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EZYMIGRATE PRIVACY POLICY


1.     PRIVACY POLICY


1.1     Ezymigrate  is committed to ensuring compliance with the New Zealand Privacy Act 1993 and the European Union’s General Data Protection Regulation (GPDR). 

1.2     Ezymigrate’s  Privacy Policy applies to anyone who visits the Ezymigrate website  or uses Ezymigrate platform. From time to time,  Ezymigrate may change this Privacy Policy and will post the changes on the Ezymigrate website. If You don’t agree with the changes to the Privacy Policy then you may not be able to fully use Ezymigrate Website and Web Application. 


2.     WHAT EZYMIGRATE WAKE COLLECTS

2.1     Ezymigrate Wake may collect from You:


 (a)     Your Personal Information, including:

(i) Your Sensitive Information; 

(ii) Your name;

(iii) Your contact information, including email address; 

(iv) Information that you disclose to us in relation to your business processes that help us advise you on suitable features and services . 

(iv) Other information relevant to surveys or interviews You participate in and/or offers You accept; and 

(v) Information about Your preferences and activities on Ezymigrate Application; and 


(b)      Personal Information (including Sensitive Information) about anyone else that You give to Ezymigrate. 


2.2     When You disclose Your Personal Information to Ezymigrate  it must be accurate, complete, up to date and not misleading. If You give Ezymigrate Personal information about someone else, then You must be authorised to do so, and You must tell that person about this Privacy Policy.


 3.     HOW EZYMIGRATE COLLECTS YOUR PERSONAL INFORMATION


 3.1     Ezymigrate collects Your Personal Information only when needed and for lawful purposes connected with performing its functions or activities. You authorise the collection of Your Personal Information from Ezymigrate when You: 


(a)     Use the Ezymigrate on Your computer, mobile, tablet or any other electronic device; 

(b)     Create a user account with Ezymigrate;

(c)     Communicate with our team members by phone, email, app, via the Ezymigrate website or otherwise; 

(d)     Enter into any Ezymigrate educational program, competitions and/or promotions.


 3.2     Ezymigrate may also collect Your Personal Information from publicly available sources or from Third Parties from time to time.


 4.     HOW EZYMIGRATE WILL USE YOUR PERSONAL INFORMATION


 4.1     You authorise Ezymigrate  to use Your Personal Information (and where necessary), to disclose Your Personal Information to Third Parties for the following Purposes: 


(a)     for the Purposes of providing You with the Ezymigrate Services, including to:


(i) communicate with You, including to send promotional emails about new services, special offers, promotions or other information; 

(ii) provide client services;

(iii) respond to Your queries regarding Ezymigrate features and services; 

(iv) verify Your identity when You create a user account with Ezymigrate; 

(v) administer Your account; (vi) provide You with a good user experience;

(vii) develop new Services, features and/or Content; and 

(viii) keep You updated on things that are happening at Ezymigrate;


(b)     for internal record keeping purposes;


(c) to the extent necessary to perform the purposes specified in this Privacy Policy and to allow for the operation of Ezymigrate’s business activities and functions;


 (d) for any other purposes You authorise;


 (e) for the purpose of Ezymigrate selling all or most of Ezymigrate’s assets; and


 (f) to comply with Ezymigrate’s Legal Obligations


4.2 You agree that Tompkins Wake may share Your Personal Information with Third Parties to fulfil business transactions for the purposes specified in this Privacy Policy (for example providing customer services, sending marketing communications, and providing maintenance services). 


5. HOW LONG EZYMIGRATE HOLDS YOUR PERSONAL INFORMATION


 Ezymigrate will hold Your Personal Information for as long as Your Personal Information is required for the Purposes and for as long as is necessary to comply with its Legal Obligations. 


6. HOW TOMPKINS WAKE STORES AND PROTECTS YOUR PERSONAL INFORMATION 

Ezymigrate will use reasonable care to protect Your Personal Information from unauthorised access, use, modification, disclosure, and loss. 


