SaferMe's Privacy Policy

Privacy Policy

SaferMe Privacy Policy

Current as of 24 July 2023

Application

This Privacy Policy describes how SaferMe Limited (trading name ‘SaferMe’) a registered New Zealand company NZBN 9429030665927 with a registered office at Level 3, 354 Lambton Quay, Wellington 6011, New Zealand (SaferMe) collects, uses and discloses Personal Information, and what choices you have with respect to your Personal Information.

This Privacy Policy applies whenever you use our platform, applications, contact tracing cards, database, or our web app (app.safer.me) (collectively referred to as ‘Services’). We only collect personal Information through the Services (collectively referred to as ‘Service Data’) that we need to provide our Services to you and your employer.

This Privacy Policy also applies to Personal Information we collect for marketing, billing, account management and business administration purposes from visitors to our marketing website (www.safer.me or app.safer.me), our customers and other persons with whom we deal directly (collectively referred to as ‘Account and Marketing Data’).

We collect and process Service Data solely to provide you and your employer with the Services. Your employer determines what and how they collect, use, disclose and transfer Service Data and we process this service Data as an agent for our Account Holders (under the NZ Privacy Act 2020) and and, if applicable, as a data processor (under the GDPR and the UK GDPR).. Your employer act as the data controller in respect of all Service Data, and is responsible for obtaining the appropriate consents and approvals for us to lawfully process such information. This means that the collection and use by your employer of your Personal Information (including disclosure of your Personal Data at any worksite that you are associated with) is governed by their privacy policy and practices, not ours. If you have any questions about Personal Information about you that is Service Data, or you wish to access, request correction of, or request deletion of, that Personal Information, please contact your employer.

This Privacy Policy uses the same definitions as those used in our terms of use, found at (Terms of Use). References to “employer” include references to the Account Holder whose account you are associated with.

Third-Party Services

This Privacy Policy does not apply to any third-party applications or software that integrate with our Services or any other third-party products or services (‘Third Party Services’). These Third Party Services have their own privacy policies and data processing procedures. We are not responsible for the data processing of Third Party Services. This includes software your organization might use including single-sign-on or other applications that they have integrated with SaferMe.

Information that we collect about you

We collect and process Personal Information about you as follows:

Creating an account: Your employer may request or require that you use our Services. To do this, your employer will set up an account for you and invite you to use our Services. As between you and us, it is entirely up to you to decide whether you want to use our Services.
Newsletter: If you subscribe to our newsletter then we will collect your name, surname, and email address.
Customer Support: We may collect Personal Information that you provide to us when you contact us with questions or comments about our Services. We may collect and process Personal Information such as your device ID, email, user ID, device type, operating system, available storage on your phone, phone platform and carrier, country code, and language. We only collect what we need to support you, and you can request that we delete this information.
Report Details and Metadata: We collect data from reports you make in the platform, including data from image, video and other files which may be shared. We also collect metadata about your reports and your interaction with other reports and our overall Services.
Data integration: We provide organizations and their users with the ability to link or merge data with third-party systems via our API. It is your responsibility to ascertain how your information is processed when it leaves our system, as we have no control over Third Party Service Provider’s systems and processes. It is your responsibility to familiarise yourself with the Privacy Policy of the Third Party Service Provider (see also clause 2 of this Privacy Policy). If you have any questions, please speak to your employer.
Technical Information: When you use our Services, we may automatically collect and process Personal Information.
Metadata: When you use our Services metadata is generated that provides additional context about the way you are using the Services. For example, the SaferMe app logs, the duration and minutes that you use our Services.
Log data: Our servers automatically collect information when you access or use our Services and record it in log files. This log data may include your device’s IP address, network status, information about browser configuration, language preferences, cookie data, bug tracking, and crash reporting data. This information is important and enables us to provide our services to you.
Device information: SaferMe collects information about devices accessing the Services, including the type of device, what operating system is used, device settings, device ID, email address, user ID, device type and model, the device’s operating system, vendor ID, the phone storage available, platform, network carrier. Whether we collect some or all of this information often depends on the type of device used and its settings. This information helps us diagnose the cause of any problems, as well as to develop and maintain compatibility with the devices our clients use.
Location information: We receive information from your device and about the country you access our Services from. We may also collect location information from devices in accordance with the consent process provided by your device. If you opt into sharing your location information, you can subsequently stop sharing this information at any time by deleting the SaferMe app or changing the preferences on your device. Please note, however, that if you withdraw consent to the sharing of location information, you will no longer be able to use some features of the SaferMe app.
Contact tracing cards: If you carry one of our contact tracing cards, we receive information from the card, including time and date, whether you have been in proximity with other persons carrying one of our cards and, if so, identifying details for the other person’s card that can be traced to the other person. You can subsequently stop sharing this information by ceasing to carry the card. Please note, however, that if you cease to carry the card your employer won’t be able to warn you of potential contact with colleagues, contractors, and visitors.
Content submitted by you or your employer: You and your employer may upload and create content such as videos, text, and images and personal details, which may include your Personal Information. We may collect Personal Information from the content we receive from you or your employer, including associated metadata.

