Privacy Policy - Metlifecare

METLIFECARE LIMITED PRIVACY POLICY

INTRODUCTION

Metlifecare Limited is committed to safeguarding personal information and complying with the privacy principles set out in the Privacy Act 1993 (Act), together with the requirements of the Health Information Privacy Code 1994 (Code). This privacy policy governs Metlifecare Limited’s collection, use, disclosure, storage and retention of personal information you may supply to us through your use of our website, products, and services.

You, acknowledge that you have read this privacy policy carefully and that you understand and consent to the collection, use, disclosure, storage, and retention of your personal information as described in this privacy policy when you access or use our website, products, or services. If you do not agree with any term set out in this privacy policy, you should not share personal information on our website, or register to use, or use, our products and/or services.

Unless the context otherwise requires, in this privacy policy, the following terms have the following meanings:

“health information” has the meaning given to that term in the Code;
“personal information” means any information about an identifiable individual, including health information;
“Prospects” means individuals who are not Residents but have expressed interest in, or registered for, our website, products or services;
“Residents” means individuals who are resident at any of our retirement facilities;
“we”, “us” and “our” means Metlifecare Limited, and may include any company within the group of companies of which Metlifecare Limited forms part, as well as its affiliates, officers and employees;
“website” means http://www.metlifecare.co.nz and any other website, internet property or application (including any applications for mobile devices) that are owned or operated by us; and
“you” and “your” means you, whether an individual, company, or other form of entity, and includes Prospects and Residents (as applicable) and includes your authorised representatives (including pursuant to a power of attorney) as the context may require.

CHANGES TO THIS POLICY

We may amend this policy from time to time by posting the revised policy on our website. We will provide you with reasonable notice before we implement any changes by email or by posting a statement on our website. If you do not agree to any amendments, you should notify us at privacy@metlifecare.co.nz, and we will arrange for your personal information to be removed.

If you continue to use our website, or our products or services, or subsequently agree to the amended policy, this will be treated as consent to the collection, use, disclosure, storage, and retention of your personal information as described in this privacy policy.

WHO WE COLLECT YOUR PERSONAL INFORMATION FROM

We collect personal information about you in order to enable you to register for our services and to use our websites and any products or services we provide to you. If you provide it to us, the personal information we collect will include:

your name, email address and telephone number;
your address;
your age/date of birth;
your gender, ethnicity, job title and organisation;
for Residents, details of your bank account;
details of any enquiries you have made to us, and our response to you; and
any other personal information requested by us.

If you provide it to us, we will also collect health information from you, including your medical history, medication and prescription details, clinical notes, and health services you are currently being or have been provided, but only to the extent necessary that such health information is required for us to provide you with the requested products or services.

We collect personal information about you from:

you, when you provide that personal information to us, including via the website and any related service, through any registration or subscription process, through any contact with us (e.g. telephone call or email), or when you buy or use our products or services; and
third parties, where you have authorised us to collect information in this way or the information is publicly available.

Where possible, we will collect personal information from you directly. If we believe on reasonable grounds that you have authorised the collection of your personal information from another person or that you are unable to give your authority and have appointed a representative, then we will collect your personal information from that other person or representative provided that the other person or representative has agreed to the terms of this privacy policy.

If you do not provide us with certain information where required, you may not be able to access or use some parts or all of our website, or our products or services.

We may also use CCTV cameras to record footage at our facilities. This footage may be considered as personal information under the Act. We may use CCTV footage for the purposes of detecting criminal behaviour at our facilities or to monitor the safety and security of our Residents, staff and property and of visitors to our facilities.

HOW WE USE YOUR PERSONAL INFORMATION

The personal information that we collect will only be collected, used, stored, and retained by us:

to verify your identity;
to contact you about registration and/or allow you to register for, and use, our services and products;
subject to your consent (in accordance with the Unsolicited Electronic Messages Act 2007), to market and promote our services and products to you, including contacting you electronically (e.g. by text or email for this purpose);
to improve the services and products that we provide to you;
to undertake credit checks on you (if necessary);
to bill you and to collect money that you owe us, including authorising and processing credit card transactions;
to respond to communications from you, including in relation to requests, enquiries, or complaints, or to otherwise contact you about our products or services;
to conduct research and statistical analysis (provided that any information will be analysed on an anonymised basis and aggregated form) in a manner permitted by New Zealand law;
to protect and/or enforce our legal rights and interests, including defending any claim for any other purpose authorised by you or by the Act or Code; and
to carry out any activity in connection with a legal, governmental or regulatory requirement or in connection with legal proceedings, crime, or fraud prevention, detection or prosecution.

