For the purposes of this Policy, “personal information” means information relating to an individual which can be used to identify that individual.
Why do we collect personal information?
Colliers is dedicated to providing innovative solutions across a broad range of services and locations and is part of a global group of companies (Colliers Group).
We collect personal information in order to conduct our business, to provide and market our services and to meet our legal obligations.
By using our services or providing your personal information to us, you consent to our collection, storage, use and disclosure of your personal information in accordance with this Policy.
How do we collect personal information?
Directly from you: We endeavour to generally collect information from you directly. This may be done in a number of ways, including by telephone communication, email, post, completed application forms and other documentation that is provided to us, website enquiries and in person in meetings or interviews.
From third-parties: In some cases, a third party may collect information from you on our behalf, including our data suppliers and third party providers who verify your identity on our behalf for the purpose of compliance with our anti-money laundering obligations.
Publicly available: We may collect or obtain your personal information that you have chosen to make public, for example via social media, public websites or other public sources.
Created by us: We may also create or obtain personal information in the performance of our services, for example evaluative information about your interactions with us and such evaluative information may be confidential to us.
Automatically: We also collect information from our website. When you visit our website, we collect general user information that does not include any personal identifiable information. More detail is given below under the heading “Cookies and analytics”.
What personal information do we collect?
The types of personal information we collect may include, but is not limited to:
- your name;
- your address and other contact details;
- your bank account and other financial information such as the source of your funds; and
- information which allows us to identify you like your driver’s licence or passport, and other information that will help us conduct our business, provide and market our services and meet our legal obligations, including our anti-money laundering obligations.
If the client with whom you are associated is, for example, a company or trust, we might also ask you for information about, and evidence of, the nature of your relationship with that client.
In many cases, if personal information is not provided as requested by us we may not be able to provide our services to you or carry out your instructions.
Use or disclosure of personal information
Use: We may use the personal information we have collected for the purpose for which it is collected, for reasonably expected secondary purposes related to the purpose for which it is collected and in other circumstances authorised by the Privacy Act. Generally, this means that we use your personal information for purposes related to the services including:
- conducting our business;
- providing our services to you;
- performing a contract with you;
- communicating with you;
- marketing our services, and those of our selected partners, to you - including sending you direct marketing communications and information about offerings and services that we consider may be of interest to you. This may be sent in various forms, including email, post or SMS, in accordance with applicable laws;
- engaging third-parties on your behalf;
- helping us manage and enhance our services;
- for debt recovery purposes, which may also include disclosing information to debt collectors;
- checking your identity against governmental databases, and to otherwise comply with our anti-money laundering and sanctions obligations;
- complying with our other legal obligations; and
- otherwise, if you have consented to the use of your personal information in a particular way.
Disclosure: We may disclose personal information to:
- other members of the Colliers Group;
- other companies or individuals who assist us in providing services or who perform functions on our behalf (such as mailing houses, hosting and data storage providers);
- other companies or individuals who perform checks that are necessary or desirable under law on our behalf;
- other companies, agencies or individuals that maintain databases against which your identity may be verified, which may include the New Zealand Department of Internal Affairs, Centrix Credit Bureau and the Commonwealth of Australia Document Verification Service;
- courts, tribunals, government and regulatory authorities;
- anyone else to whom you consent to us disclosing your information; and
- where we are required to do so by law.
Storage, Security and Retention
Personal information may be stored in hard copy and/or electronic form including with third party data facilities and in cloud storage located in and outside New Zealand. When you provide us with your personal information you give us your consent to store your personal information outside of New Zealand and in third party facilities.
We take all reasonable steps to protect the personal information we hold from misuse and loss and from unauthorised access, modification or disclosure. We have implemented policies and procedures to safeguard the secure storage and processing of data and have verified the security arrangements of our outsourced data providers.
We will retain your personal information for as long as we have a relationship with you and for a period of time afterwards where we have an ongoing legal or business need to retain it - for example to comply with our anti-money laundering obligations. After that period, we will comply with our legal obligations in respect of that information and, generally this means we will delete it or make sure it is anonymised.
