Privacy Policy

Halter exists to help farmers and ranchers run their most productive operations: healthier herds and smarter grazing, season after season. That comes with a responsibility to handle your data and personal information carefully, and we don't take this topic lightly. The personal information that we collect is limited, handled securely, and used only for the purposes set out in this Privacy Policy. We never sell your personal information. This Privacy Policy sets out the policies and practices of the Halter Group, including how we collect personal information, why we collect it, and the rights you have over it.

For any queries or further information about our Privacy Policy, or about our privacy or data practices, please contact our Privacy Officer: contact@halter.co.nz.

1. Definitions
   
   1. Defined terms in this Privacy Policy take their meaning as given in the Halter Terms of Service (unless otherwise specified). Halter’s Terms of Service are available on Halter’s website. Halter may update the Terms of Service at any time by publishing an updated version: see clause 19 of the Terms of Service for further information.
   2. For the purposes of this Privacy Policy, the following terms have the following meanings:
      
      Direct Marketing has the meaning given in clause 5.1.
      
      GDPR means the European Union’s General Data Protection Regulation.
      
      Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable.
      
      Halter, “we”, “our”, “us” or similar terms means Halter USA Inc. (a company with a registered office at 201 Spear St Ste 1100, San Francisco, CA 94105, USA) and its subsidiaries, affiliates and related bodies corporate.  
      
      “You”, “your”, or similar terms means a person that we may collect or hold Personal Information in relation to.
2. Our privacy commitment
   
   1. We are committed to maintaining the privacy of customers and users of our Services, employees, suppliers and anyone else that we interact with in our business dealings. We do this by:
      
      1. limiting our collection of information to only what we have a lawful purpose for collecting, such as information we need for our operations;
         
      2. securely storing any information that we collect; and
      3. deleting or anonymising information where no longer used or needed.
   2. This Privacy Policy describes how we collect, use and disclose Personal Information, and the purposes for which we may hold, use and disclose Personal Information.
3. Information we collect‍
   
   1. Automatic or direct collection
      
      In the course of providing or making available the Services, interacting with you for employment purposes (including prospective employment), while receiving goods or services from you or while otherwise carrying on business, we may collect Personal Information automatically or directly from you. This may include:
      
      1. information you provide such as your name, work or residential address, email address, phone number, employment history, deployment location information, and financial or payment information (such as credit card or bank details) in the following circumstances:
         
         1. where you input or provide it directly to us, for example while using mobile apps, forms, websites, or when speaking directly to us (and where legally permissible, such calls may be recorded).
         2. where you input or provide it directly to us during the course of establishing and maintaining any account you hold with us, including during initial or subsequent access to the Services.
         3. where you apply for employment with us (and we may collect any other information you provide, such as your cover letter, resume, referee reports, education information and other sensitive information) or during the course of your employment (such as during your onboarding or in any subsequent communications).
         4. where you input or provide it directly to us in the course of any support or helpdesk services, or while responding to any queries or requests from you for further information about us or our Services.
      2. information collected by cookies or other tracking technologies in connection with any mobile app, website, or form.
      3. usage information from the Services that may be identifiable to you, such as location activity, function and feature usage, Content generated or any diagnostic data.
   2. Collection from third parties
      
      In the course of interacting with you, or while providing or making available the Services, we may collect Personal Information from third parties. The third parties we collect information from may include:
      
      1. contractors, agents, infrastructure, IT services and cloud service providers.
      2. delivery services, call centres, finance providers and collection agencies.
      3. buying groups, incorporated societies, local associations or other voluntary organisations you have elected to join.
      4. professional advisers, when they provide services to us or assist us to interact with you.
      5. previous employers or academic institutions, when you apply for employment with us, or other third parties that may assist us with managing your recruitment or ongoing employment.
      6. other Halter customers, suppliers, or contractors that we interact with when those individuals give us information about you.
   3. Sensitive information
      
