Our Privacy Policy

Updated: June 2023

INTRODUCTION

This privacy policy applies to Storbie Limited (and its New Zealand subsidiaries, including Storbie International Limited, companies registered in Wellington, New Zealand (we, us, our and Storbie).

It describes how we collect, process, dispose of and protect information that relates to an identified or identifiable individual across the Storbie Website, Storbie Customer Websites and the Services (Personal Information).  Aggregated and anonymised data that we collect and use is not Personal Information and, as such, this privacy policy does not apply to it.

Unless a capitalized term has been defined in this privacy policy, it uses the same definitions as those used in our terms and conditions, available at Terms of Service.

When handling Personal Information, we will comply with the any other Applicable Privacy Laws, including (as applicable),  the General Data Protection Regulation (EU) 2016/679 (EU GDPR), the United Kingdom Data Protection Regulation (UK GDPR), the New Zealand Privacy Act 2020 and/or the Health Insurance Portability and Accountability Act of 1996 (HIPAA). 

PERSONAL INFORMATION WE COLLECT

Anonymous Users

If you visit the Storbie Website or fill in a form on a Storbie Website (or contact us in another way such as via a phone call or email), we may collect your name, email address, phone number, location information, information about how you use the Storbie Website, IP addresses and/or other device identifying data, and any other information contained in your correspondence with us.

Storbie Customers and other Authenticated Users

If you are a Storbie Customer or another Authenticated User, in addition to the information referred to above, we may also collect the following information:

  • Your business email address, phone number and physical address.
  • Billing information such as credit card details.
  • Other information required to create a Storbie Customer Website and perform the Services, such as website content and business information (like tax details).

Storbie Customer Shoppers

When you browse a Storbie Customer Website, Storbie collects information about the pages you are accessing and the products you are viewing and purchasing, and stores this in an anonymized format that doesn’t contain any Personal Information.

If you make a purchase from a Storbie Customer Website, Storbie collects and stores your Personal Information (on behalf of the relevant Storbie Customer) as part of the checkout process, such as your name, phone number, email address and contact and delivery address.

When you pay for an order via a Storbie Customer Website using a third party payment provider, Storbie will collect and store information about the transaction (on behalf of the relevant Storbie Customer), such as the amount of payment and the transaction number, but your complete credit card number is never stored in Storbie’s systems. 

Without limiting any provisions of this privacy policy relating to Storbie’s access to and use of Storbie Customer Shoppers’ Personal Information, you acknowledge that all Personal Information that you supply to (or is processed via) a Storbie Customer Website, will be processed in accordance with the privacy policy on the relevant Storbie Customer Website.  We suggest you review that website’s privacy policy before you provide access to your Personal Information.

WHO WE COLLECT PERSONAL INFORMATION FROM

We collect Personal Information from:

  • you, when you provide that Personal Information to us, through registration and use of the Storbie Website and/or the Services, or through any other contact you have with us (e.g. telephone call or email, web chat).
  • third parties, where you have authorised this (including by providing consent to the collection and processing of your Personal Information by a Storbie Customer, Storbie Customer Website Owner or a Storbie Partner), or where the information is publicly available.
  • your use of the Storbie Website, Storbie Customer Websites and/or the Services, when you perform any action on, or interact with, any part of the Storbie Website, a Storbie Customer Website and/or the Services, including (as applicable):
  • clickstream data, which is a record of how you navigate or click through a website; and
  • information obtained through the use of cookies, web beacons and similar storage technologies. Please refer to the section of this privacy policy entitled “Cookies and Tracking” for further information, including information on how you can disable these technologies.

          Children's Privacy

  • Our Storbie website does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us if we become aware that we have collected Personal Information from anyone under the age of 16 without verification of parental consent, We take steps to remove that information from our servers.
  • If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, We may require your parent's consent before we collect and use that information.

HOW WE USE YOUR PERSONAL INFORMATION

We will not use your Personal Information without having a lawful basis to do so. 

Storbie Customers and Anonymous Users

We may process your Personal Information (as applicable):

  • to create accounts within the Storbie Website and the Service;
  • to provide the Storbie Website and the Services and otherwise carry out our obligations under the Terms of Service;
  • to provide ways for customers to contact Storbie Customers’ businesses;
  • to bill you (or the Storbie Customer on whose behalf you are acting) and to collect money that is owed, including authorising and processing credit card transactions,

and such processing is necessary for the performance of the contract between you and us.

