Skinny Privacy Policy

This policy is correct as of 30 September 2020.

At Skinny, we'll do anything to keep prices low and customers happy. As part of that, we want to be transparent about how, we as a business, use our customers’ data. We’re also very aware of the responsibility that comes with being a telco in today’s world, by keeping you connected and ensuring the personal information you share with us is treated with care.

We’ve worked with our lawyers to put together this Privacy Policy to tell you how we as Skinny collect, use, protect and share your personal information. We hope you find it transparent and easy to understand.

Who are we?

Where this Policy says “we” or “us” or Skinny, it means Skinny, a division of Spark New Zealand Trading Limited.

What’s this Privacy Policy about?

In this Policy, we’ll tell you how we collect, use and protect your personal information. We’ll also tell you who we share your personal information with and when. 

Personal information is any information that can be used to identify you. For example, your name, your address, phone number and email address are all personal information. Personal information can also include your credit card details or the way you use your phone. For example, what phone numbers you call.

Skinny collects, uses and discloses your personal information in ways that follow applicable legal requirements. This includes the Privacy Act 1993 and the Telecommunications Information Privacy Code 2003.

Go to Privacy Act 1993

Go to Telecommunications Information Privacy Code 2003

When does this Privacy Policy apply?

The Privacy Policy applies whenever you interact with us or use our products and services. This includes our mobile and broadband services, and our digital platforms (such as our websites and apps). This Privacy Policy forms part of the terms and conditions applicable to all Skinny products and services that you agree to when you sign up.

People who aren’t Skinny customers

Even if you aren’t a Skinny customer, this Policy applies to any personal information you provide to us or that we collect when you interact with us or use our products and services. For example, if you:

Use Skinny services that another person in your household or your employer pays for. Are an authority on someone else’s account (as nominated by the Skinny account holder).

Contact us – for example, to enquire about our services.  Register online to receive information about our products and services. Download or interact with us through one of our digital platforms, including, for example, our apps. Take part in a Skinny survey or trial or enter a competition or promotion. Engage with us on our Social Media channels; Facebook or Instagram. 

This is personal information we receive from you (for example when you sign up for a Skinny product or service), that third parties give to us or that we create about you. 

To provide you with Skinny products and services, interact with you and conduct our business, we need to collect some information directly from you and sometimes from publicly available data sources and third parties. If we ask you for information and you decide not to supply it, we may not be able to provide some products and services to you.

Information we collect from you

We collect information directly from you when you:

Sign up for a Skinny product or service. This may happen online, through our website, Skinny online, or through our other digital platforms such as the Skinny app. It may also happen through Skinny dealers, our contact centres (such as 204 or 0800 4 SKINNY), or a mobile app.

Communicate with one of our team, including our virtual assistants and online chat sessions. 

Pay for our products or services. Enter a competition or promotion run by Skinny or one of our trusted business partners. Complete a Skinny online form or respond to a questionnaire. For example, if you tell us the reason you would like to attend a Skinny hosted event.  Provide or submit information to us through one of our digital platforms, like our apps.

The personal information we collect may include:

Name, address and date of birth. Contact (and alternative contact) information such as email address and phone number. Language preferences. Communication and notification preferences. Personal preferences, including, for example, product alias information (when you give a name to services or products that we supply to you). Any photos or images you choose to provide us (like when you upload a profile picture), when using Skinny digital platforms, such as our website or app. Residency and housing status.  Employment information, including status and employer.  Identification documents like your driver’s license or passport. Payment information like your credit card or bank account details.  Verification information and security credentials such as your security questions and responses. Relevant medical conditions, including if you want a landline to use for emergency services only or are seeking Vulnerable End User status for you or a member of your household.  Information you share with us in calls and online chats (Live Chat) with our Contact Centre staff or Virtual Assistants or when you email or write to us. (We record contact centre calls, Live Chat and online help message requests to help improve our customer service and assist in resolving disputes.) 

Information we collect from other divisions of Spark

We may collect information about you from other divisions of Spark New Zealand Trading Limited and companies within the Spark group.

Information we collect from third parties

We may sometimes collect or purchase personal information about you from publicly available sources like real estate listings or from other people, like loyalty programme partners, credit reference agencies or information aggregators. We only do this if we reasonably believe you’ve authorised us to do so, or if you’ve authorised the third party to share your information with us.

