Link Engine Management Ltd is a company registered in New Zealand, which is part of the Link Engine Management group of companies (collectively referred to as "Link", "we" and "us" in this policy).

Overview

We at Link take data protection seriously and are committed to ensuring trust and confidence when using any of the services on our website. Your data is used to create a tailored and customised experience on our website and is never traded or sold on to any other business for marketing purposes. This policy will explain exactly what we use your data for and what information is captured and held on our systems.

Types of data we collect

Link may collect the following information about you:

• your name, age/date of birth and gender;
• your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile/cell numbers) and e-mail address;
• all purchases and orders made by you;
• your on-line browsing activities on the Link websites;
• your password(s);
• your payment card details (when you make a purchase or place an order with us);
• your communication/marketing preferences;
• your preferences, interests, feedback and survey responses;
• your location;
• any of your correspondence and communications with Link; and
• other publicly available personal data of yours, including any which you have shared via a public platform (such as a Twitter feed or Facebook page).

Where relevant, data will be encrypted in a secure manner.

Link's websites are not intended to be used by children and we do not knowingly collect data relating to children.

When someone visits www.linkecu.com we use a third party service, Google Analytics, to collect standard internet log data and details of visitor behaviour patterns. This allows us to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify any users of the site. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.

This is not an exhaustive list and, in specific instances, we may need to sometimes collect additional data for the purposes set out in this Privacy Policy. Some of the above personal data is collected directly by us, for example when you set up an on-line account on our sites, or send an email to our customer service or technical support team. Other personal data is collected indirectly, for example your browsing or shopping activities. We may also collect personal data from third parties to whom you have given your consent to pass your details to us, or from publicly available sources.

As part of the registration process for our regular newsletter that is delivered via electronic mail, we collect personal information. We use that information for a number of reasons: to tell you about things you’ve asked us to tell you about; to contact you if we need to provide or obtain additional information; to check that our records are right and to check periodically that you are happy and satisfied. We never rent or trade email lists with other organisations and businesses.

Link use a third-party provider, MailChimp, to deliver our regular newsletters. We gather various statistics around email opening and clicks, using industry standard technologies, to help us monitor and improve our newsletter. For more information, please see MailChimp’s own privacy notice. You can unsubscribe to mailings at any time of the day or night by clicking the unsubscribe link at the bottom of any of our emails or by emailing our data protection officer.

How do we use your data?

General

Link (and our trusted partners acting on our behalf) use your personal data:

• to provide goods and services to you;
• to make a tailored website available to you;
• to manage any registered account(s) that you hold with us;
• to verify your identity;
• for crime and fraud prevention, detection and rlated purposes;
• with your agreement, to contact you electronically about promotional offers and products and services which we think may interest you;
• for market research purposes - to better understand your needs;
• to enable Link to manage customer service interactions with you; and
• where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).

Marketing

Link uses your personal data for electronic marketing purposes (with your consent) and may send you electronic or postal mail to update you on the latest Link offers, products and services.
You have the right to opt out of receiving these communications at any time, by:

• Making use of the "unsubscribe" link in emails, or
• contacting Link via the contact channels set out in this Policy.

Sharing data with third parties

Our service providers and suppliers
In order to make certain services available to you, we may need to share your personal data with some of our service partners. These include IT, delivery and marketing service providers.
Link only allows its service providers to handle your personal data when we are sure that they apply appropriate data protection and security controls like ourselves. Service providers can only use your data to provide services to Link and to you, and for no other purposes.

Other third parties
Aside from our service providers, Link will not disclose your personal data to any third party, except as set out below. We will never sell or rent our customer data to other organisations for marketing purposes

We may share your data with:

• our carefully selected partners and dealers who provide Link branded products and services, if we have your consent to do so;
• credit reference agencies where necessary for card payments;
• governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so:
  - to comply with our legal obligations;
  - to exercise our own legal rights (for example in a court case);
  - for the prevention, detection, investigation of crime or prosecution of offenders; and
  - for the protection of our employees and customers.

