TETHER PRIVACY POLICY 
 

Last updated:  13 May 2020

Tether is committed to protecting your privacy, so we have prepared this policy to help you understand what information we collect, how we use it, and what choices you have.

 

When we talk about the “Website” in this policy, we are referring to the Tether website at https://www.tether.co.nz/. 
 

When we talk about “Users”, we are referring to our users, who are generally occupants, owners, or property managers of Tether-enabled properties, and any other users of our Services. 

 

When we talk about the “Platform” we are referring to the software, hardware, systems and technology that we use to provide our Services.
 

When we talk about the “Services”, we are referring to the services we provide to our Users, including allowing you to use our Portal, Management App and Occupant App, and access information about the indoor environment quality (IEQ) and energy consumption of Tether-enabled properties. 
 

When we talk about the “Portal” we are referring to our online portal which enables owners and property managers to monitor and manage IEQ and energy consumption in individual properties and across property portfolios. 
 

When we talk about the “Occupant App” we are referring to our mobile application which enables property occupants to view and manage the IEQ and energy consumption within their property and provides them with ways to improve their living comfort and efficiency, and prevent factors that could lead to dangerous conditions. 
 

When we talk about the “Management App” we are referring to our mobile application which enables owners and property managers to collect building information, run compliance certification and manage all Tether Sensors in individual properties and across property portfolios. 
 

When we talk about the “Tether Sensors” we are referring to sensor devices installed in Tether-enabled properties which detect various measurements relating to IEQ and energy consumption, and which allow us to provide Users with IEQ and energy consumption information.
 

When we talk about “personal information”, we are referring to information that identifies you as an individual or relates to an identifiable individual, which can include (for example) name, insurance details, postal address, telephone number, or email address, and can also include IEQ or energy consumption information where it relates to an identifiable individual.

 

Structure of this policy
 

This privacy policy is provided in a layered format so you can click through below to the section which relates to the information that we collect about you.

 
1.    IMPORTANT INFORMATION AND WHO WE ARE
2.    CATEGORIES OF USERS
       (A)    PROPERTY OCCUPANTS
       (B)    PROPERTY OWNERS AND MANAGERS
       (C)    VISITORS TO OUR WEBSITE 
       (D)    OUR BUSINESS CONTACTS AND SUPPLIERS 
3.    PROMOTIONAL COMMUNICATIONS
4.    DISCLOSURES OF YOUR PERSONAL INFORMATION
5.    INTERNATIONAL TRANSFERS
6.     INFORMATION SECURITY
7.    YOUR LEGAL RIGHTS

 

1.    IMPORTANT INFORMATION AND WHO WE ARE


Tether Limited is the company which provides the Website and the Services, and operates the Platform.

 
This privacy policy is issued by Tether Limited. When we mention "Tether", "we", "us" or "our" in this privacy policy, we are referring to Tether Limited.

 
This privacy policy gives you information on how we collect and handle your personal information.

 
Please contact us at Bizdojo, Level 9, Cider Building, 4 Williamson Avenue, Grey Lynn, Auckland, 1021, New Zealand or at Privacy@tether.co.nz if you have any queries in relation to the processing of your personal information under this policy.

 
We have appointed a privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the privacy manager at Privacy@tether.co.nz.


We sometimes update this policy. Please refer back to this page regularly to see any changes or updates to this policy.


2.    CATEGORIES OF USERS


(A)    OCCUPANTS


This section of this policy describes how we process personal information about people who are living in Tether-enabled properties.


If you are living in a Tether-enabled property you can download and access the Occupant App to gain insights into the property you occupy without needing to register an account with us or identify yourself. However, to create a personal profile and receive [customised alerts and information], occupants of Tether-enabled properties will need to provide us with personal information.


Information we collect


We may hold personal information provided to us by you directly through your use of the Services, or collected by Tether Sensors, [or where it’s provided to us by third parties].

 
We may collect, store, and use the following categories of personal information about you: [contact details (including name, title, address, telephone number, personal email address)], gender, age bracket, location details, information we collect through Tether Sensors including IEQ and energy consumption information, [information we collect automatically (see our Cookies Policy)], publicly available information about you and any other personal information you provide in an interaction with the Occupant App.

 
How we use your information


We may store or use your personal information for the following purposes:

 
(a)    to provide the Services to you and to allow you access to the Occupant App, including to present relevant IEQ and energy consumption information to you;
(b)    to hold IEQ and energy consumption information, and your personal information, on our system and to contact you as necessary in relation to the Services;
(c)    to provide you with information about us, our Services, or the Occupant App;
(d)    to allow us to administer and manage your access to the Occupant App;
(e)    to monitor, develop and improve the Website, the Services, the Platform and the Occupant App;
(f)    to update and maintain our records, including details of people that have accessed our Services and the Occupant App;
(g)    to comply with our legal obligations (including detecting, preventing or investigating fraud or crime);
(h)    on an aggregated or anonymised basis (i.e. in a way that doesn’t identify you) to improve the Website, the Services, or the Platform; and for our business                           purposes, such as data analysis, audits, identifying usage, IEQ and energy consumption trends, and developing new products and services; and
(i)    other actions that are necessary to manage our activities or to comply with our legal and regulatory requirements.