      We may also collect and hold sensitive information including health information and criminal background checks. We will only do so if the sensitive information being collected is reasonably necessary for our functions or activities (for example, where we collect personal information in the context of an employment application or relationship) and you have consented to the collection, or we are required or authorised by or under law to do so.
4. How we use information
   
   1. The primary reason we collect, use and disclose Personal Information is to perform our business activities and provide the Services. In particular, we use and disclose Personal Information that we collect for the following purposes:
      
      1. Account establishment and management
         
         1. Establish and maintain any account that you hold with us, or to complete any sales transactions related to your account (including credit checks and verification, billing, payment processing, and receipting).
         2. Provide technical support, administration services, or after-sales service to you.
         3. Respond to queries or requests for information that you submit to us.
      2. Provision and improvement of the Services
         
         1. Enable us to provide the Services to you, including the generation of reports and data via the Services.
         2. To undertake comparative activities, where we analyse and compare information collected from you and other customers, to improve our Services.
         3. Train our staff and improve the Hardware and Services we provide to you.
         4. Detect and prevent attacks against our system and threats to their security/integrity.
         5. To assess and improve the performance of our sales team, including by using automated tools to review compliance with our internal procedures, and to provide coaching and feedback.
      3. Service provision
         
         1. Assess and consider any service proposals that you provide to us.
         2. Engage and manage external service providers and suppliers to obtain goods and services necessary for our business.
      4. Employment
         
         1. Assess any job applications and your suitability for employment with us. To learn more about how we process and protect this information, please see clause 6.
         2. Manage your employment or engagement with us, including onboarding, contract administration, remuneration, communication with you and professional development.
         3. Manage insurance policies, payroll, workplace health, safety, and wellbeing, and our employment records.
      5. Marketing and Development
         
         1. Business development or research purposes, including evaluation of your satisfaction and the performance of marketing activities.
            
         2. To keep you informed about products, services, events, promotions or any other marketing activities through communications such as those under clause 5, but only to the extent permissible under applicable laws, and subject to any other restrictions contained in this Privacy Policy.
      6. Compliance
         
         1. Maintenance of our records, including records we are required to keep by law.
            
         2. Compliance with legal obligations, including court orders and legal processes, law enforcement assistance, and emergency response assistance.
         3. To prevent or detect fraud, or to prevent or lessen a serious threat to public health, public safety, or someone’s life or health (including your own).
      7. Cookies and tracking technologies
         
         We may use cookies or other tracking technologies to:
         
         1. recognise a computer or device when you access the Services without requiring a login, or to learn about your preferences so that we can present you and others with content that is relevant;
         2. measure traffic patterns to determine which areas of our Services have been visited, to measure transaction patterns in the aggregate, and to research the habits and preferences of our customers so we can improve the Services.
         3. allow us to operate the Services efficiently and measure the effectiveness of our marketing activities.‍
            
5. Marketing
   
   1. We may use your Personal Information to send you marketing or promotional information about the Services or the services or products of other companies (mobile message frequency varies, reply “HELP” for more information) (Direct Marketing).
   2. If you do not want to receive any further Direct Marketing, you can contact us at any time to request that we stop sending you Direct Marketing as follows:
      1. contacting our Privacy Officer and requesting to be removed from our marketing distribution lists;
      2. using the “Unsubscribe” button at the bottom of any email or communication; or
      3. replying “STOP” to any mobile messages.
   3. We do not sell your Personal Information and no mobile messaging data will be shared with third parties for marketing or promotional purposes. The categories under clause 10.2 exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
   4. We will only send Direct Marketing communications in compliance with applicable law (including the Spam Act 2003 (Cth) (Australia), the Unsolicited Electronic Messages Act 2007 (New Zealand), the CAN-SPAM Act of 2003 (USA), and Canada’s Anti-Spam Legislation).
6. Job applicants
   
