We care about your privacy
Nik Wakelin Consulting Limited (trading as Breve) is committed to ensuring the privacy of all customers’ information.
Breve (we, us, our) complies with the New Zealand Privacy Act 1993 and the General Data Protection Regulation of the European Union (GDPR) when dealing with personal information.
Personal information is information about an identifiable individual (a natural person), and includes personal data, personally identifiable information and equivalent information under applicable privacy and data protection laws.
This policy does not limit or exclude any of your rights under the New Zealand Privacy Act 1993 or the GDPR. For further information on the New Zealand Privacy Act 1993, see www.privacy.org.nz. For further information on the GDPR, see ec.europa.eu/info/law/law-topic/data-protection_en.
This policy was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal information. We are happy to provide any additional information or explanation needed. Any request for further information should be sent to firstname.lastname@example.org.
Changes to this policy
We may change this policy by uploading a revised policy onto our website. The change will apply from the date that we upload the revised policy.
This policy was last updated on 1 May 2020.
When does this policy apply?
Users of our SaaS service may collect personal information from individuals (e.g. their employees and customers) and upload, store or process that information to or in that service (User Data).
We only process User Data as authorised by our customers in our Terms of Service. Unless required otherwise under applicable law, if we receive any request or enquiry relating to User Data, we will forward this request to our relevant customer.
We do not intend to collect personal information from or about children aged under 16. If you have reason to believe that we have collected personal information from or about a child under the age of 16, please contact us at email@example.com.
What personal information do we collect?Directly from you
We collect the following information directly from you.
When you register for, or login to, an account on our website or related services, we collect your name, email address, password and any other information we require or ask for to set you up with an account.
When you sign up to our newsletter and other electronic alerts, we collect your name, email address and any other information you provide to us when you ask to receive our newsletter or other alerts.
When you respond to our feedback surveys, we collect your name, email address and any other information you choose to include in your response.
Some of the personal information that we collect directly from you may be mandatory and some may be optional. We will let you know which of these applies at the time we collect the relevant personal information. While you do not have to provide us with some of the information that we may request, this might mean that our products and services may not perform as well as they should, or that we may not be able to provide some parts of the website or all of our products or services to you. If you require further information about the consequences of not providing us with any information, please contact us at firstname.lastname@example.org.Automatically when you use our website
When you access and use our website or related services we may automatically collect information about your device and usage of our website, products and services, including your IP address, operating system, browser type, time spent on certain pages of the website, pages visited, links clicked and language preferences.
How we use your personal information
We may use your personal information to:
- provide our website, products and services to you
- market our products and services to you, including contacting you electronically (e.g. by text or email for this purpose)
- improve our website, products and services
- respond to communications from you, including enquiries and complaints
- conduct research and statistical analysis (on an anonymised basis)
- protect and/or enforce our legal rights and interests, including defending any claim
- respond to lawful requests by public authorities, including to comply with law enforcement requirements, or
- for any other purpose authorised by you or applicable law.
We may transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition.
You can stop receiving our marketing emails by following the email preferences and/or unsubscribe instructions included in those emails or contacting us at email@example.com.
Disclosing your personal information
We may disclose your personal information to:
- another company within our group
- a person who can require us to supply your personal information (e.g. a law enforcement agency or regulatory authority)
- any other person with your consent
- any other company in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition
- any other person authorised by applicable law.
International transfer of personal information
A business that supports our website, products and services may be located outside of New Zealand (the country where we are incorporated) and also outside of the country where you are located. This means that the personal information we collect may be transferred to, and stored in, a country outside of New Zealand and the country where you are located.
If you are located in the European Economic Area (EEA), your personal information may be transferred outside of the EEA. Under the GDPR, the transfer of personal information to a country outside the EEA may take place where the European Commission has decided that the country ensures an adequate level of protection. In the absence of an adequacy decision, we may transfer personal information if other appropriate safeguards are in place.
Where we transfer personal information outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data, or to a third party where approved transfer mechanisms are in place to protect your personal information (e.g. to organisations in the United States under the EU-U.S. Privacy Shield framework or by entering into the European Commission’s Standard Contractual Clauses). For further information, please contact at firstname.lastname@example.org.
Some of the personal information we collect is processed in New Zealand. New Zealand is recognised by the European Commission as a country that has an adequate level of data protection and we rely on this decision in transferring personal information to New Zealand.
Protecting your personal information
As required by applicable law, we will take 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 the risks inherent in processing personal information.
You play an important role in keeping your personal information secure by maintaining the confidentiality of any password and accounts used in relation to our products and services. You should 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 under applicable law, you have the right to access your 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.
Where you request a correction, if we think the correction is reasonable and we are reasonably able to change your personal information, we will make the correction. In all other cases, we will take reasonable steps to make a note of the personal information that was the subject of your correction request.
