Privacy Policy

1. Introduction

1. ThroughLine Limited (we, us, our), is a company based in New Zealand. Our primary goal is to support people experiencing an emotional crisis throughout the world.

2. In the provision of our Services, we endeavour to comply with the New Zealand Privacy Act 1993 (Act) and the European Union's General Data Protection Regulation (GDPR) when dealing with personally identifiable information.

3. This policy sets out how we will collect, use, disclose and protect your personally identifiable information for each of our Services. It also sets out how you can get access to or request a correction of the personally identifiable information we hold about you.

4. This policy does not limit or exclude any of your rights under the Act or the GDPR. If you wish to seek further information on the Act, see https://www.privacy.org.nz/the-privacy-act-and-codes/the-privacy-act/ and for more information on the GDPR, please see https://ec.europa.eu/info/law/law-topic/data-protection/eu-data-protection-rules_en.

2. Changes to this policy

1. We may change this policy by uploading a revised policy onto our Websites. The change will apply from the date that we upload the revised policy.

2. This policy was last updated on 20 May 2022.

3. Definitions

1. In this policy:

Personally Identifiable Information means information that could be used on its own to directly identify, contact, or precisely locate an individual. This includes:

• personal email addresses
• mailing addresses
• phone numbers
• precise locations (such as GPS coordinates)
• full names
• usernames that contain personally identifiable data

We interpret Personally Identifiable Information to exclude, for example:

• pseudonymous (false or disguised) cookie IDs
• pseudonymous advertising IDs
• IP addresses

Services means https://www.findahelpline.com, partner-branded websites at https://[companyname].findahelpline.com, and the Find A Helpline embeddable widget that provides Find A Helpline on third party websites

Websites means https://www.findahelpline.com and partner-branded websites at https://[companyname].findahelpline.com

We, us or our means ThroughLine Limited

You or your refers to you, the individual using our Services

4. Who do we collect personally identifiable information from?

1. In the provision of our Services, we only collect Personally Identifiable Information about you when you provide that information to us via a contact form on our Websites.

2. In the provision of our Services to users located in the European Union our basis for collecting and processing the personally identifiable information provided to us is consent under the GDPR. If you are under the relevant legal age at which you can provide consent to the collection of your personal data, then this consent must have been provided by your parent or guardian. Upon giving this consent, you have consented to the collection and use of the personally identifiable information you provide in the ways described in clause 5 of this policy.

3. You are entitled to withdraw this consent at any time. To do so, please contact us by email to [email protected]

5. How do we use your personally identifiable information?

In the provision of our Services the Personally Identifiable Information you provide will be used:

1. to engage in and respond to communications with you;

2. to protect and / or enforce our legal rights and interests, including defending any claim; and

3. for any other purpose authorised by you or the Act.

6. How do we use aggregated data?

In the provision of our Services we collect aggregated data, which does not include personally identifiable information, for analytical purposes. This aggregated will be used:

1. to provide our Services to you;

2. to share this aggregated and anonymized information with the service providers who are linked on the site; partners who use the embeddable widget or partner-branded website; or with the underlying IT support providers whose system are used in the operation of Find A Helpline;

3. to conduct research and statistical analysis on an anonymised basis;

4. to share aggregated and anonymized versions of this information, for example, in website and customer usage trend reports, and in conjunction with our development processes;

5. to understand generally who the users of Find A Helpline are, how they use our Services, and how we may improve their experience of Find A Helpline in the future; and

6. to protect and / or enforce our legal rights and interests, including defending any claim.

7. How long will information collected from Find A Helpline be kept for?

We keep the information provided through Find A Helpline until it is no longer necessary for the purposes it was obtained for.

8. Disclosure of information to third parties

We will only disclose Personally Identifiable Information to third parties in the following circumstances:

1. to a person who can require us to supply your personally identifiable information (e.g. a regulatory authority);

2. to any other person authorised by the Act or another law (e.g. a law enforcement agency); and / or

3. to any other person authorised by you.

We will only disclose the aggregated information to third parties in the following circumstances:

1. to any business that supports our services and products, including those service providers linked on the site or to any person that hosts or maintains any underlying IT system or data centre that we use to provide the Services;

2. to a person who can require us to supply your personally identifiable information (e.g. a regulatory authority);

3. to any other person authorised by the Act or another law (e.g. a law enforcement agency); and / or

4. to any other person authorised by you.

Please note that a business that supports our services and products may be located outside New Zealand. This may mean that the aggregated information collected is held and processed outside New Zealand.

9. Use of Cookies on Find A Helpline

1. Our Services uses cookies through Google Analytics. We use these cookies to track and analyse non-personally identifiable data to learn more about how Find A Helpline is used. You may disable cookies by changing the settings on your browser, although this may mean that you cannot use all of the features of Find A Helpline.

2. Google Analytics' scripts are incorporated into our Websites. You can find more about Google Analytics' use of cookies here: https://support.google.com/analytics/answer/6004245. We do not and will not assist or permit any third party to pass information to Google that Google could use or recognize as personally identifiable information.

3. Our Websites use the software system reCaptcha when you complete a review of the service or when using our Contact Us form. reCaptcha is governed by Google's policy and terms of service.

4. Our Websites use Hotjar in order to better understand our users’ needs and to optimize our Services and user experience. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

10. Protecting your personally identifiable information

1. We will take reasonable steps to keep your personally identifiable information obtained through any of our Services safe from loss, unauthorised activity, or other misuse.

2. While we take reasonable steps to maintain secure internet connections, if you provide us with personally identifiable information over the internet, the provision of that information is at your own risk.

3. We may share a link to a third-parties' websites, services or other platform on our Websites, or through any other communication by us to you. In addition, our Services use Google Analytics, HotJar and the reCaptcha software system. These third-party websites, services, platforms and software, may have their own privacy policies relating to the use of your personally identifiable information. We suggest you review the privacy policies of these third parties before you provide personally identifiable information.

11. Accessing and correcting your personally identifiable information

1. European Union Users

If you are a user of our Services located in the European Union, then you have a right under the GDPR to access your personally identifiable information, ask for a correction of, or to erase that information.

2. New Zealand Users

If you are a user of our Services located in New Zealand, then subject to certain grounds for refusal set out in the Act, you have the right to access your readily retrievable personally identifiable information that we hold and to request a correction to your personally identifiable information. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personally identifiable information relates. In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the personally identifiable information, we will make the correction as soon as reasonably possible. If we do not make the correction, we will take reasonable steps to note on the personally identifiable information that you requested the correction.

3. If you wish to exercise any of the above rights to which you are entitled, email us at [email protected]. Your email should provide evidence of who you are and set out the details of your request (e.g. the personally identifiable information, or the correction, that you are requesting).

4. We may charge you our reasonable costs of providing to you copies of your personally identifiable information or correcting that information.

If you have any questions regarding this privacy policy, please contact us at [email protected]