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.
Who are we?
Where this Policy says “we” or “us” or Skinny, it means Skinny, a division of Spark New Zealand Trading Limited.
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.
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.
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.
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.
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.
We may use your personal information and share it with others, including:
Divisions of Spark New Zealand Trading Limited and companies within the Spark group. Carefully selected and trusted third parties like service providers, business partners, agents and advisors. Contact centre providers. Other network operators and telecommunications companies. Government and law enforcement agencies. Emergency response agencies. Credit reporting and debt collecting organisations.
We’ll use and share your information with these various groups for the purposes listed below. As we don’t use and share every type of information we collect for every purpose, we’ve identified the kind of information we use for each purpose.
To provide you with products and services
We use and may share your supplied data, usage data and Skinny online experience data to provide you with products and services, including to:
Verify your identity and manage your account. Deliver products and services to you. Enable you to communicate with people on other telecommunications networks. Process applications and online transactions. Charge you for our services, send you bills and process your payments. Offer and provide you with rewards, discounts and other benefits. Enable you to earn rewards and participate in any third-party loyalty programme or to receive any third-party products and services that you’ve signed up for. Communicate with you about our products and services, including if you contact us. Install products and services like broadband at relevant properties. Monitor how you use our network and alert you if we observe unusual or potentially fraudulent or unpermitted usage. Understand your use of our services to make sure you’re following our terms and conditions. This includes any applicable Fair Use Policies, which can be found in the terms and conditions for the relevant service.
To improve our customer service, products and services
We may use your supplied data, usage data and Skinny online experience data to improve our customer service, products and services, including to:
Help you when you report a problem. Offer you better deals and more cost efficient ways of receiving Skinny products and services. Investigate and address customer concerns. Analyse and understand the types and number of enquiries we receive. Understand what you think of our products and services. Help us find ways to simplify and improve our services and to better understand your needs. Innovate, develop and improve current and new products and services.
To manage and secure our services, systems and network
We may use your supplied data, usage data and Skinny online experience data to:
Operate, maintain, develop, test and optimise our services, processes, systems, platforms and networks. For example, we may use buffering and streaming experience information to make decisions on how to manage the network. Manage traffic over our network, manage network capacity and plan for how we use our network in future. Secure and protect our systems, platforms, networks and Skinny sites. This includes managing, improving and monitoring their operation, security and integrity. Monitor, detect and prevent fraudulent or illegal use of our services, network and Skinny sites. Detect and prevent attacks against our networks, systems and platforms, and threats to their security or integrity. This may include monitoring traffic over our network and communications between customers and third parties. It may also include sharing information (like the IP address responsible for a cyber-attack) so other organisations can protect themselves. Ensure compliance with our terms and conditions.
We may also need to share your personal information with other telecommunications service providers to monitor or investigate fraud or other offences.
To communicate with you
We may use your supplied data, Skinny online experience data and usage data to let you know about:
Any changes that might affect your service. Other information about your service, for example telling you that we have processed your order or providing you with technology updates. Skinny offers, products and services we think will interest you. This may include promotional messages about special offers and events, rewards, competitions, promotions and other information from the Skinny group of companies.
You can opt out of all promotional messages by getting in touch with us. Or you can opt out of promotional emails and SMS by updating your settings via our online dashboard. You can also click ‘unsubscribe’ on marketing emails.
To personalise your experience of Skinny digital platforms
We may use your supplied data, Skinny online experience data and usage data to:
Give you relevant information and optimise your experience when you visit or use Skinny digital platforms. Help us understand and save your preferences for future visits and use. Understand your interests and personalise the content and offers presented to you. Improve our online customer experiences and Skinny digital platforms. Measure the effectiveness of advertising on Skinny and third party digital platforms.
To personalise your experience on third party websites and apps
We may use your supplied data, Skinny online experience data and usage data to:
Present you offers and information about Skinny products and services we believe will interest you when you visit other websites, apps or digital platforms. Make information about our products or services relevant to you when we promote them on platforms such as Google, Facebook and TradeMe.
We sometimes run advertising campaigns where we share your email address and mobile number with Google, Facebook and TradeMe to help us show you relevant content, offers and ads when you visit other websites. This also helps us avoid showing you information about Skinny products and services you’ve already signed up for.
Google, Facebook and TradeMe may provide us with aggregated, anonymised information about people who responded to the advertising campaign. This can include age brackets, gender, assumed interests and affinities for each campaign response type. This information won’t identify you. For example, Google, Facebook or TradeMe may tell us that most people who clicked on the ad were aged 20 - 40 and like cooking. Google, Facebook and TradeMe collect this information based on your browser language and online behaviour. Google, Facebook and TradeMe only provide this information about people whose privacy settings allow it. You can change your permissions in your Google, Facebook and TradeMe settings.
We use this aggregated, anonymised information to:
Understand the effectiveness of our content, offers and advertising. Provide relevant content, offers and ads to other people who may have similar interests, based on those who responded to the ad.
The information we share with Google, Facebook and TradeMe is provided to them so they can deliver these services to Skinny. Skinny is not selling this data to Google, Facebook or TradeMe, nor allowing them to use it for any other purpose. Please note, Skinny doesn’t use Facebook “Event Data” services.
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.
Opt out of having your information shared with Google, Facebook and TradeMe:
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 above.