   1. When you apply for one of our open positions, we collect the information that you provide in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history, and other information that may be included in a resume or that you may provide during the interview process. This may also include demographic or diversity information that you voluntarily provide. Where permitted under applicable law, we may also conduct background checks and receive related information. We also collect Personal Information from other sources where relevant for your application, such as employment research firms, recruiters, identity verification services, and information that you make publicly available on websites or social media platforms (for example, LinkedIn).
   2. Throughout the recruitment process, we may supplement your Personal Information in connection with the assessment of your application. For example, we may record the views of those considering your application about your suitability for the role for which you have applied and retain interview notes. If you accept an offer from us, your Personal Information will be incorporated into and used as part of your employee record.
   3. We use applicants’ Personal Information to facilitate our recruitment activities, process employment applications and personalise candidate communication, including evaluating candidates and monitoring recruitment statistics. We also use successful applicants’ Personal Information to administer the employment relationship. We may also use and disclose applicants’ Personal Information to improve our Services and for the compliance and protection purposes described above.
7. If you choose not to provide requested information
   
   1. You are not legally required to provide the information detailed above to us. However, if you choose not to provide this information:
      1. it may reduce or limit the functionality of the Services and in some cases we may not be able to provide the Services;
      2. we may not be able to process your employment application or continue to effectively manage your ongoing employment with us;
      3. it may impact our ability to interact with you, accept any services you provide, or otherwise deal with you; or
      4. we may not otherwise be able to fulfil the purpose for which we have requested the information.
   2. You may be able to change the settings on any device that you use to access the Services in order to reject or limit the use of such cookies or tracking technologies. If you do so, it may reduce or limit the functionality of the Services.
8. Lawful basis for processing information
   1. In the case of Personal Information collected from European Union subjects, we will always make sure that we have a lawful basis for the processing of any Personal Information.
   2. 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 your benefit or our customers benefit. In claiming legitimate business interests to process Personal Information, we will balance those legitimate business interests against your interests – which may in some cases override our legitimate business interests.
9. Information retention
   1. We will not hold any Personal Information for longer than is reasonably required for the purposes for which we may lawfully use that Personal Information. After this time, we will delete the information or ensure it is anonymised.
   2. Some Personal Information may be held or used for longer for purposes directly connected to the original purpose (for example, to respond to service queries) or to comply with our legal and regulatory obligations (such as tax reporting requirements).
10. Transfers of information
    1. We may transfer your Personal Information to other companies in the Halter Group or to third parties.
    2. We only share your Personal Information with third parties in connection with:
       1. the original purpose for which it was collected;
       2. for a directly related purpose;
       3. with your consent; or
       4. for another lawful purpose.
    3. The purposes listed in clause 10.2 may include one or more of the following:
       1. to third-party infrastructure providers, IT service and cloud service providers to enable us to operate and make available the Services;
       2. with our marketing partners, including for interest-based advertising purposes;
       3. on an aggregated and unidentifiable basis and in a way that ensures that no individual can be identified from such data, and that no deployment location can be identified from such data;
       4. in connection with a capital raise or the sale of a business or asset, 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;
       5. where reasonably necessary to achieve any other purposes described in this Privacy Policy; and
       6. with other third parties at your direction or consent.
    4. Halter Group companies or third parties may operate or be located outside the country where Personal Information was collected. If we transfer any Personal Information outside the country in which it was collected, we will do so in accordance with applicable law. In particular:
       1. if we transfer the Personal Information of any New Zealand-based person to a recipient outside New Zealand, we will ensure that recipient is subject to appropriate safeguards, as prescribed by the Privacy Act 2020 (NZ), before we transfer that Personal Information; and
       2. if we transfer the Personal Information of any Australia-based person to a recipient outside Australia, we will ensure, before making that transfer, that the overseas recipient is required to handle that Personal Information in a manner that is substantially similar to the way in which the Australian Privacy Principles protect that Personal Information.