7. TOMPKINS WAKE MAY TRANSFER YOUR PERSONAL INFORMATION TO OTHER COUNTRIES 


In order to provide You with Ezymigrate Services, Ezymigrate may need to disclose and transfer Your Personal Information to Third Parties located in a different country from where You live. This may include countries located outside the European Economic Area (EEA). If those countries do not have data protection laws comparable to the data protection laws of Your country of residence, then Ezymigrate will take reasonable steps to ensure that Your Personal Information (including any Sensitive Information) is protected in those countries.


 8. FOR THE PURPOSE OF THE GDPR


 8.1 Ezymigrate is the data controller for personal data collected by it in the provision of its Services, support and assistance to You as the user. If  Ezymigrate uses personal data that has been collected by a Third Party, it will process the information as a data processor on behalf of the Third Party that collected Your Personal Information.


 8.2 Request Access to Your Personal Information: You have the right to request access to any Personal Information that Ezymigrate holds about You or your clients, the right to know the source of Your Personal Information and the processing methods used by Ezymigrate. If Tompkins Wake cannot give You access to the Personal Information that You have requested, then Tompkins Wake will let You know the legal reasons for not disclosing Your Personal Information. If You are not happy with the legal reasons provided, then You have the right to complain to the New Zealand Privacy Commissioner: www.privacy.org.nz/your-rights/how-to-complain/. 


8.3 Request correction of Your Personal Information: You have the right to request correction of the Personal Information that Tompkins Wake holds about You. Tompkins Wake will correct Your Personal Information if it is necessary to ensure that Your Personal Information is accurate, up to date, complete and not misleading. If Tompkins Wake decides that it is unnecessary to correct Your Personal Information, Tompkins Wake will let You know the legal reasons for its decision. If You are not happy with those reasons, then You have the right to complain to the New Zealand Privacy Commissioner: www.privacy.org.nz/your-rights/how-to-complain/. 


8.4 Request to restrict the use and processing of or delete Your Personal Information: You have the right to request that Tompkins Wake delete Your Personal Information when it is no longer needed for the Purposes, or withdraw your authorisation for Tompkins Wake to use Your Personal Information. You also have the right to restrict Your Personal Information from being processed in the event You consider Your rights and freedoms outweigh our legitimate interests in using Your Personal Information.


 8.5 Data portability: You have the right to request that Tompkins Wake transfer Your Personal Information from one electronic processing system to another electronic processing system.



 9. RIGHTS OF ACCESS AND CORRECTION OF YOUR PERSONAL INFORMATION


Under the Privacy Act 1993, You have the right to request access to any Personal Information that Tompkins Wake holds about You and the right to request correction of the Personal Information that Tompkins Wake holds about You. If Tompkins Wake cannot give You access to the Personal Information that You have requested, then Tompkins Wake will let You know the legal reasons for not disclosing Your Personal Information. Tompkins Wake will correct Your Personal Information if it is necessary to ensure that Your Personal Information is accurate, up to date, complete and not misleading. If Tompkins Wake decides that it is unnecessary to correct Your Personal Information, You have the right to request a statement of the correction sought but not made be attached to the information. If You are not happy with the response to your request, then You have the right to complain to the New Zealand Privacy Commissioner: www.privacy.org.nz/your-rights/how-to-complain/. 



10. INFORMATION THAT EZYMIGRATE PROCESSES ON YOUR BEHALF


10.1     Information entrusted to Ezymigrate and purpose

Information provided in connection with services : You may entrust information that you or your organization (“you”) control, to Ezymigrate in connection with use of our services or for requesting technical support for our products. This includes information regarding your customers and your employees (if you are a controller) or data that you hold and use on behalf of another person for a specific purpose, such as a customer to whom you provide services (if you are a processor). The data may either be stored on  Microsoft Azure SQL Server or transferred or shared to us as part of a request for technical support or other services.


We recognize that you own your service data. We provide you complete control of your service data by providing you the ability to (i) access your service data, (ii) share your service data through supported third-party integrations, and (iii) request export or deletion of your service data.


10.2     How we use service data

We process your service data when you provide us instructions through the various modules of our services. For example, when you generate an invoice, information such as the name and address of your customer will be used to generate the invoice; and when you use our campaign management service for email marketing, the email addresses of the persons on your mailing list will be used for sending the emails.


