Privacy Policy

Footprint Australia PTY LTD (A.C.N. 701 665 554) (“Footprint”, ”we”, “us”, “our”) is committed to complying with the Privacy Act 1988 (the "Act") and the Australian Privacy Principles as set out in the Act when dealing with personal information.

Personal information is defined in the Act as ‘information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not or recorded in material form or not’. An identifiable individual is a natural person.

The collection of your personal information is essential to enable us to conduct our business of offering and providing you with our range of products and services, including the use of our website (“Services”). This information may be confidential or sensitive, so we think it is important you know how we treat this information. Please read this Privacy Policy as well as our service terms and conditions, to understand how we collect, store, use, process and disclose your personal information.

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.

What information does Footprint collect?

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

The information we collect can include:

  • Information you provide when using our Services. This includes information such as your name, date of birth, email address, address and mobile phone number, provided at the time of registering or utilising any of our Services, interacting with our staff, or posted material. We may also collect your personal information from a third party or other sources where you have authorised us to do so, or where it is otherwise consistent with the Act.
  • If you contact us via our website or by phone, we may receive additional information about you. For example, we will receive your name, date of birth, email address, phone number and, we may keep a copy of the correspondence.
  • Details of transactions you carry out with our team or using our technology including the fulfilment of these transactions.
  • Details of your visits to our websites including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise, and the resources you access.
  • Any other information that you voluntarily provide to us.

How do we collect personal information?

We collect personal information by a range of means including:

  • when you provide it directly to us, including by email, by telephone, in person or online, including when you use our services to create a will;
  • when another person, for example your employer or advisor, may provide it to us on your behalf;
  • when you engage with us by completing forms for purposes such as registering for events, subscribing to newsletters or other marketing communications, responding to surveys or entering trade promotions;
  • from public records and sources; and
  • when you use our website or any software we make available to you, including from cookies and analytics and the providers of those and similar services – see further details below.

Payment Information and Payment Security

Payments are processed through the secure Stripe system. Any credit card details stored for payments are done so on the Stripe system. No identifiable or sensitive credit card information is stored by us.

Payment Security is managed through Stripe for mutual security. Encryption protection is managed with a Transport Layer Security (TLS) certificate.

IP Addresses

We may collect information about your computer, including, where available, your IP address, operating system, website activity and browser type, for system administration and to report aggregate information for our advertisers. This is statistical data about our users’ browsing patterns and actions, and does not identify any individual.

Cookies

In order for us to provide the Services, you may be asked to access websites operated by Footprint. These websites use cookies, and usage monitoring software such as pixel tags, web beacons, embedded web links, and similar technology, to improve and personalise your user experience. Cookies are small text files, which are placed on your computer when you access a website or application. They are a common feature used by many websites and other applications. Cookies do not have the capability to perform actions by themselves. They can be used for tracking, authentication, marketing and managing user information. Most browser technology will allow you to prevent your browser or device from accepting cookies. This may result in certain functions of the website being diminished.

Sensitive information

We may collect Sensitive Information for the purpose of storing, with your consent. Sensitive Information is defined in the Act to include information or an opinion about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, sexual orientation, criminal record, health information and some aspects of genetic and biometric information.

We do not intend to collect Sensitive Information otherwise than for storage purposes. Services, such as the Vault is managed by you, however, if you have accidently provided Sensitive Information to us, please notify us immediately.

How does Footprint use your information?

We use your personal information only for purposes you have agreed to, for purposes related to the provision of our Services or where we are authorised, or required to under the Act or any other law.

For example, we may use your information:

  • to establish your requirements and provide the appropriate Services;
  • to set up, administer and manage our Services;
  • to understand your needs and improve our Services, including training and developing our staff and representatives;
  • to verify your identity;
  • to communicate with you;
  • to protect our rights;
  • to ensure the secure and proper operation of our website;
  • for internal research purposes;
  • for any other use you authorise;
  • for the security of our staff and clients; and
  • in any other way set out in this Privacy Policy.

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.

Sharing your information

We may disclose your personal information where you have authorised such disclosure, where disclosure is directly related to the purpose of collection or where we are required or permitted to under the Act.

