ActionHQ Privacy Policy

1.    Applicability of This Privacy Policy

This Privacy Policy (“Policy”) describes how Actionmail Limited (trading as ActionHQ), a private limited liability company incorporated in New Zealand, incorporation number 805411 (“we”, “our”,“us”) collects, uses and discloses information from users of our website actionhq.co.nz, letterlatch.com, vetserve.co.nz, numerous campaign websites which ActionHQ host for specific customer project registrations, event participation, phone calls, emails, physical mail, job applications, other business interactions and situations where ActionHQ is the controller (“Services”), and from the use of our hardware, software, and professional services (collectively “Offerings”). For purposes of this Policy, the terms “user,” “you,” and “your” are meant to refer to the individuals (including individual personnel at Customers) about whom we may collect information, and at times may be used within this Policy interchangeably. “Customer” refers to the entity that purchases/uses our Offerings.  

Openness and transparency are important to us. The New Zealand Privacy Act 1993 requires ActionHQ - like any other NewZealand entity - to tell you certain things about the personal information we need to carry out our functions. This is where we explain our privacy practices and why you can trust us to handle your information with care and respect.

2.    Information We Collect and Receive

We collect the following categories of information (collectively “Information”):

2.1.    Contact Information. If you create an account through our Websites, engage with us through our Services, order our Offerings, request support and maintenance for our Offering, or otherwise contact us, we collect contact information from you and the company that you represent (e.g., your name, title, organization, address, email address, phone number, etc.), in addition to any attachments or additional information you may have included in your communication.

2.2.    Order Information. If you order our Offerings, we collect payment and shipping information including billing contact information, payment method, shipping address, shipping contact information, etc.

2.3.    Cookies. If you engage with our Websites, we may use cookies and other technologies such as pixel tags and web beacons to collect the information. A cookie is a small piece of data that may be stored on your computer or mobile device. It allows a website to “remember” your actions or preferences over a period of time. You do not need to have cookies turned on to visit or use the Website. You can refuse cookies by turning them off on your browser. For more information, you can visit our Cookies Policy here.

2.4.    Third-Party Data. We may receive data about organizations, industries, lists of companies that are our Customers, Website visitors, marketing campaigns and other matters related to our business from our clients or our partners, or others that we use to make our own information better or more useful, for example, how well an online marketing or email campaign performed. This data may be combined with information we collect and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries.

2.5.    Interactive Features. ActionHQ’s Websites, Services, and Offerings may include interactive features (such as community forums) that allow you to disclose information directly to others. Your participation in any such forum is completely voluntary and should correlate with the degree of interaction you want to have with other users. Please note that any Information you disclose on such forums will generally be publicly accessible.

You are not required to provide any Information to ActionHQ but if you do not provide any Information to us, you may not be able to use our Websites, Services or Offerings and we may not be able to authenticate and assist you with your inquiries or requests.

3.    How We Use Information

We use Information in furtherance of our legitimate interests in operating our Websites, Services, Offerings, and business. More specifically, we use Information:

3.1.    To provide, update, maintain, and protect our Website, Services, Offerings, and business. This includes the use of Information to support delivery of the Offerings under a Customer Agreement, to address security or technical issues, analyse and monitor usage, trends, and other activities, or at a User’s request.

3.2.    Required by applicable law, legal process, or regulation.

3.3.    To communicate with you by responding to your requests, comments, and questions. If you contact us, we may use your Information to respond.

3.4.    To develop and improve our Websites, Services, and Offerings.

3.5.    To send emails and other communications. We may send you service, technical, and other administrative emails, messages, and other types of communications. We may also contact you to inform you about changes in our Offerings. These communications are considered part of the Offering and you may not opt-out of them. In addition, we sometimes send emails about new product features, promotional communications, or other news about ActionHQ. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from ActionHQ please reach out through the contact mechanisms described below.

3.6.    To send to you courier and direct mail communication.

3.7.    Employment purposes. If you submit an employment application, we will use your Information to administer and evaluate your application and comply with obligations we have in relation to your application, including confirming your eligibility to work in a given location.

3.8.    For billing, account management, and other administrative matters. ActionHQ may need to contact you for invoicing, account management, and similar reasons and we use your Information to administer accounts and keep track of billing and payments.

3.9.    To investigate and help prevent security issues and abuse.

If Information is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, ActionHQ may use it for any business purpose. To the extent, Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection laws, it is referred to in this Privacy Policy as “Personal Data” and shall be used in accordance with applicable data protection laws.

4.    Data Retention

We generally retain personal data for as long as needed for the specific business purpose or purposes for which it was collected. In some cases, we may be required to retain personal data for a longer period time based on laws or regulations that apply to our business or for other necessary business purposes. Where possible, we aim to anonymize the information or remove unnecessary identifiers from records that we may need to keep for periods beyond the original retention period. 

