This Privacy Policy describes how your personal information is collected, used, and shared when you visit www.36atp.com (the “Site”) or when you apply to use any of the products or services offered by 36 ATP Limited (“we” or “us”). We are committed to ensure compliance with the Privacy Act 2020 and European Union’s General Data Protection Regulation (“GPDR”).
PERSONAL INFORMATION WE COLLECT
If you choose to provide us with personal information such as your email address, for example by filling out an electronic query or order form, we will use that information to communicate with you in response to your query, about the goods and services we provide or are about to provide you or other matters we consider might be of interest to you. You may choose not to provide us with your personal information, however we may not be able to process your application or provide you with certain products or services if you do not provide your personal information.  
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”
We collect Device Information using the following technologies:
   – “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
   – “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
   – “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
When we talk about “personal information” in this Privacy Policy, we are talking both about Device Information and Order Information that identifies you.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We use the Order Information that we collect generally to fulfill any requests made through the Site (including providing you with invoices and/or order confirmations).  Additionally, we use this Order Information to communicate with you and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
Your personal information generally may be provided to our third party IT provider as our data is stored and monitored by third parties engaged by us. We do not sell any information which identifies you personally. We may gather more extensive information if we are concerned, for example, about security issues.
If you have opted to receive it, we may also use this information to send you marketing messages in accordance with our electronic marketing policy set out below.
SHARING YOUR PERSONAL INFORMATION
We share your personal information with third parties to help us use your personal information, as described above.  For example, we also use Google Analytics to help us understand how visitors use the Site–you can read more about how Google uses your personal information here:  https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Finally, we may also share your personal information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
As described above, we use your personal information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.  For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by:
   FACEBOOK – https://www.facebook.com/settings/?tab=ads
   GOOGLE – https://www.google.com/settings/ads/anonymous
   BING – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
DO NOT TRACK
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
DATA RETENTION AND PROTECTION
When you submit information to us or our Site, we will maintain your Information for our records unless and until you ask us to delete this information. We ensure, to the extent reasonably possible, that your personal information is protected against loss, unuathorised access, modification and disclosure, or other misuse.
We may be required to disclose and transfer your personal information to third parties located in a different country from where you live. If those countries do not have data protection laws comparable to the data protection laws of your country of residence, then we will take reasonable steps to ensure that your personal information is protected in those countries.
CHANGES
We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. You may request access to your personal information at any time, and may request correction to your personal information, which will be actioned as soon as reasonably possible following receipt of such a request.
GDPR COMPLIANCE
36 ATP Limited is the data controller for personal data collected by it in the provision of its services, support and assistance to you as the user. If we use personal data that has been collected by a third party we will process the information as a data processor on behalf of the third party that collected your personal information.
Request access: You have the right to request access to any personal information that we hold about you, the right to know the source of your personal information and the processing methods used by us by contacting us as set out below. If we cannot give you access to the personal information that you have requested, then we will let you know the legal reasons for not disclosing your personal information.  If you are not happy with the legal reasons provided, then you have the right to complain to the New Zealand Privacy Commissioner.
Request correction: You have the right to request correction of the personal information that we hold about you, by contacting us as set out below. We will correct your personal information if it is necessary to ensure that your personal information is accurate, up to date, complete and not misleading.  If we decide that it is unnecessary to correct your personal information, we will let you know the legal reasons for its decision.  If you are not happy with those reasons, then you have the right to complain to the New Zealand Privacy Commissioner or to us, as set out below. 
Request to restrict the use and processing of or delete your personal information: You have the right to request that we delete your personal information when it is no longer needed for the purposes described in this policy, or withdraw your authorisation for us to use your personal information. You also have the right to restrict your personal information from being processed in the event you consider your rights and freedoms outweigh our legitimate interests in using your personal information.
Data portability: You have the right to request that we transfer your personal information from one electronic processing system to another electronic processing system.
 CONTACT US
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, or request correction or deletion of personal information, or request any restrictions on the use or processing of your personal information please contact us by e-mail at [	] or by mail using the details provided below:
[postal address]
For any complaints in respect to our handling on any matters of your privacy you may contact the New Zealand Privacy Commissioner: www.privacy.org.nz/your-rights/how-to-complain/.