Privacy
Policy

1. Boxer has implemented this Privacy Policy to provide information about what kinds of Personal Information we may collect or hold, how we collect, hold, use and disclose that Personal Information, choices you have regarding our use of that Personal Information, and your ability to access or correct that Personal Information. If you wish to make any inquiries regarding this Privacy Policy, you should contact our Privacy Officer in any of the ways specified in section 16.
2. This Privacy Policy applies to the use of your Personal Information (including its collection, use, communication, and processing) by Boxer, as well as by service providers on behalf of Boxer, and any of those parties may be located anywhere in the world including within and outside the European Economic Area (“EEA”) or the United Kingdom ("UK") from time to time.
3. Please consider this Privacy Policy alongside our other policies, including the Boxer Terms of Use, available in the Legal Library.
4. Capitalised terms used in this Privacy Policy are defined in section 18.
5. We keep this Privacy Policy under regular review and may update this Policy from time to time. You will be notified in advance of any such changes where required under applicable law.
6. This Privacy Policy was last updated on 1 February 2022.

1. The types of Personal Information we may collect about an individual will depend on the nature of our interaction with them. We collect, including but not limited to, the following types of Personal Information:
   1. name
   2. age
   3. contact details including telephone numbers (landline and/or mobile), email address and current address (including postal address)
   4. payment details, such as your bank account details
   5. geographical location including your country of residence
   6. preference information
   7. Product and transaction information from your purchase, including serial numbers or any photos of the Product that you provide
   8. information about your browsing activity, including by using analytical and targeting Cookies (see section 4 for more information)
   9. for countries other than the UK and Australia, to the extent permitted under applicable law, information about our employees including employment agreements, visa information, tax numbers, social security information, information collected by using technology, and similar information, and
   10. for countries other than the UK and Australia, information about our job applicants including applications, CVs, interview notes, credit and police checks to the extent permitted under law, and similar information.

1. We use the Personal Information we collect about you for our business functions and activities, to operate our business efficiently, and to market our Products and Services for the benefit of our customers and stores who supply our Products and Services
2. We may collect, hold, and use your Personal Information for the purposes set out below. If you are located in the EEA or the UK, we are also required to identify a legal basis for holding and using your Personal Information for these purposes. If you are a resident of Canada, we will only collect, use, or communicate your Personal Information with your consent. We may however use or communicate your Personal Information without your consent in certain situations when permitted by applicable law. For example, we may use your Personal Information when it is necessary to allow the provision of certain services requested by you, or for fraud prevention purposes. In certain cases, we may not be able to provide certain services to you or process an application on your behalf if you do not agree to the collection of Personal Information.

3. We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but we have no obligation to monitor the use of the Website or Apps to retain the content of any user session.
4. We may otherwise collect, use or disclose your Personal Information where the collection, use or disclosure is:
   1. in accordance with this Privacy Policy or any agreement you enter into with us, or
   2. required or authorised by law.
5. Where required by law, if your Personal Information is to be used for a purpose not previously identified, we will disclose the new purpose to you before such use (including, where applicable, the legal basis for such use), and if required by law we will seek your consent to such use. We may also process your Personal Information without your knowledge or consent where this is required or permitted by law.
6. We may share information about you with a third party if we believe that sharing is reasonably necessary to:
   1. comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, and our service providers may also do this
   2. enforce our agreements, policies, and terms
   3. protect the intellectual property rights of any person
   4. protect the security or integrity of the Website, Apps, and our related services; or
   5. protect us, you, or the public from harm or illegal activities.