5.    How We Share and Disclose Information

We may share and disclose your Information in the following scenarios:

5.1.    Upon your instruction.

5.2.    To our business partners such as system integrators, distributors, resellers and channel partners, so they can provide you with information you have requested on a Service or Offering, or follow up on a sales lead.

5.3.    To our third-party service providers, who act on our behalf and instructions to fulfil Offering orders, deliver Services, provide IT, provide billings and corporate functions, and to fulfil the other purposes set forth above.

5.4.    To a prospective or actual purchaser or seller in the context of a merger, acquisition, or other reorganization or sale of our business or assets.

5.5.    As required by applicable law, including, without limitation, in response to any government or regulatory agency request, to cooperate with law enforcement investigations, or upon receipt of any court order. To courts and public authorities to protect you, us, or third parties from harm, including fraud or instances where somebody’s physical safety is at risk.

5.6.    With your consent.  

6.    Third-party websites

We may provide links to other third-party websites and services that are outside our control and not covered by this Policy. We encourage you to learn about the privacy practices of those third parties.

7.    Security

We implement physical, administrative, and technical safeguards designed to protect your Information from unauthorized access, use, or disclosure. We also contractually require recipients of your Information to protect such information from unauthorized access, use, and disclosure. The Internet, however, is never 100% secure or error-free, and we cannot ensure or warrant the security of any Information you provide to us.

8.    Unsolicited email

Publication of email addresses on our websites should not be taken as deemed consent to receiving unsolicited email. Persons or organisations wishing to send email material to individuals or organisations whose email addresses appear on our websites must comply with the requirements of the New Zealand Unsolicited Electronic Messages Act 2007.

9.    Age Limitations

Our Websites, Services and Offerings are not intended for use by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with information, please contact us and we will take steps to delete such information.

10.  Changes to This Privacy Policy

This Policy is effective as of April 1, 2020. We reserve the right to change, modify, add, or remove portions of this Policy from time to time and will provide you with notice of such updates as required by applicable law. To the extent, we wish to use your Information other than for the purpose it was collected, we will notify you of that other purpose and seek your consent as required by applicable data protection laws. We recommend that you regularly revisit this Policy to learn of any changes.

11.  International Data Transfers

ActionHQ may transfer your Personal Data to countries other than the one in which you live. For example, ActionHQ digital mailbox solution LetterLatch is hosted by global hosting provider Amazon Web Services (AWS), whose servers are hosted outside of New Zealand.

12. Identifying the Data Controller and Processor

Data protection laws in certain jurisdictions differentiate between “controller” and “processor” of Personal Data.

If you are using our Website or Service, the data controller is the ActionHQ entity operating such Website or Service, which will be identified in the terms and privacy disclosures relating to that Service.

If you are communicating with the personnel of an ActionHQ entity in-person or via phone, email, or mail, the data controller is the ActionHQ entity with whom you are communicating and any other ActionHQ entity with whom you or your organization does business.

Where ActionHQ is the controller of your personal data, as described above, you can reach us at Unit 1, Building F, 4 Orbit Drive, Rosedale, Auckland 0632, New Zealand, or telephone: +64 9 415 4508 or email privacy@actionhq.co.nz.

13. Your Rights

If you are receiving our commercial email communications and no longer wish to receive them, please click on the “opt-out” link in the communication or please contact us at privacy@actionhq.co.nz.

Individuals located in certain countries, including the European Economic Area and the United Kingdom, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can do this by emailing your request to privacy@actionhq.co.nz.

Individuals located in certain countries, including the European Economic Area and the United Kingdom, subject to applicable law, also have the right to (i) restrict ActionHQ’s use of Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority. Once the United Kingdom is no longer a Member State of the European Union, if you are a resident of the United Kingdom and believe we maintain your Personal Data within the scope of the applicable laws relating to personal data in the United Kingdom, you may direct questions or complaints to the UK supervisory authority, the Information Commissioner’s Office.

To the extent that ActionHQ’s processing of your Personal Data is subject to the General Data Protection Regulation (or applicable laws covering the processing of Personal Data in the United Kingdom), ActionHQ relies on the legal basis of its legitimate interests to process your Personal Data. ActionHQ may also process Information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to ActionHQ’s use of your Personal Data for this purpose at any time.

14. Your California Privacy Rights

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”

For more details about the personal information we have collected over the last 12 months, including the categories of sources, please see the Information we Collect and Receive section above. We collect this information for the business and commercial purposes described in the How we Use Information section above. We share this information with the categories of third parties described in the How We Share and Disclose Information section above. ActionHQ does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt-out). Please note that we do use third-party cookies for our advertising purposes as further described in our Cookie Policy.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt-out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at privacy@actionhq.co.nz. We will verify your request using the information associated with your account, including the email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

15. Contact Us

Please feel free to contact us with any comments, questions, complaints, or suggestions you might have regarding the information practices described in this Policy. You can reach us at ATTN: Privacy Office: PO Box 204 Albany Village, Auckland 0755, New Zealand, or telephone: +64 9 415 4508 or email privacy@actionhq.co.nz.