Privacy Policy

Last updated: 18/06/2024

PRIVACY POLICY 

INTRODUCTION 

TracPlus Global Limited (we, us, our, TracPlus) is committed to protecting the privacy of those who  use our website, mobile applications, services and associated equipment and others who we interact with us. We comply with all Data Privacy Laws that are applicable to our dealings with your Personal Information.  

This policy sets out how we collect, process, use, dispose and protect information that relates to an  identified or identifiable individual across our Website, Mobile Applications, and TracPlus Services (Personal Information).  If you can’t be identified (for example, when Personal Information is aggregated and anonymised)  then the information or data is not Personal Information and this notice doesn’t apply. 

Our cookie policy (available at www.tracplus.com/termsandconditions) also forms part of this  Privacy Policy and, if you are based in the European Union and we process any of your Personal  Information, the additional terms in our GDPR addendum (available at www.tracplus.com/termsandconditions) will also form part of this Privacy Policy and apply to you. 

This Privacy Policy is governed by New Zealand law. For more information about privacy issues in  New Zealand and protecting your privacy, visit the New Zealand Privacy Commissioner's website at  www.privacy.org.nz. 

This Privacy Policy uses the same definitions as those used in the TracPlus terms and conditions,  available at Terms and Conditions. 

CHANGES TO THIS POLICY 

We may change this Privacy Policy by uploading a revised policy onto the Website. The change will apply from the date that we upload the revised policy. 

This Privacy Policy was last updated on 18 June 2024. 

WHAT PERSONAL INFORMATION DO WE COLLECT 

We collect, hold and process two categories of Personal Information: 

Account and Marketing Data is Personal Information that we collect about you: 

• in connection with the creation or administration of a customer account 
• if you ask to receive information about us or our services or sign up to our newsletter 
• when you contact us directly (e.g. telephone call, Website enquiry form, email or through your user dashboard) or visit our Website 

The Account and Marketing Data we collect may include company/personal names, usernames, phone numbers, email addresses and any other contact information you provide to us, your location, billing information, purchase history, information about how you use the TracPlus Services (for example, transactions, data and call volumes, Plan details), your IP  address and/or other device identifying data, information contained in your correspondence with us  or survey responses and other information required to 

provide a service or information you have requested from us. 

Operational PI is personal information about our customers’ personnel that is collected using or input into the TracPlus Solution. Operational PI may include personnel names, addresses and contact details, emergency contacts, position, event and messaging data, and any other information that our customers capture using the TracPlus Solution.

WHO DO WE COLLECT YOUR PERSONAL INFORMATION FROM 

We collect Personal Information about you from: 

• third parties where you have authorised this (e.g. satellite, cellular and radio networks) or where the information is publicly available (e.g. online public registers or your Website). If possible, we will collect Personal Information from you directly; and 
• your use of the Website and/or the TracPlus Service, as a consequence of any action you might  take while using our Website or TracPlus Service or interacting with any part of the TracPlus Service.  

When you visit or use our Website or the TracPlus Solution, we may collect information about you: 

• by recording clickstream data, which is non-personal information that is recorded when you click anywhere on a webpage and is used for the purposes of collecting, analysing and reporting data about how you use our Website and related services; and 
• through the use of cookies, web beacons and similar storage technologies. Please refer to our cookie policy at www.tracplus.com/termsandconditions for further information, including information on how you can disable these technologies. 

You do not have to provide us with your name and email address to access and use the Website. However, you must provide us with your name, contact and billing details when using some of our services such as signing up for our newsletter or creating an account to access our paid services. The consequence of not providing your name, contact and billing details is that we will not be able to provide paid services to you. 

HOW WE USE YOUR PERSONAL INFORMATION 

We will use your Operational PI solely as provided for in our Terms and Conditions and/or other  agreements with our customers that govern the processing of your Operational PI (as applicable).  We require our customers to comply with all applicable Data Privacy Laws in connection with their  access to and use of the TracPlus Service. 

We may use your Account and Marketing Data: 

• to verify your identity 
• to provide the Website and TracPlus Service to you 
• to market our services to you, including contacting you electronically (e.g. by text or email for this purpose). You can stop receiving our marketing emails by following the unsubscribe instructions included in those emails 
• to improve the services that we provide to you 
• to undertake credit checks of you (if necessary) 
• to bill you and to collect money that you owe us, including authorising and processing credit card transactions 
• to tailor content or advertisements to you 
• to respond to communications from you, including enquiries and complaints
• to conduct research and statistical analysis (on an anonymised basis) 
• to protect and/or enforce our legal rights and interests, including defending any claim 
• for any other purpose authorised by you or any applicable Data Privacy Law
• to respond to lawful requests by public authorities, including to meet law enforcement requirements 
• to respond to due diligence requests and/or transfer your information in the case of a sale,  merger, consolidation, liquidation, reorganisation or acquisition 

DISCLOSING YOUR PERSONAL INFORMATION 

We will disclose your Operational PI solely as provided for in our Terms and Conditions and/or other  agreements with our customers that govern the processing of your Operational PI (as applicable). 

We may disclose your Account and Marketing Data to: 

• another company within our group for the purposes described in this Privacy Policy
• an Outsourced Service provider, where you have agreed to procure an Outsourced Service
• any other person authorised or requested by you, including emergency services organisations 
• any business that supports our services, including any person that hosts or maintains any underlying IT system or data centre that we use to provide our website or services or that we use to process payments 
• other third parties (for anonymised statistical information) 
• a person who can require us to supply your Personal Information (e.g. a regulatory or public  authority) 
• any other person authorised by applicable Data Privacy Laws (e.g. a law enforcement  agency) 
• professional advisers e.g accountants, lawyers, auditors 
• any other company in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition. 

