Privacy Policy

Last updated: March 2020

1. This Privacy Policy (“Policy”) sets out how we collect, store, use, process and disclose your personal information in connection with our website, services and our OpenLoop app (“App”) (collectively, our “Services”). When we refer to “we”, “us” or “our” in this Privacy Policy, we mean Counties Energy Limited, having its offices at 14 Glasgow Road, Pukekohe 2120, New Zealand and our related companies (as that term is defined in the Companies Act 1993). Beyond this Privacy Policy, your use of the App (and associated services) is also subject to our service terms and conditions (“Terms”).

2. We take our obligations in relation to your personal information seriously. We are committed to protecting your personal information and ensuring we comply with all relevant privacy laws, including the Privacy Act 1993 (“Privacy Act”).

3. By providing us with your personal information, you agree to the collection, storage, use and disclosure of your personal information in accordance with this Privacy Policy. If you do not agree, you may not be able to use the Services.

4. We may need to change this Privacy Policy from time to time. If we make any changes, then we will tell you about them by posting an updated policy on our website. By continuing to use the Services, you will be agreeing to any changes to the Privacy Policy. Any changes will take effect from the date we update and post the Privacy Policy, so please check this Privacy Policy when you access our website.

How do we collect your personal information?

5. We collect your personal information for lawful purposes connected to our functions and activities (including providing the Services to you), for purposes directly related to this or where you have agreed we can do so. Information we collect may include:

(a) Registration information: When you sign up for an account with us you give us your name, email address, address, mobile phone number, age and proof of identity (if applicable). We may also collect information, including personal information, from social media websites if you choose to connect your account using your social media account.

(b) Payment details: When you add a credit card or payment method to your account with us, a third party that handles payments for us will receive your card information and this will be collected and processed pursuant to that third party payment providers privacy policy terms.

(c) Communications: If you contact us directly, we may receive additional information about you. For example, when you contact our Customer Support Team, we will receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide. We may also collect information about your engagement with marketing, promotions or offers available through the Services (whether offered by us or any of our third-party service providers).

(d) Location Information: When you open the App on your mobile device, we may receive your location in order to provide you with certain Services. We may also collect the precise location of your device when the App is running in the foreground or background. Your location information is necessary for things like suggesting electric vehicle charging stations available as part of the Services. If you give us permission through your device settings to access your location information, we may also collect your location to identify promotions or service updates in your area.

(e) Device and usage information: We may collect analytics information such as your IP address, web browser type, mobile operating system version, phone carrier and manufacturer, app installations and website activity. To help us understand how you use Services and to help us improve it, we automatically receive information about your interactions with the Services, like the pages or other content you view, your actions within our App, and the dates and times of your visits and usage.

(f) Third party providers. We may also collect your personal information from a third party or other sources where you have authorised this or where it is consistent with the Privacy Act.

(g) Cookies and other tracking technology: Once you access our website or publish content through the Services, we and our third party suppliers that assist us in performing the Services, may collect information by using cookies and usage monitoring software such as pixel tags, web beacons, embedded web links, and similar technology. Information stored or collected regarding your usage of the Services helps us improve and offer the Services you need each time you visit.

Refer to your mobile device or browser’s technical information for instructions on how to delete and disable cookies and other tracking or recording tools, if you wish to do so. Please note that if you delete or choose not to accept cookies from us, you may be missing out on certain features of the Services.

(h) Other information: We may collect any other information that you voluntarily provide to us.

6. You have no obligation to provide any information requested by us. However, if you choose to withhold any information requested, we or our suppliers involved in the provision of the Services may not be able to provide you with services or products that depend on the collection of that information.

How do we use your personal information?

7. We use your personal information only for purposes you have agreed to, for purposes directly related to our functions or activities or where we are authorised to under the Privacy Act.

8. We may use your personal information:

(a) to provide Services to you, including our electric vehicle charging station billing services;

(b) to help us offer, manage, improve and promote the Services and our operations;

(c) to notify you of services, products, offers, events or other benefits offered by us or our business partners that we think may be of interest to you;

(d) to conduct market research and to contact you with market, research or survey communications;

(e) to process transactions;

(f) to confirm any information you have provided to us;

(g) for the prevention, detection, investigation and analysis of incidents around any of our, or our third party suppliers, electric vehicle charging stations; and

(h) any other purposes you agree to.

9. We may de-identify and aggregate data collected through the Services and use it for any purpose. It is important to remember that such information does not identify you individually.

Marketing communications

10. We may contact you using the email address you provide to us to verify your account and for administration purposes, such as account management, customer service or system maintenance.

11. You consent to us sending you information connected with the above collection and use purposes via email or text message when you provide us with your email address and/or mobile phone number. We may also send you updates or push notifications related to the Services such as Service updates or to identify promotions, if you give us your permission. We may send you other information we think you may be interested in and which may market and promote the Services, or the products and services of our third party service providers. The messages you receive from us will have instructions for how you can remove yourself from our mailing list.

12. Email marketing will only be sent to your email address if you have given your consent. You may unsubscribe to any email marketing message at any time by following the unsubscribe instructions contained in the message.

Who do we give your personal information to?

13. We will only disclose your personal information where you have authorised such disclosure, where disclosure is connected to one of our functions or activities or where we are able to under the Privacy Act.

14. Examples where we may disclose your personal information are:

(a) to our service providers in order to provide the Services to you;

(b) to debt collection agencies;

(c) to law enforcement agencies for the purposes of prevention, detection, investigation and analysis of incidents or offences related to the Services;

(d) to meet our legal obligations;

(e) to protect users, ours or other rights, property or safety; and

(f) in order for us to sell any of our assets and parts of our business.

How do we store your personal information?

15. We will retain your personal information for no longer than is required for the purpose for which the information was initially collected and where necessary to comply with our legal obligations.

16. We will only store and process your personal information in New Zealand and Australia.

17. We take reasonable steps to ensure that your personal information is protected against loss, unauthorised access, use, disclosure, alteration or destruction. We adopt policies and procedures to protect your personal information, and we review these regularly.

18. Communications over the internet, such as emails, are not secure, unless they have been encrypted. We may allow third parties to monitor our network for security and information assurance purposes.

Access to, correction, modification and deletion of your information

19. We take reasonable steps to ensure that the personal information we hold about you is accurate. You have the right at any stage to request us to provide you with access to your personal information. We will respond to any request by you to correct or access your personal information as soon as practicable following receipt of such request, but there are exceptions under the Privacy Act where we may not be able to do so. We will tell you if that is the case.

20. If you have any questions or requests for your information, please contact support@openloop.co.nz.