Privacy Policy

PRIVACY POLICY

This Privacy Policy explains our policy for dealing with personal information that we collect through the following channels (here and after, the Collection Channels):

• our online properties (here and after, each a “Website”), including:
  • any Shopa Marketing website and
  • any of our related websites, social media pages, internal websites;
• any other means through which an individual provides personal information to Shopa Marketing, including either physically or electronically; and
• any other means through which we lawfully collect personal information about you. You may contact us with any queries you may have in respect of this Privacy Policy or your personal information by contacting Shopa Marketing’s Privacy Officer via email: customerservice@shopamarketing.com.

MOBILE INFORMATION SHARING COMPLIANCE

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

PERSONAL INFORMATION IS IMPORTANT TO US

1. We are committed to safeguarding your personal privacy. We recognise that you have a right to control how your personal information is collected and used. Providing personal information is an act of trust and it is taken seriously. Unless given consent to do otherwise, we will only collect and use personal information as set out below
2. Throughout this Privacy Policy, we refer to your ‘personal information’, which means information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not. Your full name, gender, date of birth, home address, home telephone number, mobile telephone number, email address and workplace contact details are examples of information which may constitute personal information. Personal information may also include information we may collect about your individual preferences.
3. Shopa Marketing has developed and implemented its Privacy Policy with respect to personal information to reflect world best practice on privacy policies.
4. In order to keep up with changing legislation and best practice, we may revise this Privacy Policy at any time without notice. We will post any changes to this Privacy Policy on our Websites, so we encourage you to check this Privacy Policy from time to time.
5. In addition to the provisions of this Privacy Policy, there may also be specific and additional privacy and consent provisions that apply to certain Collection Channels. Because those specific and additional provisions also relate to your privacy protection, we recommend that you review them wherever they appear. In the event of any inconsistency between the provisions of this Privacy Policy and those other specific and additional provisions, the specific and additional provisions will prevail.

ANONYMITY AND PSEUDONYMITY

1. Where practicable, we will allow you to deal with us on an anonymous or pseudonymous basis. If this is practicable, our Collection Channels will only seek information in this way. However, where it is not practicable for the purposes for which information is collected, we will seek the information identified below. It will not be practicable to deal with you on an anonymous or pseudonymous basis when we wish to send you direct marketing materials or need to provide you with goods or services requested by you.

KINDS OF PERSONAL INFORMATION THE SHOPA MARKETING COLLECTS AND HOLDS

1. Personal information that may be requested includes, but is not limited to:
   1. contact information such as your full name, date of birth, telephone number, mobile telephone number, current and valid email address, residential address, shipping address, billing address and postcode;
   2. more detailed contact preferences;
   3. your gender
   4. your Apple AppStore and/or Google Play Store ID and your unique device identifier (UDID);
   5. location information;
   6. your occupation and information regarding your professional history and professional interests;
   7. information regarding your education and qualifications;
   8. information regarding your personal interests and interesting and relevant information about you;
   9. financial details including your bank account, PayPal or other electronic payment details;
   10. transaction data including the details of any products or services you have purchased from our partners through the Website;
   11. your online behaviour and interests based on your online browsing activity;
   12. demographic information such as age group, preferences and interests;
   13. information about your preferences, interests, and experiences with our products or services. This information is collected in order to tailor our communications to you and continuously improve our products and services;
   14. information about your experience with our products or services or third party products or services listed on a Website;
   15. the contact details of third parties. If you are asked to provide details about other people, please ensure that these individuals are happy for their details to be given to Shopa Marketing and used for the purposes set out in this policy (which may include using their details for marketing purposes); and
   16. any other personal information which you provide directly to us. Where you provide us with unsolicited personal information, we will retain this information where it falls within our primary purposes for collection of personal information (as stated in this Privacy Policy).
2. When you use a Website, we may also collect personal information about you in the following general categories:
   1. usage and preference information: we collect information about how you interact with a Website, including the pages you visit, your preferences and settings that you choose. We may do this through the use of cookies and other similar technologies that uniquely identify you;
   2. device information: we may collect information about your mobile device such as the hardware model, operating system, preferred language, unique device identifier and mobile network; and
   3. other information: we may also collect and log information such as your IP address, access dates and times, browser type and pages visited when you interact with a Website.