1. Boxer may disclose, or provide access to, your Personal Information to third parties in connection with the purposes described in section 5. Depending on the circumstances and the nature of your engagement with us, we may disclose your Personal Information to our related entities, to third parties that provide products and services to us or through us, or to other third parties where requested or indicated by you (such as local repairers in connection with an Issue Raised).
2. We may also disclose your Personal Information in connection with the purposes described in section 5 to:
   1. any of Boxer’s internal divisions, business units or departments
   2. your nominated representatives
   3. other organisations or individuals who assist us in providing Products and Services to you
   4. professional service providers and advisors who perform functions on our behalf, such as lawyers, accountants and auditors
   5. medical providers including medical and rehabilitation practitioners for assessing travel or health insurance claims
   6. representatives, agents or contractors (including repairers) who are appointed by us in the ordinary operation of our business to assist us in providing Products or Services or administering our business (such as for data storage or processing, printing, mailing or logistics, marketing, planning and Product or Service development)
   7. allow third parties to market products and services if you opt in to this type of sharing, for example, as described in Section 4 and through our Cookie Settings
   8. insurers, brokers, auditors, business consultants and IT service providers (including web hosting, data storage and analytics cloud service providers such as Amazon Web Services and Google Cloud Platform), and
   9. government, regulatory authorities and other organisations as required or authorised by law.
3. If a third-party service provider needs to access information about you to perform services on our behalf, they do so under instruction from us, including abiding by policies and procedures designed to protect your information.
4. We may also disclose your Personal Information to our Website host or software application providers in limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.
5. We may also disclose your Personal Information to a purchaser or potential purchaser in connection with the sale or potential sale of Boxer, our business or any of our assets, including in insolvency, in circumstances which require the purchaser or potential purchaser to use such Personal Information consistently with this Privacy Policy.

1. Some of your Personal Information may be disclosed, transferred, stored, processed or used overseas by us, or by third-party service providers. This may happen if:
   1. our offices or related entities are overseas
   2. we outsource certain activities overseas
   3. transactions, information, Services or Products have an overseas connection, or
   4. our computer systems including IT servers are located overseas.
2. We may collect, use, store, and process your Personal Information outside of your jurisdiction of residence (including, where you reside in the EEA or the UK, or outside of the EEA or the UK) as set out in this Privacy Policy and in accordance with applicable laws.
3. In particular, your Personal Information may be disclosed to third parties in Australia, Canada, Hong Kong, Ireland, Japan, New Zealand, Singapore, the United Kingdom and the United States of America, and such other countries in which those parties or their, or our, computer systems may be located from time to time, where it may be used for the purposes described in this Privacy Policy. Where such parties are located outside of your jurisdiction of residence, you may have rights to enforce those parties’ compliance with applicable data protection laws, but you might not have recourse against those parties under relevant laws in your jurisdiction of residence in relation to how those parties treat your Personal Information. As well, applicable laws in those jurisdictions might permit foreign governments, courts, law enforcement or regulatory agencies to access the information in those jurisdictions. However, we will not store your Personal Information in such jurisdictions if prohibited by data protection laws in your jurisdiction of residence.
4. If you are located in the EEA or the UK, whenever we transfer your Personal Information out of the EEA or the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
   1. We may transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the UK Government. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries (for the EEA) and here (for the UK).
   2. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries (for the EU) and here (for the UK).
5. If you are a resident of the province of Quebec (Canada), whenever we transfer your Personal Information out of the province of Quebec, we will conduct all assessments required by applicable law and use all reasonable safeguards, including contractual requirements, to ensure that your Personal Information will benefit from an adequate level of protection. If you are a resident of another Canadian jurisdiction, we will take similar measures whenever we transfer your Personal Information out of Canada.
6. Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Information out of the EEA or the UK.

1. We may collect, use and disclose your Personal Information for other purposes not listed in this Privacy Policy. If we do so, we will make it known to you either at the time we collect your Personal Information, or prior to using such Personal Information for those other purposes. We will ask for your consent for such other purposes whenever legally required.

1. As permitted by applicable law, we may send you, from time to time, information, including promotional material, about us or our Products and Services by means of email and electronic messages (including SMS and MMS messages). We may also send you information about the Products and Services of our related entities and third parties, subject to any requirement to obtain your consent to do so first.
2. If you do not want to receive marketing information from us, you can request not to receive such information in any of the following ways:
   1. clicking on the “Unsubscribe” or subscription preferences link in a direct marketing email that you have received from us
   2. signing in to your account on the Website and editing your communication preferences, or
   3. contacting us using the contact details specified in section 16.
3. If you opt out of receiving marketing-related emails from us, we may still send you important administrative communications.

1. We aim to keep your Personal Information secure and take reasonable measures to help protect your Personal Information that is collected via our Website or which is held on our computer systems from unauthorised access or misuse in accordance with applicable laws.

