Introduction
The Privacy Act 2020 (Act) sets out thirteen privacy principles (Principles) which establish rules for the collection, storage, security, accuracy, use and disclosure of personal information, as well as an individual’s rights to access, and correct, personal information. Kiwi Property (we, us, our) is committed to compliance with the Principles and the Act and to protecting your personal information.
By providing your personal information to us, accessing a property that we manage or using our services, you agree to this Privacy Policy. This Privacy Policy may change at any time and we will tell you about any changes by posting an updated policy on our websites or in any of the properties we manage. Any change will apply from the date such policy is posted.
This Privacy Policy is subject to and should be read in conjunction with the Terms and Conditions on our website (kiwiproperty.com/corporate/) and any other terms and conditions you agree to when using or signing up to any of our services.
Collection of information
Personal information will only be collected for a lawful purpose connected with a function or activity carried out by Kiwi Property. The personal information we may collect includes (but is not limited to) your:
- name, contact details, date of birth;
- Online profile or algorithm (e.g. a computer-aided process designed to save time, identify relevant information, increase productivity or improve decision making);
- vehicle licence number, and vehicle location and movements on any of the properties we manage and in public areas to which we have visibility;
- location and movements around and in the properties we manage and in public areas close to those properties, including via media recording devices;
- phone conversations with our staff (which may be recorded);
- information lawfully obtained from any of our partners, tenants and other businesses that operate within any of the properties we manage; and
- your communications with us.
Please be aware that we collect some of this personal information through media recording devices, including but not limited to CCTV cameras, automatic number plate recognition cameras, body worn cameras and facial recognition technology.
In order to better protect our staff, our tenants and their customers and any of the properties we manage, we may use facial recognition software. We only use this software for permitted purposes and any personal information collected using this software is only stored for as long as we need it and in accordance with our obligations under the Act.
We may collect your personal information when you complete a form, engage with our online platforms or otherwise make an enquiry via our website. We may also collect your personal information from businesses such as Meta or Google where this has been authorised or from tenants and other businesses operating in any of the properties we manage. We may also collect personal information on your website activity.
Email marketing will only be sent to your email address if you have given your consent. You may unsubscribe to any email marketing message at any time by following the unsubscribe instructions contained in the message.
When transmitting information online (including via email), you should be aware and remember that online platforms are not a secure environment. Personal information submitted online is therefore susceptible to loss, interception or alteration. We accept no responsibility for any unauthorised access or loss of personal information that is beyond our reasonable control.
We use location-based services to understand traffic patterns at properties we manage. The location data we capture helps us to understand the properties we manage, such as how long customers stand in line and how they generally move around the property, enhancing operational efficiency and improving user experience. If you would like to find out more about the data we collect through mobile location analytics, feel free to contact us by emailing privacy@kp.co.nz. You can access your data at purple.ai/my-data.
Use of information
Kiwi Property (and any authorised third parties in accordance with this Privacy Policy) may use your personal information for the following reasons:
- to process transactions and administer your account;
- to help us develop, market, improve, manage, administer and facilitate our services and operations and those of our business partners (including the owner of any property we manage);
- for internal purposes (such as risk management, health and safety, staff training and billing);
- as part of the prevention, detection, investigation and analysis of incidents and offences;
- for us or our commercial partners to notify you of services, special offers, opportunities, products or benefits which are being offered by Kiwi Property or any of our commercial partners or associated organisations; and
- to conduct market research and to promote and market our, or our commercial partners’, products and services, including sending personalised advertisements.
By providing us with your email address, online profile and/or mobile phone number, you consent to us sending you information (via email, text or other form of message service) connected with the above collection and use purposes. We may also send you other information we think you may be interested in and which may market and promote our products and services, or the products and services of other parties we think you may be interested in. The messages you receive from us will have instructions on how you can remove yourself from our messaging list.
Some uses of your personal information may involve the transfer of that information outside of New Zealand, to be held and used by our related companies and commercial partners.
Storage of information
We will use reasonable endeavours to ensure that all personal information is securely protected against loss, unauthorised access and other misuse. We have a range of physical and technology policies in place to provide a robust security environment. We will use reasonable endeavours to ensure the on-going adequacy of these measures by regularly reviewing and testing them.
Disclosing information
We may use the information you have provided us to inform our promotional and marketing strategies, as well as for research and profiling purposes including customer demographics, interests and behaviours. You further acknowledge that to the extent permitted by law, we may share any personal information collected from you with third parties.
We will not disclose your personal information to other people or agencies except where:
- you have authorised such disclosure;
- disclosure is required by our contractors (for the purposes of the services they provide), so that we can complete a transaction on your behalf or provide you with a service that you have requested;
- disclosure is to a law enforcement agency (or agency working on behalf of a law enforcement agency) that requires this information for a permitted purpose;
- we are required to provide the information by law or we are able to do so under the Privacy Act;
- disclosure is required for safety and security and information assurance purposes;
- disclosure was the purpose of collecting the information;
- disclosure is required to facilitate the sale, disposal, assignment or transfer of Kiwi Property or any of its assets or subsidiaries or related companies;
- disclosure is necessary to market, review or improve our services or facilities or those of our business partners;
- disclosure is necessary for third parties to offer you products and services that may be of interest to you and to optimise the advertisements on our online platforms including but not limited to our websites, apps or social media pages;
- it is necessary for a function of Kiwi Property, such as for legal or auditing purposes.
In particular, you specifically authorise us to disclose information we have collected from CCTV, body worn cameras or automatic number plate recognition cameras at any of the properties we manage to law enforcement agencies (or agencies working on behalf of us or the relevant law enforcement agency) for the purposes of prevention, detection, investigation and analysis of incidents or offences in and around any of the properties we manage. This may also include law enforcement agencies having real-time access to live feeds of CCTV cameras at any of the properties we manage.
Correction
Kiwi Property will take reasonable steps to ensure that personal information held by us is accurate. You have the right at any stage to request us to provide you with access to the personal information we hold about you. We will respond to any request by you to correct personal information held about you as soon as practicable following receipt of such request. All requests of this nature should be directed to privacy@kp.co.nz in the first instance.
Further information
If you would like further information about our Privacy Policy, please contact privacy@kp.co.nz.
If you would like more information about privacy in general, please refer to the Privacy Commissioner’s website: privacy.org.nz
Policy owner: Senior Legal Counsel & Privacy Officer
Review date: November 2022
Next review date: November 2024
Policy approver: Board