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Transhold Systems Ltd Privacy Statement

 

At Transhold Systems Ltd we recognise the importance of privacy protection. We have created this Privacy Statement to demonstrate our commitment to you, your privacy and to secure and trustworthy Internet commerce.

 

Contents:

  • Types of personal information we collect

  • Transhold Systems Ltd’s compliance commitment

    Collection of Personal Information

    Use and Disclosure

    Data Quality

    Data Security

    Openness

    Access and Correction

    Identifiers

    Anonymity

    Transborder Data Flows

    Sensitive Information

  • Removal from Transhold Systems Ltd mailing lists

  • Complaints management

  • Access to personal information held by Transhold Systems Ltd

  • Enquiries

  • Protection and use of information collected online

    Use and purpose of collected personal data

    Online security

    Privacy across the entire Transhold Systems Ltd network

    Consent

  • What information do we collect online and why?

    IP addresses

    Cookies

    User registration

    E-mail addresses

    Registration for third-party services at Transhold Systems Ltd

    “Send this to a friend” service

    Shopping

    Online surveys

    Demographic and user profile data

  • Links to other sites

  • Choice/Opt-out

    Unsubscribe from Transhold Systems Ltd newsletter

    Removal from registration database

    Removal from other Transhold Systems Ltd e-mail lists

 

Types of Personal Information we collect

Generally, the only personal information we collect is contact details of representatives of:

  • customers,

  • prospective customers,

  • partners, and

  • other individuals interested in receiving information from Transhold Systems Ltd.

This includes details such as their names, addresses, telephone numbers and email addresses. We also record information concerning transactions that individuals make or wish to make with Transhold Systems Ltd and as well as information concerning customer preferences and satisfaction with Transhold Systems Ltd’s products and services.

For more information, see below: What information do we collect online and why?

 

Transhold Systems Ltd’s Compliance Commitment

Generally, Transhold Systems Ltd will only collect personal information when necessary to provide a specific service or function. This includes Transhold Systems Ltd product and event information and software upgrade information.

Where practicable, when this personal information is collected it is done so directly from the individual, either by phone, over the Internet or in person. We may also collect personal information indirectly such as where one customer representative gives us details of another customer representative.

 

Collection of personal information

Transhold Systems Ltd will take reasonable steps to ensure that the individual is aware of:

  • Transhold Systems Ltd’s identity and how to contact us,

  • their ability to gain access to their personal information,

  • the purposes for which the information is collected,

  • the organisations (or the types of organisations) to which Transhold Systems Ltd usually discloses information of that kind,

  • any law that requires the particular information to be collected, and

  • the main consequences (if any) for the individual if all or part of the information is not provided.

If Transhold Systems Ltd collects personal information about an individual from someone else, Transhold Systems Ltd will take reasonable steps to ensure that the individual is or has been made aware of the matters listed above.

 

Use and Disclosure

Generally Transhold Systems Ltd will only use and disclose personal information for the primary purpose for which it was collected. For example, personal information may be used to provide a specific service or function to individuals, to process requests and transactions, and to communicate marketing offers and information to individuals.

This may include providing personal information to external organisations or to our related companies where they are assisting us to provide a service or function. Where we do provide third parties with personal information, we have measures in place to ensure they do not use the personal information for any purpose other than providing the relevant service or function.

Fiesta Bulb Marketing Ltd will only use or disclose personal information about an individual for a purpose other than the primary purpose (the secondary purpose) of collection if:

  •  

    The secondary purpose is related to the primary purpose of collection; and

    The individual would reasonably expect Transhold Systems Ltd to use or disclose the information for the secondary purpose; or

  • The individual has consented to the use or disclosure; or

  • If the information is not sensitive information and the use of the information is for the secondary purpose of direct marketing: it is impracticable for Transhold Systems Ltd to seek the individual’s consent before that particular use; and

    Transhold Systems Ltd will not charge the individual for requesting to not receive direct marketing communications; and

    the individual has not made a request to Transhold Systems Ltd not to receive direct marketing communications; and

    in each direct marketing communication with the individual, Transhold Systems Ltd directly advises the individual, or prominently displays a notice, that he or she may express their desire not to receive any further direct marketing communications; and

    each written direct marketing communication by Transhold Systems Ltd with the individual (up to and including the communication that involves the use) sets out Transhold Systems Ltd’s business address and telephone number and, if the communication with the individual is made by fax, telex or other electronic means, a number or address at which Transhold Systems Ltd can be directly contacted electronically; or

