Working International Visas Ltd (“Working In”, “we”, “us” or “our”) provides immigration services to assist individuals and their family to work and live in New Zealand. Working In provides a complete visa assessment of your eligibility to move to New Zealand based on current immigration policy and regulations, and we can assist you to complete and lodge your visa application with the relevant immigration agency (“Services”).
In order for Working In to provide you with our Services, Working In will need to collect, use, disclose and store your personal information. Protecting your personal information is important to us. We are committed to ensuring compliance with the Privacy Act 2020 (NZ) (the “Privacy Act
“Personal Information” means any information that can directly or indirectly identify you or another person.
2. What Working In collect
2.1 Working In may collect from you:
- your name and age;
- your contact information, including email address;
- information about your preferences and activities on the Working In Website;
- your employment or work history, including your CV;
- your qualifications;
- your medical condition;
- your country of birth; and
- any other information about you that we need in order to provide you with our Services.
2.3 When You disclose information to Working In it must be accurate, complete, up to-date and not misleading.
3. How Working In collects your personal information
3.1 Working In collects your Personal Information only when needed and for lawful purposes connected with its business functions and providing the Services to you. You authorise the collection of your Personal Information from Working In when you:
- visit and use the Working In Website, include creating a user account;
- use the Working In Services on your computer, mobile, tablet or any other electronic device;
- communicate or interact in any way with Working In; or
- enter into any Working In competitions and/or promotions.
3.2 Working In may also collect your Personal Information from publicly available sources or from third parties from time to time.
4. How Working In will use your personal information
4.1 You authorise Working In to use your Personal Information (and where necessary), to disclose your Personal Information to third parties for the following purposes:
- to provide you with the Working In Services;
- respond to your queries regarding the Working In Website or our Services;
- verify your identity when you create a user account with Working In;
- administer your account;
- provide you with a good user experience;
- develop new Services, features and/or content;
- keep you updated on things that are happening at Working In;
- for internal record keeping purposes;
- for any other purposes you authorise;
- for the purpose of Working In selling all or most of Working In’s assets; and
- to comply with Working In’s legal obligations,
4.2 You agree that Working In may share your Personal Information with third parties for the purpose of providing you the Services.
5. How long Working In holds your personal information
5.1 Working In will hold your Personal Information for as long as your Personal Information is required for the Purposes and for as long as is necessary to comply with its legal obligations.
6. How Working In stores and protects your personal information
6.1 Working In will use reasonable care to protect your Personal Information from unauthorised access, use, modification, disclosure, and loss.
7.2 There are two types of cookies used by Working In:
- Session cookies. These are used to store information about your activities so you can move from one webpage to another. These cookies track your movement from webpage to webpage of a website so that you do not have to provide the same information provided on earlier webpages. Session cookies only remain in the cookie file of your browser until you close the browser.
- Persistent cookies. These are used to store your preferences to improve your experience on future visits to the Working In Website. For example, these cookies can remember log-in details or language preferences so that you don’t have to continually re-enter these each time you visit the Website. Persistent cookies stay in the cookie file of your browser after you have closed your browser, and activate again when you next visit that website.
7.3 To enable some of the features and functionality of the Working In Website, you will need to permit Working In to place cookies on your device. If you choose not to, then those features and functionality will not be available to you. You can remove or block cookies by using the settings in your browser but it may affect your ability to use the Working In Website.
8. Working In may transfer your personal information to other countries
8.1 From time to time, we may disclose your Personal Information to third parties located outside New Zealand in connection with the Purpose. We make sure that the overseas third party is:
(a) a participant in a prescribed binding scheme for international disclosures of Personal Information; and/or
(b) is located in a country that provides comparable safeguards to New Zealand’s privacy laws.
8.2 If not, then we will take reasonable steps to ensure that the overseas third party is required to protect your Personal Information in a way that, overall, provides comparable safeguards to those required under the applicable privacy laws. Examples of these steps include a written agreement between us and the third party or making reasonable enquiries regarding data protection standards of the country in which the overseas third party is located.
9. Request access or correction to your personal information
9.1 You’re allowed to see what Personal Information Working In holds about you, and you can ask us to correct it if you think it’s wrong. If there is a legal reason why we can’t let you see it, or if we don’t agree with your correction, then we’ll tell you.
10. What happens if you don’t give Working In your personal information
10.1 If you decide not to give Working In your Personal Information, or otherwise wish to withdraw your authorisation at any time, then you:
- may not be able to use Working In’s Website and Services; and
- won’t be kept updated on things that are happening at Working In.
11. Privacy complaints
11.1 If you think that your privacy rights have been breached, you can make a written complaint to Working In at email@example.com or otherwise contact the NZ Privacy Commissioner at https://www.privacy.org.nz/your-rights/making-a-complaint/complaintform/.
13. GDPR privacy notice
13.1 As a resident of the European Union (“EU”), you have certain data protection rights under the General Data Protection Regulations (“GDPR”) and Working In has certain data protection obligations under the GDPR.
13.2 The GDPR defines “personal data” to mean “any information relating to an identified or identifiable natural person”.