If you want to exercise either of the above rights, email us at email@example.com. Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information to be corrected and the correction that you are requesting).
Subject to applicable law, we may charge you our reasonable costs of providing to you copies of your personal information or correcting that information.
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.
The personal information that we collect and use will not be kept longer than necessary for the purposes for which it is collected, or for the duration required for compliance with applicable law, whichever is longer.Contact us
The name and contact details of our Data Protection Officer for the purposes of the GDPR are:
Nik Wakelin, firstname.lastname@example.org.GDPR Additional Terms
Lawful basis for processing personal information
Our lawful basis for processing (as that term is defined in the GDPR) personal information that we collect, use and disclose depends on the personal information collected and the context in which we collect it.
Generally, we collect personal information from you where we have your consent, where processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, or where processing is necessary for the purposes of our legitimate interests (except where such interests are overridden by your interests or fundamental rights and freedoms).
Where we process personal information based on your consent, you may withdraw your consent at any time.
Despite the above, we may process your personal information where such processing is necessary for compliance with applicable laws.
If you have any question about the legal basis on which we process personal information or need further information, please contact us at email@example.com.Your rights under the GDPR
If you are located in the European Union, your rights in relation to your personal information include:
- right of access - if you ask us, we will confirm whether we are processing your personal information and provide you with a copy of that personal information
- right to rectification - if the personal information we hold about you is inaccurate or incomplete, you have the right to have it rectified or completed. We will take reasonable steps to ensure inaccurate personal information is rectified. If we have shared your personal information with any third party, we will tell them about the rectification where possible
- right to erasure – when your personal information is no longer needed for the purposes for which you provided it, we will delete it. You may request that we delete your personal information and we will do so if deletion does not contravene any applicable law. If we have shared your personal data with any third party, we will take reasonable steps to inform those third parties that they must delete your personal information
- right to withdraw consent - if the basis of our processing of your personal information is consent, you can withdraw that consent at any time
- right to restrict processing - you may request that we restrict or block the processing of your personal information in certain circumstances. If we have shared your personal information with any third party, we will tell them about this request where possible
- right to object to processing - you may request that we stop processing your personal information at any time and we will do so to the extent required by the GDPR
- rights related to automated decision-making, including profiling - you have the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such automated decision-making is necessary for entering into, or the performance of, a contract with you, is authorised by applicable laws or is based on your explicit consent. We do not undertake automated individual decision-making
- right to data portability - you may obtain your personal information from us that you have consented to give us or that is necessary to perform a contract with you. We will provide this personal information in a commonly used, machine-readable and interoperable format to enable data portability to another data controller. Where technically feasible, and at your request, we will transmit your personal information directly to another data controller
- the right to complain to a supervisory authority - you can report any concern you have about our privacy practices to your local data protection authority.
Where personal information is processed for the purposes of direct marketing, you have the right to object to such processing, including profiling related to direct marketing.
By continuing to use our website and related services, you indicate your agreement for us to use the cookies described below.
Cookies are text files containing small amounts of information which are downloaded to your browsing device, e.g. a computer or smartphone, when you visit a website. Cookies can be recognised by the website that downloaded them, or by other websites that use the same cookies. This helps a website know if the browsing device has visited that or other websites before.
Cookies can be used to collect information relating to your use of a website or your device, let you navigate between pages effectively, help to remember your preferences and generally improve your browsing experience.
Cookies can be session or persistent cookies. Session cookies are temporary and only stay on your browser until you stop browsing. Persistent cookies stay on your device until they expire or are deleted.
The cookies used on our website may be first party cookies (i.e. set by us) or third party cookies (i.e. cookies set on our website by a person other than us). The third party companies that place cookies on our website will have their own privacy policies.What type of cookies do we use?
The types of cookies used by us, and most websites, can generally be categorised as follows.
Strictly necessary cookies
These cookies are essential for the full functionality of our website and related services. They enable you to navigate around our website and services and use their features e.g. accessing secure areas and enabling services that you have asked to receive. If you opt out of these cookies, you may not be able to access all the functions of our website and some services that you have asked to receive.
These cookies do not track where else you have been on the internet and do not remember your preferences beyond your current visit. These cookies are generally first party session cookies which will expire when you close your browsing session. These cookies do not collect information that could be used for marketing purposes.
We use Google Analytics to collect information about visitors to our website. Google Analytics collects information related to your device, browser, IP address, network location, and website activities to measure and report statistics about your interactions on our website. We use this information to help us manage the performance and design of our website and to improve our website.
You can control and/or delete cookies as you wish. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. However, if you do this, you may have to manually adjust some preferences every time you visit our website and attempt to use our services, you may not be able to access certain parts of our website or services, and some functionalities may not work.
You can find out more information about how to change your browser cookie settings at http://www.aboutcookies.org.uk.Third party website cookies