10.3 Push notifications

If you have enabled notification on our desktop and mobile applications, we will push notifications through a push notification provider such as Apple Push Notification Service, Google Cloud Messaging or Windows Push Notification Services. You can manage your push notification preferences or deactivate these notifications by turning off notifications in the application or device settings.


10.4     Who we share service data with

Employees and independent contractors : We may provide access to your service data to our employees and individuals who are independent contractors of Ezymigrate entities involved in providing the services (collectively our “employees”) so that they can


 (i) identify, analyze and resolve errors,

 (ii) manually verify emails reported as spam to improve spam detection, or


We ensure that access by our employees to your service data is restricted to specific individuals, and is logged and audited. Our employees will also have access to data that you knowingly share with us for technical support or to import data into our products or services. We communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within the Ezymigrate.


10.5    Third-party integrations you have enabled :

 Some of our products and services support integrations with third-party products and services. If you choose to enable any third-party integrations, you may be allowing the third party to access your service information and personal information about you. We encourage you to review the privacy practices of the third-party services and products before you enable integrations with them.


10.6    Retention of information

We hold the data in your account as long as you choose to use Ezymigrate Services. Once you terminate your Ezymigrate user account, your data will eventually get deleted from the active database during the next clean-up that occurs once in 6 months. 


10.7    Data subject requests

If you are from the European Economic Area and you believe that we store, use or process your information on behalf of one of our customers, please contact the customer if you would like to access, rectify, erase, restrict or object to processing, or export your personal data. We will extend our support to our customer in responding to your request within a reasonable timeframe.


11. MINORS


 Ezymigrate does not knowingly collect Personal Information from children (as defined by local laws) and does not target its Website and/or Services towards children.



 


12.     PRIVACY COMPLAINTS


 If You think that Your privacy rights have been breached, You can make a written complaint to Tompkins Wake at tomwake@tompkinswake.co.nz, or otherwise contact the NZ Privacy Commissioner at https://www.privacy.org.nz/your-rights/making-a-complaint/complaintform/. 


13. COOKIES


13.1      A cookie is a small file that can be placed on Your computer, mobile, tablet or any other electronic device when you’re using Ezymigrate. Cookies allow the web application to recognise Your device. Ezymigrate may use cookies in order to make it easier to use the Ezymigrate application  and to help Ezymigrate to analyse the profile of visitors and users in order to improve usability and features of the Ezymigrate Website and Services.



13.2 There are two types of cookies used by Ezymigrate:


(a) Session cookies: These are used to store information about Your activities so You can move from one webpage to another. These cookies track Your movement from webpage to webpage of a website so that You do not have to provide the same information provided on earlier webpages. Session cookies only remain in the cookie file of Your browser until You close the browser. 


(b) Persistent cookies: These are used to store Your preferences to improve Your experience on future visits to the Ezymigrate Website. For example, these cookies can remember log-in details or language preferences so that You don’t have to continually re-enter these each time You visit the website. Persistent cookies stay in the cookie file of Your browser after You have closed Your browser and activate again when You next visit that website. 


13.3 To enable some of the features and functionality of the Ezymigrate application, You will need to permit Ezymigrate to place cookies on Your device. If You choose not to, then those features and functionality will not be available to You. You can remove or block cookies by using the settings in Your browser but it may affect Your ability to use the Tompkins Wake Website.


 14. DEFINITIONS


 “Ezymigrate” means Smitten Online Ltd  T/A Ezymigrate


“Ezymigrate Services”: means any  Ezymigrate application, products, services, software, Content, features, functionalities and any other services provided to You in person, by phone, email, app, or via the Ezymigrate Website;


 “Ezymigrate Website” means the website (or websites) located at www.ezymigrate.co.nz;


“Legal Obligations” means any legal or regulatory obligation that Ezymigrate has under the laws of any relevant any country in relation to the collection, use, disclosure, storage or processing of Your Personal Information;


 “Personal Information” means any information that can be used to directly or indirectly identify an individual, and includes Sensitive Information, and references to “Your Personal Information” also includes any Personal Information that You provide/process/control  through Ezymigrate about someone else; 


“Purposes” means the purposes for which Your Personal Information is used and disclosed as specified in this Ezymigrate Privacy Policy;


 “You” means you as an individual and Your has a corresponding meaning

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