Privacy and Data Usage Policy

KPEX Limited (“KPEX” or “we”) values the privacy of our customers and is committed to protecting the personal information of all Customers of its advertising exchange for the buying and selling of digital advertising inventory (“Customers”) and users of the KPEX website and the websites on which we serve advertising (“Users”). We take our privacy obligations seriously.

This Privacy & Data Usage Policy (“Policy”) explains how and why KPEX collects information and how we store and use the information.

This Policy does not limit or exclude any rights that a Customer or User has or may have under the Privacy Act 1993. For further information on this, you can find out more at www.privacy.org.nz.

How is this Policy applied?

This Policy applies to all instances in which personal information is collected from a Customer or User by KPEX. By using the services offered by KPEX, Customers and Users consent to the collection, use, disclosure, storage and processing of personal information in accordance with this Policy. People use our website, assess traffic patterns and improve the services we provide to you. 

Who are we, and how can you contact us?

KPEX (Kiwi Premium Ad Exchange) is an online marketplace that enables advertisers to buy advertising space in real-time on websites that partner with us (our “Publishers”). We are a consortium that's owned by New Zealand's four largest media brands - NZME, Stuff, TVNZ and Mediaworks - allowing us to provide programmatic access to New Zealand's most premium and brand-safe online ad inventory.

We are a New Zealand company that’s located at 13 Hargreaves Street, Auckland, New Zealand. You can contact us by sending an email to: contact.us@kpex.co.nz.

Why do we collect personal information?

We use the information that we collect or process about our Customers and Users to enable us to perform our business activities and to provide the best possible quality of customer service. We collect, hold, process and disclose Customers’ and Users’ personal information for the following purposes:

  • To verify the identity of the Customer or User;
  • To operate our core business of providing online advertising services through the KPEX advertising marketplace, including audience targeting based on browsing behaviour, location, demographic segment and expressed interests;
  • To service our advertising Customers, including communicating by email, phone, mail and in person to share information about current and new products and services;
  • To undertake credit checks of any Customer (if necessary);
  • To invoice any Customer and to collect money that a Customer owes us, including authorising and processing credit card transactions;
  • To operate our website, which includes providing access to protected areas and analysing usage patterns in order to improve our services;
  • To co-operate with any government, industry or regulatory authorities;
  • To protect and/or enforce our legal rights and interests, including defending any claim; or
  • For any other purpose authorised by a Customer, User or the Privacy Act.
What personal information do we collect and hold about you?

We collect, process and/or use the follow types of personal information:

1. Personally identifiable data: For Customers who enquire about or engage the advertising services of KPEX, we require personal information about them for us to be able to do business. Personal information we may collect includes: 

a. name;
b. mailing or street address;
c. email address;
d. telephone number;
e. profession, occupation or job title;
f. details of the products and services the Customer has purchased from us or which they have enquired about, together with any additional information necessary to deliver those products and services and to respond to their enquiries;
g. any additional information that the Customer provides to us directly through our website or other online services; and
h. information the Customer provides to us through meetings with our representatives.

2. KPEX website usage data

For Users of the www.kpex.co.nz website, we collect data related to their usage of the website. This data is not personally identifiable and is aggregated to help us understand how people use our website, assess traffic patterns and improve the services we provide to you.

This data is collected through the use of cookies, which are small files placed on your computer each time you access our website. We may also log your IP address (the electronic addresses of computers connected to the internet).

We use the following third party services to collect, store, aggregate and analyse this website usage data: Google Analytics, Lotame.

Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing Users about their own privacy practices.

3. Website usage data from the Publishers we partner with: Because we are an advertising marketplace, we process data that has been collected by our Publisher partners and passed to us. This data is collected through the use of pixel tags, cookies, and/or other technologies. It is anonymised and not personally identifiable, but it enables advertisers to better understand the Users of the Publishers’ websites and target their adverts to Users who will be most interested in their messages. We only receive and process data from our Publishers that they have determined can be shared with us, either because the Sser gave permission for their data to be collected and shared, or because no permission is required due to the data being anonymised. Data passed to KPEX is determined by the Publisher and KPEX does not control this process. Please refer to the privacy policy of the relevant Publisher to understand how they collect, use and share personal information.

All non-personal information collected for the purposes of interest-based advertising shall be appropriately safeguarded. The non-personal information will only be retained for as long as is necessary to fulfil KPEX's business purposes relating to interest-based advertising.