Access and correction
We endeavour to ensure that the personal information we hold is accurate, complete and up-to-date. You have the right to request that we correct any personal information we hold about you in accordance with the Privacy Act.
Subject to the exceptions set out in the Privacy Act, you may seek access to the personal information which we hold about you by contacting our Privacy Officer – see the section How to Contact Us, below.
Once a request for access to personal information is received, we will review your request as soon as reasonably practicable. To comply with our legal obligations, we will require you to provide proof of your identity. If we are unable to give you access to the information you have asked for, we will give you reasons for this decision when we respond to your request.
Concerns and Complaints
Colliers takes your concerns seriously. If you have any concerns about privacy or the use or collection of your personal information by us, please contact our Privacy Officer – see the section How to Contact Us, below.
We will investigate your complaint and endeavour to respond to you as quickly as we can and to handle all complaints or concerns in a way that is fair and consistent.
If we are unable to satisfactorily resolve your concerns, you can contact the Office of the Privacy Commissioner at: PO Box 10-094, The Terrace, Wellington 6143, phone 0800 803 909, http://privacy.org.nz/.
By subscribing to emails and/or text communication, or otherwise providing your email address and/or mobile number, you consent to receiving emails and/or texts (as the case may be) which promote and market our products and our services or those of others, from time to time. You can unsubscribe from the email or text communication at any time by clicking on the “Unsubscribe” link in any email or text received from us, or by contacting our Privacy Officer – see the section How to Contact Us, below.
Once you have unsubscribed you will be removed from the corresponding marketing list as soon as is reasonably practicable. Please note, this may take up to 10 business days.
International data transfers
When we disclose personal information, it may be transferred to, and processed in, countries other than New Zealand. There may be differences with New Zealand’s privacy laws. We may disclose your personal information to an overseas person or entity (“overseas person”) who is not already subject to the Privacy Act only if:
- the overseas person is subject to privacy laws which provide comparable safeguards to the Privacy Act, or the overseas person agrees with us to be bound by comparable safeguards to the Privacy Act. We would ensure the overseas person’s compliance with the relevant legal obligations by including standard contractual clauses in our agreement with them; or
- you authorise the disclosure after we have advised you that the overseas person may not have to protect the information in a way that provides comparable safeguards as the Privacy Act.
For individuals in the European Economic Area (EEA), your personal information may be transferred outside the EEA. Where your personal information is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data (like New Zealand), or to a third party where we have approved transfer mechanisms in place to protect your personal information (e.g. by entering into the European Commission’s Standard Contractual Clauses). Where our third party service providers process personal data, provided in the EEA, outside the EEA in the course of providing services to us, our written agreement with them will include appropriate measures to ensure compliance with the relevant legal obligations, usually standard contractual clauses.
Cookies and analytics
Colliers use third party analytics providers to collect data about your interaction with our websites. This data is hosted by third parties. The sole purpose of collecting this data is to improve your experience when using our websites. The type of data we collect includes but not limited to:
- your device's IP address (collected and stored in an anonymized format);
- device screen size;
- device type, operating system and browser information;
- geographic location (country only);
- referring domain and out link if applicable;
- search terms and pages visited; and
- date and time when website pages were accessed.
Colliers run re-targeting campaigns, enabling us to present you with advertising on other sites based on your previous interaction with the Colliers and developer websites.
Notifiable privacy breach
If we become aware that there has been a notifiable privacy breach of your personal information (being a privacy breach that has caused or is likely to cause you serious harm), we will, in accordance with the Privacy Act, notify:
- the Privacy Commissioner; and
- you (individually or by public notice), unless we are not required to notify you because specific exceptions in the Privacy Act apply relating to your health or safety or the safety of another person, national security or law enforcement or a trade secret, or we are required to delay notifying you because notification or public notice may have risks for the security of the personal information we hold that outweigh the benefit of notifying you.
Links to other websites
This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment.
How to contact us
You can contact our Privacy Officer, at Colliers, 10 Athol Street, Queenstown, email email@example.com or call +64 (0)3 441 0790.