We may review and revise this policy from time to time and will publish any updated version on our website. Changes apply from the time we upload the revised policy.

What is personal information?

Personal information is information about an identifiable individual (a living, natural person) — such as a name, address, phone number, email or date of birth. It does not include information about a business.

Who do we collect personal information about?

We collect personal information about individuals who interact (or may interact) with our business, including:

• Our customers and end users — current, prospective and past — and their associates, such as authorised or nominated representatives, the cardholder who pays an account, secondary account holders, guarantors, the landlord of a tenanted property, or the nominated contact on a business account.
• Our suppliers, service providers and business partners, including their staff and agents.
• Our staff and job applicants.
• Visitors to our websites, social media pages and premises.

If you give us personal information about another individual, you must have their authority to do so and should refer them to this policy.

What types of personal information do we collect?

The information we collect depends on your interaction with us, and may include:

• Contact and identity details — name, date of birth, email, phone number(s) and address; for business customers, nominated-contact details.
• Proof-of-identity information — e.g. passport or driver-licence number, where we need to verify who you are (sometimes required by law).
• Financial and credit information — bank account, credit/debit card or direct-debit details, credit history and related information, to process payments and assess creditworthiness.
• Vulnerability or medical-dependency information — it is important you tell us if you or anyone in your household relies on the service to contact the 111 emergency service or has a particular vulnerability, so we can support you appropriately; we may ask for supporting evidence.
• Occupancy, change-of-name and employment information where relevant to your account.
• Service-usage information — use of our communications and messaging services, payment patterns and history, and notes or recordings of your interactions with our customer-service team (calls may be recorded for training, quality and verification).

If you choose not to provide requested information, we may be unable to provide our products or services, or may only provide them on a limited basis.

How do we collect personal information?

We collect information directly from you where possible, and indirectly from third parties. Sources include: our websites, apps and support platforms (including cookies and analytics); social-media interactions (we never receive your social password); our contact centres; our network equipment; wholesale service providers (e.g. local fibre companies); credit-reporting agencies; your other providers when you transfer (port) services to us; referrals; and public sources. Where we ask to collect information from particular third parties, we do so only with your consent unless authorised by law. We handle unsolicited personal information in accordance with the Privacy Act 2020.

How do we use personal information?

We use personal information for legitimate business purposes, including to:

• process applications and verify identity;
• provide, provision and manage our products and services;
• undertake credit checks and assess suitability;
• bill and collect payment, and process card and direct-debit transactions;
• respond to your enquiries and complaints;
• market our products and services, including electronic messages (text/email) — you can unsubscribe at any time (see Your rights);
• improve and personalise our products, services and customer experience;
• manage and secure our systems and networks, and detect and prevent fraud or threats to network security;
• conduct research and statistical analysis (on an anonymised basis); and
• protect or enforce our legal rights, or as otherwise authorised by the Privacy Act 2020 or by you.

Who do we disclose personal information to?

We may disclose personal information to our related companies and to third parties who help us provide our services, including:

• sales, marketing and support partners we engage;
• banks and payment processors;
• wholesale network operators and local fibre companies (for provisioning, interconnection, fault and network management);
• your other service providers, to complete a transfer (port) of services;
• printers, couriers and dispatch centres;
• IT service providers and data managers;
• public directories, where you ask to be listed;
• credit-reporting and debt-collection agencies;
• our professional advisers (legal, accounting, insurance);
• government agencies, dispute-resolution schemes (e.g. the Telecommunications Dispute Resolution scheme), emergency services and law enforcement, where permitted or required by law; and
• a third party in connection with any actual or proposed merger, acquisition, reorganisation or insolvency of our business.

We require our service providers to protect personal information consistently with this policy and the Privacy Act 2020.

Disclosure outside New Zealand

Some of our service providers (for example cloud, payment or messaging providers) may store or process information outside New Zealand. Before disclosing personal information overseas, we take reasonable steps to ensure the information is protected by comparable safeguards to those in the Privacy Act 2020, consistent with Information Privacy Principle 12. Where those safeguards are not available, we will seek your authorisation.

How do we store and protect personal information?

We take reasonable technical and organisational steps to protect personal information against loss, misuse, unauthorised access, disclosure, alteration or destruction — including access controls, encryption in transit where appropriate, and staff confidentiality obligations. No system can be guaranteed 100% secure, but we work to protect your information and require our providers to do the same.

How long do we keep it?

We keep personal information only for as long as it is needed for the purposes described in this policy, or for as long as we are required to keep it by law (for example tax, telecommunications or anti-money-laundering requirements). When it is no longer required, we take reasonable steps to securely destroy or de-identify it.

Your rights: access, correction and marketing

Under the Privacy Act 2020 you have the right to request access to the personal information we hold about you, and to request that we correct it if it is wrong. To make a request, contact our Privacy Officer using the details below; we may need to verify your identity first. We will respond within the timeframes required by the Act.

You can opt out of marketing communications at any time by using the unsubscribe link in our emails, replying STOP to a text, or contacting us. We comply with the Unsolicited Electronic Messages Act 2007 for all commercial electronic messages.

Cookies and website analytics

Our website uses cookies and similar technologies to make the site work, remember your preferences, and understand how the site is used so we can improve it. You can control or disable cookies through your browser settings, although some features may not work correctly without them.

Privacy breaches

If a privacy breach occurs that we assess is likely to cause serious harm, we will notify the affected individuals and the Office of the Privacy Commissioner as required by the notifiable-privacy-breach provisions of the Privacy Act 2020.

Complaints, questions and how to contact us

If you have a question, a request about your information, or a privacy complaint, please contact our Privacy Officer:

• Email: sales@bedigital.co.nz
• Phone: 0800 233 444
• Post: Privacy Officer, Be Digital Limited (Be Connect), New Zealand

If you are not satisfied with our response, you can contact the Office of the Privacy Commissioner (privacy.org.nz) or, for telecommunications matters, the Telecommunications Dispute Resolution scheme (tdr.org.nz).

This policy is provided as clear, good-faith information and reflects the requirements of the Privacy Act 2020 and the Telecommunications Information Privacy Code 2020. It is not legal advice; Be Connect recommends a final review by a New Zealand-qualified lawyer.