We may also process your Personal Information:

  • to verify your identity;
  • to communicate with you (including responding to feedback and information requests relating to the Storbie Website and the Services);
  • to communicate with, and comply with our obligations to, our third-party service providers, suppliers and other Users of the Storbie Website and Services;
  • to send administrative messages, reminders, notices, updates, security alerts, and other information relevant to your use of the Storbie Website and/or the Services;
  • to analyse and report on usage of the Storbie Website and Services, so we can improve the Storbie Website and Service;
  • to keep you informed of any changes to our Terms of Service or this privacy policy;
  • to send you marketing and promotional messages and other information that may be of interest to you where you have consented to receiving such material. You can opt out of this at any time by contacting us at privacy@storbie.comor by clicking on the unsubscribe link that will be provided in the footer of any messages or emails that are sent to you (and which are not essential for providing our Services to you);
  • to protect and/or enforce our legal rights and interests, including defending any claim; and
  • to comply with our legal obligations, including any notification and reporting obligations and any access directions imposed on us by an applicable Government agency, law enforcement agency or regulatory authority,

and such processing is necessary for the purposes of a legitimate interest pursued by us, and we have assessed that our interests are not overridden by your interests or fundamental rights and freedoms.

Storbie Customer Shoppers

We may process your Personal Information to:

  • allow Storbie Customers to provide their products and services to you;
  • help Storbie Customers understand which Storbie Aggregation Websites are referring orders to their Storbie Customer Website and from what promotions;
  • help Storbie Customers to understand the performance of (and improve) their Storbie Customer Website;
  • provide Storbie Customers with information that helps them improve their products and services;
  • where applicable, to help Storbie Customers calculate commission payments;
  • provide you with a convenient and unified shopping experience;
  • monitor system performance and improve the Storbie Website and Services;
  • understand, respond to and report on market trends;
  • to protect and/or enforce our legal rights and interests, including defending any claim; and
  • to comply with our legal obligations, including any notification and reporting obligations and any access directions imposed on us by an applicable Government agency, law enforcement agency or regulatory authority,

and such processing is necessary for the purposes of a legitimate interest pursued by us, and we have assessed that our interests are not overridden by your interests or fundamental rights and freedoms.

All Users

We may also process your Personal Information for such other purposes that are compatible with the original purposes described above, or that you otherwise consent to.

We may anonymise and aggregate information such that no person could be re-identified from the information. This aggregated and anonymised data is not Personal Information and this privacy policy does not apply to it.

DISCLOSURE OF YOUR PERSONAL INFORMATION

Storbie Customers and Anonymous Users

Third party service providers

We use third party services for marketing and providing the Storbie Website and/or Services and for improving the Storbie Website and/or Services (for example, to payment processors, point of sale service providers and shipping service providers). In the process of doing so, the third party service providers may have access to Personal Information. However, these third parties do not have the right to use the Personal Information for their own purposes.

We may also disclose your Personal Information to any business that supports us, including hosting or maintaining any underlying IT system or data centre that we use to provide our Storbie Website and/or the Services/

We will pass your billing information (such as credit card details) to our billing partners, for example PayPal, eWAY, Stripe. For a full list of our billing partners, see https://www.storbie.com/us/partners. However, each third party processor’s collection and processing of your Personal information will be governed by its own privacy policy, which will be available on the third party’s website.

Storbie Partners

Storbie also works with Storbie Partners who provide and support Storbie Customer Websites on our behalf. For a full list of these partners, see https://www.storbie.com/us/partners. If you indicate to us that you would like to work with one of these third parties (either via a Storbie Website, by email or on a phone call) we will pass your name, email and phone number on to them.

Storbie Supplier and Aggregation Websites

When you request that your Storbie Customer Website connect with a Storbie Supplier Website or Storbie Aggregation Website, then a notification is sent to that website, which contains the name and email address of the Storbie Customer Website Owner.

When you connect with a Storbie Supplier Website, Storbie will share with the relevant Storbie Customer Website Owner which specific products you have chosen to connect with.