Why we collect information about you

We use personal information about you for the following purposes:

provide our Services to you and your employer and manage your access to our Services;
to update, maintain and protect our Services, including software updates;
to respond to your questions and communications to us;
for account management and other administrative matters, including billing and collection; prevent and investigate fraud and other misuses;
to protect our rights or our property; send you service-related information, including incident and hazard reports, confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
to deliver advertising and marketing and promotional information to you;
to notify you about changes to our Services;
to create a list of actual and prospective users and subscribers for our Services;
to assemble statistics regarding the use of our Services;
for any other purpose we describe at the time we collect Personal Information from you;
to conduct research and statistical analysis (on an anonymised basis)
to protect and/or enforce our legal rights and interests, including defending any claim; and
for any other purpose authorised by you or applicable law.

If you are located in New Zealand and your employer subscribes to the SaferMe mobile app contact tracing functionality, your location information may be collected for contact tracing purposes.

Cookies and advertisements

When you use our Services or our marketing website, we may store cookies on your device in order to facilitate and customise your use of our Services or website. A cookie is a small data file, which is placed on your computer or mobile device that can later be retrieved to identify you. You can usually remove or reject cookies through the settings on your browser or device.

We may use cookies and similar technologies to:

allow us to recognise you and your device, for example by identifying your IP address;
provide you with more customised Services or website content, for example, to provide our Services or website in your preferred language; or
obtain data which will allow us to understand how people are using our Services and website so that we can improve them.

How we share and disclose information

We may disclose to the following categories of third parties the personal information which you provide yourself to the Service or which we collect in the Service:

Your employer: Your employer has access to Personal Information about you that is Service Data. As noted above, your employer’s privacy policy and processes will govern how your employer uses or discloses your Service Data.
As instructed: We may make Your Content (such as any videos, text, images or personal details you upload or create) available to others as you (or your employer) instructs as part of your (or their) use of the Services. The metadata associated with Your Content may also be viewed and accessed by others, including titles, descriptions, and tags.
Third-Party Services Providers: We may engage third party companies or individuals as service providers or business partners which enable us to provide Services to you. These third-party services providers may, for example, provide web hosting, customer software or payment services. Third-Party Services are not owned or controlled by SaferMe and third parties service providers that have been granted access to Personal Information may have their own policies and practices for its collection and use. Please check the privacy settings and notices in these Third Party Services or contact the provider for any questions (see clause 2 of this Privacy Policy).
Affiliates: SaferMe may share information with its corporate affiliates, parents and/or subsidiaries.
Change Control: In the event of a merger, acquisition, restructure, bankruptcy, or other similar events, any information in our possession may be transferred to our successor or assignee.
Public authorities: SaferMe may disclose Personal Information to public authorities or law enforcement if we have reason to believe that we must disclose Personal Information in response to legal process (for example a court order, search warrant), that it is appropriate in the context of public health, or to comply with any applicable laws or regulations.

We may disclose information to third parties in an aggregate and anonymized format. However, such information does not constitute Personal Information under applicable law and is not governed by this Privacy Policy.

If you are located in New Zealand and your employer subscribes to the SaferMe mobile app contact tracing functionality, your location information including time and date, whether you have been in proximity with other persons using our mobile app contact tracing features and, if so, identifying details for the other person’s device that can be traced to the other person may be disclosed to the Ministry of Health in the event that the Ministry of Health requests that we provide that information for contact tracing purposes.

Security

SaferMe takes data security seriously. We take commercially reasonable security measures to protect your Personal Information against accidental or unlawful destruction or loss, alteration, unauthorised disclosure or access, use and all other unlawful forms of processing of the data in our possession. Among others, we employ the following security measures:

We encrypt many of our Services using SSL and other common encryption technologies.