SENSITIVE INFORMATION

1. We will only collect sensitive information with your consent and where you provide it to us directly. Where you provide us with any sensitive information (including, but not limited to, information about your sexual orientation, religious beliefs, medical and/or criminal history), we will only use this information for the purposes stated at the time of collection will share this information with our trusted third parties in the manner stated on the Website or in this Privacy Policy.

HOW THE SHOPA MARKETING COLLECTS AND HOLDS PERSONAL INFORMATION

1. We will only collect or monitor any personal information about you with your consent including as provided in this Privacy Policy or if it is otherwise lawful to do so. The only personal information collected by us is what has been provided to or collected by us in accordance with this Privacy Policy or has been provided to us lawfully by third parties.

ACTIVE INFORMATION COLLECTION

1. Personal information may be collected (and combined) via our Collection Channels if you:
   1. have previously provided us with personal information prior to this Privacy Policy coming into effect, either directly from you personally or via a third party;
   2. sign-up and/or register to become a member of any Collection Channel;
   3. download and use a mobile and/or tablet application;
   4. submit any content to or participate in any way via a Collection Channel, including engaging with other users or taking part in campaigns or offers;
   5. subscribe to any newsletters, updates, alerts or news and media releases, or request launch or event information or information about our products or services or other information services as well as third party products or services;
   6. complete and submit any forms or applications to us;
   7. contact us directly in person or via any medium including mail, telephone, social media and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Message Service), IM (Instant Messaging) and email) including via the contact details listed on a Website;
   8. participate in any offers, promotions, competitions, games, rewards, marketing activities or other activities offered by Shopa Marketing from time to time;
   9. interact with a Website for a specific purpose;
   10. interact with or browse a Website generally; or
2. Personal information is requested in order to allow you to participate in a Collection Channel, to facilitate or provide you with certain content, products or services, and information about such content, products or services (including offers made available via our Collection Channels), marketing materials (including direct marketing materials), newsletters, electronic newsletters (e-newsletters), news and media releases / launch information, and also to advise you of other Shopa Marketing or third party opportunities and products, services, offers, competitions or promotions which may be of interest. No one is obligated to provide personal information. However, failure to do so may result in you being unable to participate in a Collection Channel and Shopa Marketing being unable facilitate or provide you with certain content, products or services, products or services information, upcoming opportunities and promotion, competition, game, offer or event information or accept competition entries or other content from you (where applicable).
3. We may also obtain your personal information from legitimate third party sources and platforms including social media channels, marketing companies, targeting companies, list brokers and other data providers or organisations that share data in circumstances where it is lawful and/or you have given permission for them to do so. For example:
   1. we may use services from other companies that enable us to derive a general geographic area based on your IP address in order to customise certain services to your geographic area.
   2. if you connect your third-party social networking or other platform service profile (such as but not limited to Facebook, LinkedIn, Twitter, Google, Apple or Windows Live) to your Shopa Marketing registration, we may access and use your username, profile image, location information, interests, activities, ‘likes’, connection list and age for those services; and
   3. we may obtain third party information relating to your advertisement interaction and viewing data, such as ad click-through rates and information about how many times you viewed a particular advertisement.

CHILDREN

1. The collection of personal information is neither intended for, nor directed to, persons who are under the age of sixteen (16) years old. Personal information will not be collected by any person who is known by Shopa Marketing to be under the age of sixteen (16) without the consent of a parent or legal guardian. Persons under age sixteen (16) may only use our Websites with the involvement and consent of a parent or legal guardian.