When you connect with a Storbie Aggregation Website, Storbie will share with the relevant Storbie Customer Website Owner the details of products that your Storbie Customer Website is displaying in that Storbie Aggregation Website.

Storbie will share statistics about each Storbie Customer Website with Storbie Aggregation Websites and Storbie Supplier Websites such as total page hits, order counts and purchase value. These statistics will be filtered to only those that are relevant to the products and other assets, such as images, that are from or displayed in your website and will not contain any of your Storbie Customer Shopper’s Personal Information, unless you have configured for them to receive this information in order to assist with the fulfilment of an order.  Storbie Customer’s are solely responsible for obtaining any consents and approvals necessary to receive and transfer such Personal Information in accordance with Applicable Privacy Laws.

Storbie Customer Shoppers

Third party payment providers

When you pay for an order via a Storbie Customer Website using a third party payment provider, you share your payment details such as your credit card number with the third party provider and the Storbie Customer Website Owner.  Storbie will collect and store information about the transaction, such as the amount of payment and the transaction number, but your complete credit card number is never stored in Storbie’s systems.

Some payment providers require Storbie to pass on your checkout details such as your name, email address and contact and delivery address information and, in these cases, we pass this information to them. Each third party processor’s collection and processing of your Personal information will be governed by its own privacy policy, which will be available on the third party’s website.

Other third party service providers

Some Storbie Customer Websites work with third party service providers and suppliers when fulfilling your order and may configure Storbie’s system to pass some or all your information that you enter during the checkout process from that Storbie Customer Website on to those third parties for the purpose of fulfilling your order.

Storbie Aggregation Websites

A Storbie Aggregation Website displays products and other information aggregated across a number of other Storbie Customer Websites. When you click through to a Storbie Customer Website from a Storbie Aggregation Website:

  • Storbie will automatically pass your current Storbie Aggregation Website identity on to any Storbie Customer Websites you visit from that Storbie Aggregation Website; and
  • If you make a purchase, then we share the Storbie Aggregation Website and sub-page URL that you came from with the Storbie Customer Website before adding each product to your cart.

Storbie Aggregation Websites are provided with aggregated information on the time and value of page views and orders across Storbie Customer Websites that you interact with after clicking through from that Storbie Aggregation Website.

Storbie Aggregation Websites are not provided with your Personal Information or the details of your individual orders unless you specifically provide it, for example by filling in a form on the relevant website.

All Users

We may also disclose your Personal Information to:

  • a person who can require us to supply Personal Information (e.g. a Government agency, regulatory authority or law enforcement agency);
  • respond to due diligence requests and/or transfer Personal Information in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition of our business; and
  • any other person or entity authorised by you.

The rights of disclosure in this clause 5 may, if applicable, be subject to further restrictions contained in data processing agreements with our Storbie Customers and/or third party service providers (as applicable).

OVERSEAS TRANSFERS OF PERSONAL INFORMATION

Storbie is located in New Zealand, so your Personal Information may be transferred and/or stored there. For the purposes of the EU GDPR and the UK GDPR, New Zealand has been recognized as providing adequate protection and Storbie subscribes to the principles of the US Privacy Shield Framework.

We utilise the services of third party processors (or sub-processors, as applicable) in various countries who may access your Personal Information. An up to date list can be found on our partners page. Consequently, we may transfer Personal Information to persons or entities located in these countries.  Although we will endeavour to ensure that Personal Information is treated securely and in accordance with this privacy policy as well as Applicable Privacy Laws, we advise that some of these countries may not have an equivalent level of data protection laws as those in New Zealand.

For the purposes of the EU GDPR or the UK GDPR (if applicable):

  • Storbie is the data controller in respect of Personal Information collected fromStorbie Customers and Storbie Partners.
  • Details of the data controller will be specified in the privacy policy on the relevant Storbie Customer Website. The controller will have its own privacy policy that will apply to its use of your Personal Information processed via its Storbie Customer Website and we suggest you review that website’s privacy policy before you provide access to your Personal Information.