  • Transhold Systems Ltd has reason to suspect that unlawful activity has been, is being or may be engaged in, and uses or discloses the personal information as a necessary part of its investigation of the matter or in reporting its concerns to relevant persons or authorities; or

  • the use or disclosure is required or authorised by or under law; or

  • Transhold Systems Ltd reasonably believes that the use or disclosure is reasonably necessary for one or more of the following by or on behalf of an enforcement body:

    the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law;

    the enforcement of laws relating to the confiscation of the proceeds of crime;

    the protection of the public revenue;

    the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct;

    the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal.

 

Data quality

Transhold Systems Ltd will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. If you believe that the information held is inaccurate please do not hesitate to contact the Privacy Officer below.

 

Data Security

Transhold Systems Ltd will take reasonable steps to protect the personal information we hold from misuse and loss and from unauthorised access, modification or disclosure. Transhold Systems Ltd stores personal information in various secure electronic storage facilities and paper-based files.Fiesta Bulb Marketing Ltd will also take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for any purpose for which the information may be used or disclosed.

 

Openness

Transhold Systems Ltd policy on our management of personal information is set out in this document, as may be amended by Transhold Systems Ltd from time to time. 

 

Access and Correction

If Transhold Systems Ltd holds personal information about an individual, we will provide the individual with access to the information on request by the individual, except to the extent that:

  • in the case of personal information other than health information-providing access would pose a serious and imminent threat to the life or health of any individual; or

  • providing access would have an unreasonable impact upon the privacy of other individuals; or

  • the request for access is frivolous or vexatious; or

  • the information relates to existing or anticipated legal proceedings between the organisation and the individual, and the information would not be accessible by the process of discovery in those proceedings; or

  • providing access would reveal the intentions of Transhold Systems Ltd in relation to negotiations with the individual in such a way as to prejudice those negotiations; or

  • providing access would be unlawful; or

  • denying access is required or authorised by or under law; or

  • providing access would be likely to prejudice

    an investigation of possible unlawful activity; or

    the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law; or

    the enforcement of laws relating to the confiscation of the proceeds of crime; or

    the protection of the public revenue; or

    the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct; or

    the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of its orders;by or on behalf of an enforcement body; or

  • an enforcement body performing a lawful security function asks Transhold Systems Ltd not to provide access to the information on the basis that providing access would be likely to cause damage to the security of the country.

However, where providing access would reveal evaluative information generated within Transhold Systems Ltd in connection with a commercially sensitive decision making process, Transhold Systems Ltd may give the individual an explanation for the commercially sensitive decision rather than direct access to the information.

If Transhold Systems Ltd is not required to provide the individual with access to the information because of one or more of the above paragraphs Transhold Systems Ltd will, if reasonable, consider whether the use of mutually agreed intermediaries would allow sufficient access to meet the needs of both parties.

If Transhold Systems Ltd charges for providing access to personal information, those charges:

  • will not be excessive; and

  • will not apply to lodging a request for access.

IfTranshold Systems Ltd holds personal information about an individual and the individual is able to establish that the information is not accurate, complete and up-to-date,Transhold Systems Ltd will take reasonable steps to correct the information so that it is accurate, complete and up-to-date.

If the individual and Transhold Systems Ltd disagree about whether the information is accurate, complete and up-to-date, and the individual asks Transhold Systems Ltd to associate with the information a statement claiming that the information is not accurate, complete or up-to-date, Transhold Systems Ltd will reasonable steps to do so.

Transhold Systems Ltd is obliged to provide reasons for denial or refusal of access to correct personal information. If you would like to access any personal information held by Transhold Systems Ltd about you, please do not hesitate to contact the Privacy Officer below.

 

Identifiers

Transhold Systems Ltd does not use identifiers such as Tax File Numbers to identify individuals.

 

Anonymity

Where lawful and practicable, Transhold Systems Ltd will provide individuals with the option of not identifying themselves when providing personal information.