For instance, we encrypt Personal Information ‘At Rest’ using AES, SHA and other algorithms in line with industry best practice. We use up to date SSL connections to ensure the security of Personal Information when transmitting over networks such as the Internet.

Although we strive to protect your Personal Information, we cannot guarantee that unauthorised access, hacking, data loss, or other breaches will never occur. We cannot guarantee the security of your information while it is being transmitted to our Services or systems. Any transmission of your personal information is at your own risk.

Children

The Services are not intended for children under the age of 13, and we do not knowingly collect any Personal Information from children under 13. If we become aware that Personal Information we hold relates to a child under the age of 13, we will promptly delete that information from our Services, unless we are prohibited by law from doing so.

If you are under between the ages of 13 and the “full age” in your country of residence (ordinarily 18 years old), you can only use the Services if your parent or legal guardian has reviewed and agreed to the Terms of Use on your behalf.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. You should periodically check this privacy page for updates. Your continued use of the Services signifies your acceptance of our Privacy Policy as modified. If you disagree with the changes to this Privacy Policy, you should cease using the Services.

How long we keep information

We will retain your Personal Information for as long as is necessary to fulfil the purposes for which it was collected.

We retain Service Data as needed to provide you and your employer with Services.

If you are an account owner user and we need any Account and Marketing Data about you to comply with our legal obligations or protect and/or enforce our legal rights and interests, we may retain that Personal Information after you have deleted your account or stopped using our Services.

International Data Transfer

SaferMe may transfer your Personal Information to countries other than the one in which you live. We are located in New Zealand and will transfer, store and process Personal Information to New Zealand. The European Commission and the government of the United Kingdom recognises that New Zealand provides adequate privacy protection.

We utilise the services of third party processors (or sub-processors, as applicable) in various countries who may access your Personal Information. Consequently, we may transfer Personal Information to persons or entities located in these countries. Although we will endeavour to ensure that Personal Information is treated securely and in accordance with this Privacy Policy as well as applicable privacy laws, we advise that some of these countries may not have an equivalent level of data protection laws as those in New Zealand.

Where we use third-party services providers to process your data (such as Google, AWS, and Apple), we ensure that transfers are made under legally acceptable transfer mechanisms (e.g., for Personal Information that is subject to the General Data Protection Regulation of the European Union (GDPR) or the equivalent laws of the United Kingdom (UK GDPR), the European Commission’s Standard Contractual Clauses).

Your Rights

You have the right to access your readily retrievable personal information that we hold about you, and to ask for it to be corrected if you think it is wrong.

If you are based in the EU or the UK you have the right, under the GDPR or the UK GDPR (as applicable), to:

in certain circumstances, have your personal information erased;
restrict the processing of your personal information;
move, copy or transfer your personal information easily for your own purposes across different services in a safe and secure way;
object to processing where we rely on our legitimate interests as the lawful basis for processing;
withdraw your consent at any time, where our processing of your personal information is based on consent; and
lodge a complaint with an appropriate supervisory authority, if you consider that our processing of your personal information has breached the GDPR or the UK GDPR (as applicable).

We will respond to any request made in respect of the above in accordance with the applicable privacy laws.

Please note that in certain circumstances we may refuse to respond to a rights request where we have the right to do so under applicable privacy laws, for example, where a request is manifestly unfounded or excessive

How we respond to your inquiries

If you wish to exercise any of the above rights in relation to Service Data, you should contact your employer. If we receive any requests to access, correct or delete Service Data, we will forward this request to the relevant customer, unless we are prohibited to do so by law.

We will respond to access requests that relate to Account and Marketing Data without undue delay and in any event within one month of receipt of your access request.

If you need help or wish to exercise any of the above rights or have questions about them, please contact us at support@safer.me

If you believe that the Ministry of Health holds any information collected through your use of the Services and wish to exercise any of the above rights, please contact the Ministry of Health.

Deleting your Account

You can delete your account at any time. If you choose to delete your account, we will delete your account information as soon as possible.

If you are using the Services at the invitation or request of your employer, deletion of your account does not result in Service Data about you being deleted. If you wish to seek deletion of this information, please contact your employer.

Information that you have shared or reported through our Services cannot be amended or deleted by us where it is in the control of a third-party platform.

Contacting SaferMe

If you have any questions regarding our Privacy Policy or practices, please feel free to contact us by sending an email to support@safer.me or by writing to us:

SaferMe Limited, Level 3, 354 Lambton Quay, Wellington 6011, New Zealand