1.1  Vulcan Steel Limited (company number 681317) (Vulcan, we, us) is committed to ensuring that your privacy is protected.

1.2  In handling your personal information, Vulcan will comply with the Privacy Act 2020 (Privacy Act).

1.3  This Policy explains what personal information Vulcan may collect from you, the purpose of collecting this information, how Vulcan will use and protect this information, and your rights of access to the information. Personal information is any information (including an opinion) that Vulcan holds about you which identifies you or from which you are reasonably identifiable.

1.4  See section 13 for a full list of definitions used in this Policy.

2.1  Depending on the ways in which you interact with Vulcan, Vulcan may collect certain personal information from you, including:

(a) your name, gender, date of birth, contact information (such as your email address, telephone numbers and current or last known residential and/or business address and previous two addresses), occupation;
(b) details from your identity documents, such as your driver’s license number;
(c) financial details, such as your tax file number and bank account number;
(d) information required for recruitment purposes, including name of your current or last known employer;
(e) information required to open or maintain a trading account with Vulcan or otherwise do business with us;
(f) credit information, such as details relating to credit history, credit capacity, and eligibility for credit;
(g) information about your prior dealings with Vulcan; and
(h) information on your use of Vulcan’s customer service support, websites and social media accounts, such as your IP address, and times, dates and/or duration of your interaction with Vulcan.

3.1  Unless it is unreasonable or impracticable, Vulcan will try to collect personal information directly from you. Personal information may be collected from you when you:

(a) fill out a Credit Application Form, Personal Guarantee or any other application or form with us (whether online or otherwise);
(b) submit an application for employment;
(c) contact Vulcan, including via email, telephone or social media;
(d) use Vulcan’s websites;
(e) visit a Vulcan branch;
(f) interact with Vulcan’s social media accounts, digital platforms, advertising, marketing or other digital content; or
(g) respond to surveys or research conducted by us.

3.2  Please note that Vulcan may also collect your details if you start but do not submit an online application or form, including to contact you to offer to help you complete it. This unsubmitted on-line application or form information will only be kept temporarily then deleted if the application or form is not completed after a certain period.

3.3  Sometimes it may be necessary for Vulcan to collect personal information about you from other sources, including where:

(a) Vulcan cannot get hold of you, and it relies on publicly available information to update your contact details;
(b) Vulcan checks the security you are offering through public registers and external service providers; and
(c) at your request, Vulcan may exchange information with your legal or financial advisers or other representatives.

3.4  If we receive information about you from someone else (for example from someone who supplies goods or services to us or is our customer), we will take reasonable steps to ensure you are aware that we have collected personal information about you and the circumstances of the collection.

3.5  You can choose to deal with us anonymously. However, if you do not provide your personal information to us, Vulcan may not be able to:

(a) provide you with the product, service or facilities you want;
(b) manage or administer your account or service;
(c) assess your application for employment;
(d) verify your identity or protect against fraud; or
(e) let you know about other products or services from across the Vulcan range that might better meet your needs.

3.6  Vulcan will collect your credit information from details included in your Credit Application Form. Sometimes it may be necessary for Vulcan to collect credit information from other sources, including:

(a) credit reporting bodies;
(b) other credit providers;
(c) your co-applicants;
(d) your guarantors/proposed guarantors;
(e) your accountant or other referees;
(f) your agents and other representatives, such as your referrers, brokers, solicitors, conveyancers, and settlement agents;
(g) organisations that help process credit applications;
(h) organisations that check the security you are offering, such as valuers;
(i) organisations providing insurance; and
(j) external service providers involved in helping Vulcan to provide credit or to administer credit facilities, including debt collectors and legal advisers.

4.1  Vulcan’s websites use cookies to collect and store information about how you interact with our sites.

4.2  A “cookie” is a small text file placed on your computer by a webpage server which may later be retrieved by webpage servers. Cookies do not allow Vulcan to collect personally identifiable information about you. Like most websites, Vulcan uses cookies to:

(a) assign a unique identification number to your internet browser (this number does not identify you personally), allowing us to associate website requests with a specific device;
(b) track and report on website performance; and
(c) recognise if you have previously visited our website and identify other pages or third-party websites you have accessed.

