We value your privacy!

Introduction

This privacy policy applies to Topline Roofing NZ Limited (“Topline”) NZBN 9429042098911 and any entity owned or controlled by Topline in operation in New Zealand.

At Topline, we are committed to protecting the privacy of the personal information we collect about any person and to ensuring our compliance with the New Zealand Privacy Act 2020 (the “Privacy Act”). This privacy statement describes why and how we collect and use personal data and provides information on individuals’ rights.

In-order to conduct normal business operations, Topline will collect personal information in-order to provide our products and services safely and effectively, to operate our business, to hire, train and manage our staff.

Notwithstanding the means of collection, processing, use, disclosure and retention periods for each purpose, this policy forms the overarching policy and guidelines of personal information collected.

When collecting and using personal data, our policy is to be transparent about why and how we process personal data.

Topline reserves the right to amend this privacy policy at any time. Amendments will be posted on our website and will be deemed effective once posted.

Exclusions

This policy relates to Topline’s collection and handling of personal information that is covered by the Privacy Act. It is not intended to cover categories of personal information that are not covered by the Privacy Act unless otherwise specified.

Nature of Information Collected:

Topline will collect, store and use personal information from customers, suppliers, contractors and other individuals. We collect and hold this information when it is necessary for business purposes.

Typically, this information includes, as appropriate:

• Personal contact details such as name, title, addresses, telephone numbers, and email addresses.
• Financial information.
• Credit and other reference check information.
• details of the products and services provided to you by us.
• Images and videos of you captured on our sites or locations by CCTV.
• Photographic proof of identity.
• Government related identifiers (i.e. IRD numbers).
• Other personal information you voluntarily provide to us.

Sensitive Information:

Topline may also collect, store, and use sensitive personal information such as:

• Information about membership of a trade union or professional association
• Health and Safety information (where we have to access your location/worksite and/or operate any equipment at your location/worksite.
• Other sensitive personal information you voluntarily provide to us.

We will only collect this type of personal information with your consent.

Collection of Personal Information:

Topline will collect most information directly from you unless it is unreasonable or impractical to do so, or unless expressly authorised by you, and by dealing with Topline you agree that we may collect, store, use and disclose your personal information for the purposes and in the manner outlined in this privacy policy. Information is collected via all forms of interaction you may have with us, surveys and forms completed by you, when you place an order for products and services, face to face meetings, email messages, telephone conversations or digital forms completed via our website.

If you choose not to provide personal information that we request, we may not be able to provide some or all of our products or services to you or be able to respond and assist in the manner required. We also may not be able to provide you with information about products and services that you may want or otherwise interact with you in the way we would otherwise have liked.

How Topline uses the Personal Information:

Topline will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• To perform our obligations under a contractual relationship with you; or
• To comply with a legal obligation; or
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, such as reviewing the quality of the products and services we provide to you.

Specifically, Topline may also use your personal information in the following situations:

• Where we need to protect your interests (or someone else’s interests),
• When providing our products and services to you,
• Where it is needed in the public interest or for official purposes, and as directed by current legislation,
• Where we are required to make investigative enquiries,
• When dealing with requests, enquiries or complaints and other customer care related activities,
• To assess our capability to provide our products and services,
• To review and improve our products, services, standards, and procedures,
• To determine performance requirements,
• For education, training, and development requirements,
• To comply with current health and safety obligations,
• For business management and planning, including audit purposes,
• In connection with monitoring, testing and maintenance of computer and other IT systems and networks,
• For general administrative and business purposes (including credit checks),
• For direct marketing including promotions, newsletters and competitions and to carry out analysis of market activity, market research and surveys,
• In connection with the change of ownership of any part of our business involving you as a customer, employee, supplier, contractor or franchisee (as the case may be). Your personal information may be transferred to the new owner so that the business can continue operations.
• For any other purpose which is stated to you at the time of collection or that you otherwise authorise.

Disclosure of Personal Information:

Topline will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you, or where we have another legitimate reason in doing so (including for any of those purposes outlined above). Some of your information may be shared with:

• Relevant members of our staff and contractors, who need to know this information in-order to provide our products and services. In this case, only directly relevant information will be shared with certain staff members as appropriate for them to fulfil their obligations to you and to Topline.
• Third parties who deliver our products and services to you (who may use and disclose your personal information for the same purposes as us), e.g. staff, contractors, payment service providers, marketing and promotion companies, training and training certification agencies, web analytics services, business support services, information technology service providers and system hosting services.
• Professional advisers, for example, law firms, as necessary to establish, exercise or defend our legal rights and obtain advice in connection with the running of our business. Personal data may be shared with these advisers as necessary in connection with the products and services they have been engaged to provide.
• Parties and agencies involved in data protection and/or crime prevention, detection, investigation and/or prosecution.
• Any other recipient which is notified to you at the time of collection or that you otherwise authorise.
• Other parties (including for example government agencies) in accordance with our legal obligations under relevant legislation.

