As at 4th September, 2019
When we refer to:
- “personal information” or “information about you” we mean information that identifies you or could be used to identify you, for example, your name, email address, date of birth, gender, address, phone number, IP address, and Point-of-Sale (PoS) transactional information;
- “our platform” we mean any Marsello website or page derived from www.marsello.com (and our associated applications);
- “Services” we mean the use of our platform for the optimisation and improvement of promotions and rewards that Marsello suggests to merchants, which the merchants may then offer to consumers (at the merchant’s discretion);
- “you” and “your” we mean either merchants, consumers or website visitors, as the context requires; and
- “your merchant” we mean the particular merchant with whom a consumer has registered to receive awards and promotional offers via our platform.
- WHO WE ARE
Marsello is a provider of rewards and recognition services to merchants. We provide merchants with the ability to collect personal information about consumers so that we can optimize and improve the promotions and rewards that Marsello suggests to merchants, which the merchants may then offer to consumers (at the merchant’s discretion). Collecting this information enables Marsello to let merchants know what type of promotions and rewards consumers like and actually use so that they can offer consumers targeted promotions. When we refer to “Marsello”, “we” (or “our” or “us”) that means Marsello Limited which is based in New Zealand.
- MERCHANT’S RESPONSIBILITIES
3.1 Merchant acknowledgement and agreement
If you are a merchant you are separately obligated to act in accordance with those privacy laws that apply in the country where you are located. Even if you are not established in the EU, you may also be obligated to act in accordance with the GDPR if you are offering goods and services to consumers who are located in the EU at the time they transact with you. You should:
- obtain the informed consent from your consumers to the collection and use of their personal information by Marsello.
- INFORMATION WE COLLECT ABOUT YOU
If you are a merchant we collect personal information about you when you register to access and use our Services and then subsequently when we provide Services to you via our platform, including:
- contact name and contact details (including address);
- username and password;
- support information including issues, dates of contact, and corrective measures undertaken
- technical information including browser software, device, IP address, referral links (UTM), language, and operating system.
If you are consumer we collect personal information about you on behalf of your merchant when we provide our services to the merchant, including:
- your name, email address, age and gender;
- the products and/or services purchased by you;
- the value of your purchase;
- time and date of purchase;
- rewards or discounts applied/redeemed.
We collect this information when:
- you register as a customer of your merchant;
- you accept any rewards or promotions offered to you by your merchant;
- you purchase goods or services from your merchant;
- you supply any additional information to your merchant;
- you view goods or services from your merchant.
4.3 Website visitors
If you are website visitor we collect information including:
- Referral links (UTM)
- Pages visited
- WHAT WE DO WITH THE INFORMATION WE COLLECT ABOUT YOU
We use the personal information we collect about you to:
- process your account registration;
- provide you with services;
- identify you when you sign into your account;
- to communicate with you in relation to the services;
- to resolve technical queries;
- to enhance and further develop our service offering;
- to produce reports and summarise research data
We use the personal information we collect about you on behalf of your merchant so that we can provide our services to merchants, including:
- to inform the merchant about the types of services that you, and other consumers like you, are likely to use so that the merchant can offer promotions and rewards that are more likely to be relevant and effective;
- to improve and personalize the services we provide to the merchant;
- to improve our business processes, such as security, speed and information systems; and
5.3 Website Visitors
- Optimize marketing efforts by tracking website referrals
- HOW WE SECURE YOUR PERSONAL INFORMATION
We employ technical and organizational security measures designed to provide reasonable protection for your personal information (whether you are a merchant, consumer or eebsite visitor) against unauthorised access, disclosure, alteration, loss and misuse. These security measures include:
- Immediate notification of security breach to security officer and defined process for notification of affected individuals and proper authorities within 72 hours of the breach
- Regular security compliance training
- Two-factor authentication for all data services access by Marsello employees
- HOW WE SHARE YOUR PERSONAL INFORMATION
We do not share merchant personal information outside Marsello, except for third-party billing services
We will disclose your personal information only to the merchant with whom you have registered as a customer (and on whose behalf we are collecting and using your personal information)
7.3 Website visitors
Website data will only be disclosed to third-party data analytics and integration services
- LOCATION OF PERSONAL INFORMATION
Personal information is held within the AWS Server Cloud, in the United States
Cookie information may be removed according to the specific documentation pertaining to the users’ browser software
We will occasionally send you transactional emails or other communications regarding your account with us, updates to our website and maintenance, and new features/special offers.
You can ask us not to use your personal information for communications, marketing and promotional purposes at any time by:
- unsubscribing to our marketing emails using the unsubscribe function; or
- contacting us by using the details below and asking us to unsubscribe you.
You understand that if you instruct us not to email you then you may delay or forego receipt of service related information or access to new functionality.
Marsello will only send email (or other) correspondence to consumers on behalf of the merchant
- YOUR RIGHTS TO ACCESS AND CORRECT YOUR INFORMATION
You have the right under the Privacy Act 1993 to access and/or request the correction of your personal information held by us. You can do this by contacting us using the details below.
We collect and use your personal information on behalf of your merchant. If you would like to access and/or correct your personal information then please contact your merchant directly. We will then act on the merchant’s instructions to us. If you send a request to us then we will forward your request on to the merchant so that the merchant can respond to you.
- DELETION AND RETENTION OF YOUR INFORMATION
You can ask us to delete information we hold about you and stop collecting and using your personal information by closing your account with us. After you notify us that you wish to delete your account then we will only hold your personal information for up to 30 days after your account is closed. If we are not able to delete all your information then we will let you know.
We collect and use your personal information on behalf of your merchant. For this reason, it is up to your merchant to determine how long we will retain your personal information on our systems. If you would like us to
- stop collecting and using your personal information; and/or
- delete or return information that we hold about you, then please contact your merchant directly. We will then act on the merchant’s instructions to us. You understand that if your merchant instructs us to stop collecting and using your information then you will no longer be able to receive promotion and reward offers via our Platform.
We may need to update this notice from time to time. If you are a merchant then where a change is significant we will notify you via email. The merchant then has the responsibility of forwarding these notifications to their consumers if necessary.
- HOW TO CONTACT US
4th September, 2019