Wellbeing Connection Limited Privacy Notice

This privacy notice sets out how Wellbeing Connection Limited ("we", "us", "our") collect, use, and disclose information collected through use of our website, mobile applications, social media and other digital platforms (the "Platforms") and in any other interactions with you.

We may also collect, use and disclose information to the extent applicable law does not prohibit it.

What kind of Information do we collect?
Information we collect may include personal information about you. The personal information we collect may include your name, address, email address, telephone number, location, role, title, work history, information on your use of our services, and other information including as further described in this Privacy Notice.
Collection of Information:
The information collected by us may include personal information:
1. provided by you through registering an account on the Platforms and becoming a member. If you are a registrant on our Platforms and use our services and wellbeing resources, you will need to provide certain personal information in order to register your account, such as: name, email address, phone number, company, location, and your role or title. This information is required at registration so that we can:
  1. create your account; and
  2. ensure you receive appropriate surveys and/or questionnaires;
2. provided by you when submitting an online form, request for information, survey or application through the Platforms or otherwise submitting information to us through the Platforms or posting or uploading to the Platforms;
3. provided to us by you, or your employer or member organisation, through any other method (including, without limitation, meetings, correspondence and discussions);
4. relating to interactions and transactions you carry out on, or through, the Platforms;
5. as described elsewhere in this Privacy Notice; and
6. through tracking your use of the Platforms, including the content you access and any services you utilise and information collected through automated technology as further detailed below.
You may provide information to be published or displayed ("posted") on public areas of the Platforms, or transmitted to other users of the Platforms or third parties (collectively " Contributions"). If you use any discussion forum feature on the Platforms, be aware that any personally identifiable information you submit there can be viewed and used by other Platforms users. Your Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of those with whom you may choose to share your Contributions.
Automatic Data Collection Technologies:
As you navigate through and interact with the Platforms, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns. Some of this information may be linked to you personally. This information helps our Platforms function correctly, helps us understand the needs of our users and may be used for the other purposes set out in this privacy notice. Examples of this information include:
1. website related traffic data, location data, logs and other communication data;
2. data related to your use of the Platforms. This includes the pages you visit, the resources and services that you access; the time you spend on each page, the date and time of your visit, referring pages (pages you came from or go to) and statistical and other aggregated data derived from your use of the Platforms;
3. information about your device, computer and network connection, including your IP address, operating system, hardware version and browser type; and
4. if you allow our Platforms to deliver content based on your location (for example by enabling this feature on your mobile device) we may collect location data (such as through GPS, Bluetooth, or WiFi signals) including for the automated delivery of relevant content and advertising to you.
The technologies we use for this automatic data collection may include log files, usage monitoring software and cookies. Cookies are small pieces of information that are stored on a user's device that can identify the device you are working from. The cookie file gives us details such as your IP address, platform, browser and domain (whether you are accessing the Platforms from NZ or elsewhere). We may use the information generated by cookies to personalise your experience on the Platforms, make it easier for you to navigate our Platforms, and improve your experience by storing your search, posting and other viewing and usage history, and your login details (if you choose) enabling you to use certain services as a registered user without having to log on each time. We may also use cookies to provide you with certain advertisements which may be of interest to you. If you disable cookies it may limit your access to some of the Platforms' content and features. You can choose to refuse cookies by turning them off in your browser and/or deleting them from your hard drive. You do not need to have cookies turned on to use our Platforms, but your experience may be affected.
Other Tracking Technologies:
We may advertise in a number of ways, including online through managed social media presences, and on other unaffiliated sites and mobile applications. To understand how our advertising campaigns are performing, and better understand the visitors to our Platforms, we may collect certain information via our Platforms through our advertising service providers. We or our vendors use several common online tracking tools to collect information about our users, such as browser cookies, web beacons, and other similar technologies. The information we collect includes IP addresses, the number of page visits, pages viewed via our Platforms, search engine referrals, browsing activities over time and across other websites following your visit to one of our Platforms or applications, and responses to advertisements, campaigns and promotions on the websites and applications where we advertise.
We also store data locally on your device to enhance the user experience for our Platforms and services. For example, browser local storage allows us to save the state of your current page so that when you return at a later time or refresh the browser, the page will remain the same. We may also use browser local storage to:
1. save a list of items the user last used on the Platforms and/or services (such as events and properties the user selected) so we can display "recently viewed items"; or