We may also share non-personal, de-identified and aggregated information for research or promotional purposes. Except as set out in this policy, we do not sell to or trade personal information with third parties.

Retention of Personal information and Data:

All personal information collected by Topline will be stored securely either electronically and/or physically. We may use a variety of security techniques, including encryption and authentication, to help with protection of your personal information and to maintain the availability, security and integrity of your personal information.

All paper-based documents are held in secure filing systems at Topline’s Head Office as appropriate and are directly accessible only by a small number of key personnel who have the appropriate authorisation to access the documents.

Electronic storage of personal data is retained in secure, password protected and where necessary, encrypted software platforms and products. This is accessible by key personnel who require access explicitly for the purpose to perform their roles in relation to providing Topline’s services.

Topline retains personal information and data processed for as long as is required for the purpose for which it was collected, and in accordance with the current legislative requirements. In some instances, personal information may be held for longer periods where extended retention periods are required by law or regulation and as necessary in-order to defend our legal rights.

At the conclusion of the retention period, your personal information will be destroyed via the following methods:

• Paper based, via a confidential and secure destruction service,
• Electronically held data – will be deleted or anonymised as applicable and all third parties will be notified to do the same as appropriate.

Storage of information in cloud systems:

Topline may store personal information within services provided by offshore cloud service providers (CSP’s). Topline will make every endeavour to ensure that all CSP providers meet the Privacy Act requirements and all other New Zealand legislative requirements that Topline is obliged to adhere to.

Transfer of Information Outside of NZ:

Topline does not disclose your personal information to third party overseas recipients unless you have provided your consent. We will notify you if circumstances change regarding overseas disclosure and will comply with the Privacy Act.

Privacy on our Web Sites and Applications:

This policy also applies to any personal information we collect via our websites and any Topline applications, including mobile applications.

Direct marketing:

We may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications may be sent using various methods including mail, SMS, and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth) and the Unsolicited Electronic Messages Act 2007. You consent to us sending you those direct marketing communications by any of those methods. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us (see the details below) or by using opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list.

We do not provide your personal information to other organisations for the purposes of direct marketing.

Right to Access Personal Information:

Topline will provide access to personal information upon request by you (or your representative) once identity has been satisfactorily confirmed, except in limited circumstances in which it is permitted under the Privacy Act for us to withhold this information (for instance, any of those reasons specified in sections 49-53 of the Privacy Act).

If at any time you wish to enquire about the personal information we hold about you, you may contact Topline Privacy Officer at info@topline.co.nz.

Corrections and Concerns:

If we provide you access to personal information that we hold about you, then you may also,

• Request a correction of the personal information that we hold about you. This enables you (and assists us to ensure) that the personal information we hold about you is always accurate, current, complete and not misleading. If we inform you that we will not make the correction sought, then you have the right to make a complaint to the Office of the Privacy Commissioner in respect of that refusal.

• Provide us with a Statement of Correction for us to attach to the personal information we hold about you, if we do not correct the personal information you have requested us to.  

If you would like to exercise any of the above rights, please contact the Topline Privacy Officer at info@topline.co.nz.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.

Right to Complain

If Topline becomes aware of any ongoing concerns or problems concerning our privacy practices, we will take these issues seriously and work to address these concerns. If you have any further queries relating to our privacy policy, or you consider you have cause for complaint, please contact our Privacy Officer. If you are not satisfied with our handling of your concern, you may make a complaint to the Office of the Privacy Commissioner: https://privacy.org.nz/your-rights/making-a-complaint/

Privacy Breach

If we become aware of a privacy breach, we will take the following actions:

1)       Take all reasonable steps to immediately contain the breach, utilising contracted 3^rd parties specialising in privacy/data breaches and/or key personnel with the appropriate expertise (including for example our appointed Privacy Officer).

2)       Assess the seriousness, the cause, the extent, and the possible harm resulting from the breach.

3)       If we reasonably believe that the privacy breach has caused or is likely to cause serious harm to affected parties (after taking into account any mandatory considerations imposed by the Privacy Act), we will notify the affected parties, the Privacy Commissioner and any third party required for notification and/or follow up (for instance, Topline’s insurers, governmental agency(ies) and other agencies connected with data protection or crime detection, investigation, prevention or prosecution) as soon as practicable after becoming aware of that notifiable privacy breach (unless we are not required to do so pursuant to any permitted exception specified under the Privacy Act).

4)       Review our processes and update our policies and prevention plans, as necessary.

Contact us

Contact:                 Privacy Officer C/- Topline Group

Address:                P O Box 99-353, Newmarket, 1149

Email:                     info@topline.co.nz

Phone:                   0800 111 818