If we transfer Personal Information to a third party located in a country outside:

  • The European Economic Union that the European Commission has not recognised as providing adequate protection, if required by the EU GDPR we will enter into an agreement with that third party that containing the standard contractual clauses approved by the European Commission; or
  • The United Kingdom that the United Kingdom Government has not recognised as providing adequate protection, if required by the UK GDPR we will enter into an International Data Transfer Agreement or Addendum (as appropriate) issued under section 119A of the UK Data Protection Act 2018.
  1. For the purposes of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) (if applicable), if we provide services as a business associate to a covered entity or to another business associate (or procure services from a business associate) and HIPAA and HIPAA regulations apply, our privacy obligations are governed by the Business Associate Agreements we enter into with those covered entities and/or business associates. Under HIPAA, the covered entity should be your point of contact for any privacy-related requests.

INTERNET USE

While we take reasonable steps to maintain secure internet connections, the supply of Personal Information over the internet is at your own risk.

If you follow a link on a Storbie Website or a Storbie Customer Website to another website, the owner of that website will have its own privacy policy that will apply to its use of your Personal Information processed on that website. We suggest you review that website’s privacy policy before you provide access to your Personal Information.

HOW LONG WE KEEP PERSONAL INFORMATION

We will keep your Personal Information:

  • until we no longer have a valid reason for keeping it;
  • until you request us to stop using it; or
  • for as long as required by law (for example, we keep invoice information for 7 years to fulfil our tax obligations).

You should be aware that we do keep backups and logs for up to six months before they are automatically deleted.

If you are a Storbie Customer and you fully delete a Storbie Customer Website that you own, or cease the required payments for that website, then that website will be purged pursuant to our standard processes. However, we will continue to store anonymous or anonymised information, such as usage statistics and other information about deleted Storbie Customer Websites, without identifiers, in order to improve our Services.

COOKIES AND TRACKING

Web analytics

We use web analytic tools, such as Google Analytics, to collect information about use of the Storbie Website and/or the Services, with the goal of improving such websites and Services. These web analytic tools collect anonymous and anonymised information, such as how often Users visit the Storbie Website and Services, what pages they visit when they do so, and what other websites they used prior to coming to the Storbie Website.  This information is stored in Google Analytics and our own back end systems.

Cookies

We may use various technologies to collect and store information about you when you use the Storbie Website and/or the Services, and this may include using cookies and similar tracking technologies, such as pixels and web beacons, as described below.

In addition, some Storbie Customer Websites use cookies and marketing services (such as Google and Facebook Pixel). You should refer to the individual Storbie Customer Website’s privacy policy for details on their use of such services.

A cookie is a piece of information that a web server may send to your machine when you visit a website. The cookie is stored on your device, but does not identify you or give us any information about your device.

The types of cookies we use may include:

  • Strictly necessary cookies: These cookies are essential to the full functionality of a website. They enable you to navigate around a website and use its features. Without these cookies, you may not be able to access all the functions of the Storbie Website and/or the Services.
  • Performance cookies: These cookies collect information about how you use the Storbie Website and the Services. All information these cookies collect is anonymous and only used to improve the Storbie Website and/or the Services.
  • Functionality cookies: These cookies allow a website to remember the choices you make (for example, your user name, language or your region). Although these cookies are used to enhance the performance of the Storbie Website and/or the Services, they are non-essential to their use. However, without these cookies, certain functionality may become unavailable.

The length of time a cookie will stay on your browsing device depends on whether it is
a persistent or session cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies will stay on your browsing device until they expire or are deleted.

With most internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. If you want to do this, refer to your browser instructions or help screen to learn more. If you reject the use of cookies, you will still be able to access the Storbie Website but please note that some of its functions may not work as well as if cookies were enabled.  To learn more about how to enable, edit, or disable cookies on your computer, please visit the www.aboutcookies.org website.

Here are some links that might assist you to change the cookie settings on your browser:

Additionally, most advertising networks offer you the option to opt out of targeted advertising. See http://www.aboutads.info/choices or http://www.youronlinechoices.com for more information.

Web beacons

Web beacons are tiny graphics with a unique identifier that may be included on the Storbie Website for several purposes. For example, we may use web beacons to deliver or communicate with cookies, to track and measure the performance of the Storbie Website and/or the Services, to monitor how many visitors view the Storbie Website, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on an individual’s hard drive, web beacons are typically embedded invisibly on web pages (or in an email). We use these web beacons to customise content and advertising and to analyse traffic to a website.