4.3  Cookies are used by Vulcan for the following purposes:

(a) to analyse your use of our websites;
(b) to maintain and improve our websites, including personalising your experience on our websites;
(c) to enhance our marketing strategies;
(d) to display advertising for Vulcan’s products and services on our websites and on third parties’ websites; and
(e) to support security and fraud prevention measures.

4.4  In addition, Vulcan’s websites use a range of third-party cookies, including those from Google Analytics and Meta cookies. These cookies help us gather insights into user interactions and improve our services. Specifically:

(a) Google Analytics – These cookies provide anonymised, aggregated data about the demographics and on-site behaviour of our users. This information helps us understand browsing patterns and enhance your experience while using our websites.
(b) Meta’s Pixel – This tool allows us to track anonymised user interactions with Vulcan’s websites and advertisements. It helps us understand how users engage with our sites and enables us to deliver more relevant content and recommendations to individuals who may be interested in Vulcan’s products and services.

4.5  If you wish, you can generally configure your browser settings so that it does not receive cookies, but if you do so some of the functionalities on Vulcan’s websites may not be available.

5.1  Vulcan stores information in different ways, including in paper and electronic form. The security of your personal information is important, and Vulcan takes reasonable steps to protect it from misuse, interference and loss, and from unauthorized access, modification, or disclosure. Some of the ways Vulcan does this are:

(a) confidentiality requirements of Vulcan employees;
(b) document storage security policies;
(c) implementing security measures for Vulcan’s systems, including firewalls, data encryption on Vulcan’s websites and only giving access to personal information to verified personnel; and
(d) control of access to Vulcan buildings.

5.2  Vulcan can store personal information physically or electronically with third party data storage providers. Where Vulcan does this, it uses contractual arrangements to ensure those providers take appropriate measures to protect that information and restrict the uses to which they can put that information.

5.3  Vulcan will only keep your personal information for as long as it is required for Vulcan’s purposes. When Vulcan no longer requires your personal information, Vulcan will ensure that it is destroyed or de-identified.

6.1  Collecting, holding and using your personal information allows Vulcan to provide you with a range of services. Vulcan may use your information for the following purposes:

(a) supplying Vulcan products and services to you;
(b) processing credit application(s) and credit checks;
(c) identifying you or verifying your authority to act on behalf of a customer;
(d) processing quotes, orders, exchanges and refunds of Vulcan products and services;
(e) providing you with information about changes to our business, and existing and/or new Vulcan products and services;
(f) administering and managing our supplier/customer relationship, including responding to your enquiries, queries, requests and complaints;
(g) assessing employment applications;
(h) advertising and direct marketing purposes (see section 10 below);
(i) analysing your use and interaction with our customer service support and sales teams, websites, social media accounts, digital platforms, advertising, marketing and other digital content to evaluate, develop and improve those services and platforms, and to provide a better and personalised user experience;
(j) taking any required debt recovery or legal action in relation to your account;
(k) undertaking research and surveys;
(l) for all other purposes to which you have expressly or impliedly consented; and
(m) complying with all applicable laws and regulations and our internal policies (including in relation to occupational health and safety).

6.2  When you contact Vulcan by clicking on a telephone number on our website, your telephone call may be recorded and/or monitored. We utilise call tracking and recording services, such as WildJar, to:

(a) verify and process verbal orders;
(b) ensure the accuracy of order details and delivery information;
(c) maintain records for quality assurance and staff training; and
(d) protect our lawful interests in the event of disputes or misunderstandings.

6.3 If you no longer wish to receive Vulcan’s direct marketing offers (including electronic marketing communications), you may opt out / unsubscribe at any time by following the opt-out / unsubscribe instructions provided in the communication. You may also request that you be removed from our direct marketing list by contacting our Privacy Officer using the contact details listed in section 12 below. Vulcan will process your request as soon as practicable.

6.4 In addition to the ways for using personal information mentioned above, Vulcan may also use your credit information to:

(a) enable a credit insurer to assess the risk of providing insurance to Vulcan or to address Vulcan’s contractual arrangements with the insurer;
(b) assess whether to accept a guarantor or the risk of a guarantor being unable to meet their obligations;
(c) consider payment arrangements relating to any outstanding accounts; and
(d) assess whether to register a security interest.