International transfers

To deliver products and services to you, it is sometimes necessary for Link to share your data outside of the European Economic Area. This will typically occur when service providers are located outside the EEA or if you are based outside the EEA. These transfers are subject to special rules under data protection laws.

If this happens, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to use ‘standard data protection clauses’ which have been approved by the European Commission for such transfers.

How long do we keep your data?

We will not retain your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data, however the longest we will normally hold any personal data is 6 years.

Protecting your data

Link is committed to keeping your personal data on our systems safe and secure.

Our security measures include: -

• encryption of data;
• regular scenario planning and crisis management exercises to ensure we are ready to respond to cyber security attacks and data security incidents;
• security controls, which protect the Link IT infrastructure from external attack and unauthorised access; and
• internal policies which set out our data security approach and training for employees.

What you can do to protect your data

Link will never ask you to confirm your bank account or credit card details via email. If you somehow receive an email claiming to be from Link asking you to confirm your details, please ignore it and do not respond.

If you are using a device in a public location, we highly recommend that you log out and close the website browser when you complete an online session.

In addition to this, we recommend that you take the following security measures to enhance your online safety both in relation to Link and more generally:

• keep your online account passwords private
• when creating a password, use at least 8 characters. A combination of letters and numbers is best. We also recommend that you frequently change your password
• avoid using the same password for multiple online accounts

Your rights regarding your data

You have the following rights:

• the right to ask for a copy of any personal data that we hold about you;
• the right (in certain circumstances) to request that we delete all personal data held on our systems about you; where we no longer have any legal reason to keep it;
• the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you;
• the right to opt out completely of any marketing communications we may send you and to object to us using, or holding, your personal data if we have no legitimate reasons to do so;
• the right (in certain circumstances) to ask us to ‘restrict processing of data’; this means we would need to secure and retain any data for your benefit but not otherwise use it; and
• the right (in certain circumstances) to ask us to supply you with some of the personal data we hold about you in a structured format and/or provide a copy of the data in such a format to another organisation.

If you wish to exercise any of the above rights, please contact us using the contact details set out below.

Why we collect data on you

General

Link collects and uses customers’ personal data because is it necessary for:

• the pursuit of our legitimate interests (as set out below);
• the purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a customer; or
• complying with our legal obligations.

In general, Link only rely on consent as a legal basis for processing personal data in relation to sending direct marketing communications to customers via email.

Customers have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.

Our legitimate interests

The normal legal basis for processing any customer data, is that it is necessary for the legitimate interests of Link, including:-

• selling and supplying goods and services to customers;
• protecting our customers, employees and other individuals and maintaining their welfare, health and safety;
• promoting, marketing and advertising Link's products and services;
• sending relevant promotional communications, tailored to individual customers;
• understanding our customers’ activities, behaviour, preferences, and needs;
• improving our existing products and services and also developing new products and services;
• complying with all of our legal and regulatory obligations;
• preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
• handling contacts, queries, complaints or disputes from customers;
• managing insurance claims by customers;
• protecting Link, its employees and customers, by taking appropriate legal action against third parties who may have committed criminal acts or are in breach of legal obligations to Link;
• effectively handling any legal claims or regulatory enforcement actions taken against Link; and
• fulfilling our duties to our customers, colleagues and other stakeholders.

Contacting us

Link has appointed a Data Protection Officer to ensure we protect the personal data of our customers, staff and others, and comply with EU data protection legislation.

If you have any questions about how Link uses your personal data that are not answered here, or if for whatever reason you want to exercise your rights regarding your personal data, please contact our Data Protection Officer’s team by:

Phone: +64 (0)3 348 8854;

E-mail: [email protected] or

Write to: Data Protection Officer, Link Engine Management, 45 Ron Guthrey Road, Avonhead, Christchurch, 8024, New Zealand.

If you are an EU resident, you have the right to lodge a complaint with your local office that deals with data protection issues.

 

THIS POLICY WAS LAST UPDATED ON MAY 2018.