1. We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for in accordance with applicable laws. To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information, including to satisfy applicable legal, accounting or reporting requirements, and whether we can achieve those purposes through other means.
2. Details of retention periods for different aspects of your Personal Information are available on request by contacting our Privacy Officer in any of the ways specified in section 16.
3. In some circumstances you can ask us to delete your data: see section 12 below for further information.
4. As permitted by applicable laws, in some circumstances we may anonymise your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, and in such instances, we may use this information indefinitely without further notice to you in accordance with applicable laws.
5. We may also de-identify or aggregate your Personal Information in a way that cannot be used to identify you.

1. You are generally entitled to request access to your Personal Information that we hold about you. If you request access, in ordinary circumstances we will make reasonable efforts to give you access to your Personal Information in accordance with the nature of your request and the rights of others, subject to any applicable law. Depending on the request, Boxer may charge for providing access to this information. Any charge will not be excessive and will be subject to any applicable law.
2. There may be some legal or administrative reasons to deny access. If we refuse your request to access your Personal Information, we will provide you with reasons for the refusal where we are required by law to give those reasons.
3. Where we are relying on consent to process your Personal Information, you have the right to withdraw consent at any time and we will delete the relevant aspects of your Personal Information.
4. You can access and correct some of your Personal Information through the Website and Apps by signing in to your account and updating or editing your details at any time. Alternatively, you can make a request for access by contacting our Privacy Officer in any of the ways specified in section 16.
5. We take all reasonable steps to ensure that any Personal Information we collect and use is accurate, complete and up to date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested, and properly update the information provided to us to keep it true, accurate, current and complete.
6. It is important that the Personal Information we hold about you is accurate and current. If you believe that your Personal Information is inaccurate, incomplete or out of date, please update your details in your account or contact us in any of the ways specified in section 16. We will use all reasonable efforts to correct the information. If a challenge regarding the accuracy of your Personal Information is not resolved to your satisfaction, we will, if permitted by applicable law annotate the Personal Information under our control with a note that the correction was requested but not made.
7. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
8. We try to respond to all legitimate requests within one month, unless a shorter timeframe is legally required. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9. It will assist us to ensure we properly understand your request and allow us to respond more promptly if requests are made in writing and include as much detail as possible.

1. If the GDPR applies to the processing of your Personal Information by us, you have specific rights under applicable privacy laws in relation to your Personal Information.
2. Your GDPR privacy rights may include your right to:
   1. Request access to your Personal Information (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
   2. Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
   3. Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with applicable law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, following your request.
   4. Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
   5. Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios:
      1. if you want us to establish the data's accuracy;
      2. where our use of the data is unlawful but you do not want us to erase it;
      3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
      4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
   6. Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
   7. Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Products and Services to you. We will advise you if this is the case at the time you withdraw your consent.
3. If the Personal Data Protection Act 2012 of Singapore (“PDPA”) applies to the collection, use, disclosure or processing of your Personal Information by us, we will ensure that we will obtain your consent for the collection, use, disclosure or any other forms of processing of Personal Information as regulated under the PDPA, save where an exemption under the PDPA could be relied upon.
4. Please contact our Privacy Officer in any of the ways specified in section 16 if you wish to exercise any of your privacy rights.

1. The California Consumer Privacy Act or "CCPA" (California Civil Code Section 1798.100 et seq.) affords consumers residing in California certain rights with respect to their Personal Information. If you are a California resident, this section 14 applies to you.
2. In the preceding 12 months, we have collected the following categories of Personal Information: identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name or other similar identifiers. For examples of the precise data points we collect and the sources of such collection, please see sections 2 and 3 above. We collect Personal Information for the business and commercial purposes described in section 5 above. In the preceding 12 months, we have disclosed the above categories of Personal Information for business purposes to the recipients listed in section 6.2.
3. California law requires that we provide transparency about Personal Information we “sell”, which for purposes of the CCPA broadly means scenarios in which we have shared Personal Information with third parties in exchange for valuable consideration. Boxer does not sell your identifying information (such as your name, email address, phone number, or postal address); however, we do allow our advertising partners to use Cookies and other technologies to collect Personal Information about you in order to show ads that are targeted to your interests if you opt-in via your Cookie preferences. In order to opt out of having your Personal Information used for targeted advertising purposes, please see Advertising and Analytics Services Provided by Others in section 4. You have the right to opt out of these sales at any time by changing your preferences in Cookies Settings or the Do Not Sell My Info page.
4. Subject to certain limitations, you have the right to, free of charge, (1) request to know more about the categories and specific pieces of Personal Information we collect, use, disclose, and sell, (2) request deletion of your Personal Information, (3) opt out of any “sales” of your Personal Information that may be occurring, and (4) not to be discriminated against for exercising these rights. You may make these requests by contacting us via the methods in section 16. We will verify your request by asking you to provide information related to your recent interactions with us, such as information regarding a recent Issue Raised. We will not discriminate against you if you exercise your rights under the CCPA.
5. If we receive your request from an authorised agent, we may ask for evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorised agent seeking to make a request, please contact us via the methods set forth in section 16.