 

Transborder Data Flows

Transhold Systems Ltd may transfer personal information about an individual to someone (other than Transhold Systems Ltd or the individual) who is in a foreign country only if:

  • Transhold Systems Ltd reasonably believes that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information; or

  • the individual consents to the transfer; or

  • the transfer is necessary for the performance of a contract between the individual and Transhold Systems Ltd, or for the implementation of pre-contractual measures taken in response to the individual’s request; or

  • the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the individual between Transhold Systems Ltd and a third party; or

  • all of the following apply:

    the transfer is for the benefit of the individual;

    it is impracticable to obtain the consent of the individual to that transfer;

    if it were practicable to obtain such consent, the individual would be likely to give it; or

  • Transhold Systems Ltd has taken reasonable steps to ensure that the information that it has transferred will not be held, used or disclosed by the recipient of the information inconsistently with this Privacy Statement.

 

Sensitive Information

GenerallyTranshold Systems Ltd does not collect sensitive information. In the event Transhold Systems Ltd does wish to collect sensitive information however, we will not do so unless:

  • the individual has consented; or

  • the collection is required by law; or

  • the collection is necessary to prevent or lessen a serious and imminent threat to the life or health of any individual, where the individual whom the information concerns

    is physically or legally incapable of giving consent to the collection;

    physically cannot communicate consent to the collection; or

  • the collection is necessary for the establishment, exercise or defence of a legal or equitable claim.

 

Removal from Transhold Systems Ltd Mailing Lists

Should you decide that you no longer wish to receive promotional and marketing material from Transhold Systems Ltd, please advise as directed on the material you have been sent or via email, fax or letter being sure to include your name, address and contact details.

 

Complaints Management

Individuals are to direct all complaints to Transhold Systems Ltd’s privacy officer.

To be removed from a distribution list:

  • Transhold Systems Ltd requires this request to be advised in writing via email, letter or fax.

  • Transhold Systems Ltd will notify all departments within Transhold Systems Ltd to remove the individual from distribution lists.

  • Transhold Systems Ltd will advise the individual in writing that this request has been actioned.

To access information held by Transhold Systems Ltd:

The individual is to advise Transhold Systems Ltd in writing via email, fax or letter. (See below, Access to Personal Information held by Transhold Systems Ltd)

 

Access to Personal Information held by Transhold Systems Ltd

When an individual requests access to their personal information, Transhold Systems Ltd will:

  • take all reasonable endeavors to take action within 30 days of receipt of notification from the individual;

  • require individuals to provide written notification to access personal information held by Transhold Systems Ltd;

  • evaluate the request for access to determine motivation for requesting access: e.g. is the request frivolous or vexatious?

For a valid request,Transhold Systems Ltd’s privacy officer will:

  • inform all relevant departments that this individual has requested to access the information held;

  • consolidate all of the information;

  • discuss with the individual how they would like to view this information:

    If personally, Transhold Systems Ltd’s privacy officer and the individual will arrange a meeting time and place;

    If via letter / photocopies, Transhold Systems Ltd’s privacy officer will prepare and send these to the individual.

 

Enquiries

If you require any further information or confirmation about this Privacy Statement or if you are concerned that Transhold Systems Ltd is not complying with its privacy obligations in respect of your personal information, please contact:

Postal Address:263 Te Matai Road Palmerston North 4470 New Zealand

Phone:(06) 3571452

Fax:06 3549898

Email:sales@transholdsystems.com

Website:http://www.transholdsystems.com/

In addition, please find below our statement relating to personal information collected online.

 

Protection and use of information collected on-line

 

Use and purpose of collected personal data

On our Web sites we only collect information relating to you with your permission. You may choose to reveal information to us if, for example, you register or complete a survey. Companies in the Transhold Systems Ltd group may use the information internationally in connection with processing your inquiries and orders or to help improve our products and services. We would only share such information with third parties outside the Transhold Systems Ltd group with your express permission or as required by law. It is used solely for the purposes described below.

 

Online security

Transhold Systems Ltd supports secure online shopping using secure server technology, because we want your shopping experience to be simple and safe. There are state-of-the art security arrangements and facilities on Transhold Systems Ltd sites to prevent security abuse. The secure server technology used on Transhold Systems Ltd Store encrypts your personal financial information before it is transmitted over the Internet. This technology works best when the store site is viewed using a browser that supports secure server technology.

 

Privacy across the entire Transhold Systems Ltd network

As a global company, Transhold Systems Ltd operates a number of Web sites around the world. Any information that you submit to one of our sites in any one country or language may be sent electronically to a server for one of these sites in another country. As such, the information may be used, stored, or processed outside the country where it was recorded. We safeguard your privacy interests around the world by ensuring that the Transhold Systems Ltd site adheres to our policies described in this statement. We bind our employees to observe your privacy and confidentiality rights.

