Privacy Policy

1. Background

1.1  Your privacy is important to Cooperative Business New Zealand Incorporated (we, us, our) and that is why we wish to make clear in this Privacy Policy (Policy) how we collect, use, disclose and protect your personal information. This Policy also sets out the way in which we comply with our obligations under the Privacy Act 2020 (Privacy Act).

1.2  This Policy should be read alongside the following documents:

(a) the Cooperative Business NZ Constitution, Bylaws and Rules;
(b) the terms of use for our website at nz.coop (Website); and
(c) the terms of use for the chatbot featured on our Website (Chatbot).

These documents may include other information about how we perform our functions and make our Website and Chatbot available to you (Services).

2. Changes to this Policy

2.1  At our discretion, we may change our Policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this Policy, we will post the changes here at the same link through which you are currently accessing it.

2.2  Any changes will be effective from the date that the revised Policy is uploaded. We encourage you to review the Policy regularly for the latest information on our privacy practices.

2.3  This Policy was last updated on 14 October 2024.

3. Purposes of collection

3.1  We collect personal information from you for the purpose of facilitating and improving the provision of our Services to you. We also collect your information to provide you with marketing materials where you have consented to us doing so (Purposes).

3.2  We only collect and use your personal information for reasons associated with these Purposes.

4. Your consent to our collection of your personal information

4.1  By engaging with our Services, you consent to your personal information being collected, held and used in accordance with this Policy or for any other use that you authorise.

4.2  Where you access our Services on behalf of a third party, you warrant to us that you have informed those third parties of this Policy and that you have authority to provide consent on behalf of that third party.

5. How we obtain your personal information

5.1  Source of information: We may collect your personal information from:

(a) you, when you provide that information to us, including but not limited to when you:

(i) become a Member of Cooperative Business NZ;
(ii) apply to attend our conferences and other events;
(iii) nominate your business and leaders for our Annual Business Awards;
(iv) register for professional development / training programmes;
(v) use our Member Services;
(vi) make enquiries about or apply to be a part of our programmes; or
(vii) otherwise provide information to us voluntarily in order for us to provide you with our Services; or

(b) third parties, where you have authorised that your information be shared with us (such as through interaction with any of our advertising on social media or any other website that does not belong to us, or where you have authorised others to disclose your information to us, such as our Corporate Associate Members); or

(c) other sources where the information is publicly available.

5.2  Consequences of not providing us with, or authorising us to collect, information required to provide the Services: You may choose not to consent to our collection of your personal information. Please be aware, however, that should you do so, you, or the organisation that you represent, may not be able to enjoy your Member rights and benefits or we may not be able to provide you with some or all of our Services, including, without limitation, registration, notification of, or participation in:

(a) upcoming events and training;
(b) attendance and voting at an Annual General Meeting;
(c) access to the Online Services; and
(d) respond to any queries or requests for information you have submitted.

6. The personal information that we may collect

6.1  Information about you:

(a) In providing you with our Services, we may collect the following personal information from you:

(i) your name;
(ii) your contact details (including your email address and phone numbers); and
(iii) your address.

(b) Where you are (or wish to become) a member of ours, we, as an incorporated society, are required to collect certain information about you as required by the Incorporated Societies Act 2022. In addition to collecting the information set out in 6.1(a) above, we may also collect the following information from you:

(i) the date that you became a member of our incorporated society; and
(ii) any other information we are required to collect from you pursuant to the Incorporated Societies Act 2022, regulations made under that Act, or any other law which compels us to collect other information about you.

6.2  Payment information: If you are applying for membership with, or purchasing paid Services from, us we will also collect your payment information for the purpose of processing your payment. Your card information will not be retained after we have processed your payment.

6.3  Information provided to Chatbot:

(a) Our Website features a generative AI Chatbot licensed to us by Chatbase.co, Inc (Chatbase). To the extent that any personal information is disclosed to the Chatbot, it will be treated, administered and dealt with by us in accordance with this Policy. For further information about the terms that apply to the Chatbot, please see the Chatbot Terms located at our Terms of Use – CBNZ Chatbot page.
(b) To the extent that Chatbase receives personal information through your use of the Chatbot, Chatbase’s privacy policy will apply.
(c) In using the Chatbot, you acknowledge and agree that:

(i) any personal information that you provide to the Chatbot may be stored, processed, or otherwise disclosed to Chatbase’s partners located within the United States of America (USA);
(ii) depending on where in the USA Chatbase transfers your personal information, it may not be subject to equivalent data protection laws as in New Zealand; and
(iii) for the purposes of Privacy Principle 12 of the Privacy Act 2020, you have been expressly informed by us that Chatbase may not be required to protect your personal information in a manner that offers comparative safeguards as those offered under the Privacy Act 2020; and
(iv) you nevertheless authorise us to disclose your personal information to Chatbase should you choose to use the Chatbot.

6.4  Accuracy of information: You are responsible for ensuring that all information provided to us about you is current, complete and accurate. If we believe that the information you provide is not current, complete, or accurate, we have the right to decline you access to information or Services, deny access to certain parts of our Website, decline your application for membership with us or applications for event registrations until current, complete or accurate information is provided.

6.5  Queries: More detailed information about why we collect the personal information outlined above is available upon request.

7. Device information, cookies and Google Analytics

7.1  Device information:

(a) We may also collect technical information about your device when you access our Services. This includes information about your:

(i) device and web browser.
(ii) mobile phone carrier;
(iii) date and time of your use of the Services;
(iv) approximate location of device;
(v) IP address; and
(vi) interactions with our Services, and
we will treat this information as personal information.