We may disclose your personal information to:

  • Third party service providers and/or customers in order to provide the Services to you.
  • Subsidiaries, related companies or joint venture companies where required or authorised under our relationship.
  • Information technology providers, including hardware and software vendors and consultants such as programmers, for the development or delivery of our Services only.
  • Intermediaries including your agent, adviser, broker, a representative acting on your behalf with your consent, or our authorised representatives and our agents.
  • Accounting and financial specialists, trustees associated with superannuation funds, government, law enforcement or statutory bodies, professional advisers, administration or business management services.
  • Printers and mail service and delivery providers for the mailing of statements in connection with the provision of the Services, and marketing material in accordance with the terms of this Privacy Policy.
  • Imaging and document management services.

When appropriate, to ensure your Will can be found, we may register whether your Will is stored with Footprint on a Will registry.

Disclosure overseas

As we are part of a multinational group with its global headquarters and key operations in New Zealand, we may need to send your personal information to New Zealand from time to time. This could be for operational or reporting purposes. We also operate in New Zealand to provide similar services to those we provide in Australia and are already subject to obligations under the New Zealand equivalent to the Act, the Privacy Act 2020 (NZ) which we believe provide overall protection to your privacy rights and personal information that are at least substantially similar to the protections you have under the Act.

There may be other instances where we send your personal information overseas or collect personal information from overseas. These instances include:

  • When you have asked us to do so.
  • When we are required by law to do so, including in response to any order from any regulator or court in any jurisdiction.
  • When it is necessary in order to facilitate a transaction on your behalf.
  • When you make an enquiry or complaint about our services, including in relation to this Privacy Policy.

In all instances where we may share your personal information overseas this will only occur when we believe that the overseas party will protect your personal information in a way that provides comparable safeguards to those in this Act.

Our third party service providers may also send your personal information overseas where you receive services directly from them. It is the responsibility of our third party service providers to collect appropriate consents from you in order to send your personal information overseas. You should check the privacy policies of any such third party service providers to ensure that you are comfortable with their terms.

Access to, correction, modification and deletion of your information

You are entitled to obtain confirmation from us that we hold personal information about you and can request access to the personal information by contacting us. In some circumstances, as provided for under the Act, we are able to deny your request for access to personal information. If we deny your request, we will tell you why.

We will normally get back to you with a response within 20 working days. If accessing your personal information will take an extended period of time, we will inform you of the likely delay. For more detailed requests for access to information, an administration fee may be charged to cover the associated cost of supplying this information, but we will discuss this with you before we go ahead.

If you believe the information we hold about you is incorrect, out of date, misleading or irrelevant you may ask for it to be corrected. If we decline to correct the information, you may request a statement be attached to the information that a correction was sought but not made.

Personal Information Storage

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.

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.

Marketing

We would like to use and disclose your personal information to keep you up to date with the range of products or services available from us.

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 other information we think you may be interested in and which may market and promote the Services, or the products and services of our subsidiaries, related or joint venture companies. The messages you receive from us will have instructions for how you can remove yourself from our mailing list.

Electronic marketing will only be sent to your email address or mobile phone number 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.

General

Third parties and external links may appear on our website. They are not governed by this Privacy Policy and we are not responsible for them. You should check the privacy policies of the relevant third party.

This Privacy Policy is governed by and construed in accordance with the laws in force in the State of New South Wales and each party submits the non-exclusive jurisdiction of the courts of that State.

Complaints or Enquiries

If you have any questions, issues about how we handle your personal information or requests for your information, please contact us by:

  1. Emailing privacy@myfootprint.co.nz
  2. Telephoning us on +64 9 304 0196; or
  3. Writing to us at Footprint, PO Box 301637, Albany, Auckland, New Zealand 0752

If you are not satisfied with our response to a privacy complaint, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or 1300 363 992.

Changes to our Privacy Policy

Changes in legislation, industry codes, the business environment, or the addition of new products and services to this site may result in changes to this Privacy Policy. If we make any changes, then we will tell you about them by posting an updated policy on our website. We encourage you to look at this Privacy Policy on a regular basis to stay informed of any changes. By continuing to use our Services or provide information to us, you agree to any changes made to this Privacy Policy.

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