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Our Privacy Policy
1. When did we last update this Privacy Policy?
January 2022
2. About this Privacy Policy
2.1. BAT (New Zealand) Limited (BATNZ, we, our, or us) respects your privacy. We are committed to safeguarding the privacy of our customers including, but not limited to those:
2.3. Please read this Privacy Policy carefully as it informs you of our privacy practices, including the way your information is collected, how that information is used and how we share, store and protect that information.
2.4. You agree to the collection, use and disclosure of your personal information under this Privacy Policy when you:
4.1. We may collect any personal information that you provide to us or authorise us to collect. This may include:
4.3. There may be times when you provide us with personal information about another person, for example, in connection with promotional events. If you do so, you confirm that:
January 2022
2. About this Privacy Policy
2.1. BAT (New Zealand) Limited (BATNZ, we, our, or us) respects your privacy. We are committed to safeguarding the privacy of our customers including, but not limited to those:
(a) using any of our websites (including batnz.co.nz; vuse.co.nz; vuse.com.au, vusionry.co.nz. batorders.co.nz) as well as any applicable redirected websites(collectively our websites);
(b) visiting our specialist vape retail store (at 270 Broadway, Newmarket, Auckland); and
(c) visiting our various offices throughout New Zealand.
2.2. In this Privacy Policy, including any future updates, (Privacy Policy) our customers (including visitors to our websites and physical premises) are referred to as you. 2.3. Please read this Privacy Policy carefully as it informs you of our privacy practices, including the way your information is collected, how that information is used and how we share, store and protect that information.
2.4. You agree to the collection, use and disclosure of your personal information under this Privacy Policy when you:
(a) visit one of our websites;
(b) visit our speciality vape retail store;
(c) visit one of our various offices;
(d) access and use of our Wi-Fi;
(e) contact us by any means (including by calling our customer response centre or speaking to our customer service representatives in-store); or
(f) authorise us to collect your personal information in any other way, such as at promotional events.
2.5. This Privacy Policy applies to and does not restrict, our rights and obligations under applicable laws, including New Zealand’s Privacy Act 2020 as amended or replaced from time to time (Privacy Act).
3. How can you contact us?
If you have any questions about this Privacy Policy, you can write to us at:
Privacy Officer, BAT (New Zealand) Limited, P.O. Box 2618, Auckland 1010, New Zealand.
4. What personal information do we collect?4.1. We may collect any personal information that you provide to us or authorise us to collect. This may include:
(a) your name, date of birth and contact details (including home address, phone number and email address);
(b) details of transactions you carry out or orders you place through one of our websites and information that you submit online via our websites;
(c) details of your visits to our websites and the resources that you access (which may include, amongst other things, traffic data and communication data);
(d) details of transactions you carry out or orders you place through our speciality vape retail store and information that you submit whilst shopping at our speciality vape retail store;
(e) details that you provide to our customer response centre or our customer service representatives in our speciality vape retail store;
(f) details about other people that you provide to us with their consent (see section 4.3); or
(g) any other personal information that you authorise us to collect, for example, if you authorise us to collect your photo at a promotional event; or
(h) if you are ordering from Australia, details on your valid Australian prescription for the purchase of nicotine products under the Therapeutic Goods Administration’s personal importation scheme.
4.2. We will usually collect your personal information directly from you unless it is not reasonable or practical to do so. We may collect personal information about you from another person if we have, or they confirm that they have your consent.4.3. There may be times when you provide us with personal information about another person, for example, in connection with promotional events. If you do so, you confirm that:
(a) they are over eighteen years old;
(b) you have their authorisation to:
(i) provide their personal information to us; and
(ii) allow us to collect and use their information under this Privacy Policy.
(c) you have or will inform them of their rights to access and request correction of their personal information as set out in this Privacy Policy.
4.4. We will not intentionally collect any information about anyone who is under eighteen years of age. If we become aware that anyone who is under eighteen years of age has provided us with any information, that information will immediately be deleted from our records.
4.5. When you use one of our websites, we may also collect information about you and your use of our websites using automatic data collection tools. These tools collect certain standard information about your access and computer, such as your browser type, operating system and language, access times and your Internet Protocol (IP) address. We use the information for statistical reporting and analytics and do not link it to any named individuals.
4.6. You do not have to provide us with any personal information that we request. However, if you do not do so, it may affect our ability to provide you with products or services or further information you have requested.
Payment information
4.7. We use WorldPay and Zip to process payments you make using one of our websites or in our speciality vape retail store. WorldPay and Zip operate a secure server to process your payment details. WorldPay and Zip encrypt your credit, debit card or PayPal account information and authorises payment directly. Any payment transactions will be stored on WorldPay or Zip's hosting services.
4.8. This means that your credit card, debit card, or PayPal account details are never revealed to us.
4.9. To see what security measures WorldPay and Zip have in place and how they treat your information, please read the:
(a) WorldPay privacy policy available at www.worldpay.com/uk/privacy-policy;
(b) Zip privacy policy available at www.zip.co/page/privacy.