2. marking once a user has seen a tutorial, video, tooltip or onboarding flow so that the user only sees the content one time.
We may also collect information from your mobile device, such as, but not exclusively, the first time the mobile application is opened, mobile carrier, the versions used, and the type of device that is being used, if you have downloaded our applications. This information is generally used to help us deliver the most relevant information to you and improve our services and Platforms. Examples of information that may be collected and used include how you use the Platforms and services and information about the type of device you use. In addition, in the event our mobile applications crash on your mobile device, we will receive information about your mobile model and OS version, which allows us to identify and fix bugs and otherwise improve the performance of our Platforms and services. We send you push notifications from time-to-time such as reminders for any support sessions. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from
Third Parties, Advertising and third party links:
We may allow third-party companies to place ads and collect information when you visit our Platforms. This may include information that will not identify you personally (such as click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) and other information such as precise geo location and user device identification. This information is collected to provide advertisements about goods and services likely to be of greater interest to you. The Platforms may also contain links to a variety of advertising and third party platforms and website sources. Some of these links may request or record information from users, use cookies or other methods to collect information from you. We have no control over the content or privacy notice practices of such sites. We encourage you to review the privacy policies of such sites before engaging in any activity with them.
Social Media and APIs:
Our Platforms include social media features such as the Facebook like button, twitter and widgets, the share button or interactive programs. These features may collect your IP address, which pages you visit on our Platforms, and how long for. If you're a member of a social media site, the interfaces may allow the social media site to connect your visits to the Platforms with other personal information. Social media features and widgets are either hosted by a third party or hosted directly on our Platforms. Your interactions with these features are governed by the privacy notice of the third party providing it and to the maximum extent permitted by law we accept no responsibility for the actions of those third parties.
1. We may provide an application programming interface (API) to enable third party applications to interface with our Platforms. Some applications enable you to interact with us through the API in a way that requires you to log in. To do this, most of these applications will direct you through a process where you are able to let the application connect to your account.
2. If you allow an application to connect to your account on our Platforms, including if you set up your account on our Platforms using an API with a third party social media platform, that application will be able to access information that you can see when you are logged into our Platforms. You should only allow applications you trust to access your account on our Platforms.
3. If you set up your account on our Platforms using an API with a third party social media platform, you also consent to us obtaining and using your information from such platform.
Information we collect from other sources:
We may also obtain information from other sources, such as list providers and publicly available sources, and combine that with information we collect through the Platforms and services. There may also be limited instances where we receive information about you from the content providers with whom you interact through the services, such as when there is an issue with a session, or if you have raised an issue or concern with the content provider and that content provider needs additional information from us.
Consequences for failure to provide:
You may decide not to provide your personal information to us. However, if you do not provide it, we may not be able to provide you with access to the Platforms or certain parts of the Platforms or you may not be able to fully utilise all of our products and services.
Personal information of a more sensitive nature:
There may be times, such as testing a new tool or feature, or staffing a specific program for customers, where we will seek your authorisation to collect demographic information such as gender, race or ethnicity, or pronouns. In all such instances your involvement and providing such information is voluntary, and will have no impact on your ability to use our tools and resources if you decline. In the case you provide us with authorisation, such authorisation may be withdrawn at any time. At the time of requesting your authorisation, we will provide you details of how the personal information will be used or processed and how to withdraw your authorisation.
Prospective Wellbeing Connection employees:
We collect information if you apply for a job with us or otherwise communicate with us. We will need to collect certain personal information from you in order to process your application, such as your name, email address, phone number, IRD number, location, and work history. This information is used to evaluate your experience and communicate with you.
Use of information:
Your personal information may be used by us (and our employees, officers, agents, contractors and affiliates) for any purpose which is stated to you at the time of collection or that you otherwise authorise and for the following purposes:
1. to provide you with the goods, services, payments processing and/or information you have requested;
2. verification of your identity for use of the Platforms, to obtain authorisation for you to use the Platforms (e,g. from your employer) and to assist you if you forget your username or password for the Platforms;
3. to assess and improve the quality of our services;
4. to assist in providing better services to you by tailoring them to meet your needs;