We will only use and store your information where this is necessary for the purposes we described above.


If you choose not to provide personal information when requested, this may mean that some of the Services will not be available to you or you may not benefit from certain functionality offered by the Website or Occupant App.

 
(B)    PROPERTY OWNERS AND MANAGERS


The following section of this policy sets out how we process personal information about owners and property managers of Tether-enabled properties, and anyone else that uses our Portal or Management App.


Information we collect


If you create an account to use the Portal or Management App we will collect, store and use the following categories of personal information about you: name, title, address, property details (including address, property type, completion date, specifications), telephone number, personal email address, employer or business information (where you are a property manager), work email address, company name, company contact details, billing information,  information we collect automatically (see our Cookies Policy), publicly available information about you and any other personal information you provide in an interaction with the Platform or Management App.


How we use your information


We may store or use your personal information for the following purposes:

 
(a)    to provide the Services to you and to allow you access to the Portal and Management App, including to present information relevant to you;
(b)    to hold IEQ or energy consumption information, and your personal information, on our system and to contact you as necessary to provide the Services and in line          with our contractual or legal obligations;
(c)    to provide you with information about us and our Services;
(d)    to allow us to administer and manage your access to the Portal and the Management App;
(e)    to monitor, develop and improve the Website, the Services, the Platform and the Management App;
(f)    to update and maintain our records, including details of people that have accessed our Services;
(g)    to comply with our legal obligations (including detecting, preventing or investigating fraud or crime);
(h)    on an aggregated or anonymised basis (i.e. in a way that doesn’t identify you) to improve the Website, the Services, the Platform, the Management App or the                 Occupant App; 
(i)     for our business purposes, such as information analysis, audits, fraud monitoring and prevention, identifying usage, IEQ and/or electricity consumption trends,                and developing new products and services; and
(j)    other actions that are necessary to manage our activities or to comply with our legal and regulatory requirements.

 

We will only use and store your information where this is necessary for the purposes we described above.


If you don’t provide necessary information when requested, then we may not be able to provide you with the Services or access to the Portal or the Management App.

 
(C)    VISITORS TO OUR WEBSITE

 

The following section of this policy sets out how we process personal information about visitors to our Website.


Information we collect


We may collect, use, store and transfer different kinds of personal information about you which you provide to us though our Website: name, address, email address, telephone numbers, technical data (including internet protocol (IP) address, your login information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website, usage information (including information about how you use our Website, products and services), and marketing and communications preferences (including your preferences in receiving marketing from us and your communication preferences).


We use different methods to collect information from and about you including through:

 
(a)    Direct interactions with you, including by filling in forms. This includes personal information you provide when you contact us through the Website. 
(b)    Automated technologies or interactions. See our Cookies Policy for more information on this. 

 

How we use your information


We may use your personal information for the following purposes:

 
(a)    to use information analytics to improve our Website, marketing, and customer experience; 
(b)    to comply with legal or regulatory requirements; 
(c)    to scan and monitor emails sent to us for viruses or malicious software, to process and encrypt personal information to protect and manage email traffic; and
(d)    for our business purposes, such as information analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying                 our Websites, the Services, the Platform, the Management App or the Occupant App, and identifying usage trends.


Where the Website provides links to other websites, we are not responsible for the information protection/privacy/cookie usage policies of these other websites, and you should check these policies on the other websites. If you use one of these links to leave our Website, you should know that we do not have any control over that other website.


(D)    OUR BUSINESS CONTACTS AND SUPPLIERS

 
The following section of this policy sets out how we process personal information about our business contacts, service providers and people who have corresponded with our employees.

 
Information we collect


We may collect, use, store and transfer different kinds of personal information about you which you provide to us including: name, address, email address, telephone numbers, place of work, job title.


How we use your information


We may use your personal information for the following purposes (as applicable):

 
(a)    to hold your personal information on our system and to contact you as necessary in accordance with our contractual arragnements, or on the basis of our                      legitimate business interests;
(b)    to provide you with information about us and our Website, the Services and the Platform;
(c)    to allow us to process payments and orders for any goods and services you provide;
(d)    to comply with legal or regulatory requirements; 
(e)    to scan and monitor emails sent to us for viruses or malicious software, to process and encrypt personal information to protect and manage email traffic; and
(f)    for our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our                      Websites, the Services, the Platform, the Management App or the Occupant App, and identifying usage trends.


If we consider we need your consent in relation to our use of your personal information, we will contact you to request this consent and provide you with full details of the personal information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. If you decide to consent, you have the right to withdraw your consent at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purposes you originally agreed to, unless we have another legitimate legal basis for doing so.