Cookies
4.10. Like many online services, we use a feature called a 'cookie', which is a small data file that is sent to your browser from a web server and stored on your device's hard drive. We also use a feature called a ‘pixel’ , which is code that we place on our websites to collect data about ‘pixel events’. ‘Pixel events’ are actions that happen on our websites, such as adding items to your cart or signing up for our newsletter. References in this Privacy Policy to ‘cookies’ also include other means of automatically accessing or storing information on your device.
4.11. Cookies enable us to provide you with a better experience by enabling our websites to recognise that you have visited before and in some cases to record preferences to personalise your visit. Cookies also assist us to analyse the profile of our visitors and how you use our websites.
4.12. Sometimes we partner with third parties (such as advertising and social media partners) who may place a cookie (or cause a pixel event to trigger) on your device when you visit our websites to remember that you have visited our websites. This means that when you later visit another website, the advertisements displayed to you may be advertisements for our websites or products or about other products and services that are tailored to your apparent interests. If you click on one of our advertisements, it will redirect you back to one of our websites. Our third-party partners may provide us with information about the total number of views, shares, and click-throughs these advertisements have received. However, they will not collect or provide to us or any other third party any information that identifies you.
4.13. To delete or stop cookies being placed (or pixel events triggering) on your computer, refer to the help menu on your internet browser. In some cases, blocking cookies and pixels may reduce the functionality of our websites or otherwise prevent access to them depending on your chosen browser options. For further information visit www.aboutcookies.org.
5. What do we do with your personal information?
Use of your personal information
5.1. We (and the third parties described in section 6) may use your personal information:
(a) to provide you with information, products and services that you request;
(b) to respond to your queries (including when you contact our customer care centre or speak with one of our customer service representatives in our speciality vape retail store);
(c) to, if required, verify your age and identity (see sections 5.7 to 5.11);
(d) to facilitate our internal business operations (including for training and for developing, maintaining and testing our IT systems and infrastructure);
(e) to ensure that our websites’ content is presented as effectively as possible for you;
(f) for our internal purposes, such as quality control, website performance, system administration and to evaluate the use of our websites, so that we can provide you with enhanced services;
(g) to notify you about changes to our websites or our services;
(h) to provide you with information about products or services that we think may interest you (see section 5.4 and 5.5);
(i) to create reports to assist with future marketing, including sharing your information with third-party agents, representatives, business partners, sub-contractors, suppliers, or other organisations to assist with marketing or responding to your requests;
(j) to carry out our obligations arising from any contracts with you, including providing you with the products you have ordered and for billing and delivery purposes;
(k) to enable you to participate in the features of our websites, when you choose to do so; or
(l) for any other purpose that you authorise or that is permitted by applicable law, including the Privacy Act.
Use of statistical and aggregated information
5.2. We may monitor your use of our websites and record your email address and/or IP address, operating system and browser type, for system administration and to report aggregate information. This is statistical information about our users’ browsing actions and patterns and does not identify any individual.
5.3. We may collect non-personal aggregated statistics data about visitors to our websites and, if applicable, sales and traffic patterns. Just to be clear, this information does not identify users in any personal capacity and we do not use this information to build profiles on individual users; it just contains generalised information about the users of our websites.
Marketing
5.4. Unless you have ‘opted-out’ and indicated that you do not want to hear from us if you provide us with your contact details, we may contact you by electronic means (including email or text message) and by telephone and post, with information about products and services that we think may be of interest to you. Please indicate with the relevant boxes when you create an account, or during the order process when we collect your information, if you do not want to receive such direct marketing communications. We may also pass your information to other organisations who may contact you to provide marketing information about their products and services by electronic means (including email or text message) and by telephone and post.
5.5. You may ask us at any time not to use your information for direct marketing purposes by contacting us using the details set out under the “How to contact us” heading below or by following the unsubscribe instructions contained in each electronic marketing communication.
5.6. We may also use statistical and aggregated information, as well as Cookies, for marketing purposes. Please refer to the information above, including details on how to delete or stop cookies being placed on your computer.
Verifying your age
5.7. If you use any of our websites or visit our speciality vape retail store, you will be asked to confirm that you are 18 years or over and we may keep a record of that confirmation.
5.8. We may take additional steps to verify that you are aged 18 years or over before we supply any products to you. To enable us to do this we will require certain information about you. This information will then be passed to our identity verification service provider who will check it against public sources of information to deliver confirmation of your identity and age. To verify your identity, we may also require you to provide:
(a) demographic information (such as gender and birth date); and
(b) personally identifiable information (such as your passport number or driving licence number) which may be used by our identity verification service provider to verify your details.
This information is checked against secure independent data sources to help verify identity.
5.9. In some cases, we may need to ask for further information to verify your age. If this is necessary, we will contact you to explain why.
5.10. Failing age verification will mean you cannot complete a purchase.
5.11. All information we collect from you for verifying your age will be used, held and disclosed by us under this Privacy Policy.
