Privacy Policy

The information we collect

Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

The types of personal information we may collect about you include:

• Identity Data including your name, age and gender.
• Contact Data including your telephone number, address and email.
• Financial Data including bank account.
• Background Verification Data including your government-issued identification details if requested as part of our onboarding process to comply with our due diligence obligations, anti-money laundering laws and related ongoing monitoring commitments.
• Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.
• Technical and Usage Data when you access any of our websites or platforms, details about your internet protocol (IP) address, login data, browser session and geo-location data, statistics on page views and sessions, device and network information, acquisition sources, search queries and/or browsing behaviour, access and use of our website (including through the use of Internet cookies or analytics), and communications with our website.
• Profile Data including your username and password for any of our platforms, purchases or orders you have made with us, content you post, send receive and share through our platform, information you have shared with our social media platforms, and support requests you have made.
• Interaction Data including information you provide to us when you participate in any interactive features, including surveys, contests, promotions, activities or events. As part of Interaction Data we may record conversations for the use of being transcribed into written messages, for our own internal use.
• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
• Professional data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience.

How we collect personal information

We collect personal information in a variety of ways, including:

• when you interact directly with us, including face-to-face, over the phone, over email, or online;
• when you complete a form, such as registering for any events or newsletters, or responding to surveys;
• when you apply for a job with us;
• from third parties, such as details of your use of any website we operate (from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies); or
• from publicly available sources, such as social media or the New Zealand Companies Office.

Our website contact form

If you send us a message through the contact form on our website, we collect the details you enter: your name, email address, organisation, the topic you select, your message and, if you choose to give it, your phone number.

• We use these details only to read and respond to your enquiry, except for the topic, which is also used as described below.
• Your message is sent by email to our team through a third-party email delivery provider. We do not store form submissions on our website servers; they are kept as part of our normal business email records.
• To limit spam and repeated submissions, our website temporarily uses your internet protocol (IP) address while processing a submission. We do not keep it as part of your enquiry.
• The form includes a hidden field that is only filled in by automated software. A submission with that field filled in is discarded.
• When a message is sent successfully, or when you click a link to book a meeting with us, we record that this happened, and for the contact form the topic you selected, in Google Analytics and Google Ads to measure how well our website and advertising work. We do not send your name, email address, phone number or message to Google.

You can also contact us by email or phone using the details on our Contact page. Please do not include sensitive information, such as passwords or confidential client data, in a contact form message.

Why we collect, hold, use and disclose personal information

Personal information: We collect, hold, use and disclose your personal information for the following purposes:

• to assess whether to take you on as a new client, including to perform anti-money laundering, anti-terrorism, sanction screening, fraud and other background checks on you;
• to do business with you, including to dispatch and deliver our products or services to you;
• to contact and communicate with you about our business, including in response to any support requests you lodge with us or other enquiries you make with us;
• to contact and communicate with you about any enquiries you make with us via any website or platform we operate;
• for internal record keeping, administrative, invoicing and billing purposes;
• for analytics (including profiling on our website), market research and business development, including to operate and improve our business, associated applications and associated social media platforms;
• for advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you;
• to run promotions, competitions and/or offer additional benefits to you;
• if you have applied for employment with us, to consider your employment application; and
• to comply with our legal obligations or if otherwise required or authorised by law.

Our disclosures of personal information to third parties

Google Analytics

We have enabled Google Analytics Advertising Features. We and third-party vendors may use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together. These cookies and identifiers may collect Technical and Usage Data about you.

You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.

Google Maps

Our Contact page includes an embedded Google Map showing our office location. When the map loads, Google may receive technical information from your browser, such as your IP address and device details, and may set or read cookies, in accordance with Google’s own privacy policy. We do not control this. You can avoid it by not scrolling to the map, or by using the “Open in maps” link only when you choose to.

Email delivery provider

Messages sent through our contact form are passed to a third-party email delivery provider so that we can receive them. The provider processes your message only to deliver it to us.

Overseas disclosure

Personal Information

We may store personal information overseas, including in, Australia. Where we disclose your personal information to the third parties listed above, such as Google and our email delivery provider, these third parties may also store, transfer or access personal information outside of New Zealand, including but not limited to, Australia and the United States. We will only disclose your personal information overseas in accordance with the New Zealand Privacy Principles.

Your rights and controlling your personal information

Your choice

Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to do business with you.

Information from third parties

If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict and unsubscribe

To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the optout facilities provided in the communication.

Access

You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

Correction

If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

Complaints

If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you may contact the Office of the New Zealand Privacy Commissioner.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

Cookies

We may use cookies on our website from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Links to other websites

Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Use of location services data

We may collect your precise or approximate location via our platform or website for the following purposes:

• for security and safety;
• to prevent and detect fraud; and
• as permitted by law.

We collect this information when you do business with us. If you do not want us to use your location for the purposes above, you should turn off the location services.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.