The types of data that we process include:

a. Device information, such as the unique device identifier, hardware model, operating system and browser used;
b. Information from the User’s visits to the websites of KPEX’s Publishers, including access times, pages viewed, URLs clicked on,IP address, and pages visited before navigating to the Publisher’s website;
c. Location information, such as the User’s IP address and internet service provider; and
d. Demographic information, such as the User’s age category and/or gender, that has been provided by the User to the Publisher (for example, during a registration process) or has been deduced by comparing the User’s online profile with other similar Users.

4. Non personally identifiable data from other sources: To help target the adverts we show on our Publishers’ websites, we may also receive and process non personally identifiable information about Users from other sources, such as data owners, data aggregators, match partners, and providers of data management platform services. This data helps us to learn about Users’ likes and dislikes so that Users can be provided with adverts that are tailored to their interests.

We use the following data sources: Lotame, AA Smartfuel.

KPEX will take all reasonable steps to ensure the personal information collected, used or disclosed in accordance with this Policy is accurate, complete, up-to-date and stored in a secure environment protected from unauthorised access, modification or disclosure.

KPEX will hold personal information collected in accordance with this privacy policy both before and after the provision of its Services, but only for so long as we are legally entitled to do so.

How is personal information shared outside of KPEX?

We never share personally identifiable information, such as names and phone numbers, with anyone in the conduct of our service unless expressly authorised to do so by the relevant User. However, we may:

  • Share non personally identifiable information required to provide our service with our partners, such as advertisers and other technology companies operating within the advertising eco-system, so that they can use the KPEX service to serve an online advertisement;
  • Share Users’ data with the trusted business partners that work with us on collecting, storing and processing information for us. We only give them the information that they need in order to perform their specific obligations and we require them to do it based on our instructions and in compliance with this Privacy Policy and any other relevant confidentiality or security measures;
  • Share Users’ information in circumstances where we have a good faith belief that we may or should do so;
  • To comply with applicable laws, regulations, legal processes or enforceable governmental requests;
  • To enforce applicable Terms and Conditions, including the investigation of potential violations; or
  • To protect against or prevent harm to rights, property or safety of KPEX, or Users, or those of the public, as required or permitted by law.
How can you prevent KPEX from collecting and/or processing your personal information?

Customers may request to see the personal information that is held by KPEX, ask to correct or update any personal information, request to opt out from our marketing communications, or ask to have your personal information deleted from our systems. For any of these requests, please contact us at contact.us@kpex.co.nz.

If you do not want your website usage information to be processed by KPEX, you will need to advise each website owner and data provider that you wish to opt-out from their data collection, and you will need to set your browser so that your computer does not accept cookies, and delete all existing cookies on your computer. This can be done through the settings in your browser software.

We make no representations or warranties in relation to the privacy practices of any third party website that shares its data with KPEX, and we are not responsible for the privacy policies or the content of any third party website. We encourage our Publishers and other data partners to have a privacy policy that outlines their data collection activities and usage. Please refer to such third party privacy policies for more information.

What happens if we cannot collect and process your personal information?

If you do not provide us with the personal information described in this policy, some or all of the following may happen:

  • We may not be able to provide you with the products or services you requested, either to the same standard, or at all;
  • We may not be able to provide you with information about products and services that you may want to purchase from us;
  • We may be unable to tailor the content of our website to your preferences and your experience of our website may not be as efficient or useful; or
  • We will be unable to customise the display adverts you see on our Publishers’ websites to make their messages tailored to your interests and preferences.
How can you complain about a breach of your privacy?

We will take all reasonable steps to protect the personal information that we hold from misuse, loss, or unauthorised access, including by means of firewalls, password access and secure servers. If you believe your privacy has been breached by us, or if have any questions or concerns about our Privacy & Data Usage Policy, please contact us and provide details of the incident so that we can investigate it.

We have a formal procedure for investigating and dealing with privacy breaches. Once the Privacy Officer receives a complaint, whether it is in writing or verbal means, the Privacy Officer will commence an investigation to determine the nature of the breach and how it occurred.

We may contact you during the process to seek any further clarification if necessary. If a breach is found, the Privacy Officer will escalate the matter so that the process can be rectified to prevent any further breaches from taking place. We will also contact you to inform you of the outcome of the investigation. We will endeavour to resolve all investigations within a reasonable time.

We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.
Updates

KPEX reserves the right, at any time and without warning, to alter or update this Privacy and Data Use Policy. The date upon which this Policy was last updated is shown below.

This Privacy & Data Usage Policy was last updated in September 2018.