Privacy policy

Last updated: 17 February 2021

Who

In this Privacy Policy:

"you" means you, a customer and/or user of the Warehouse Mobile services and website.

"we", "our", "us" means Two Degrees Mobile Limited, as provider of the Warehouse Mobile services, and The Warehouse Limited.

Purpose

To deliver the highest standard of service, we will ask you to provide us with personal information from time to time.  We believe it is important that you know how we treat that information.

This policy outlines how and why we collect information from you, how we store it, how you can access and correct that information and when we might disclose information to other people.

This privacy policy also confirms our obligations under the Privacy Act 2020 and the Telecommunications Information Privacy Code 2003.

For more information about how your personal information is protected under the Privacy Act 2020 and the Telecommunications Information Privacy Code 2003 visit www.privacy.org.nz.

Collection

We will collect information about you when you complete application forms, enter promotions or competitions, and sign up for MyWarehouseMobile (for instance, your name, address, contact number(s), email address, etc).

We will also collect information that you provide us when you buy and use Warehouse Mobile products and services (such as call and text message information, including date, time, some content, duration, and the number contacted). We may also look at where your mobile device is from time to time, how much you're spending and how you browse our internet site.

Other entities, like marketing organisations and credit reference agencies, may also provide us with information about you from time to time.

If you choose not to provide information when we ask for it, certain services and/or product features may not work properly or we may not be able to provide you with service or a product altogether.

Use

We hold and use the information we collect for a number of purposes, including:

  • Processing application forms and any online transactions you make;
  • Billing you;
  • Providing and assisting you with products or services you request;
  • Monitoring compliance with the terms and conditions of Warehouse Mobile services and products you purchase and use;
  • Offering you rewards, special offers, competitions and other promotions; 
  • Responding and following up on any queries, complaints or requests you might have made, and other customer care issues;
  • Complying with legal, governmental or regulatory agencies' requests in connection with the regulation of telecommunications services, and in connection with any legal proceedings, crime or fraud prevention or detection, or prosecution;
  • Training our staff, monitoring our network and services, and maintaining our systems;
  • Providing handset location information to emergency services including Fire, Police and Ambulance when you dial 111.

You agree that we and our agents may send you marketing messages, electronic or otherwise, about (amongst other things) our rewards, special offers, competitions and other promotions, and those of our agents or third parties which we consider may be of interest to you. You may unsubscribe from receiving marketing messages from us and our agents at any time through Your Warehouse Mobile.

Disclosure

Sometimes we may disclose your information to third parties (some of whom may be located outside of New Zealand). These third parties may include:

  • Dealers and suppliers whose products and services support our services, or the Network, including the providers of infrastructure where your information is processed, and providers involved with monitoring and protecting the operation and security of the Network;
  • Our dealers and agents, contractors and advisers;
  • Other network operators as required to provide and/or support the products and services we provide to you;
  • Credit reference agencies (if you have agreed) who may share your information with other organisations and who may keep a record of the searches we make against your name;
  • If someone else pays your bill, that person;
  • Our advertisers, customers, potential customers and associates with whom we may share aggregated information such as user statistics and other information that does not personally identify you;
  • Persons we are legally obliged to provide your information to,  including law enforcement agencies (such as the police, or the Serious Fraud Office), emergency services, government departments and regulatory authorities, as well as any person or organisation authorised to obtain your information in accordance with the Privacy Act 2020 and/or the Telecommunication Information Privacy Code 2003;
  • Any of our potential or actual assignees or transferees, such as a potential purchaser of our businesses.

Mobile Caller Emergency Location Service

When our customers (and overseas visitors roaming on our network) make an emergency 111 call from their mobile phone, data that could help determine the location of their phone may be sent to the Ministry of Business, Innovation and Employment's (MBIE) emergency Location Area Service system. This system is an additional location verification tool and callers will still need to try their best to provide their address or accurate location.

This service is called the Mobile Caller Emergency Location Service. The service provides a way to collect information identifying which of our cell sites a customer is using to make an emergency 111 call. All 111 calls originating on our mobile network automatically generate information identifying our relevant cell site.

Location information is sent from our network to MBIE's Location Area Service system which then provides information about your phone's likely location to Authorised Emergency Service Providers (New Zealand Police, New Zealand Fire Service, St John and Wellington Free Ambulance). Authorised Emergency Service Providers are allowed to use this location information to help them verify where you are calling from, to assist them to respond to the emergency.

Most recent Android phones have a feature called Android Emergency Location (AEL) which provides high precision location data. AEL information is automatically sent from the caller's phone to MBIE's Location Area Service system when a caller makes an emergency call using an Android phone.

Emergency Caller Location Information (ECLI) is personal information indicating the approximate geographical position of a mobile phone derived from this service. ECLI is stored on our secure systems based in New Zealand. We will only use ECLI for the purpose of helping Authorised Emergency Services Providers identify the location of callers to 111. We may retain ECLI information together with a record of its delivery to MBIE's Location Area Service system for operational purposes for up to six months.

The provision of ECLI is authorised in an Amendment to the Telecommunications Information Privacy Code 2003. You can access and correct ECLI that we hold about you, or if you have a complaint regarding ECLI, by contacting us in writing. If the ECLI held by us is inaccurate or incomplete you may ask us to correct the information.

We are pleased to be working with MBIE to provide this important and potentially lifesaving service to our customers. You can find further information on this service on MBIE's website: http://www.mbie.govt.nz/info-services/sectors-industries/technology-communications/communications/emergency-call-services/ecli

Monitoring

To maintain and improve the services we provide to you, we may monitor and record calls you make to us or we make you.

Caller Identification

Unless you request our caller line identification restriction service (CLIR) your mobile phone number may be displayed to the person you have called.  Where you have requested CLIR, we will prevent your mobile phone number being shown to the recipient of your calls. Your mobile phone number may however still be displayed to us, the emergency services, or when you send a text message. 

Analytics

Like many websites, we use web analytics services, like Google Analytics for example. These services use "cookies", which are text files placed on your computer, to help us analyse how you use our site. The information generated by the cookie about your use of our website (including your IP address) will be transmitted to and stored on servers belonging to the companies providing the analytic services. These companies will use this information to evaluate your use of our website, and to compile reports for us on the site's activity (for example, number of visitors to our site, how long they spend on the site when they visit and their geographical location).  They may also transfer this information to their agents or where required to do so by law. The companies providing the web analytic services will not associate your IP address with any other data they hold. You may refuse the use of cookies by selecting the appropriate settings on your browser. By using our website, you consent to the processing of data about you as set out above.

Access and Correction

You can access personal information that we hold about you by contacting us in writing. If the information held by us is inaccurate, incomplete or not up to date you may ask us to correct the information. 

If you consent to receiving emails or other communications from us, but later change your mind, just let us know and we will take you off our list. Get in touch via our 'Contact Us' web page.

Change in Policy

We may need to amend the terms of this Policy if our practices change. If we do so, we will post the updated version on our website

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