumer or commercial complaints and issues;
• carry out internal functions including training; and
• conduct marketing research and analysis.

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In what circumstances will EziBuy disclose your personal information?

In the course of conducting our business and providing our products and services to you, we may disclose your personal information.

We only disclose personal information for the purposes for which it was given to us, or for purposes which are directly related to one of our functions or activities.

We do not give it to anyone else unless one of the following applies:

• you have consented to the disclosure;
• you would reasonably expect, or have been told (by this Policy or by other means), that your information is passed to those individuals, businesses or agencies; or
• the disclosure is otherwise required or authorised by law.

If we engage third party agents or contractors, we will take all reasonable steps to ensure that they do not breach privacy requirements in relation to the information, before we share your personal information with them.

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Who do we disclose your personal information to?

We may disclose your personal information to:

• another EziBuy business;
• to companies that perform services on our behalf such as printers, post suppliers, delivery companies, data entry service providers, trade promotion or gift card administration, account management providers, IT companies that manage and maintain our database, survey companies acting on our behalf and digital marketing agencies (for the purposes of targeting on social media);
• professional advisers (such as lawyers or auditors);
• payment systems operators and financial institutions;
• organisations authorised by EziBuy to conduct promotional, research or marketing activities;
• upon lawful request from law enforcement agencies or government authorities; and
• any persons acting on your behalf including those persons nominated by you, executors, trustees and legal representatives.

In all circumstances where your personal information is disclosed, we will take all steps reasonable to ensure that these third parties undertake to protect your privacy. Data is always transferred via Secure File Transfer Protocol.

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Direct marketing

We are committed to compliance with all laws and requirements relating to the use of your personal information. We will only use or disclose your personal information for direct marketing purposes if you have provided your information for that purpose (and you would expect us to use the information for that purpose), or if you have provided consent for your information to be used in this way (for example, though a catalogue, email, SMS/TXT message or direct mail permission).

When we contact you it may be by mail, telephone, email, SMS/text message or social media message.

Where we use or disclose your personal information for the purpose of direct marketing, we will:

• allow you to request not to receive direct marketing communications (also known as ‘opting-out’); and
• comply with your request to ‘opt-out’ of receiving further communications within a reasonable timeframe.

You can subscribe to promotional and marketing email communications by registering for My Account here. The boxes to subscribe for email, catalogue, DM or or SMS/TXT communications will be pre-ticked. If you are registering for My Account and do not wish to receive email or SMS/TXT communications please remember to un-check these boxes.

Occasionally we will send SMS/TXT messages to you about exclusive offers and early notice of our flash sales on your mobile. You can unsubscribe to SMS/TXT communications received from us by signing into My Account here and un-checking "I want to receive: SMS" box or by calling us on 0508 500 500 or emailing us at mail@ezibuy.co.nz

By subscribing to our email, you consent to receiving emails which promote and market our products and services, or the products and services of others, from time to time.

You can unsubscribe from our email communications at any time by clicking the "Unsubscribe" link in any promotional or marketing email received from us or by signing into My Account here and unchecking "I want to receive: Email" box or by calling us on 0508 500 500 or emailing us at mail@ezibuy.co.nz.

We use email open and click tracking including cookies, a single pixel image for tracking and link redirects for tracking clicks, for us to get a better understanding of which email communications are of most interest to you so we can provide you with a better experience by sending relevant and interesting email communications.

From time to time, we may contact you with information about products and services offered by us and our related entities or our business partners, which we think may be of interest to you.

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Remarketing with Google Analytics and Others

We use Remarketing through Google Analytics and other third party providers to advertise online by delivering EziBuy ad content to you which is specifically targeted to your interests based on your visits to our website. Third-party vendors, including Google and Bazaarvoice, show EziBuy ads on sites across the Internet.

EziBuy website visitors who wish to opt out of Google Analytics or Bazaarvoice for Display Advertisers and/or customized Display Network ads can do so by visiting Google's Ads Preferences Manager or Bazaarvoice's opt-out mechanisms (the NAI opt-out page or the DAA opt-out page). You can also download the Google Analytics Opt-out Browser Add-on.

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Cookies

Our website uses a technology called cookies. A cookie is a small element of data that our website may send to your computer. Any such cookie is typically stored on your computer's hard drive and permits our website to recognise you when you return. Our use of cookies helps us to provide you with a better experience during your use of our website by allowing us to understand what areas of the site are of interest to you. You may configure your web browser to not accept cookies, although you may experience a loss of functionality as a result.

Reputable third party vendors, including Google and Bazaarvoice, show advertisements for our products on various sites on the internet. EziBuy and third-party vendors, including Google and Bazaarvoice, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone's past visits to our website. If you would like to opt out of the use of cookies for this purpose, please visit Google's Ads Preferences Manager (and select Opt Out from the left hand menu and follow the prompts) or Bazaarvoice's NAI opt-out page or DAA opt-out page.

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Does EziBuy disclose your personal information to overseas recipients?

Your personal information may be disclosed to business partners and EziBuy’s service providers in Australia and overseas.