 

Consent

By using our Web sites, you consent to the collection and use of the information as described here. If we decide to make changes to this privacy statement, we will post the changes on this page so that you will always know what information we collect, and how we use it.

 

What information do we collect on-line and why?

 

IP addresses

We may use your IP address to help diagnose problems, to administer our Web site, or to gather general demographic information.

 

Cookies

We use cookies to make your use of our online offering more enjoyable and to deliver personalised content. Cookies help us give you information that interests you, they save you having to reenter your password every time you visit our site, and help to keep track of your shopping cart. Cookies also allow us to better analyse our site traffic patterns so that we can improve our Web offering. We do not follow your browsing path outside of the Fiesta Bulb Marketing Ltd site; Web partners that serve ads onto our Web site may also use their own cookies.

 

User registration

You may choose to fill out a registration form on our Web site with contact information. This information is used to send you requested information or products, to contact you with other product information, news, or promotions, and to learn more about our Web visitors.

 

E-mail addresses

If you give us your e-mail address, we may communicate with you via e-mail. However, we will not share your e-mail address with others outside the Transhold Systems Ltd group of companies without your consent. You can choose not to receive e-mails at any time - for more details, read the Choice/Opt-out section below. Depending how your e-mail application is set up, information about you may be transmitted automatically when you send e-mail to Transhold Systems Ltd.

 

Registration for third-party services at Transhold Systems Ltd

At Transhold Systems Ltd you can register for third party services. Those services are available throughTranshold Systems Ltd, but are provided by a third party, which is typically not affiliated with Transhold Systems Ltd. When you sign up for one of these services, it may be necessary to transfer some of your Transhold Systems Ltd.com registration information to this service provider. Also, if the service you chose requires your e-mail address to fulfill this service, we will also give your e-mail address to the service provider. This means we will pass your e-mail address to a service provider only in the event that you specifically asked for this service and the service cannot be provided without your e-mail address. For privacy practices and opt-out procedures of those service providers, refer to the individual privacy policy of the respective service provider.

 

"Send this to a friend" service

You can choose to forward information, a Web page, or link to someone else using our "Send this to a friend" e-mail service. In order to do that, you provide us with your e-mail address, as well as that of the recipient. This information is used only in the case of transmission errors and, of course, to let the recipient know who sent the e-mail. The information is not used for any other purpose.

 

Shopping

Our site includes order forms that you fill out to request information, products, and services. These forms collect your financial information, such as your banking details or credit card. We will only use this financial information that you submit solely for billing and payment purposes.

 

Online surveys

Occasionally we conduct online surveys. Our surveys may ask you for demographic information, such as postal codes or your industry sector. If the online survey collects contact data, we may use that data to send you further information only if we specifically asked for your permission in the survey. You are free to opt out of receiving future mailings at any time. For more details, read the Choice/opt-out section below.

 

Demographic and user profile data

We may use demographic or user profile data we collect to tailor your Web experience, showcase content that we think may interest you, and display information that matches your preferences. This data also gives us an insight into your needs and interests.

 

Links to other sites

Our site contains links to other sites. Transhold Systems Ltd is not responsible for the privacy practices or the content of other Web sites. For more information, refer to the privacy policies of the respective site.

 

Choice / opt-out

Transhold Systems Ltd gives you the choice to opt out at any time. You can opt-out of receiving communications from us whenever you like: now or at the point on our site where we request information from you.

 

Unsubscribe from Transhold Systems Ltd newsletter

If you no longer wish to receive our free newsletter Transhold Systems Ltd Newsletter, you can cancel your subscription at any time. Just send an e-mail message to sales@transholdsystems.com with “Unsubscribe” in the subject field.

 

Removal from our registration database

If you wish to be removed from the Fiesta Bulb Marketing Ltd’s Web registration database, please contact:

Postal Address:263 Te Matai Road Palmerston North 4470 New Zealand

Phone:(06) 3571452

Fax:06 3549898

Email:sales@transholdsystems.com

Website:http://www.transholdsystems.com

 

Removal from other Transhold Systems Ltd e-mail lists

If you no longer wish to receive other information or promotional e-mails from Transhold Systems Ltd, follow the opt-out instructions on the last e-mail you received.

Want to learn more? Contact Transhold Systems Ltd for additional information.