Privacy Policy

Overview

This policy sets out the kind of information CLNZ collects and holds; how CLNZ collects, uses, discloses and stores personal information; the purposes for which this information is collected; how it may be accessed and corrected; how you may complain about a breach of the principles of the Privacy Act 2020 and how we will deal with such a complaint.

Under section 2 of the Privacy Act 2020 “personal information” is defined as “information about an identifiable individual”, and includes certain information relating to a death.

Types of personal information collected

Information we collect includes:

• Names and pseudonyms
• Contact information
• Job title
• Date of death
• Residency status
• Bank account details for electronic funds transfer payments
• Lists of works and the copyright owners of those works
• Information used to assess funding applications

We collect the following information for users of creative rights services Catalogue and Legal Service:

• Names and demographic information
• Contact information
• For Catalogue: lists of works and associated copyright and other licencing and legal details
• For Legal Service: details of legal matters

Anonymity

In some circumstances we provide the option for individuals to either not identify themselves or to use a pseudonym when dealing with us. In some circumstances if you choose not to provide requested information, we may not be able to provide you with certain services. We do not provide this option in circumstances where it is impracticable to do so or where we are legally required to deal with identified individuals only.

Information on children aged under 13

CLNZ does not knowingly collect or maintain personally identifiable information from persons under 13 years of age, and no part of our site is directed to persons under 13 years of age. If you are under 13 years of age, then please do not use or access this site at any time or in any manner. We will take appropriate steps to delete any personally identifiable information of persons less than 13 years of age that has been collected on our site without verified parental consent upon learning of the existence of such personally identifiable information.

Data Sources

We collect personal data through:

• Data collection activities pursuant to our licensing business: surveys, e-reporting, from copyright owners, and from the open Web from sites such as WorldCat
• Overseas licensing bodies and collective management organisations
• Organisations that act as an agent for us, including New Zealand School Trustees Association
• MyCreativeRights services Catalogue and Legal Service
  
• Customer relationship management software
• Website enquiries, the MyCopyright user portal, and email correspondence with licence-holders, rightsholders, and others
• Marketing activities
• Recruitment activities
• Google Analytics
• CLNZ social media pages
• Moodle
• Zoho business management applications
• Telephone calls, through notes arising from calls and through recording conversations where callers have been advised the recording is activated

Users should be aware that there are inherent risks in transmitting information across the internet.

Use of cookies

Our websites generate small text files known as cookies often containing a unique ID number for the purposes of advertising and monitoring site usage. The information we collect and share with the third parties listed below is anonymised and aggregated and does not include personal information that is likely to identify you.

Cookies can be disabled by or cleared from your web browser if you prefer: refer to your browser’s help function for information on how to do this. Cookies are generated by some of the services listed below. Refer to individual services’ webpages for further information.

Amazon Web Services

CLNZ uses Amazon Web Services to host MyCreativeRights code and users’ data. Information on Amazon Web Services’ privacy policy is available here: https://aws.amazon.com/privacy

Auth0

CLNZ uses Okta’s Auth0 to manage and validate user login credentials in MyCopyright and MyCreativeRights. CLNZ does not have access to your login password. Further information is available in Auth0’s privacy policy: https://www.okta.com/privacy-policy/

Calendly

CLNZ uses Calendly to schedule meetings between Legal Service users and legal advisors. Some of this information may be passed on to our legal advisors’ third party calendar applications such as Outlook. Further information is available in Calendly’s privacy policy: https://calendly.com/privacy

Google Analytics

CLNZ uses Google Analytics to collect data about users’ usage and activity on our websites. This is collected for the purpose of improving the website and is not used by us to personally identify users. All tracked data is anonymously collected in accordance with Google Analytics’ privacy policy. By using our websites you consent to processing of data about you by Google in the manner described here. Further information is available from: http://www.google.com.au/policies/privacy/

LinkedIn Pixel

We use LinkedIn Pixel to help measure how users interact with our websites. Refer to https://www.linkedin.com/legal/privacy-policy for further details.

Meta or Facebook Pixel

We use Facebook Pixel to help measure how users interact with our websites. Refer to https://www.facebook.com/privacy/policy for further details.

Stripe

CLNZ uses Stripe to record and process payments received for Legal Service and Catalogue. CLNZ does not have access to credit card numbers processed or recorded by Stripe. Further information is available in Stripe’s privacy policy: https://stripe.com/en-nz/privacy

Xero

CLNZ uses Xero for storage of payment-related information. Further information is available in Xero’s privacy policy: https://www.xero.com/nz/legal/privacy/

Zoho business management applications

CLNZ uses various Zoho business management applications including Zoho CRM and Zoho Sign to obtain, record, and manage personal information obtained through the activities listed here. The information recorded in Zoho applications is transmitted and stored securely in the countries in which Zoho processes data and is subject to the privacy laws of those countries and Zoho’s privacy policy: https://www.zoho.com/privacy.html

Reasons for provision of personal data to CLNZ
CLNZ collects and holds personal information for the business purposes detailed generally on our website. These purposes include:

• Collecting and distributing payments for uses of copyright works by licence-holders
• Identifying and locating copyright owners
• Licensing copyright works to licence-holders
• Providing services to users and receiving payments through Catalogue and Legal Service
• Monitoring websites patterns of usage by users and for advertising purposes
  
• Supporting infringement actions which assist copyright owners with rights management
• Administering funding applications, prizes and awards
• During recruitment activity, directly by us and through third-parties such as recruitment websites and recruitment agencies
• Other secondary purposes you might reasonably expect us to apply related to these primary purposes.

