Ditto Plus Workflow Limited NZCN 8330786, trading as DittoFlow (we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our workflow automation platform (Platform) to you. 

This Privacy Policy takes into account the requirements of privacy laws, codes and regulations in New Zealand, including the Privacy Act 2020 (Privacy Laws).

In addition to the Privacy Laws, individuals located in the European Union (EU) may also have rights under the General Data Protection Regulation 2016/679 and individuals located in the United Kingdom (UK) may have rights under the General Data Protection Regulation (EU) 2016/679) (UK GDPR) and the Data Protection Act 2018 (DPA 2018) (together, the GDPR). Appendix 1 outlines the details of the additional rights of individuals located in the EU and UK as well as information on how we process the personal information of individuals located in the EU and UK.

This Privacy Policy explains:

• the types of personal information we may collect about you;
• how we might collect your personal information;
• how we may use and disclose your personal information;
• how we will store your personal information;
• our use of cookies and analytics tools in connection with our Platform;
• your rights to request access to and correction of your personal information; and
• how you can contact us if you have any other questions regarding our collection, use, storage and disclosure of your personal information.

Personal information

Personal information means identifiable information about you, for example your name, email, address, telephone number and so on. If you cannot be identified (for example, when personal information has been aggregated and anonymised) then certain parts of this policy may not apply to that information.

The personal information we collect

The types of personal information we may collect about you include:

• Identity Data including first name, last name and title. 
• Contact Data including billing address, email address and telephone numbers.
• Financial Data including bank account and payment card details (including through our third party payment processor).
• Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.
• Technical and Usage Data including internet protocol (IP) address, your login data, your browser session and geo-location data, your location information (for example your GPS location), device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour, information about your access and use of our website, including through the use of Internet cookies, your communications with our website, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider.
• Account Data including your username and password for our Platform, support requests you have made, content you send, receive and share through our Platform, your interests, preferences, feedback and survey responses, additional personal information that you provide to us, directly or indirectly, through your use of our Platform, associated applications or accounts from which you permit us to collect information.  
• Interaction Data including information you provide to us when you participate in any interactive features of our Platform, including surveys, contests, promotions, activities or events.  
• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
• Professional data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience. 
• Requested data: including any other personal information requested by us and/or provided by you or a third party.

How we collect personal information

We collect personal information in a variety of ways, including:

• Directly: We collect personal information which you directly provide to us, including when you register for an account, through the ‘contact us’ form on our website or when you request our assistance via email, our online chat or over the telephone.
• Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries.
• From third parties: We collect personal information from third parties, such as details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.
• From publicly available sources: We collect personal information from publicly available sources such as the New Zealand Companies Office and professional networking sites such as LinkedIn.

Collection and use of personal information

Personal information: We may collect, hold, use and disclose personal information for the following purposes:

• to enable you to access and use our Platform, including to provide you with a login; 
• to assess whether to take you on as a new client, including to perform anti-money laundering, anti-terrorism, sanction screening, fraud and other background checks on you;
• to enable you to access and use our associated applications;
• to contact and communicate with you about our Platform and any enquiries you make via our website;
• for internal record keeping, administrative, invoicing and billing purposes;
• for analytics, market research and business development, including to operate and improve our Platform, associated applications;
• to detect and/or prevent any illegal activity that may threaten us or our Platform;
• for advertising and marketing, including to send you promotional information about our Platform and information that we consider may be of interest to you, noting we will comply with all laws that are relevant to marketing (including the Unsolicited Electronic Messages Act 2007 and Fair Trading Act 1986);
• to comply with our legal obligations and resolve any disputes that we may have; 
• if you have applied for employment with us; to consider your employment application; and
• if otherwise required or authorised by law.

Disclosure of personal information to third parties

We may disclose personal information to:

• third party service providers for the purpose of enabling them to provide their services, to us, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, couriers, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
• our employees, contractors and/or related entities;
• our existing or potential agents or business partners;
• anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
• courts, tribunals and regulatory authorities, in the event you fail to pay for the Platform we have provided to you;
• courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; 
• third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Facebook Pixel or other relevant analytics businesses; and
• any other third parties as required or permitted by law, such as where we receive a subpoena.

Google Analytics: We may have enabled Google Analytics Advertising Features including Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Store Visits, Google Display Network Impression reporting etc. We and third-party vendors may use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together. 

You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here.  To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device. 