If you’re moving services to Skinny we may collect personal information from your current provider. For example, we may confirm your account number with them. This helps us transition you smoothly.

We may also collect your personal information if we’re investigating alleged fraud. This can include information from the person who says they’ve been defrauded, verification of your passport from the Department of Internal Affairs and confirmation of the order delivery status and address from courier companies for deliveries of Skinny products.

We may also collect or purchase data and combine it with other information that we hold about you to help us better understand your needs and those of potential customers. For example, we may:

Obtain aggregated, anonymised information – such as census data. Collect information from public websites (such as data about individual house sales). Purchase information that is collated by third parties and may relate to identifiable individuals.

We will only collect this kind of data from trusted providers if we’re satisfied they have permission to share this information with us and the collection, use and disclosure meets the requirements of the Privacy Act.  

Information we create to manage your account

We also create and hold information to manage your Skinny account, including:

An account number and phone numbers (if any apply). Your service connection and disconnection dates. Your billing information and purchase and payment records. Skinny products and services you use now or have used or bought before. 

Account authorities

If you give someone else authority to manage your account, we’ll collect their name and contact information from you. Please make sure you have this person’s agreement before you share their information with us. 

Market research, surveys and customer focus groups

To help improve our products, services and your customer experience, we may ask you to take part in market research. When we ask this, we take the information you share with us and combine it with responses from other people. While we may use some of the information about you and your account (e.g. what plans you have with Skinny) alongside your survey response to help us with our analysis, we don’t hold a copy of your responses with your account information.

This is personal information relating to the use of mobile and broadband connections or products which we collect automatically when you use Skinny products or services. It does not include data that we collect when you use our digital platforms, which is Online Experience Data, as described below.

When you use Skinny products and services, we receive information about how our network, systems and platforms are working. This includes personal information about the way you use our products and services, including:

Technical device information

This is the technical information about your device, and how it interacts with our networks, products and services. This could include information like performance-related settings and networks to which your device connects.

Service usage information

This is information such as how much data you’ve used or how many calling minutes or texts you’ve used. It can include what you’ve used the service for, like whether you’ve streamed music or browsed the web.

Call and text data

This is information such as the phone numbers you’ve called and sent texts to, or phone numbers you’ve received calls and texts from. Please see the ‘Your content’ section for how we deal with the content of your texts and phone calls. 

Service location data

This is created when:­

You use our mobile and wireless networks. Information is generated about network activity (such as calls, SMS, data usage) at a particular cell site and when this activity occurs. You call 111. This turns on GPS location capability which is used solely to notify emergency services of your location and help them respond to your call.

Internet Protocol (IP) address information and device identifiers

The IP address, unique identification numbers, online identifiers (including device IDs), browser information and other similar or alternative identifying information of the device you use to access Skinny’s network services and the dates and times you were using our network services.

This is personal information we collect automatically about your Skinny digital experience when you visit, download or use Skinny websites, apps and other digital platforms to interact or engage with us. We set out examples of Skinny online experience data below. Please note that if you use our apps, you can choose use the app without logging in. When you use the app without logging in, we may still collect some Skinny online experience data and information about your device but it will not identify you.

Online device information

This may include details of the device you use and its attributes, like your provider, device ID and your device’s technical and performance-related settings (including your language preferences).

User behaviour information

Like many companies, when you visit or use our websites, apps or our other digital platforms or receive communications from us, we collect and store information about your experience. We use several kinds of technologies or software for this, for example: 

Advertising cookies Analytics cookies Web beacons Clear gifs

A cookie is a small packet of information that our digital platform sends to your web browser, app or device. It lets our digital platform recognise you when you visit or interact with us and keep track of your preferences. A web beacon or clear gif is a small image file embedded onto a webpage or email that tracks what you do on that webpage or how you interact with the email. 

We collect and store information about your visit to, or use of, Skinny digital platforms, including:

Your device’s IP address or the mobile device type you’re using to connect to the internet. Your device’s mobile advertising identifiers (MAIDs). The dates and times you log on and off Skinny digital platforms. Your internet service provider (ISP). Your operating system and browser type. Your browsing behaviour on any Skinny digital platform, including the date and time and pages or screens visited. If applicable, the search engine or other search data used to locate a Skinny platform. The last page you visited before coming to a Skinny digital platform, but only if you came to our site by clicking on a link or URL on another webpage, email, or some other identifiable digital resource. Your account settings, app settings, push notifications, other communications preferences, app usage, profiles and service experience and quality. We’ll only collect this information where applicable, depending on your products, services and communication channels. 