3.    PROMOTIONAL COMMUNICATIONS


Where you have provided consent, we may use your personal information and information about how you use our Website, the Services, and the Platform (as applicable) to send promotional communications that may be of specific interest to you. These communications are aimed at driving engagement and maximising what you get out of our Services, including survey requests, newsletters, and information about new features or third-party products or services we think may be of interest to you or improve the IEQ or energy consumption in your property. We may also communicate with you (for example using email, text messaging and through an interaction with the Occupant App, Management App or the Platform) about IEQ and/or electricity consumption advice, new product offers, promotions, general business and marketing purposes relating to our Website, the Services, the Platform, the Management App and the Occupant App.


You can opt-out of receiving marketing messages from us by sending an email to privacy@tether.co.nz, by unsubscribing through the unsubscribe link in an email, or by unsubscribing [here].

 
We will try to comply with your request as soon as reasonably practicable. If you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages if you use our Services, the Platform, the Management App or the Occupant App directly.


4.    DISCLOSURES OF YOUR PERSONAL INFORMATION


We will not disclose personal information we hold about you to any third party except as set out below.


Within the Platform, the Occupant App and Management App


We will share real-time IEQ and energy consumption information (which may include your personal information) collected by Tether Sensors with property owners and managers (through the Portal and Management App) and property occupants (through the Occupant App). We will share IEQ and energy consumption information and insights for the purpose of informing and educating property owners, managers and occupants on how to maintain a healthy home and for the purpose of notifying them when something is wrong.

 
Service providers


We work with third-party service providers to provide hosting, maintenance, backup, storage, infrastructure, payment processing, analysis and other services for us, which may require them to access information about you. If a service provider needs to access information about you to perform services on our behalf, they will do so under instruction from us. Some of these service providers may be located internationally.


Affiliated businesses

 
In certain situations, businesses or third party websites we’re affiliated with may sell or provide products or services to you in connection with the Services, the Platform, the Management App or the Occupant App (either alone or jointly with us).  We will share your personal information with that affiliated business only if you have provided us with prior consent to do so. We have no control over the policies and practices of other websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review their policies.


De-identified information

 
We may de-identify or anonymise your personal information so that you are not identified as an individual, and provide that information to our Users or other organisations. We may also provide aggregate usage information to our Users or other organisations, who may use such information to understand trends in IEQ and energy consumption, and how often and in what ways people use our Services. However, we never disclose aggregate usage or anonymised information to any third party in a way that would identify you as an individual person.


Legal obligations


In exceptional circumstances, we may share information about you with another party if we believe it is reasonably necessary to (a) comply with any applicable law legal process or governmental request (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our Services, Website or Platform, or (d) protect us, our Users or the public from harm or illegal activities.


Sale of our business


Where we sell or transfer our business, we may provide your personal information as part of a database to the buyer, so that they can contact you about their plans for the business.  In that case, we may also retain your information and use it in accordance with this privacy policy (or any other terms we agree with you). If our business is acquired, we go out of business, or go through some other change of control, your personal information could be one of the assets transferred to or acquired by a third party.

 
5.    TRANSFERS OUTSIDE NEW ZEALAND


Some of our external service providers may be based outside New Zealand.

 
Whenever we transfer your personal information out of New Zealand, we comply with New Zealand law, and ensure a similar degree of protection is given to it using contractual or other safeguards.

 
Please contact us if you want further information on the specific safeguards used when transferring your personal information out of New Zealand.


6.    INFORMATION SECURITY


We have put in place measures to ensure the security of the personal information we collect and store about you. Tether Sensors are connected to a Low Powered Wide Area Network provided by Sigfox, a leading and trusted provider of secure Internet of Things networks.  We strive to protect your personal information from unauthorised disclosure or access, including through the use of network and database security measures, but cannot guarantee the security of any information we collect and store.

  
If you have an account with us, you must prevent unauthorised access to your account and personal information by selecting and protecting your password or other sign-on mechanism appropriately and limiting access to your computer or device by signing off after you have finished accessing your account.


7.    YOUR LEGAL RIGHTS


We will only keep your personal information for as long as necessary for the purposes for which the information can be lawfully used, including the purposes for which we collected it.


In certain circumstances, by law you may have the right to:


(a)    Request access to your personal information. This enables you to receive a copy of the personal information we hold about you.
(b)    Request correction or updating of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold               about you corrected, deleted or updated.


If you wish to exercise the rights set out above, please email privacy@tether.co.nz.


We will not charge you a fee for requesting access to, or correction of, your personal information. However, we may charge a reasonable fee for making information available to you in accordance with your request (for example if there is significant work involved).


We may need to request specific information from you to help us confirm your identity and ensure your right to access or correct your personal information. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.


We try to respond to all legitimate requests within two weeks. Occasionally it may take us longer to respond if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


You have the right to make a complaint at any time to the New Zealand Privacy Commissioner. We would always appreciate the chance to deal with your concerns ourselves before you approach them, so please consider contacting us in the first instance.


If you have any queries about this policy or your personal information, or you wish to submit an access request or raise a complaint about the way your personal information has been handled, please email privacy@tether.co.nz.


8.    COOKIES


We use cookies on our Website. Please see our Cookies Policy here for more information on how we use cookies.
 

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