6. Who do we share your information with?
6.1. We may share your personal information in the following ways:
(a) From time to time your personal information may be transferred to
(i) other BAT entities worldwide; or
(ii) third party agents, representatives, business partners, sub-contractors or suppliers, to provide us with services, such as system maintenance and support, marketing, storage services, customer response centre services and to assist us to respond to your requests (including, if required, to verify your age and identity).
(b) We may also disclose your personal information to other BAT entities worldwide for any of the purposes set out in section 4above.
(c) We may also be required to disclose your personal information to
(i) respond to duly authorised information requests from the police and governmental authorities;
(ii) comply with any law, regulation, subpoena or court order;
(iii) help prevent fraud or to enforce or protect the rights and properties of BAT or its subsidiaries; or
(iv) protect the personal safety of BAT employees, third party agents or members of the public.
6.2. We may also disclose your personal information to enforce or apply our terms or any other agreements we have with you or to protect our rights, property or our customers. This may involve exchanging information with other companies and organisations for fraud protection and credit risk reduction.
6.3. Circumstances may arise where, whether for strategic or other business reasons, BAT decides to sell, buy, merge or otherwise reorganise businesses or our assets in some countries. Such a transaction may involve the disclosure of your personal information to prospective or actual purchasers, or the receipt of it from prospective or actual sellers. It is BAT’s practice to seek appropriate protection for personal information in these types of transactions.
6.4. We may pass your information to other organisations who may contact you to provide marketing information about their products and services by electronic means (including email or text message) and by telephone and post (see section 5).
6.5. We may share the non-personal aggregated statistics data about visitors to our websites with third parties.
6.6. The disclosure of your personal information, in accordance with this section, may involve the transfer of your personal information outside New Zealand (which may include countries that do not have developed data protection laws). For example, disclosure may take place in countries in which BAT group has business operations including those countries listed on our global website at www.bat.com/countries, in addition to India and the United States of America. From time to time we may need to disclose your personal information to parties in countries other than these. This will be on an ad hoc or case by case basis and for the purposes described in this Privacy Policy.
6.7. Any third party, agent or representative of BAT who imports personal information in the course of providing services to BAT is required to keep that information confidential and comply with national data protection laws or, where applicable, to be bound by appropriate contractual obligations that protect your personal information, to ensure that your personal information continues to be protected by security safeguards that are comparable to the safeguards that are required under the Privacy Act.
7. How do we manage the accuracy of your personal information?
7.1. We strive to keep your personal information accurately recorded. Generally, we will rely on you to update any personal information that you have provided to us.
7.2. If you would like copies of your personal information that we hold about you, or to request correction of any factual inaccuracies in that information, please contact our Privacy Officer (see section 3).
8. How do we manage the security and storage of information we hold?
Security
8.1. Any personal information that we collect in accordance with this Privacy Policy will be held by us at our head office, or on our behalf by our group companies or service providers.
8.2. We take reasonable technical and organisational security measures to prevent loss or unauthorised access, use, alteration or disclosure of personal information you provide to us or authorise us to collect. Any third party, agent or representative of ours who requires access to your information is also required to implement reasonable technical and organisational security measures to protect your information.
8.3. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will apply our normal procedures and comply with legal requirements to protect your information, we cannot guarantee the security of your information transmitted to or from our websites and any transmission is at your own risk.
Links to third-party websites
8.4. Our websites may, from time to time, contain links to and from other websites. If you follow a link to any of those sites, please note that those sites ought to have their own privacy policies and that we do not accept any responsibility or liability for those sites or their privacy policies. Please check those privacy policies before you submit your information to those sites.
Login details
8.5. If you have a username, password or other login details which enable you to access certain parts of our websites, you must not allow any other person to use them and must treat them as confidential. If you believe or suspect that someone else knows your login details you must contact us as soon as possible (see section 3). Please also see our Terms and Conditions of Sale.
9. Our e-commerce websites?
9.1. We use the Shopify e-commerce platform. If you order a product through our vuse.co.nz or vuse.com.au websites, Shopify will collect your personal information to provide services to us, including supporting and processing orders and providing aggregated data analysis. Please read the Shopify privacy policy available at www.shopify.com/legal/privacy to see what security measures Shopify has in place and how they treat your information.
9.2. We use the Klaviyo e-commerce platform. If you order a product through our vuse.co.nz or vuse.com.au websites, Klaviyo will collect your personal information to provide services to us, including supporting and processing orders and providing aggregated data analysis. Please read the Klaviyo privacy policy available at https://www.klaviyo.com/privacy to see what security measures Klaviyo has in place and how they treat your information.
10. How (and when) we can change this Privacy Policy?
10.1. We reserve the right to change this Privacy Policy at any time by publishing an amended Privacy Policy on this website. The updated version of this Privacy Policy will take effect immediately upon such notice and will apply to all personal information that we hold about you.
10.2. You are responsible for reviewing this Privacy Policy regularly to ensure that you are aware of any updates. We will update you directly of any material changes if required by law.
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