If you enable cookies in your web browser or otherwise elect to be remembered by one of our digital platforms, you don’t have to re-enter your username every time you visit or use our websites or apps. We use cookies and other similar technologies that store your login details locally on your device so that information isn’t passed to us. Please note, cookies and other technologies will only work like this if they’re enabled. This is usually the default setting. You can turn cookies off and manage other advertising preferences and opt outs from your device. Plus other digital platforms will usually include an option not to be remembered.

Read more about how to turn cookies off using Google Chrome

Read more about how to turn cookies off using Microsoft

Read more about how to turn cookies off using Mozilla Firefox

Read more about how to turn mobile advertising identifiers off on your Apple device

Read more about how to turn mobile advertising identifiers off on your Android device

Third party provider sign in

You can sign into your Skinny dashboard online and our apps using third party login providers such as Facebook or Google. When you do this, we collect authentication information from the third party login providers such as your email address, profile photo (if you have one) and a login token. Skinny does not store any passwords from third party login providers.

We may also receive additional information from Facebook or Google, including your age, gender, assumed interests and browser language. We’ll only receive that information if you’ve given consent in your Google and Facebook privacy settings.

Go to Google privacy settings

Go to Facebook privacy settings

Skinny’s bots

When you talk to a Skinny bot from a third party platform such as Facebook Messenger, Google (our third party service provider) will temporarily store and analyse your conversation so that the bot can talk back to you. You can access information about Google’s privacy here.

The third party platform provider may also store your bot conversation. You can access information about Facebook’s privacy here. We suggest that you do not share highly sensitive personal information, such as credit card or bank account details, with any bot.

This is personal information created by you when you use Skinny products and services. For example, photos you take and text messages you write.

When you use Skinny products and services, you may create, share or send personal content. This could be things like phone calls, text messages, emails, photos and videos. 

We treat this data with great sensitivity as we know how important that information is to you. We only use this data to deliver your content to the people or places you tell us to send it to. For example, we carry your calls over our network and deliver your emails. The only exceptions are: 

Where we’re legally required to share your information. For example, if we’re ordered to do so by the Police or another Government agency under applicable laws or in response to a court order. For more on this topic, see section further below: To assist law enforcement, government and emergency response agencies. If we have reasonable grounds to believe the disclosure is necessary to prevent or lessen a threat to someone’s life or health or for reasons of public safety in line with our legal obligations.

When you use some Skinny services, information about websites you’ve visited and apps you’ve used is automatically generated. We may use this information in an anonymised, aggregated format, for example, to help us manage the Skinny network.

Where we store your personal information

We store most of your personal information on our own servers here in New Zealand. But from time to time we may need to store personal information in the cloud (online). This may involve storage in data centres outside New Zealand. We take care to carefully select data centre and storage service providers whom we trust with your information.

Keeping your personal information secure

We apply strict security measures and follow industry standards to keep your personal information secure. To help with this, we ask that you:

Keep unique account information such as your account number, PIN and password secure and don’t share them with anyone. Always select strong, unique passwords or PINs. Make sure you’ve never used them on other services or platforms now or in the past. Don’t reuse your password or PIN for any other services or platforms.

We may assume that any verbal or online request or instruction we receive is authorised by you if it’s accompanied by suitable verification (like your Skinny account number, personal identification number or password).

What we do if there’s a data breach

We work hard and follow industry best practice to ensure the information we hold is secure.

If we become aware of a data breach that we think could compromise your security, we’ll tell you as soon as we can. We may also report the breach publicly, if we consider it appropriate to do so or if we’re required to by law.

How long we keep your personal information

Generally, we only keep your personal information for as long as it’s needed. That means once we’ve carried out the purpose for which we first collected it, we get rid of it – either by deleting it or anonymising it.

More specifically:

We keep billing records for seven years.  We keep text messages for approximately one month.  That lets us verify and address any delivery issues. We generally keep recordings of Live Chat conversations between our contact centres and customers for up to 3 years. We may keep them longer to investigate a complaint, for customer service coaching or if legislation or industry codes require us to.