Overseas disclosure:Where we disclose your personal information to third parties listed above, these third parties may store, transfer or access personal information outside of New Zealand which may not have an equivalent level of data protection laws as those in New Zealand. Before disclosing any personal information to an overseas recipient, we will comply with Information Privacy Principle 12 and only disclose the information if: 

• you have authorised the disclosure after we expressly informed you that the overseas recipient may not be required to protect the personal information in a way that, overall, provides comparable safeguards to those in the Privacy Act 2020; 
• we believe the overseas recipient is subject to the Privacy Act 2020; 
• we believe that the overseas recipient is subject to privacy laws that, overall, provide comparable safeguards to those in the Privacy Act 2020; 
• we believe that the overseas recipient is a participant in a prescribed binding scheme; 
• we believe that the overseas recipient is subject to privacy laws in a prescribed country; or 
• we otherwise believe that the overseas recipient is required to protect your personal information in a way that, overall, provides comparable safeguards to those in the Privacy Act 2020 (for example pursuant to a data transfer agreement entered into between us and the overseas recipient).

Where the disclosure of your personal information is solely subject to the Privacy Laws, you acknowledge that some third parties may not be regulated by the Privacy Laws and if any such third party engages in any act or practice that contravenes the Privacy Laws, it would not be accountable under the Privacy Laws and you will not be able to seek redress under the Privacy Laws. 

Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Platform to you and your use of our Platform.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us. 

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. You also have the right to contact the Office of the New Zealand Privacy Commissioner.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is stored by us or transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. 

Cookies

We may use cookies on our website or Platform from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our website or Platform and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our website or Platform with personal information, this information may be linked to the data stored in the cookie.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website or Platform. They include, for example, cookies that enable you to log into secure areas of our website or Platform, use a shopping cart or make use of e-billing Platform.
• Analytical/performance cookies. These are cookies that allow us to recognise and count the number of visitors to our website or Platform and to see how visitors move around our website or Platform when they are using them. This helps us to improve the way our website or Platform work, for example, by ensuring that users find what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website or Platform. These cookies enable us to personalise our content for you and remember your preferences (for example, your choice of language or region).

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website or Platform.

Links to other websites

Our Platform may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

If you are in New Zealand, we may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

If you are in the EU, we may, at any time and at our discretion, vary this Privacy Policy. We will notify you if we amend this Privacy Policy, by contacting you through the contact details you have provided to us. Any amended Privacy Policy is effective once we notify you of the change.

 

For any questions or notices, please contact our Privacy Officer at:

Ditto Plus Workflow Limited, trading as DittoFlow NZCN 8330786

Address: 96 St Georges Bay Road, Parnell, Auckland 1052, New Zealand

Email: info@dittosoftware.com 

Last update: 12 July 2023

APPENDIX 1 – ADDITIONAL RIGHTS FOR INDIVIDUALS LOCATED IN THE EU OR UK 

 

Under the GDPR individuals located in the EU and the UK have extra rights which apply to their personal information. Personal information under the GDPR is often referred to as personal data and is defined as information relating to an identified or identifiable natural person (individual). This Appendix 1 sets out the additional rights we give to individuals located in the EU and UK, as well as information on how we process the personal information of individuals located in the EU and UK. Please read the Privacy Policy above and this Appendix carefully and contact us at the details at the end of the Privacy Policy if you have any questions.

What personal information is relevant? 

This Appendix applies to the personal information set out in the Privacy Policy above. This includes any Sensitive Information also listed in the Privacy Policy above which is known as ‘special categories of data’ under the GDPR.

Purposes and legal bases for processing

We collect and process personal information about you only where we have legal bases for doing so under applicable laws. We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please reach out to us if you need further details about the specific legal ground, we are relying on to process your personal information where more than one ground has been set out in the table below.  

 

If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using our Platform. Further information about your rights is available below.

Data Transfers 

The countries to which we send data for the purposes listed above may be less comprehensive that is what is offered in the country in which you initially provided the information. Where we transfer your personal information outside of the country where you are based, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred personal information in accordance with this Privacy Policy and Appendix 1. This includes:

• only transferring your personal information to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal information; or
• including standard contractual clauses in our agreements with third parties that are overseas.

Extra rights for EU and UK individuals

You may request details of the personal information that we hold about you and how we are process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal information rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to you or another organisation. 

If you are not happy with how we are processing your personal information, you have the right to make a complaint at any time to the relevant Data Protection Authority based on where you live. We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Authority, so please contact us in the first instance using the details set out above in our Privacy Policy.