We share information about your use of the Website with our trusted social media, advertising and analytics partners through the use of cookies, web beacons and similar storage technologies. Please refer to our cookies policy for further information. 

OVERSEAS TRANSFERS OF PERSONAL INFORMATION 

We utilise the services of entities in various countries (including, New Zealand, Australia, Chile, United States, Spain, United Kingdom, South Africa, Sweden) for the matters specified under the  heading “Third Party Services” below. Consequently, we may transfer your Personal  Information to parties located in these countries. Although we will endeavour to ensure that  your Personal Information is treated securely and in accordance with this Privacy Policy as  well as applicable Data Privacy Laws, you acknowledge that some of these countries may not  have an equivalent level of data protection laws as those in New Zealand. You consent to the  rights of access, processing and disclose on this basis. 

Please see the GDPR Addendum for further information about personal data transfers from the EEA  if the GDPR applies to our access and processing of your Personal information. 

THIRD PARTY SERVICES 

We use third party services for providing parts of the TracPlus Service, including service providers  that host or maintains any underlying IT system or data centre that we use to provide the website or  other services and products. We do this to ensure a better experience for users and for improving  the TracPlus Service or parts of it. In the process of doing so, the third-party service provider may  have access to Personal Information. However, these third parties do not have the right to use the  Personal Information for their own use.

The third-party providers used by TracPlus includes our professional advisers e.g accountants,  lawyers, auditors and the following service providers: Google, Xero, Ask Nicely, Freshdesk, Flightcell,  Honeywell Statamatics, Trotter, AMS, Bluesky, NAFC, Intercom, Lattitude Inc., Skyconnect, Skytrac,  Spidertracks, USFS, Philips Search and Rescue NZ, ADP PAY-BY-PAY, ADP, LLC (DD), Aeris  Communications Inc, FedEx Express Services, Forrestall CPAs, Garmin International, Inc., Tangent  Link Ltd, Airborne Mission System Pty Ltd, Apple Pty Limited, ASIC, CCM Guidance Systems Pty Ltd,  GARMIN AUSTRALASIA PTY LTD, GeoRESULTS Pty Ltd, UPS, Heli-Central Pty Ltd, Pacific Avionics PTY  Ltd, Search and Rescue Services Ltd, ShuffleHub, SMS Global, St John Ambulance, St John ECL,  Vodafone Australia, Vodafone New Zealand Limited, Wanaka Search And Rescue, Wireless  Innovation Limited, Web24 (Hostopia Australia Web Pty Ltd) (CC), Aerial Fire, Aeris Communications,  Inc, Airborne Mission System Pty Ltd, BulkSMS.com (CC), Bulletin, CCM Guidance Systems Pty Ltd,  Dext (CC), Emnify GmbH, GeoRESULTS Pty Ltd, GroundControl, Helicopters Otago Ltd, Highland  Helicopters, HubSpot, Iridium Satellite LLC, JT (Jersey) Ltd, M2M One NZ Limited, Mailgun  Technologies Inc (CC), Met Ocean Telematics, Microsoft (CC), MyNetFone, Nal Research Corporation,  Pacific Avionics PTY Ltd, Rackspace, Rackspace Technology. 

PROTECTING YOUR PERSONAL INFORMATION 

We will take reasonable steps to keep your Personal Information safe from loss, unauthorised activity, or other misuse. We implement appropriate technical and organisational measures to ensure a level of security appropriate to risks inherent in processing Personal Information. 

You can play an important role in keeping your Personal Information secure by maintaining the confidentiality of any password and accounts used in relation to our TracPlus Service. Please do not  disclose your password to third parties. Please notify us immediately if there is any unauthorised use  of your account or any other breach of security. 

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION 

Subject to certain grounds for refusal set out in the applicable Data Privacy Laws, you have the right  to access your readily retrievable Personal Information that we hold and to request a correction to  your Personal Information. Before you exercise this right, we will need 

evidence to confirm that you are the individual to whom the Personal Information relates. 

In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the Personal Information, we will make the correction. If we do not make the correction, we will take reasonable steps to note on the Personal Information that you requested the correction. 

If you want to exercise either of the above rights, email us at support@tracplus.com. Your email should provide evidence of who you are and set out the details of your request (e.g. the Personal Information, or the correction, that you are requesting). 

HOW LONG WE KEEP YOUR PERSONAL INFORMATION 

We will keep your Personal Information: 

• until we no longer have a valid reason for keeping it; 
• until you request us to stop using it; or 
• for as long as required by law e.g., we keep invoice information for 7 years to fulfil our tax  obligations.

You should be aware that we do keep backups and logs for up to six months before they are  automatically deleted. When a customer account is deleted, some information continues to be  stored in backups. 

INTERNET USE 

While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk. 

If you follow a link on our Website to another site, the owner of that site will have its own privacy policy relating to your Personal Information. We suggest you review that site’s privacy policy before you provide Personal Information. 

TRACPLUS MOBILE APPS (iOS & Android) 

TracPlus Beacon is a feature in our mobile apps that uses GPS location data from your mobile device in the background to determine your precise geographic location. This information is sent to TracPlus, stored securely and only visible to other members of your organisation that use our software, or other organisations that have been granted access by your organisation. This occurs when tracking mode is enabled in the app. 

CONTACT US 

If you have any questions about this privacy policy or our privacy practices, or if you would like to request access to, or correction of, your personal information, you can contact us here: support@tracplus.com.