11. Security and breaches
    1. We will use reasonable endeavours to implement and maintain adequate security measures to safeguard the Personal Information and other data we hold from loss or unauthorised access, use, modification or disclosure. However, no security measures are failsafe and we cannot guarantee the security of your Personal Information.
    2. If, despite our best efforts, we become aware of a data breach that could put your security at risk, we will notify you as required by law. We may also disclose the breach publicly if we believe it is appropriate to do so or if required by law.
12. Use of third-party websites
    1. 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.
    2. We are not responsible for the privacy policies or practices of third parties. Please review the privacy policies of third parties carefully.
13. Your privacy choices
    1. We will take reasonable steps to ensure that any Personal Information we hold is accurate, complete, and up to date, having regard to the purpose for which it is held. Depending on your location and how you use our services, you may have the right to request the following:
       1. Access to any Personal Information we hold about you.
       2. Correction of the Personal Information we hold about you.
       3. Deletion of Personal Information that we no longer need to provide the Service or for other lawful purposes.
       4. Objection to us processing your Personal Information where we rely on our legitimate business interest to do so.
       5. Opt-out of the sale or sharing of your Personal Information to third parties. We do not “sell” Personal Information, but our disclosure of Personal Information to our third-party advertising partners may be considered “sharing” of Personal Information or “targeted advertising” under applicable laws. You can opt out of these disclosures by clicking the “Your Privacy Choices” link on the footer of our website.
       6. Additional rights, such as to request that we restrict our use of your Personal Information, and where applicable, you may withdraw your consent to our processing of your Personal Information at any time where we rely on your consent to process that Personal Information. This won't affect anything we have used your Personal Information for before you withdraw your consent.
       7. Appeal our denial of your Personal Information request by contacting us.
    2. We’ll do our best to fulfil any requests for access to, or correction of, your Personal Information. Requests may be subject to statutory timeframes, depending on your jurisdiction. In some instances, we may not be able to fulfil all (or part) of your request for access or correction if we believe there are grounds to refuse the request under applicable law, including where:
       1. we do not have the Personal Information at issue;
       2. the Personal Information is not readily available despite reasonable efforts to locate it; or
       3. we believe your request could compromise the privacy or safety of a third party.
    3. To make a request, or to exercise any of your other data rights, please contact our Privacy Officer (whose details are at the start of this Privacy Policy). If you make a request or seek to exercise any of your other data rights, we may ask you to verify your identity. Additionally, depending on where you reside, you may be entitled to empower an authorised agent to submit requests on your behalf. We will require authorised agents to confirm their identity and authority, in accordance with applicable laws.
    4. You are entitled to exercise the rights described above free from discrimination.
14. Making a privacy complaint
    1. If you have any concerns about this Privacy Policy, or that your privacy has been compromised in any way, please let us know by contacting our Privacy Officer.
    2. Depending on where you are, you may have additional rights:
       1. In Australia, if your complaint cannot be resolved by us, you can also contact the Office of the Australian Information Commissioner (OAIC). You can do this by visiting the OAIC’s website (https://www.oaic.gov.au/) or contacting the OAIC on 1300 363 992.
       2. In Canada, if your complaint cannot be resolved by us, you can contact the Office of the Privacy Commissioner of Canada (OPC). You can do this by visiting the OPC’s website (https://www.priv.gc.ca/) or contacting the OPC on 1-800-282-1376 (toll-free) or 819-994-5444.
       3. In New Zealand, you can also request an investigation by the New Zealand Privacy Commissioner at any time during or after raising a complaint with us. You can do this by visiting the Privacy Commissioner’s website (www.privacy.org.nz) or contacting the Office of the Privacy Commissioner on 0800 803 909.
15. Children
    1. Our Services are not intended for use by children under 18 years of age without adequate supervision or parental consent (where required by law). If we learn that we have collected Personal Information through the Services from a child under 18 without their consent, or the consent of the child’s parent or guardian where required by law, we will delete it.
16. Amendments to the Privacy Policy
    1. We may change this Privacy Policy at any time. 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. The date of the last update is always shown at the bottom of this Privacy Policy.
    2. Your continued use of the Services after any changes to our Privacy Policy will constitute your acceptance of those changes.