Our Commitment to Privacy

Halter is committed to maintaining the privacy of the information of its customers and other users of its services.
This Privacy Policy sets out the privacy policies and practices of the Halter group.

Who does this Privacy Policy cover?

The Halter group comprises Halter Limited, Halter USA LLC., Halter USA Inc., Halter Pty Ltd. and their affiliates, subsidiaries and related entities.
When we refer in this Privacy Policy to 'Halter', or to 'we' or 'our' or 'us', we are referring to one or more entities within the Halter group.

Definitions

In this Privacy Policy:

'Customer' means a customer or prospective customer for the Services;
'Services' means the farm and livestock management services and technologies that we provide to our customers; and
'User' means any person who has been authorised by us to access or use any of the Services on behalf of a Customer. This may include a person we have authorised to access or use the Services for the purpose of providing rural professional services to a Customer.

Our Privacy Practices

In the course of our business dealings with Customers and Users we may collect, use, process, disclose, and hold information about identified or identifiable persons (Personal Information), as well as other business or technical data.  
This Privacy Policy describes how we collect, use, process, store and distribute Personal Information and other data, and describes the purposes for which we may use, process, disclose or hold such Personal Information and other data.

Information that we collect

During the course of our relationship with a Customer or User, or in the course of providing or making available the Services, we may collect the below information.

• We will collect Personal Information from or about a Customer or its Users during the course of establishing and maintaining an account with us. This includes in the course of creating any User account. These Customer and Users details may include names, addresses, email addresses, phone numbers, farm location information, and financial or payment information (such as credit card or bank details).
• We will collect data from collars on the Customer’s animals. This data is transmitted to us via transmission towers on the Customer’s farm. This data includes location, neck acceleration and movement details for those animals.
• We will collect data that is inputted or uploaded by Users in the course of using the Services, for example through the use of mobile apps. This data may include herd or animal information, such as an animal’s breed, farm location and date of birth.
• We may collect location activity about Users when they use the Services.
• We may collect Personal Information or other data in the course of providing any customer support or helpdesk services to a Customer or User, or in the course of responding to requests for further information.
• We will collect data related to the use or operation of the Services, including details of the functions and features accessed or used by Customers and Users, the data accessed or generated, and other diagnostic or usage data.

We may collect personal information from others

We may sometimes collect Personal Information about a Customer or User from other people, such as our contractors, agents or service providers when they provide services to us or assist us to provide the Services to our Customers. These may include IT services providers, couriers and delivery service providers, call centres, finance providers, collection agencies or professional advisers.

We may also collect Personal Information about our Customers or their Users when those Customers or Users give us information about each other.

How we use personal information and data

• To enable us and our agents to provide the Services to Customer and Users. In particular, the animal data we collect from collars is analysed by us and used to generate reports and data via the Services about animal and herd resting, movement, health, grazing and rumination activities, as well as other farm location and virtual fencing information.
• We train our computer models relating to animal reproduction and animal health, to obtain insights generally about animal and herd activities, and to improve the Services generally, we may use the animal data we collect from collars for this training. We may also undertake comparative activities, where we analyse and compare the data collected from different Customers.
• To provide technical support and administration services in relation to the Services.
• To establish and maintain any Customer account held with us.
• To complete sales transactions, including billing, payment processing and receipt, credit check and verification services.
• To respond to queries or requests from Customers and Users for additional information or support.
• To provide any after-sales service required by Customers or Users.
• To maintain our records.
• For business development or research purposes.
• For staff or computer model training in order to improve the Services.
• To evaluate Customer satisfaction and the performance of marketing activities.
• To keep Customers and Users informed about products, services, events, promotions or any other marketing activities, but only to the extent permissible under applicable laws, and subject to any other restrictions contained in this Privacy Policy.

We use, process, disclose and hold Personal Information and other data where necessary to perform our business activities and to provide Services to our Customers and Users.

In particular, we use, process, disclose and hold Personal Information and other data for the purposes below.

Sharing Halter farm and animal data

If we wish to disclose or share with any third party any animal, herd or location data that we collect from any Customer or User or that we generate from an analysis of that data, other than where necessary to provide the Services, then we may do so but only on an aggregated basis and in a way that ensures that no individual is able to be identified from such data, and that also ensures that no farm location or animal is able to be identified.

Lawful basis for processing personal information

We will always make sure that we have a lawful basis for the processing of any Personal Information.
In particular, we may need to process Personal Information to pursue our legitimate business interests. This includes to enable us to operate the Services for the benefit of Customers and Users. In claiming legitimate business interests to process Personal Information, we will balance those legitimate business interests against a Customer’s or User’s own interests – which may in some cases override our legitimate business interests.

Cookies

The Services may use cookies or other tracking technologies. Cookies are small text files that are placed on computers, devices or browsers used to access websites, apps or other internet content.

We may use cookies or other tracking technologies for the purposes below.

• To recognise the computer or device when a User accesses the Services, without requiring a login.
• To learn about User preferences so that we can present Users with content that is relevant to them.
• To measure traffic patterns, to determine which areas of our Services have been visited, and to measure transaction patterns in the aggregate.
• To research the habits and preferences of our Users so we can improve the Services.
• To allow us to operate the Services efficiently.
• To measure the effectiveness of our marketing activities.

Users may be able to change the settings on any device that they use to access the Services in order to reject or limit the use of such cookies or tracking technologies.  But if they do so, it may reduce or limit the functionality of the Services.

Statistical and aggregated data

During the course of our dealings with any Customer or User we may collect statistical data about the Customer or User, including through the use of cookies or other tracking technologies (see the above section), or through other means.

