Southern Hemisphere Proving Grounds Limited (“SHPG” or “we”, “us” or “our”) recognises the importance of protecting your privacy. We comply with our obligations under the New Zealand Privacy Act 2020 (the “Act”) with respect to the collection, storage, use and handling of your personal information, including by taking all reasonable steps to ensure that any personal information we store about you is secure.

Personal information is any information about an individual that allows an individual to be identified.

This Privacy Policy explains how we handle your personal information and your rights to access and correct your personal information. As someone who deals with us and provides us with personal information, you agree to be bound by this policy.

The type of personal information we collect

In order to conduct our business, including to provide services, to the best of our ability, we may collect:

• identifying information about you, such as your name, contact information, your address and your photo;
• payment details and other financial information;
• information about your transactions with us, including services that you acquire from us and/or services or products you provide to us;
• CCTV footage at various locations at our site (for safety and security purposes);
• information collected during any induction process whether online or otherwise;
• any information, including health information, collected during any incident or accident at SHPG’s premises; and
• other information relating to your use of our services, or your business or service relationship with us.

We may collect other personal information from time to time. We will only collect information when it is necessary or we consider desirable to conduct our business (including to provide or obtain products and/or services) or where required by law.

We may store the above information for possible future communications relevant to the purpose of collection.

How we collect your information

We may collect personal information from you in a variety of ways. We will generally collect personal information from you directly, including through the following means:

• when you first commence a business or service relationship with us;
• while providing any of our services to you;
• when you use our website as our web server logs may collect additional information, including information about the domain or ISP that you use and computer or network information;
• during your interactions and correspondence with us, including by recording telephone calls between you and our personnel; and
• from CCTV video surveillance systems which record footage at various locations at our site.

We may also collect your personal information from third parties where you have authorised this, this is permitted by law, or where the information is publically available. This may include information from:

• a contractor, supplier or other third party helping to provide services to you (including information collected as part of the online induction process for SHPG); and
• third parties who have advised you that they may pass your personal information on to us.

Purposes for which we may use your personal information

The personal information you provide to us may be used by us for:

• verifying your identity;
• providing services to you and dealing with your requests, enquiries or complaints and other customer related activities;
• our internal business and administrative purposes, including training and assessing performance of our staff or analysing our business or business tools;
• interacting and communicating with you;
• internal research and trials;
• complying with New Zealand laws;
• monitoring the safety and security of, and preventing, detecting and mitigating threats or unauthorised access to or attacks on, our and our customers’ staff, facilities, testing plant and equipment and facilities, and for completing incident investigations and for forensic and remediation purposes;
• detecting and deterring criminal behaviour on our sites or potential misconduct by staff which could result in investigation and potential disciplinary action;
• engaging with government authorities and regulatory authorities; and
• other purposes for which you have given permission or which are allowed by law.

We may also use your information in an anonymised aggregated form, to carry out analysis of our services and customer interactions.

Sharing your personal information

We may provide your personal information to, and it may be used by, the following, where relevant to them:

• our employees, contractors, suppliers and agents;
• affiliated and related companies of SHPG;
• other third parties who help provide services;
• our advisors;
• a business that supports our services (e.g. a business that hosts or maintains our IT system, data centre or website);
• service providers engaged in connection with our business, including to protect our business or any of our assets;
• any court, tribunal or regulatory authority, including government agencies with statutory law enforcement responsibilities, where disclosure is required or allowed by law; or
• other third parties, where we consider it is appropriate to do so in connection with any of the purposes set out above.

We can also release personal information to third parties as authorised by you or by law, including as permitted by the Act.

Transfer of personal information outside New Zealand

We may from time to time transfer personal information to third parties outlined above who are located outside New Zealand. If we do so, we will ensure your personal information will be protected by comparable safeguards to those in New Zealand law. If your personal information will not be protected by comparable safeguards to those in New Zealand law, we will tell you that this is the case, and only transfer your personal information with your consent.

How we store your personal information

We will store any personal information we collect from you in accordance with our obligations under the Act. In particular we take reasonable steps to ensure the security of your personal information and that it is protected from misuse, loss and unauthorised access, modification or disclosure. CCTV footage will usually be retained for a period of 180 days, after which time it will be deleted.

If a privacy breach occurs which has caused or may cause serious harm to you, we will notify you of this as soon as practicable either directly or, if that is not reasonably practicable, by public notice.

We may store your personal information using a third party service provider (including providers outside New Zealand).

Where we receive information about others from you

If you provide us with personal information about someone else, you must ensure that you are authorised to disclose that information to us, so that, without us taking any further steps required by applicable data protection or privacy laws, we may collect, use and disclose such information for the purposes described in this privacy policy.

This means that you must take reasonable steps to ensure the individual concerned is aware of and/or consents to the various matters detailed in this policy, including the fact that their personal information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual’s right to obtain access to that information, our identity, and how to contact us.

How you can access the information we hold about you

Subject to verification of your identity and some exceptions set out in the Act, you have rights under the Act to find out what personal information we hold about you, to get a copy of that information, and/or to request we correct that information. If you wish to do any of those things, or have any other privacy related queries, please contact our privacy officer, Brodie McPherson at brodie.mcpherson@shpg.co.nz.

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Changes to this policy

We may change this Privacy Policy from time to time and we will tell you about the change in the policy by posting the updated policy on our website. Any change we make to the Privacy Policy applies from the date it is posted on our website.

Updated September 2024.