CLNZ uses and discloses personal information for the purposes that it was collected, as outlined in this statement and elsewhere on the CLNZ website, and for associated management purposes. It may also use and disclose personal information for any other purposes to which you have consented. Subject to the Privacy Act 2020, CLNZ may also use and disclose personal information for any other related purpose that you would reasonably expect the information to be used or disclosed. You may request that CLNZ does not disclose certain personal information without your consent.

We may use and disclose your personal information in the following specific circumstances:

• Your participation in our licensing schemes to licence-holders and other collecting societies and copyright owner associations
• Your name, and any pseudonym, and participation to enable licence-holders and potential licence-holders to determine whether their licence covers your work or whether they need a CLNZ licence for use of your work
• That you have received a payment to other authors, publishers, or their agents who have an interest in your work
• Your personal information with other collecting societies and copyright owner associations in order to distribute payments to the copyright owner and to claim payments for foreign uses or under foreign licensing schemes
• Your personal information to third party research companies for the purposes of usage surveys and other research activity, and to our independent auditors engaged to audit CLNZ’s operations
• Your personal information may be disclosed in pursuit of dispute resolution or to external mediators or experts
• Your personal information supplied by you in our Legal Service to legal advisors

CLNZ may be obliged to disclose personal information to law enforcement bodies, or to a third party if the disclosure is necessary to prevent or lessen a serious and imminent threat to the life, health, or safety of you or another person, and it is unreasonable or impractical to obtain your consent.

CLNZ will not otherwise use or disclose your personal information without your consent unless required or authorised by law.

Marketing material

CLNZ may use your personal information to send to you marketing material that we consider will be useful to you, or other material about our activities. We will only do this if we collected the information from you and you would reasonably expect us to use or disclose the information for that purpose, or if you have consented to receiving such communications.

We will not provide your personal information to third parties for direct marketing purposes.

Sending your personal information overseas

CLNZ may disclose your personal information to overseas recipients. For example, we may disclose certain personal information to overseas collecting societies and we may use a server hosted overseas for storage and back up of data including your personal information. The exchange of data, including personal information, is usual business practice for collecting societies like CLNZ. Details of works that have been copied under licence are provided by us and to us, in order to be able to pay those copyright owners whose work or works have been copied.

If we disclose your personal information to an overseas recipient, we will take reasonable steps before disclosure to ensure that the overseas recipient will not breach the Privacy Act 2020. We may from to time to time disclose your personal information to overseas recipients for the purposes of claiming payments for use of your works in the countries where we have a fee exchange agreement with a foreign collecting society.

We may also store some classes of personal information as backup data on servers located overseas.

Generative artificial intelligence applications

CLNZ will not upload your personal information to generative artificial intelligence applications.

CLNZ takes reasonable steps to protect your personal information from loss, unauthorised access, modification, disclosure, interference or other forms of misuse.

These steps include electronic access restrictions for electronic data, and securing paper files containing personal information in locked cabinets or off-site secure storage facilities. CLNZ holds personal information in a number of different formats, including on servers located both on-site and off-site, databases, filing systems and in offsite backup storage.

CLNZ only retains personal information for as long as it is required for its business purposes or for as long as required by law, and information no longer required is destroyed securely.

You may request access to your personal information and to request correction if it is inaccurate, out of date, incomplete, irrelevant or misleading. Such requests should be directed to our Privacy Officer whose details are provided below.

We will take reasonable and practicable steps to provide you access and/or make a correction to your personal information within a reasonable period, unless we consider there is a sound reason under the Privacy Act 2020 or other relevant law to withhold the information, or not to make the changes. If we do not provide you access to your personal information, or refuse to correct your personal information, where reasonable we will provide you with a written notice including the reasons for the refusal.

If you have a complaint relating to a breach of the privacy principles outlined in the Privacy Act 2020 you should contact our Privacy Officer at the details given below. CLNZ will investigate your complaint and respond to you within a reasonable time and in accordance with our legal obligations. We will take any necessary corrective actions promptly.

How to contact us

If you have any questions or concerns about how CLNZ treats your personal information please contact our Privacy Officer directly via email at privacy@copyright.co.nz, via telephone on 0800 480 271 or write to the Privacy Officer at:

Copyright Licensing New Zealand
PO Box 331 488
Takapuna
Auckland 0740
New Zealand

Page last updated 9 February 2024.