5. to provide you with further information about us or other platforms or goods or services offered by us or our related companies or third parties or which we consider may be of interest to you;
6. to carry out marketing, promotional and publicity purposes including direct marketing, market research, analysis and surveys;
7. to respond to comments, questions and requests;
8. to send you technical notices and other administrative messages;
9. to keep the Platforms relevant and of interest to users;
10. to customise and personalise the Platforms to your preferences and to show you advertising and information that is most relevant to you and your interests based on the information you have provided to us or we have otherwise collected;
11. to contact you via electronic message (including email, text and other electronic messages) regarding purchases or orders you have made on the Platforms or other potential purchases on the Platforms we think you may be interested in;
12. communicate with you about products, services, offers, promotions, rewards, and events offered by us or others, and provide news and information we think will be of interest to you;
13. to assist us in performing our functions and activities;
14. to communicate and manage our relationships with stakeholders;
15. analysis in aggregate form (identifiable characteristics removed so that you will remain anonymous);
16. to communicate with you; and
17. to comply with our legal obligations.
Through your use of the Platforms and/or services, you will also provide us information to facilitate your experience. For example, to help you choose the right support, you will respond to surveys to help us match you with content providers that align with your goals. While these surveys will help us match you with the right content provider, the surveys do not collect any personally identifying information. We may collect information such as your Platform usage, development programs planned and attended, engagement status, session ratings, title, employment details, and any other information you choose to provide in conjunction with the services. You may also be asked, at various places within the Platforms, to provide your opinions on our services and quality of support. These opinions or reviews will be used to improve our services, and in some cases, may be shared with content providers on a de-identified basis, for quality and/or educational purposes.
Information Sharing and Disclosure: We may disclose your personal information:
1. within the organisation for the purposes set out in section 11 above;
2. to third parties in accordance with the uses set out above;
3. if you have requested or authorised us to do so, including if we notify you through the Platforms that certain information you provide will be shared in a particular manner and you provide this information;
4. to our content providers, vendors, consultants, contractors, suppliers, partners and other third parties to enable them to provide services and products to us and you, including in relation to the Platforms;
5. to your organisation, colleagues and representatives. If you are a user who is accessing the Platforms and/or services through a paid subscription through your employer, we will share information with the employer or other entity who has sponsored your use of the Platforms and/or services, such as the programme(s) you select and how you used the Platforms and/or services (such as the number of sessions you attended, when the session was attended, or completion of an assessment). We will not share your personal information you share with our content providers. Information we do share with your employer, or other entity who has sponsored your use, is provided in an aggregated and de-identified form;
6. by sharing aggregated demographic information about our user base with our affiliates, partners and advertisers;
7. when we believe it is appropriate to comply with the law, facilitate court proceedings or to protect our rights;
8. when we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property, and safety of you, us, or others;
9. in connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company; and
10. where we are authorised or required to do so by law, regulation or legal process.
Data Access and Correction:
Under the Privacy Act 2020, you have rights of access to and correction of personal information that we hold. This can be done by contacting us by email at renuka.patel@saneminvestments.com or by mail to 15A Firle Place, Green Bay, Auckland, 0604, New Zealand.
Competitions:
We will collect personal information provided by you if you participate in our promotions and competitions. We collect this information in order to conduct the promotion or competition. We may disclose such information to third parties, such as agents, contractors, service providers and prize suppliers to conduct the promotion or competition. We may also use and disclose this information as set out in this privacy notice. Entry is conditional on providing this information. If the information is not fully supplied the entry may be void.
If you provide us with the names and contact details of any other people that you would like to have participate in our contests or promotions, we will also collect this information. You promise that you have their permission to provide us with this information and for us to use it for this purpose.
Promotional communications:
You may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at renuka.patel@saneminvestments.com. If you opt out, we may still send you non-promotional communications, such as messages about your account or our ongoing business relations.
Commercial electronic messages:
If you provide us with electronic contact details, you agree that we may send you commercial electronic messages (e.g. texts and emails) for any of the purposes set out in this privacy notice.
Changes in privacy notice:
We reserve the right to make changes to our privacy notice or alter our Platforms functionality. Any changes made will be updated in this privacy notice accordingly, so we encourage you to review the policy for the latest information on our privacy practices.

Contact Details:

If you have any questions about our privacy notice, or any other matter, please feel free to contact us by email at renuka.patel@saneminvestments.com.

This privacy notice was last updated on 27/01/2022