13.3 This GDPR Privacy Notice sets out the additional rights a resident in the EU has in respect of his or her personal data under the GDPR. This GDPR Privacy Notice applies to anyone in the EU who uses our Website, uses our Services or otherwise interacts with us.
13.4 Please read this GDPR Privacy Notice carefully so you can make an informed decision on whether you wish (and continue) to visit our Website, our Services or interact with us.
13.5 Your informed consent: You can withdraw your consent at any time for any reason after it is given by not visiting our Website, delete your Working In account, not interact with us or ‘opt-out’ of your personal data being used for the purposes outlined in this GDPR Privacy Notice. This also applies if you no longer agree with our GDPR Privacy Notice or do not agree with the changes that we make to our GDPR Privacy Notice from time to time. If you withdraw your consent, we will stop collecting your personal data. The withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
13.6 Data controller: The data controller is Working International Visas Ltd (t/a Working In) with its registered office at c/o BHW Limited, Level 3, 27 Bath Street, Parnell, Auckland, New Zealand.
14. Lawfullness of processing of personal data
|Category||Types of personal information collected||Legal Basis for Processing|
|Information you give us
You may choose to provide us with personal data when you use our Services or communicate with us.
Example: when you register to complete “MyVisaPath”.
||We collect and process this information where you consent to the processing of your personal data, where the processing is necessary for the performance of your contract with Working In, or where the processing is based on our legitimate interests in verifying your identity to use Working In’s online services. Your personal data will also be processed in connection with our legitimate commercial interest in operating Working In’s business as an immigration service provider.|
|Information that is necessary for your use our Website
We ask for and collect personal data when you use our Website.
Example: when you visit our Website, use the services and functions available on our Website, register to complete “MyVisaPath”.
|We collect and process this information where you consent to the processing of your personal data, where the processing is necessary for the performance of your contract with Working In, or where the processing is based on our legitimate interests in verifying your identity to use Working In’s online services. Your personal data will also be processed in connection with our legitimate commercial interest in operating Working In’s business as an immigration service provider.|
|Information we automatically collect from your use of our Website
When you use our Website we automatically collect personal data about the functions you use and the webpages you visit.
Example: when you use certain features within our Website, browse the content on our Website, accept our ‘Cookies’.
||We collect and process this information based on our legitimate interest to provide you with a seamless and personalised user experience, improve online functionalities, and for the operation of Working In’s business as an immigration service provider.|
|Information we collect from third parties
We may collect information that others provide about you when they use the Website or obtain information from other sources (including our third party service providers) and combine that information we collect through our Website.
Example: when you link, connect or login to our Website from a third party (eg Google, Facebook etc), when other parties provide us with information, including data to help improve user experience and to detect fraud and Website security issues.
||We collect and process this information based on legitimate interest in ensuring a seamless and personalised user experience, ensuring the security of our Website and the safety of our customers, and where necessary, to communicate with you.|
14.2 In addition to those that are outlined in the table, we will also collect and process information where you give us your informed consent.
15. Processing of special categories of personal data
15.1 Working In will only collect and process personal data that reveals your racial or ethnic origin and other types of personal data that constitutes a ‘special category” of personal data under the GDPR if you give your express consent for Working In to do so. The collection and processing of any “special category” will only be to the extent that such data is reasonably necessary for, or directly related to, the provision of Services to you by Working In.
16. International transfers of your personal data outside the EU
16.1 Your personal data will be transferred and stored in New Zealand. New Zealand is covered by an adequacy decision determined by the European Commission as providing adequate level of data protection.
17. Lodging complaints
17.1 You have the right to lodge a complaint with a ‘supervisory authority’ established by a Member State under Article 51 of the GDPR if you believe your data protection rights have been breached.
18. Right of rectification
18.1 You have the right to obtain from Working In without undue delay the rectification of inaccurate personal data. Working In may seek to verify the accuracy of the personal data before correcting it.
19. Right to restrict processing
19.1 You have the right to limit the ways in which Working In uses your personal data, in particular where:
- You contest the accuracy of your personal data.
- The processing is unlawful and you oppose the erasure of your personal data and request the restriction of the use of your personal data instead.
- We no longer need your personal data for the purposes of processing, but you require the data for the establishment, exercise or defence of legal claims.
- You have objected to the processing of your personal data pending the verification by a supervisory authority of whether our legitimate grounds to process override your own.
20. Right of access and portability
20.1 You have the right to request certain copies of your personal data held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this data to another service provider nominated by you (where technically feasible).
21. Right to be forgotten
21.1 You have the right to obtain from us the erasure of your personal data without undue delay where one of the grounds set out in Article 17(1) of the GDPR apply. Please note that:
- Working In may retain some of your personal data as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety.
- Working In may retain and use your personal data to the extent necessary to comply with our legal obligations. For example, we may keep some of your data for tax, legal reporting, auditing and regulatory compliance obligations.
- Because Working In maintains our Website to protect from accidental or malicious loss and destruction, residual copies of your personal data may not be able to be removed from our backup systems.