7.1  To make sure Vulcan can meet your specific needs and for the purposes described in section 6 above, Vulcan may share your personal information with:

(a) third parties (listed in section 7.2 below);
(b) other entities within the Vulcan Group;
(c) your representative or any person acting on your behalf (for example, financial advisers, lawyers, accountants, administrators, trustees, guardians, brokers or auditors); and
(d) personal referees (to confirm details about you).

7.2  Vulcan may disclose your personal information to third parties, including:

(a) third parties who provide services to us or on our behalf in connection with our business and for the purposes set out in this Policy, such as recruitment services;
(b) organisations involved in debt collecting, including purchasers of debt;
(c) fraud reporting agencies (including organisations that assist with fraud investigations and organizations established to identify, investigate and/or prevent any fraud, suspected fraud, crime, suspected crime, or misconduct of a serious nature);
(d) government or regulatory bodies (including New Zealand Inland Revenue and Financial Markets Authority) as required or authorised by law (in some instances these bodies may share it with relevant foreign authorities);
(e) our accountants, auditors or lawyers and other external advisers;
(f) guarantors and prospective guarantors of your account; and
(g) third parties that maintain, review and develop our business systems, procedures and technology infrastructure, including testing or upgrading our computer systems; and
(h) third party vendors (such as Google LLC (Google) and Meta Platforms, Inc (formerly Facebook, Inc.) (Meta))) so we can deliver personalised and targeted advertising to you on those platforms.

7.3 Vulcan may store your personal information in cloud or other types of networked or electronic storage, which may be in countries outside of New Zealand, such as the United Kingdom, United States of America, Greece and other countries in the European Economic Area. Vulcan will not send your personal information outside New Zealand unless Vulcan is satisfied that the overseas recipient of the information handles your personal information in accordance with the Privacy Act, or you have consented to the transfer of your information. Overseas organisations may be required to disclose personal information that Vulcan shares with them under a foreign law. In those instances, Vulcan will not be responsible for that disclosure.

8.1  Vulcan may disclose personal information about you to a credit reporting body if you:

(a) are applying for credit;
(b) have obtained credit from Vulcan;
(c) guarantee or are considering guaranteeing the obligations of another person; or
(d) are a director of a company that is a credit applicant or guarantor.

8.2  When Vulcan gives your personal information to a credit reporting body, it may be included in reports that the credit reporting body gives other organisations (such as other credit providers) to help them assess your credit worthiness.

8.3  If you believe that you have been or are likely to be the victim of fraud (including identify fraud), you can request a credit reporting body not to use or disclose the personal information they hold about you for a certain period.

8.4  Credit reporting bodies can use the personal information about you that they collect for a pre-screening assessment at the request of a credit provider unless you ask them not to. A pre-screening assessment is an assessment of individuals to see if they satisfy particular eligibility requirements of a credit provider to receive direct marketing. To opt-out of credit pre-screening, contact a credit reporting body accordingly, and the credit reporting body will not use your information for that purpose.

8.5  Vulcan will not share any of your credit information with a credit reporting body unless it has a business operation in New Zealand. Vulcan is not likely to share credit eligibility information (that is, credit information it obtains about you from a credit reporting body or that Vulcan derives from credit information) with organisations unless they have business operations in New Zealand.

8.6  If you fail to meet your payment obligations in relation to consumer credit or commit a serious credit infringement, we may be entitled to inform the credit reporting body of this matter.

8.7  The credit reporting bod(ies) we deal with are 1Centre and Equifax. For contact details and information on how those credit reporting bodies manage credit-related personal information, please see their privacy policies available at the following links:

1Centre – https://www.1centre.com/privacy-policy/
Equifax – https://www.equifax.com.au/privacy

9.1  To the extent permitted by law, Vulcan will always give you access to your personal information, including for the purpose of correcting or updating that information, unless there is an exception to such disclosure which applies under the Privacy Act. If you would like to access or correct your personal information, please contact Vulcan via the contact details listed in section 12 below.

9.2  If Vulcan is unable to give you access to any personal information, Vulcan will tell you why in writing.

9.3  Vulcan will take reasonable steps to correct your personal information within 30 days from when you made your request, or any longer period that has been agreed with you. If you are worried that Vulcan has given incorrect information to others, Vulcan may be able to tell the third party about the correction.