If you’re a Skinny customer, we may continue to hold, use and share your supplied data after our agreement with you ends and you stop being a Skinny customer. We do this so that we can discuss matters relating to your former account and so it’s easier to reconnect your account if you wish to join us again in the future. We may also use this information to contact you with offers and to help improve our credit and fraud management controls and decision-making/credit scoring models. 

Accessing & correcting your personal information

You can request access to, and correction of, the personal information we hold about you. To do so, you may either:

Send a letter to the Call Investigations Centre:

PO Box 550, Wellington 6011 Or email:

skinnyCIC@spark.co.nz

Before processing your request, we‘ll contact you to verify your identity, confirm your request and advise of any charges that may apply. Occasionally, we may withhold information on one of the grounds set out in the Privacy Act 1993 or the Telecommunications Information Privacy Code 2003.

Feedback & complaints

We have robust processes to manage the personal information that we hold about you. But if you have any concerns or feel your privacy has been compromised in some way, please let us know.

The Skinny Privacy Complaints Process will ensure your concerns are addressed as quickly as possible.

View the Skinny Privacy Complaints Process

To request further investigation, you can contact the Privacy Commissioner at any point during or after having lodged a complaint with us.

Go to the Privacy Commission’s website

If anything in this policy needs clarifying, or if you have questions about your privacy, please don’t hesitate to reach out to us. Email: skinnyprivacy@spark.co.nz

Throughout this Policy, there are areas where you can make choices about your privacy. Here’s a recap on what they are:

User behaviour information

If you enable cookies and similar technologies on your device, you don’t have to re-enter your username every time you visit our websites or apps. Remember, we use cookies and other technology that store your details locally on your device so that information isn’t passed on to us. It’s usually the default setting for cookies to be enabled, but you can choose to turn them off and other digital platforms will usually include an option not to be remembered.

Learn how to turn cookies off using Google Chrome

Learn how to turn cookies off using Microsoft

Learn how to turn cookies off using Mozilla Firefox

Mobile advertising identifiers can also be managed on your device.

Read more about how to turn mobile advertising identifiers off on your Apple device

Read more about how to turn mobile advertising identifiers off on your Android device

Access to photos and images

If you choose to upload a photo or image to any Skinny digital platform (for example uploading a profile picture), Skinny will receive access to your photo library. While Skinny will only store the photos or images you choose to provide us, to remove Skinny’s permissions to access your photo library, you may need to change the preferences on your device.      

Promotional communications

You can choose whether you’d like to be kept up to date with the latest offers and promotions from Skinny.

You can opt out of all promotional messages by getting in touch with us. Or you can opt out of promotional emails only by updating your settings via your online dashboard. You can also click ‘unsubscribe’ on marketing emails.

To opt out of promotional emails and texts, login to your Skinny Dashboard

Get in touch with us

Sharing anonymised, aggregated mobile location data with Qrious

Skinny shares anonymised, aggregated mobile location data with Spark-owned company Qrious. These are large sets of data that Qrious use to provide insights to other organisations. For example, there are often 6000 people in region ‘A’ at 1pm on Saturdays. These insights help organisations improve infrastructure and services. You can choose to have your anonymised mobile location data excluded from these large data sets by emailing us with your mobile number.

Email: skinnyprivacy@spark.co.nz

Personalised Skinny experiences on third party websites and apps

We may sometimes share your email address and/or mobile number with Google, Facebook and TradeMe to help us personalise your experience of Skinny on those other websites and digital platforms with relevant content, offers and ads from Skinny.

You can opt out of us sharing information about you with Google, Facebook and TradeMe for these purposes. You can do this by clicking the link below to log in to your Skinny Dashboard to update your settings. We have also detailed the instructions on how to do this below. If you opt out, you may still see ads and other information from us, but it won’t always be as relevant to you.

Login to your Skinny Dashboard to update your settings

Instructions on how to opt-out:

Head to skinny.co.nz/Security/login and login Click on the “Settings” menu Under “Settings”, click on “Sharing your info with third parties” After reading the information on the page, decide to “Allow” or “Opt-out” at the bottom of the page Click “Save” to confirm your decision

If you don’t have a Skinny Dashboard login, you can sign up for one on the link below. Once you have signed up you can update your preferences as per the above instructions.

Sign up for a Skinny Login

We may need to update this policy from time to time to reflect changes in the law and our practices.

We will provide you with two weeks’ notice of any changes on our website. If the changes are significant we may also advise you directly. We encourage you to check this site regularly.