1. If you:
   1. have a query or concern about this Privacy Policy or our Personal Information handling processes
   2. wish to make a complaint in relation to a breach of your privacy
   3. would like to access your Personal Information held by us, or
   4. would like to update or correct your Personal Information held by us you can contact the Privacy Officer in any of the following ways:
   5. Email Address: privacy@goboxer.com or
   6. Mailing Address: ATTN: Legal Counsel, Boxer Group, PO Box 74 562, Greenlane, Auckland NZ, 1543.

1. If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Policy, please advise us as soon as possible by contacting our Privacy Officer in any of the ways specified in section 16.
2. We will investigate your queries and complaints within a reasonable period depending on the complexity of the complaint, and we will notify you of the outcome of our investigation. We will, on request, provide information regarding our complaint procedure.
3. It will assist us to respond to your complaint promptly if it is made in writing. Please detail information relevant to your complaint.
4. We hope that we can resolve any concerns you raise with us and appreciate the chance to deal with your concerns before you approach a privacy regulator. You have the right to make a complaint at any time to the relevant privacy regulator in your jurisdiction or where the issue occurred.
   1. In New Zealand, you may contact the Privacy Commissioner at https://www.privacy.org.nz/about-us/contact/.
   2. In Australia, you may submit a complaint to the Office of the Australian Information Commissioner at https://www.oaic.gov.au/.
   3. In Canada, you may raise a concern or file a formal complaint with the Federal Office of the Privacy Commissioner at https://www.priv.gc.ca/en or with a provincial privacy commissioner if you are located in British Columbia, Alberta or Québec.
   4. In the EEA, you may submit a complaint to any data protection authority.
   5. In the UK, you may submit a complaint to the Information Commissioner at https://ico.org.uk/make-a-complaint/.

Unless the context requires otherwise in this Privacy Policy, references to:
Apps mean any software applications made available from time to time by Boxer.

Boxer, we, us or ours means Boxer Worldwide Limited (company number: 5527605, Level 2, 62 Highbrook Drive, East Tamaki, Auckland, 2013 , New Zealand, its subsidiaries, and other related and associated companies and entities (related entities).

Boxer Cover means the services set out in the Boxer Cover Terms including the online international cross-border store warranty against defects provided to you under the Boxer Cover Terms for your Product whether provided as a warranty or as Insurance and includes any form of extended warranty provided by warranty or Insurance.

Boxer Cover Terms means the terms and conditions provided to you in respect of a Boxer Cover.

Cookie means a small text file that is transferred to a user's computer hard drive by a website for the purpose of storing information about a user's identity, browser type or website visiting patterns.

Insurance means any insurance policy or product procured for you by Boxer.

Personal Information means data defined as personal information or personal data in any applicable privacy-related law, and includes information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable, and also means any information provided by and/or related to an identified individual or an individual who is reasonably identifiable.

Privacy Policy means this Privacy Policy as amended by us from time to time.

Product means your product listed in the Boxer Summary in the applicable Boxer Cover Terms.

Products and Services mean any products or services provided by Boxer including the provision of Boxer's Apps or the administration of an Issue Raised in accordance with the Boxer Cover Terms.

Raising an Issue or Issue Raised means any request or demand for services to or for a Product made by you under a Boxer Cover or made by you under any Insurance.

Sensitive Information has the meaning given to it by any applicable privacy and data protection and transfer law and includes Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

Website means the website at GoBoxer.com including its subdomains and any other website we operate from time to time.