Laybuy Holdings Limited
Website Privacy Policy
Date: 4 February 2022
Laybuy Holdings Limited and its related companies and affiliates ("we", "us", "our") is committed to respecting your privacy. We will always collect, store, use and disclose your Personal Information under the Privacy Act 2020.
However, we have also put in place the following Privacy Policy to protect your Personal Information when you submit, or we collect, that information – including via our "Online Services", such as:
- information offered on, and provided by our website ("Website");
- information and services offered on, and provided by signing up for a User Account on our Website ("User Account");
- social media pages, including Facebook, Twitter, YouTube and Instagram; and
- email communications and subscription services.
By providing us with Personal Information, you consent to the collection, storage, use and disclosure of Personal Information following this Privacy Policy.
In this policy, "Personal Information" means information about an identifiable individual. By way of example, this type of information includes your name and contact details.
1. Changes to this Privacy Policy
We may modify, amend, change or replace any of the terms, conditions or provisions of this Privacy Policy from time to time, and will notify you of any changes by posting a notice with the updated version on our website, or via email if you have a User Account with us. It is your responsibility to check this Privacy Policy periodically for changes.
Your continued use of our Online Services following notification of any changes to this Privacy Policy will be taken as acceptance of those changes. If you do not agree with any aspect of the updated Privacy Policy, you must immediately cease all use of our Online Services.
2. What Information do We Collect?
Information you provide
You may give us information about yourself, such as your name, address, email address, telephone number, and credit card details, drivers licence and passport details depending on which one of our Online Services you use.
Information collected about you
When you visit our Website or other Online Services, we may collect more information, such as the address of your Internet service provider, the name of the web page directing you, and your clicks and activity on our site.
Clickstream data and other related information about visits to our Website and related Online Services may be collected. In addition to this, usage and performance data through our Website using various platform-specific tracking technologies available to the Website may be collected.
Cookies and other monitoring devices
We may collect aggregated information by using cookies. Cookies are unique identification numbers like tags that are placed on the browser of internet users. The cookies do not in themselves identify users personally, but may link back to a database record about them. We may use cookies to track any aspect of our Website or other Online Services.
We may use services such as Google Analytics, which will issue cookies from their own servers and which will be able to track website visitors throughout relevant websites. We do not control how those cookies are issued, or the data that they store.
We may use "web beacons" (electronic images also known as pixel tags or clear gifs) to recognise a cookie on your computer when you view or act upon a web page, an advertisement that we have placed on a third party web page, or an email or other electronic communication that we have sent.
Application information for Android devices: We collect application information installed on your device to help us detect any risky applications or potential fraud. If we detect suspicious activity on your applications, we may take steps to fix this through our app. This helps protect both you and us from financial crime.
3. How is Your Personal Information Used?
We do not sell, trade or rent your Personal Information to others.
We may (and may authorise third parties to) use your Personal Information to process your transactions and to help us develop, improve, manage, administer and facilitate our services and operations - including to provide the Online Services, to help us to develop our Online Services to be more available and user friendly to our customers, to administer your User Account, for safety and security issues, for our internal purposes (such as risk management, staff training and billing), to conduct market research, for any purpose permitted by law, and for any other use directly related with such purposes or which you may authorise.
In addition, we may use your Personal Information to promote and market our products and services, or the products and services of others. However, we will not do this by email or text (except as part of an email which facilitates, completes or confirms a transaction with you) unless we have your express or deemed consent to do so. These emails and texts will always include an "unsubscribe" facility (see section 9 for more information on email and text communication).
4. In what Circumstances might We Disclose Your Personal Information?
We may use third parties to perform services on our behalf. In particular, we may use third parties to run a credit and identity check on you when you sign up for a User Account. They will have access to your Personal Information needed to perform these services, but we will not authorise them to use your information for any other purposes.
In addition, we may also disclose Personal Information to our related companies (see section 5 for further details) and provide statistics about our customers, sales, traffic patterns and related site functions to reputable third parties.
We will not otherwise disclose your Personal Information unless we believe on reasonable grounds that you have provided your authorisation. However, you should be aware that we may be required to disclose your Personal Information without your consent to comply with any court orders, subpoenas or other legal processes or investigations including by tax authorities if such disclosure is required by law. Where possible and appropriate, we will notify you if we are required by law to disclose your Personal Information.
5. Disclosure Overseas
We communicate with our related companies in Australia, the United Kingdom and the United States from time to time. Therefore some disclosures may occur outside New Zealand. If we disclose your Personal Information to one or more of our related companies, any use of your Personal Information by those companies will be done following their respective Privacy Policies which can be viewed here for Australia, here for the United Kingdom and here for the United States.
When we disclose your Personal Information outside of New Zealand, we will only do so in accordance with the Privacy Act 2020 and take all reasonable measures to ensure that your information is held, managed and accessed following appropriate standards for the handling of Personal Information.
6. Storage and Security
We are committed to protecting the security of your Personal Information and we take all reasonable precautions to protect it from unauthorised access, modification or disclosure.
We use industry-standard (or better) administrative, physical and technical protections to safeguard the security, privacy, confidentiality and integrity of your Personal Information.
7. Privacy Breaches
The Privacy Act 2020 requires us to notify affected individuals and the Office of the Privacy Commissioner about ‘notifiable privacy breaches’. A notifiable privacy breach means a privacy breach that it is reasonable to believe has caused serious harm to an affected individual or individuals or is likely to do so.
We will investigate and assess a privacy breach concerning the factors set out in the Privacy Act 2020 to determine whether the breach is a ‘notifiable privacy breach’. Even if we decide the breach is not notifiable, we may decide it is appropriate to notify you anyway as part of our commitment to taking privacy seriously.
8. What About Links to Other Websites?
Our Online Services may contain links to other websites that are not under our control. These websites may use cookies. It is the responsibility of those third parties to collect appropriate consents from you to permit their own cookies (to the extent this is required by law) and to inform you about the cookies they use. You should check the Privacy Policy on all third party websites to ensure you are comfortable with third-party cookies.
We have no responsibility for linked websites and provide them solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or warranties about their accuracy, content or thoroughness. Your disclosure of Personal Information to third party websites is at your own risk.
9. Email and Text Communications
We are committed to full compliance with the Unsolicited Electronic Messages Act 2007.
By subscribing to emails and/or text communications, or otherwise providing your email address and/or mobile number, you consent to receiving emails and/or texts (as the case may be) that promote and market our products and services, or the products and services of others, from time to time.
You can unsubscribe from our email communications and/or text communications at any time by clicking the "Unsubscribe" link in any promotional or marketing email or text received or by emailing an unsubscribe request to [email protected].
Once you have unsubscribed from the email or text communications, you will be removed from the corresponding marketing list as soon as is reasonably practicable.
10. How You can Request Access or Correct Your Personal Information
You may request access to the information we hold about you, or request that we update or correct any Personal Information we hold about you, by setting out your request in writing and sending it to us at [email protected].
We will review your request as soon as reasonably practicable. If we are unable to give you access to the information you have requested, we will give you reasons for this decision following the requirements of the Privacy Act 2020 when we respond to your request.
We will only keep your Personal Information for as long as we require it for the purpose for which it was collected. However, we may also be required to keep some of your Personal Information for specified periods, for example under certain laws relating to companies, money laundering and financial reporting legislation.
11. How to contact us
Online please email us at [email protected].
In writing to Laybuy, Level 1: B:Hive 74 Taharoto Road, Takapuna, Auckland 0622, New Zealand.