The countries this information may be disclosed to will vary from time to time, but may include Australia, New Zealand, Holland, Germany and the United States of America.

Sometimes we use third party platforms and services to process sales, provide web support, send marketing messages, deliver products or otherwise deliver information. These services are hosted and managed by organisations other than ourselves, and some of these services are hosted overseas.

Your personal information may be stored in a secure and encrypted form overseas (e.g. in data storage and cloud computing facilities operated by us (or by third parties on EziBuy’s behalf).

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Use of Government Identifiers

EziBuy will not use Government Identifiers, such as a driver's licence number as its own identifier of individuals.

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Data quality and Security

EziBuy will take all reasonable steps to ensure that your personal information is stored securely and protected from misuse, loss and from unauthorised access, modification or disclosure. We use secure servers and industry standard data encryption whenever we are receiving or transferring your personal information online. However, we accept no responsibility for any loss, misuse, unauthorised access or disclosure, alteration or destruction of personal information which you submit to us.

The personal information that we collect about you is stored on our database servers and filing systems managed by us in New Zealand. The data is stored on the Emarsys server.

If you no longer consent to your personal information being stored, please send through a request to mail@ezibuy.co.nz or message us on Facebook or Instagram to request your customer record to be deleted. Please note, in doing so, your customer name and number will remain in our database as it is attached to historical transactions, and to ensure we have a record that you specifically don’t want us to contact you. However, you will be unsubscribed and removed from any further communication (such as marketing).

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Website usage

Our websites are professionally hosted and operate in a secure environment. You should however be aware that there is always an inherent risk in transmitting your personal information via the Internet. We use the secure Hosted Payment page solution from Windcave to process online orders. Customers can see their cards being debited in real time, all in an SSL secure environment. We take website and credit card security extremely seriously, and always endeavour to provide a secure safe platform on which to conduct online transactions.

We use a variety of security technologies and procedures to help protect your personal information from unauthorised access, use or disclosure. For example, we store the personal information you provide in computer servers with limited access that are located in controlled facilities secured by the latest in surveillance and security technology. When we transmit sensitive information (such as a credit card numbers) over the internet, we protect it through the use of encryption, such as the Secure Socket Layer (SSL) protocol. Credit card details stored on site are encrypted using 168bit 3DES encryption. Windcave is also certified AIS compliant.

To make sure you are accessing a secure server, check for the unbroken key or closed lock symbol located generally either at the bottom left or top right of your browser window. If it appears, then SSL is active. You can double check this by looking at the URL as well. If SSL is active, then the first characters of that line will read ‘https’ rather than just ‘http’. It is important for you to protect against unauthorised access to your password and to your computer.

Ensure you logout when you have finished visiting our websites especially if you accessed them from a shared computer.

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Links to third party sites

Whilst links to third party websites may be provided on our website, we are not responsible for the content or practices of those third party websites.

Our website may contain links to other sites that are not under our control. These websites may use cookies. It is the responsibility of those third parties to collect appropriate consents from you in order to permit their own cookies (to the extent this is required by law) and to inform you about the cookies they use. You should check the privacy policy on all third party websites to ensure you are comfortable with third party cookies (Bazaarvoice's privacy policy can be found here: Bazaarvoice Privacy Policy). We have no responsibility for linked websites, and provide them solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or warranties about their accuracy, content or thoroughness. Your disclosure of personal information to third party websites is at your own risk and we recommend that you check the privacy policies of these third parties prior to providing them with your personal information.

No links may be made to our website without our prior written consent.

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How you can access or correct your personal information

You are able to make changes to your personal information via our website or contact centre. You can also request access to the personal information we hold about you at any time (online, over the phone or instore (New Zealand), and we will provide you with that information unless we are prevented by law from giving it to you.

If we are unable to give you access to the information you have requested, we will give you reasons for this decision when we respond to your request.

You will not be charged for accessing your information, although we might have to charge the reasonable cost of processing your request, including photocopying, administration and postage. We will advise you of any fee payable before we process your request.

If you believe that your personal information is not accurate, complete or up to date, please amend via the website, contact us via email to mail@ezibuy.co.nz or address your request to The Privacy Officer, EziBuy Limited, Private Bag 11000, Palmerston North, 4442 New Zealand and we will correct this information.

How you can notify us of a privacy concern or contact our Privacy Contact Officer If you:

• have any queries, concerns or complaints about the manner in which your personal information has been collected or handled by EziBuy; or
• would like to request access to or correction of the personal information we hold about you;

Please write to:

New Zealand
The Privacy Officer
EziBuy Limited
Private Bag 11000
Palmerston North 4442
New Zealand

Email: mail@ezibuy.co.nz

If you consider your privacy concerns have not been resolved satisfactorily by us, or you wish to obtain more information on privacy requirements, please contact:

New Zealand
Privacy Commissioner (New Zealand) on 0800 803 909 or visit their website at www.privacy.org.nz.

EziBuy is part of the Data Warranty Register, a self-regulatory system under the governance of the Marketing Association that provides best-practice transparency relating to the collection, storage and use of marketing data by businesses.

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