PASSIVE INFORMATION COLLECTION

1. As with many commercial websites and mobile and tablet applications, we may also collect information which tells us about visitors to our Websites. For example, we may collect information about the date, time and duration of visits and which pages of a Website are most commonly accessed. This information is generally not linked to the identity of visitors, except where a Website is accessed via links in an email we have sent or where we are able to uniquely identify the device or user accessing a Website. By accessing a Website via links in an email we have sent and/or by accessing a Website generally including when you are logged into an account, you consent to the collection of such information where it is personal information. When you receive newsletters or promotional emails from Shopa Marketing, we may use web beacons (described below), customised links or similar technologies to determine whether the email has been opened and which links you click in order to provide you with more focused email communications or other information.
2. As you navigate through our Websites, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies, such as Unique Device Identifiers (UDI), cookies, Internet tags or web beacons, and navigational data collection (log files, server logs, clickstream). In certain circumstances, this information may be considered anonymous information or personal information under the Privacy Act2020. This is dependent on the device used and the method by which you connect to the Internet and the Website. Your Internet browser automatically transmits some of this anonymous information or personal information to the Website, such as the URL of the website you just came from, the Internet Protocol (IP) address, the UDI (if applicable) and the browser version your device is currently using. Our Websites may also collect anonymous information or personal information from your device through cookies and Internet tags or web beacons. You may set your browser to notify you when a cookie is sent or to refuse cookies altogether, but certain features of a Website might not work without cookies and this may limit the services provided by a Website. Cookies and other technical methods may involve the transmission of information either directly to us or to another party authorised by us to collect information on our behalf.
3. Our Websites may use and combine such passively collected anonymous information or personal information and/or information from various third party sources, including as described above, and may combine this anonymous information or personal information with other personal information collected from you to provide better service to Website visitors and users, customise a Website based on your preferences, compile and analyse statistics and trends, provide you with relevant advertising when you visit a Website or a third party website, and otherwise administer and improve a Website for your use. We may combine your visitor session information or other information collected through tracking technologies with personally identifiable information from time to time in order to understand and measure your online experiences and to determine what products, promotions and services are likely to be of interest to you. By accessing a Website, you consent to information about you being collected, compiled and used in this way.

PLATFORM PERMISSIONS

1. Mobile platforms such as iOS and Android generally define certain types of information or data that applications cannot access without your consent. Each platform has its own permissions system for obtaining your consent. For example, the iOS platform generally alerts you the first time a Shopa Marketing app wants permission to access certain types of data, such as location services, and will let you choose whether or not to consent to that request. Android devices will generally notify you of the permissions that an app seeks before you first use the app, and your use of the app constitutes your consent. You can generally manage your platform level permissions via the Settings section on your device. For more information, please contact our Privacy Officer at the details set out in this policy.

PURPOSES FOR WHICH THE SHOPA MARKETING COLLECTS, HOLDS, USES AND DISCLOSES PERSONAL INFORMATION

1. Personal information collected will be used for the following primary purposes:
   1. For the purposes stated in a privacy collection statement on a particular Collection Channel.
   2. To maintain the functionality of a Website, including the provision of information to you relating to the content available on the Website and e-commerce transactions conducted via the Website.
   3. To send you any technical, administrative or legal notices important to our Websites.
   4. To allow you to create an account, sign in and use the functionality of a particular Collection Channel including Shopa Marketing Website.
   5. To allow you to respond to and participate in offers and competitions.
   6. To conduct competitions or promotions and communicate offers either for us or third parties.
   7. For internal record keeping including site usage and administration of our products and services.
   8. To facilitate payments to you via a Collection Channel.
   9. To provide you with information about your transactions, content, services and products.
   10. To provide direct marketing materials, events, offers, competitions, games and promotions in person and via any medium including mail, telephone and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email, push notifications) or any other form of electronic, emerging, digital or conventional communications channel.
   11. To provide you with relevant advertising when you use our Websites or those of a third party.
   12. To render services related to our company (such as after sales services and enquiries).
   13. To provide you with newsletters via mail and electronic newsletters (e-newsletters) via commercial electronic messages.
   14. To respond to customer enquiries, complaints and complaints handling.
   15. To improve Website and system administration.
   16. To obtain opinions or comments about products and/or services and to conduct other research and development.
   17. To verify your identity.
   18. To investigate complaints made by you or if we have reason to believe that you are in breach of our Terms or otherwise engaged in unlawful activity.
   19. To record statistical data for marketing analysis and to conduct market research.
   20. To share personal information with our group companies, our promotional partners, trusted brands using a particular Collection Channel and their related bodies corporate and agents, and other trusted third parties in the manner described below.
   21. Any other purpose as may be deemed reasonably necessary by Shopa Marketing in the circumstances.
2. For the purposes described above, personal information may be shared within Shopa Marketing of companies, Shopa Marketing promotional partners and their related bodies corporate, and other trusted third parties (and their directors, servants and agents) either in New Zealand or overseas. Failure to provide personal information may result in Shopa Marketing being unable to provide you with certain content, information, upcoming opportunity, promotion, offer, event or product information and/or accept content and promotion entries (where applicable).
3. In order to operate a Website or deliver a service (including for example, processing of credit card payments), personal information may also be shared with Shopa Marketing of companies, selected service providers and their related bodies corporate, and/or other trusted third parties either in New Zealand or overseas countries. Shopa Marketing of companies, selected service providers and/or other trusted third parties may be engaged by Shopa Marketing to perform a variety of functions, such as email systems providers, legal and accounting services, data storage, fulfilling orders, conducting market research, processing credit card payments, assisting with promotions or offers and providing technical services for our Websites. These companies may have access to personal information if needed to perform such functions.
4. We recognise the trust with which you provide personal information, and except as stated in this Privacy Policy or as is otherwise lawful, such information will not be used or disclosed for any other purposes without consent. However, Shopa Marketing reserves the right to use or disclose any information, including personal information, as needed to satisfy any law, regulation or legal request, to protect the rights or property of Shopa Marketing, any member of Shopa Marketing, or any member of the public, to protect the integrity of a Website, to fulfil your requests, or to cooperate in any law enforcement investigation or an investigation on a matter of public safety.