(b) Your device may allow you to restrict our ability to view this information. In some instances, this may mean you are unable to use some or all of our Services.

7.2  Cookies:

(a) We also collect information about your usage of our Website through the use of cookies. Cookies are an alphanumeric identifier that is transferred to your device’s storage so that we can recognise you on future visits. We use the information gathered from these cookies in the administration and improvement of our Website.
(b) If you do not authorise us to use cookies, you may disable cookies by changing the settings on your web browser. Please note that this may mean that you cannot use some or all of the features of our Website.

7.3  Google Analytics: We use Google Analytics to monitor search behaviour and measure traffic flows on our Website. Information on how Google collects and processes data can be viewed at https://policies.google.com/technologies/partner-sites (or any other link Google may provide from time to time).

8. How we use your personal information

8.1  General matters: We use your personal information in accordance with the Purposes for which we collected that information. Matters for which your information may be used include:

(a) verifying your identity and contact details;
(b) communicating with you, including via email, phone, SMS or RCS;
(c) providing our Services to you (including in accordance with clause 8.2);
(d) improving our Services and customising our delivery of the Services to you;
(e) billing you and collecting money that you owe us;
(f) conducting research and statistical analysis (on an anonymised basis where possible);
(g) protecting and/or enforcing our legal rights and interests, including defending any claim;
(h) carrying out, and complying with, our administrative, business, and legal requirements including, but not limited to, administration of the Member products and Services we make available to you and ensuring compliance with our Constitution and Bylaws; and/or
(i) performing any other matters necessary to fulfil the Purposes, or as otherwise authorised by you or the Privacy Act.

8.2  Specific matters: In providing our Services to you, the following specific activities may be carried out using your personal information:

(a) processing membership applications, upgrades and membership renewals;
(b) facilitating meetings of members, including Annual General Meetings;
(c) conducting events;
(d) distributing our publications, newsletters and promoting Services (where you have consented to receiving such marketing materials);
(e) conducting competitions and promotions; and
(f) managing the safety and security of our members and other users of our Services.

9. Who we disclose personal information to

9.1  We may disclose your personal information to:

(a) 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 our Website or other Services, any payment providers, any fraud detection partners, marketing and advertising partners, and customer support partners;
(b) third parties such as sponsors, strategic partners, exhibitors and guest speakers, and any other third party who requires the information in order for us to provide you with our Services (but only to the extent required to allow us to provide you with the Services);
(c) other third parties (for the purpose of performing anonymised statistical information);
(d) any other person authorised by the Privacy Act or another law (such as a law enforcement agency); and/or
(e) any other person authorised by you.

9.2  We may also disclose your personal information to any entity that we enter into any joint venture with or any other business that we are sold to or merged with.

9.3  We will only disclose personal information to the parties listed above if it is necessary and appropriate to facilitate the Purposes for which your personal information was collected pursuant to this Policy, and only to the extent that disclosure is required to fulfill the Purposes.

10. Direct marketing

10.1  Where you have given consent to do so, we will use your personal information to directly market our Services to you. We may carry out this direct marketing by online advertising, email, phone, or post.

10.2  You have the right to revoke your consent to receive direct marketing at any time by contacting us.

11. How we protect your personal information

11.1  We ensure that we protect your personal information with reasonable security safeguards which protect against unauthorised use, access, modification or disclosure of your personal information.

11.2  In some cases, the personal information that we collect from you may be processed outside of New Zealand. Where this is the case:

(a) in the case of the Chatbot, clause 6.3(c) applies; and
(b) in other cases, we will endeavour to ensure that third parties to which we disclose personal information to overseas offer equivalent protections for your personal information as those offered under the Privacy Act.

12. Notification in event of privacy breach

12.1  Should your personal information be compromised, we will follow the notification procedure set out in the Privacy Act.

13. Your rights to access, correction and deletion of your personal information

13.1  Under the Privacy Act, you have the following rights:

(a) The right to be informed about how your data is being used. If you would like further information beyond that provided in this Policy, please contact us.
(b) The right to access readily retrievable personal information held by us about you. However, please note that this right is subject to certain grounds for our refusal as outlined in the Privacy Act.
(c) The right to request corrections to the personal information that we hold about you. Should you request a correction, we will make the correction should the correction be reasonable and we are reasonably able to make it. If we are unable to, we will take reasonable steps to note the requested correction in our records against your data.

13.2  If you would like to exercise the above rights, please contact us. In your correspondence, please clearly state what information you are requesting, provide evidence of your identity, and notify us of anything else you deem relevant to your request.

14. Third party links

14.1  Our Services may link or connect via APIs to external sites that are not operated by us (including, but not limited to, the Chatbot). Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices. We suggest that you review the privacy policy of any third party site before you provide your personal information to that site’s owner.

15. Contact details

15.1  Our data privacy officer is responsible for overseeing your personal data requests. If you have any questions or intend to exercise your legal rights, we would appreciate the first opportunity to deal with your concerns, so please contact the data privacy officer as set out below:

Data Privacy Officer: Saya Wahrlich (CEO)
Email: info@nz.coop
Address: 1 Albert Street, Auckland Central, Auckland 1010, New Zealand

15.2  If you are not satisfied with our response or believe we are processing your information unfairly, unlawfully or without transparency, then you can complain to the Office of the Privacy Commissioner. You can find more information about the Privacy Commissioner and their complaints procedure at privacy.org.nz.