AUTOMATED DECISION-MAKING AND PROFILING

The laws of some jurisdictions require that we tell you if our systems conduct any processing, including profiling, which produces a decision that is completely automated and produces legal effects concerning you or similarly significantly affects you. We do not consider that any of the automated decision-making that our system conducts fits this criteria.

Like all online services, we do undertake necessary automated decision-making and profiling in our system to make setting up and providing our Services efficient and accurate, such as pricing (if you elect certain Storbie functionality the system will automatically decide to price and bill you), payment, debt tracking, debt recovery, website hosting, goods tracking, inventory management, invoicing and ordering. If you wish our staff to review a decision taken by our system, we are prepared to do so. See below under the heading ‘Contact’ for details of how to contact us to request this.

We also conduct profiling for our general business purposes such as customer churn prediction and lead analysis. Under some circumstances we may take automated action based on this analysis. You can choose to object to this. See below under the heading ‘Contact’ for details of how to contact us regarding this.

PROTECTING PERSONAL INFORMATION

We take the protection of Personal Information seriously and we will take reasonable steps (using physical, electronic and procedural safeguards) to keep Personal Information in our possession safe from loss, unauthorised activity, or other misuse. Staff who handle your Personal Information are provided with training on how to do so appropriately.

YOUR RIGHTS

You have the right to access your readily retrievable Personal Information that we hold about you, and to ask for it to be corrected if you think it is wrong or to be deleted. If you have a Storbie Login, you can view and update some of your personal data such as your name and email address by visiting https://secure.storbie.com/account.

If you are based in the European Economic Union or the United Kingdom you also have the right, under the EU GDPR or the UK GDPR (as applicable), to:

  • in certain circumstances, have your Personal Information erased;
  • restrict the processing of your Personal Information;
  • move, copy or transfer your Personal Information easily for your own purposes across different services in a safe and secure way;
  • object to processing where we rely on our legitimate interests as the lawful basis for processing;
  • withdraw your consent at any time, where our processing of your Personal Information is based on consent; and
  • lodge a complaint with an appropriate supervisory authority, if you consider that our processing of your Personal Information has breached the EU GDPR or the UK GDPR (as applicable).

We will respond to any request made in respect of the above in accordance with Applicable Privacy Laws. However, if we receive any data subject requests relating to Storbie Customer Shopper Personal Information held by Storbie Customers (e.g. requests to access or correct Personal Information), we will forward these requests to the relevant Storbie Customer.  Storbie Customers control and are responsible for correcting, deleting or updating the Personal Information of Storbie Customer Shoppers they process.

Please note that in certain circumstances we may refuse to respond to a rights request where we have the right to do so under Applicable Privacy Law, for example, where a request is manifestly unfounded or excessive.

US State Rights

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

  • Confirm whether we process their personal information.
  • Access and delete certain personal information.
  • Data portability.
  • Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

  • Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.
  • Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.
  • To exercise any of these rights please contact privacy@storbie.com

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: privacy@storbie.com. However, please know we do not currently sell data triggering that statute's opt-out requirements.

CONTACT

If you wish to exercise your rights under this privacy policy or any Applicable Privacy Laws, you can do this by emailing our Privacy Officer at privacy@storbie.com. Your email should provide evidence of who you are and set out the details of your request (e.g. the Personal Information, or the correction, that you are requesting).

CHANGES TO THIS PRIVACY POLICY

From time to time we may make changes to this privacy policy (for example, to reflect any changes in our Services or any Applicable Privacy Laws).  Where a change is significant, we’ll make sure we let you know – usually by displaying a notice on the Storbie Website or by sending you an email.

DEFINITIONS

In this privacy policy, Applicable Privacy Laws means the laws protecting the right to privacy that apply to our processing of your Personal Information, including the New Zealand Privacy Act 2020 and, as applicable, may also include the General Data Protection Regulation (EU) 2016/679, the United Kingdom Data Protection Regulation and/or the Health Insurance Portability and Accountability Act of 1996, the Federal Trade Commission Act, the Children’s Online Privacy Protection Act and relevant US State privacy laws (and associated regulations).