We will not use personal information for the purposes other than described above, unless we have your consent to do so, or, we are required to do so by law.

Where you consent to us using your personal information to market and promote our services and products, you can opt out at any time by notifying us at privacy@metlifecare.co.nz or by clicking the unsubscribe function included in our marketing communications.

COLLECTION OF IMAGES AND PHOTOGRAPHS

We may at times record the image of Residents, unless you opt out by notifying us at privacy@metlifecare.co.nz .These images will be used for publicity and advertising purposes, including (but not limited to) on our social media platforms, in our annual reports and in our marketing material. In agreeing to this privacy policy and unless you have opted out, you consent to the use of your image, and give us the right and unrestricted permission to use, display, distribute, transmit, publish and copy your image through any media or medium. You irrevocably waive any and all moral and performers’ rights in relation to the images to the fullest extent permissible at law and confirm that you have no expectation of compensation or other remuneration, now or in the future, in return for any use of the images.

DISCLOSING YOUR PERSONAL INFORMATION

We may disclose your personal information in accordance with this privacy policy and/or in accordance with your specific instructions or authorisation. We may disclose your personal information to:

another company within the Metlifecare group, which may use your information for the same purposes as us;
our service providers or any business that supports our services and products, including any person that hosts or maintains any underlying IT system or data centre that we use to provide the website or other services and products;
a credit reference agency for the purpose of credit checking you;
other third parties, in an aggregated and anonymised form for statistical purposes;
a person who can require us to supply your personal information (e.g. a regulatory authority);
any other person authorised by the Act, Code or any other law (e.g. a law enforcement agency); and
your authorised representatives and any other person authorised by you.

PROTECTING YOUR PERSONAL INFORMATION

We will take reasonable steps to ensure the personal information we hold is accurate, complete, up to date, stored in a secure environment and safe from loss, unauthorised activity, or other misuse in accordance with our obligations under the Act.

Some of the personal information we collect and hold about you may be considered particularly ‘sensitive’ personal information and subject to additional protections and requirements under New Zealand law (such as health information). Where required by law or regulation, we will handle this type of personal information to a higher standard than other types of personal information due to its special nature.

We will only retain your personal information for as long as it is required to achieve the purposes set out in this privacy policy or as otherwise required by law.

Although we take reasonable steps to ensure personal information in our possession is protected and held securely, we do not make any warranties in relation to the security of any information you disclose or transmit to us and we are not responsible for theft, destruction, or inadvertent disclosure of your personal information where our own security measures have been breached. Any transmission of personal information is at your own risk.

Certain personal information may be transferred and/or stored outside of New Zealand by our third-party service providers, such as Marketo who hosts our data in their servers in Sydney, Australia. Where personal information is transferred outside of New Zealand we will ensure that such third party is subject to comparable privacy laws to New Zealand or is required to protect the personal information in a way that is comparable to New Zealand’s privacy laws.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

Subject to certain grounds for refusal set out in the Act or Code, you have the right to access your readily retrievable personal information that we hold and to request a correction to your personal information that we hold. 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 privacy@metlifecare.co.nz 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).

We may charge you reasonable costs for providing you copies of your personal information or correcting that information, subject to the Act and the Code.

USE OF OUR WEBSITE

If you post any personal information on our website’s message board or chat room, you acknowledge and agree that the information you post is publicly available and may be read or used by other users of our website.

Our website may have links to third party sites. Our privacy policy does not apply to those sites and we accept no responsibility or liability for the content or privacy practices of those sites. The owner of the third-party site will have its own privacy policy relating to your personal information which we suggest you review before you provide any personal information.

We use cookies (an alphanumeric identifier that we transfer to your computer’s hard drive so that we can recognise your browser) to monitor your use of the website for the purposes of providing more customised content to you on our website and conducting business and marketing analysis. All information collected via cookies will be held by us. This information will not be made available to any third party in a manner that enables you to be identified. If you do not wish to allow cookies, you may disable cookies by changing the settings on your browser, although this may mean that you cannot use all of the features of the website.

HOW TO CONTACT US

If you have any queries or concerns about our privacy policy, or our handling of your personal information, please contact us at Metlifecare Limited at Level 4, 20 Kent Street, Newmarket, Auckland, 1023, New Zealand, attention Metlifecare Privacy Officer, or call us on 09 359 8000, or email us on privacy@metlifecare.co.nz.