EMAIL OFFERS FROM THE SHOPA MARKETING

1. Shopa Marketing provides a service that delivers great offers direct to your inbox. Any promotional offers and direct marketing messages from us will be sent via the email address you have provided.
2. Opt-In – At the point you register with Shopa Marketing you subscribe to our mailing list. By subscribing to our mailing list you are opting-in to us using your personal information as set out in this Privacy Policy. You may also be asked to opt-in to receive further information or communications from our advertisers and partners.
3. Opt-Out – When you opt-out of our email services, your mailing subscription with the specific Shopa Marketing company will be cancelled and you will no longer receive marketing communications from that company.
4. Shopa Marketing is not responsible for any contact or communication that you may receive from third party providers who have received your personal information from Shopa Marketing during your registration.
5. If you receive communications purporting to be connected with us or our services that you believe have been sent to you other than in accordance with this Privacy Policy, or in breach of any law, please contact our Privacy Officer (contact details set out below).

CONTACT BY THE SHOPA MARKETING

1. Shopa Marketing (and their directors, servants and agents), promotional partners and clients and their related bodies corporate or trusted third parties and other selected service providers either in New Zealand or overseas, may contact you via telephone, SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email, post, push notification or any other form of electronic, emerging, digital or conventional communications channel using the information provided in order to contact you in respect of the primary purposes for collection of personal information as stated above.
2. Shopa Marketing does not send advertising or marketing information without obtaining prior consent, for example the consent contained within this Privacy Policy, or as is otherwise lawful. If you receive communications from Shopa Marketing which you do not wish to receive, you may unsubscribe or opt out, including by utilising the functional unsubscribe/opt-out facility (if the communication is via commercial electronic message) or by contacting Shopa Marketing at customerservice@shopamarketing.com.
3. Despite removing your name from the database from receiving future advertising and marketing information, Shopa Marketing may send you non-commercial “Administrative Emails”. Administrative Emails relate to a Shopa Marketing user account and may include administrative and transaction confirmations, requests and inquiries or information about a particular Shopa Marketing user account. If you do not wish to receive such communications from Shopa Marketing, you may remove your name from the database by utilising the functional unsubscribe facility.

ABILITY OF OTHERS TO VIEW INFORMATION

1. Shopa Marketing may provide areas on a Website where you can upload user-generated content, post or provide information about yourself, communicate with other users, utilise functionalities that allow you to post content to your own social media channels, or interact with particular content. This information may be shared with others and may be publicly posted on our Websites, including without limitation, other social media platforms and other public forums in which you choose to participate. This information may become publicly available and may be read, collected and used by others either on our Websites or outside of our Websites. Shopa Marketing is not responsible for the conduct of others who may read, collect and use this information.