To conduct credit checks, report on payments and defaults and recover debts
We may use your supplied data and Skinny online experience data to:
Assess your ability to pay for some of our services and, if you’ve agreed, we may share your information with credit reference agencies to run credit checks. Report bill payment timing (known as Positive Credit Reporting) and payment defaults to credit reference agencies.
Credit reference agencies may keep records of the information we give them. They may also use and share it with other organisations for credit checking and fraud prevention purposes.
If you use 0900 services or have unpaid bills, we may use your supplied data to:
Refer your unpaid bills to a debt recovery agency for collection, including your name, contact details, address, account number and the amount owed. Sell overdue debts to other organisations. Enable 0900 providers to collect charges for calls you have made to them. If an 0900 call (where the party you’re calling charges you for the call) is charged to you or made from your phone using the Skinny network and you don’t pay for it by the payment due date, we may share your name, address and information about the call with the 0900 provider so they can collect the money you owe from you directly.
To build credit and fraud controls
We may use your supplied data and Skinny online experience data to:
Build credit and fraud controls and decision-making systems. Help us assess risk when potential or existing customers apply for services in future. Enhance our fraud prevention and detection controls.
We may also share supplied data and online experience data with credit reference agencies. This helps us and the agencies build relevant models, and can help the agencies build models to help Skinny and other organisations make credit and fraud protection and detection decisions.
To assist law enforcement, government and emergency response agencies
We may share your supplied data, Skinny online experience data, usage data and your content to enable law enforcement, government and emergency services agencies to do their work as follows:
If we’re required to by any applicable law, court or authority or by any applicable stock exchange listing rules. For example, the Police may require us to disclose personal information in response to a production order under the Search and Surveillance Act 2012, to help with the detection and prevention of crime and the prosecution of alleged offenders. We may voluntarily share your personal information in certain limited circumstances, including: In exceptional circumstances and where we have reasonable grounds to believe it’s necessary to prevent or lessen a serious threat to public health, public safety, or a person’s life or health (including your own). For example, to help the Police locate a missing person. Where you’ve consented to the disclosure. To the New Zealand Police or other relevant government agencies, if we believe you’ve committed fraud against Skinny (for example, setting up an account in someone else’s name), or attacked or attempted to destabilise our network. To confirm you’re a Skinny customer to the New Zealand Police or a government agency so they can determine whether to issue a warrant requiring additional information. Where emergency services advise that a 111 call was made from a number that appears to have been disconnected, we may confirm to them whether an attempted 111 call was made from your number and share your name, address and phone number so they can respond to the call. Where emergency services are seeking to locate you in an emergency, we may use our GPS or cell-site based location capability to notify emergency services of your mobile or cellular device location and help them respond.
To comply with other legal obligations
We may use and disclose your supplied data, usage data and your content to comply with our legal obligations, including:
Complying with any court order that requires us to share your personal information (including your content) with another person or an organisation. Meeting our contractual and legal obligations (for example, if you participate in a loyalty programme). Exercising our lawful rights or those of any of our related companies or parties. Where we need to disclose of that information as part of the sale of a Skinny business or asset.
To support Vulnerable End Users
We may use your supplied data to manage your status as a Vulnerable End User of Skinny services (if applicable) to ensure you’re not placed at undue risk when we connect, disconnect, maintain and repair any faults with your Skinny service. To do this, we may need to share your personal information with other service providers to identify your service connection. If necessary in your situation, we may also share any medical details relevant to your connection, such as the presence of a medical device.
Using and sharing anonymised, aggregated data
Anonymised, aggregated data is a set of data about many people. It excludes personal identifiers, such as name, address and phone number. This protects your privacy. We may use anonymised, aggregated data for purposes such as internal and external reporting, and to make decisions about how to manage Skinny and deliver product and services, for example:
Improving our products, services and customer experience. Building decision making systems that help us to assess future applications for service. Enhancing our fraud prevention and detection controls.
We may also use anonymised, aggregated data to provide insights to other organisations – such as our advertisers, customers and partners.
Example – mobile and wireless location data
As you use our mobile and wireless services, we collect information about how you’re using our networks. This includes your mobile and wireless location data generated from use of our mobile and wireless networks. In addition to the uses set out in this Policy, we may also use anonymised, aggregated mobile and wireless location data sets to improve our network (for example, to plan where to increase our mobile network capacity) and enhance our customer experiences. We may also share insights gained from analysis of this data to help other organisations better understand, plan for and meet the needs of their customers and the public.
We provide anonymised, aggregated mobile location data to Qrious, a Spark-owned data and analytics organisation. Qrious analyses this and other non-Skinny data (e.g. aggregated demographic data) for insights that can help organisations improve infrastructure and services. For example, making decisions about health, transport and infrastructure investment. You can opt-out from having your information included in the data set provided to Qrious.
Opt out of having your anonymised mobile location data provide to Qrious by emailing: firstname.lastname@example.org
Sharing with your consent or for a related purpose
In additions to the reasons set out above, we may share your personal information with third parties:
Where you have consented to the information being shared, subject to appropriate confidentiality obligations. Where the reason for sharing the information is related to the purpose for which we originally collected it.
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.
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:
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.
To request further investigation, you can contact the Privacy Commissioner at any point during or after having lodged a complaint with us.
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: email@example.com
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
Mobile advertising identifiers can also be managed on your 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.
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
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.
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.
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.
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.