9.4  If Vulcan is unable to correct your personal information, or inform a third party about the correction, Vulcan will explain why in writing within five business days of making this decision. If you are not satisfied with our response or have any further concerns, you can make a complaint to Vulcan or make a complaint to the Office of the Privacy Commissioner (OPC) using their contact details below.

10.1  As part of our digital marketing and customer engagement strategy, Vulcan may use services provided by third parties to analyse your use of Vulcan’s websites, social media accounts, digital platforms, advertising, marketing and other digital content, and to deliver targeted advertising. These may include:

(a) audience segmentation services provided by Google LLC and its affiliates (Google Data Segments) (see section 10.2 below); and
(b) customer audience tools provided by Meta Platforms, Inc (formerly Facebook, Inc.) (Meta’s Custom Audiences), which enable Vulcan to target advertising to individuals on Facebook, Instagram, and Meta’s advertising network.

10.2  Google Data Segments refer to categorised groupings of users or devices based on shared characteristics, behaviours, or inferred interests. These segments are derived from both online and offline data signals and are created through automated data processing techniques, such as behavioural analytics, demographic modeling, and interest inference. The data collected by Google in this process is typically pseudonymised or anonymised identifiers, however it may include identifiers such as cookies, advertising IDs and/or device fingerprints.

10.3  Vulcan uses Google Data Segments and Meta’s Custom Audiences to:

(a) reach business and consumer audiences who are likely to be interested in our products and/or services;
(b) deliver advertising tailored to specific demographics, locations, industries, or interest groups relevant to our business operations;
(c) retarget visitors who have previously interacted with Vulcan’s websites, social media accounts, digital platforms, advertising, marketing or other digital content;
(d) create lookalike audiences to reach new users with similar characteristics to our existing customers; and
(e) analyse and improve the relevance and performance of Vulcan’s marketing strategies and advertising campaigns.

10.4 Vulcan does not receive any personal information from Google or Meta through the use of these tools. All data that Vulcan accesses and uses is anonymised or pseudonymised and is therefore not subject to the Privacy Act.

10.5  You can manage your advertising preferences or opt out of personalised advertising as follows:

(a) for Google via the My Ad Centre – available here
(b) for Meta (Facebook/Instagram) via the Meta Ads Preferences page – available here

10.6  You can review Google’s and Meta’s privacy policies through the links below:

(a) Google’s Privacy Policy – available here
(b) Meta’s Privacy Policy – available here

10.7  You can also opt out of other third party’s use of cookies for interest-based advertising by visiting the Network Advertising Initiative opt-out page (available here). Additionally, you may manage the use of device identifiers by changing your device’s settings. A guide for adjusting these settings is available here.

Vulcan reserves the right to review and amend this Policy at any time and the latest version will be posted on Vulcan’s websites.

12.1  Please contact Vulcan if you have any questions, comments or complaints about this Policy.

Email: privacy@vulcan.co
Post: The Privacy Officer, PO Box 58-009, Botany, Auckland 2163
Telephone: 09 273 7214

12.2. If you are concerned about how your personal information is being handled or wish to make a complaint about an alleged breach of the Privacy Act, please contact Vulcan using the details listed above. Vulcan will endeavour to respond as soon as practical upon receiving written notice of your complaint. If you are not satisfied with Vulcan’s response, you may complain to the OPC about the way Vulcan handles your personal information information. The Commissioner can be contacted at:

Email: enquiries@privacy.org.nz
Website: www.privacy.org.nz
Post: PO Box 10 094, Wellington 6140
Telephone: 0800 803 809 (10am to 3pm Monday to Friday)

Cookie – is a small text file placed on your computer by a webpage server which may later be retrieved by webpage servers

Credit information means Personal Information that has a bearing on credit that has been provided to you or that you have applied for. This includes credit for personal, domestic or household purposes and credit in connection with a business.

Credit worthiness means credit information, such as details relating to credit history, credit capacity, and eligibility for credit.

Google means Google LLC.

Meta means Meta Platforms, Inc (formerly Facebook, Inc.).

OPC – means Office of the Privacy Commissioner.

Personal information – means any information (including an opinion) that Vulcan holds about you which identifies you or from which you are reasonably identifiable, and covers additional information on how Vulcan manages any credit information collected in connection with your credit application or credit facility.

Privacy Act – means Privacy Act 2020.

Vulcan, we, us – means Vulcan Steel Limited (company number 681317).