YOUR RIGHT OF ACCESS

1. You have the right to access and review your personal information that may be recorded on Shopa Marketing databases. Information may be reviewed by contacting Shopa Marketing privacy officer at the contact details contained in this Privacy Policy. Please allow 20 working days for this request to be processed.
2. On a case by case basis Shopa Marketing may determine that it is not required to give an individual access to personal information to the extent that it is lawful for Shopa Marketing to do so. If such a determination is made then Shopa Marketing will provide you with a written notice.
3. Where you are seeking information held on electronic file, or where you are seeking hard copies of personal information, we reserve the right to charge reasonable handling/ postage fees as appropriate.

CHANGING AND DELETING THE INFORMATION WE HAVE ABOUT YOU

1. Information contained on the database may be amended, or your preferences for contact from us changed, by contacting Shopa Marketing’s privacy officer at the contact details contained in this Privacy Policy. Please allow 20 working days for this request to be processed.
2. In the same way, a request may be made to delete personal information, and all reasonable steps to delete the information will be made, except where it is required for legal reasons. Deletion of information may result in us being unable to facilitate or provide you with information about certain transactions (including the uploading, access to, and receipt of content on a Website, and purchase transactions undertaken on a Website), other content, services or product information, upcoming promotion, competition or event information, and/or provide certain content, goods or services.
3. We are not responsible for removing your personal information from the lists of any third party who has previously been provided your information in accordance with this policy.

SMS USAGE POLICY FOR COMMUNICATION AT SHOPA MARKETING

1. At Shopa Marketing, we are committed to safeguarding the privacy of our clients and prospects. Our employees exclusively employ SMS for communication purposes with prospects and clients and refrain from its utilization for marketing endeavors. This delineation is imperative for ensuring transparency and compliance with privacy regulations. We uphold stringent privacy standards to preserve the confidentiality of personal information, affirming our dedication to maintaining trust and integrity in all interactions.

STORAGE AND SECURITY OF PERSONAL INFORMATION

1. Shopa Marketing will endeavour to take all reasonable steps to keep secure any personal information recorded and to keep this information accurate, up to date, complete and relevant. We ensure only those necessary have access to your personal information. Personal information is stored on secure servers that are protected in controlled facilities. This service may be performed on our behalf and data may be hosted by our selected data storage providers. In some cases these facilities may be overseas.

DISCLOSURE OF PERSONAL INFORMATION TO OVERSEAS RECIPIENTS

1. In some cases, Shopa Marketing may disclose your personal information to overseas recipients. Shopa Marketing employees, data processors and other trusted third parties are obliged to respect the confidentiality of any personal information held by Shopa Marketing. However, security of communications over the Internet cannot be guaranteed, and therefore absolute assurance that information will be secure at all times cannot be given. Shopa Marketing will not be held responsible for events arising from unauthorised access to personal information.

THE SHOPA MARKETING AND LINKS TO OTHER WEBSITES

1. Our Websites may, from time to time, contain links to the websites of other organisations which may be of interest to you. Their inclusion cannot be taken to imply any endorsement or validation by us of the content of the third party website. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy statements. Shopa Marketing is not responsible, nor does it accept any liability, for the conduct of companies linked to our Websites.
2. We may use third party advertisements on our Websites. All third party advertising, if paid for, is paid for by the relevant third party advertisers and are not recommendations or endorsements by Shopa Marketing or any of its affiliates. Shopa Marketing is not responsible for the content (including representations) of any third party advertisement on a Website. Cookies may be associated with these advertisements to enable the advertiser to track the number of anonymous users responding to the campaign. We do not have access to or control of cookies placed by third parties.

RELATED SHOPA MARKETING WEBSITES

1. All Websites operated by Shopa Marketing will adhere to this Privacy Policy. The policies on the Websites of some members of Shopa Marketing may vary, however, because of local customs, practices or laws.

SALE OF THE COMPANY

1. If Shopa Marketing merges with, or is acquired by, another company, or sells all or a portion of its assets, your personal information may be disclosed to our advisers and any prospective purchaser’s adviser, and may be among the assets transferred. However, personal information will always remain subject to this Privacy Policy.

CONTACTING US

You may contact us via:

Address:	28 Church Street, Winchester Massachusetts
Telephone:	844 223 0051
Email:	        customerservice@shopamarketing.com.