We may disclose this statistical data, or other data we hold based on Personal Information collected by us, for any purpose not otherwise permitted under this Privacy Policy. But we will only do so on an aggregated basis and in a way that ensures that no individual is able to be identified from such statistical data.

Marketing

We may use Personal Information and other data collected by us or via the Services to send or email to Customers or Users marketing or promotional information about the Services or the services or products of other companies (Direct Marketing Information), but only if those Customers or Users have expressly given us permission to do so.

If you have given us permission to send to you Direct Marketing Information, and you later decide that you do not want us to send you any further Direct Marketing Information, you can contact us at any time to request that we stop sending you such information.

You can either contact our Privacy Officer (see the details at the end of this Privacy Policy) or use the “Unsubscribe” facility at the bottom of any Direct Marketing Information email or communication that we send you.

We will not sell the Personal Information of any Customer or User unless they have expressly given us permission to do so.

SMS Privacy Policy:
No mobile Opt-in Data will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

SMS Terms and Conditions:
Upon messaging opt-in, the end user agrees to receive messages from Halter regarding marketing and promotional. End users can opt-out by replying STOP or request more information by replying HELP. Message frequency varies. Message and data rates may apply. If you need assistance or have questions about our SMS service, reply with HELP to any SMS message you receive, or contact our customer support team at contact@halter.co.nz.

Business aquisition

We may transfer the Personal Information and other data of a Customer or User to another entity in connection with a sale of our businesses or assets, or a merger or consolidation or restructuring of our businesses, or any other transaction in which a third party acquires ownership of any rights in the Services.

If we transfer any such Personal Information and other data in such circumstances, we will ensure that such Personal Information and other data remain protected and that the recipient of that Personal Information and other data agrees to be bound by privacy practices and obligations that are consistent with our own under this Policy.

Disclosure of information to third-parties

We will not use or disclose any Personal Information or other data of our Customers or Users, except:

• to the extent reasonably necessary to achieve any of the purposes described in this Privacy Policy; or
• where we reasonably believe that such use or disclosure is required or expressly permitted under any applicable law.

Holding personal information

We will not hold any Personal Information and other data for longer than is reasonably required for the purposes for which we may lawfully use that Personal Information or data.

Security

We will use reasonable endeavours to effect and maintain adequate security measures to safeguard the Personal Information and other data we hold from loss or unauthorised access, use, modification or disclosure.

Transfers of information

We may transfer Personal Information to other Halter group companies, or to third parties, where necessary to achieve any of the purposes specified in this Privacy Policy. These Halter group companies  or third parties may operate or be located outside the country where that Personal Information was collected.

In particular, we may transfer Personal Information to third-party IT service and cloud service providers. These include:

• Salesforce - www.salesforce.com/platform/privacy-center;
• Amazon Web Services. - https://aws.amazon.com/privacy
• Asana - www.asana.com/terms
• Marketo - www.adobe.com/nz/privacy/policy.html
• Dialpad - www.dialpad.com/legal/  
• Intercom - www.intercom.com/legal/privacy
• Vercel - www.vercel.com/legal/privacy-policy

• Meta - www.facebook.com/privacy/policy

If we transfer any Personal Information outside the country in which it was collected, we will ensure that we take such steps as are prescribed by applicable law before we transfer that Personal Information. In particular:

• if we transfer the Personal Information of any New Zealand-based person outside New Zealand, we will ensure that appropriate safeguards are in place with the recipient of that Personal Information, as prescribed by the Privacy Act 2020 (NZ), before we transfer that Personal Information;
• if we transfer the Personal Information of any Australia-based person outside Australia, we will take such steps as are prescribed by the Australian Privacy Principles in relation to that Personal Information; and
• in the case of Personal Information collected from European Union subjects, we will ensure that appropriate safeguards are in place as prescribed by the European Union’s General Data Protection Regulation (GDPR), before we transfer any Personal Information of any European Union subjects to any data processor based in any country that the European Commission has not recognised as providing adequate protection for the personal data of European Union subjects.

Use of third-party websites

We have no control over third-party websites that a User may link to via the Services. This Privacy Policy does not apply to the collection, processing or use of any Personal Information as a result of a User linking to any third party website.

We are not responsible for the privacy policies or practices of third parties.

Your rights to access and correct personal information

You may request access to any Personal Information we hold about you. You may also request that we correct the Personal Information we hold about you. All access or correction requests will be dealt with in accordance with applicable law.
Additionally, the GDPR provides individuals within the European Union with enhanced rights in respect of their Personal Information, including rights of erasure, rights of restriction, rights of objection, a right to data portability and a right not to be subject to automated decision-making.
To make an access or correction request, or to exercise any of your other data rights, please contact our Privacy Officer (see below).  If you make a request or seek to exercise any of your other data rights, we may ask you to verify your identity.

EU subjects may complain to a supervisory authority

European Union subjects have the right to lodge a complaint about our Personal Information processing activities with a supervisory authority in the EU Member State where they are based or where the data processing activity took place.
Our Privacy Officer can help to identify who the applicable supervisory authority is.

Privacy Officer

For any queries or further information about our Privacy Policy, or about our privacy or data practices, please contact our Privacy Officer. This person’s contact details are as follows:
Halter Privacy Officer
contact@halter.co.nz

Amendments to the Privacy Policy

We may change this Privacy Policy at any time, by changing or removing existing terms or adding new ones, or by replacing this Privacy Policy with a new one.
We will take reasonable steps to notify Customers and Users of any changes to this Privacy Policy. Any such changes will take effect immediately, unless we state otherwise.
Your use of the Services after any changes to our Privacy Policy will constitute your acceptance of those changes.

Last updated 16 October 2024