Introduction

This Privacy Policy governs the manner in which your personal information and non-personal information will be dealt with and explains how we collect, share, use and protect the information we collect from you.

Please ensure that you read our Privacy Policy carefully as this forms part of our Terms and Conditions as set out on our website (“site”). Should you have any queries regarding this Privacy Policy, please contact us and we will answer and queries you may have.

This Privacy Policy is effective from 12 June 2018.

Definitions

In this Privacy Policy, “we”, “our” or “us” and “Coingrid” means Coingrid Limited and includes its directors, employees, agents and assigns.

“You” or “your” means the person, entity, organisation or any party whatsoever who, by using or visiting this website, accepts and acknowledges this Privacy Policy.

“Personal information” has the same meaning as set out in section 2 of the Privacy Act 1993.

“Non-personal information” means non-personal information that does not identify you personally.

Personal Information

By accessing this site, you agree and acknowledge that certain information will be collected by us. It is necessary for us to collect information as it helps us improve services provided to you and ensures that we comply with our legal obligations, including but not limited to, New Zealand’s AML and CFT Regulations.

Personal information will not be collected and stored by us unless you provide this personal information voluntarily. Generally speaking, if the information we collect allows us to personally identify you, then it will be construed as meaning personal information.

Personal information that may be collected by us includes, but is not limited to, your name, contact details, email address, proof of identification, proof of address, payment information, profession or occupation, all correspondence with us, and any personal information provided to us from time to time. We will only collect and use this information from you accordance with the provision of the Privacy Act 1993. In certain circumstances, the personal information you provide us may be shared with a third-party contract to the extent that it is necessary for administrative and improvements to this site.

You agree and acknowledge that in certain circumstances we may be required to disclose your personal information to our employees, contractors or external service providers to ensure the efficient operation of our site and our business. You agree that we may be required to disclose personal information to the police or relevant regulatory authorities or network administrators if we have reason to believe that you have committed a breach of our Terms and Conditions, or otherwise been engaged in any unlawful activity and we are of the view that disclosure in such circumstances is necessary in accordance with regulations and/or legal requirements.

Cookies

We may collect information through the use of cookies. We use cookies on our site where they are required for particular features to work and to help us improve functionality, structure and performance of this site and our services which we provide. You may disable cookies on your computer if you do not want your computer to accept them.

When you access this site, through the use of cookies our server also logs information which includes, but not limited to, your IP address, the time and date of your visit to this site, the domain name you use to access the internet, your operating system, information collected from you from any surveys provided, the type of web browser you use, the pages you accessed on our site, the links you clicked on, the search terms you used and the domain of website you visit when you leave our site. This information collected from you is aggregated and does not enable us to personally identify you.

Any information collected that does not enable us to personally identify you or anyone else may be used for such purposes in our sole discretion, as permitted by law.

How we use your information

We may use and disclose your personal information for the primary purpose for which it has been collected and for reasonably secondary purposes which are associated to the primary purpose and all other circumstances as permitted by the Privacy Act 1993.

Generally speaking, we use, hold, collect and disclose your personal information for purposes including, but not limited to, assist us in conducting our business, to enable you to have access to our services, to communicate with you, to market our services to you from time to time, to help us manage and enhance our services, and to ensure that we comply with our legal obligations, including those obligations under the Anti-Money Laundering and Countering Financing Terrorism Act 2009. In all circumstance, we do not permit your information to be sold.

How we protect your information

We endeavour to take all reasonable steps to ensure that your personal information is protected from any unauthorised access, misuse or loss as required by the Privacy Act 1993. Our employees, agents, assigns and any third parties who provide services relating to us are also bound by confidentiality for any personal information held by us.

Please ensure when you provide us with any personal information, or complete any transactions via our site, that the ‘padlock’ symbol is present on your web browser. If the padlock is visible, this means there is a certificate of authenticity and indicates the site is secure.

We also use Secure Socket Layer (SSL) which provides an encrypted link between our server and your web browser; this link ensures that data passed between web server and browser remains private and integral and is designed to protect all online transactions with you. Notwithstanding our use of a certificate of authenticity and SSL.

Notwithstanding our effort to ensure your personal information is protected and secure as explained above, no data transmission over the internet (or other forms of communication) can be guaranteed as completely secure and consequently any information provided to us, whether via internet, post, or any mode of communication whatsoever is provided at your own risk and under no circumstances will we be liable for any loss or breach of privacy of your personal information. You also acknowledge that any information published publically, including comments on our social media platforms is to be construed as public information.

Your rights and obligations

Any personal information we collect is stored by us in a manner which makes it accessible to you. Subject to any exceptions set out in the Privacy Act 1993, you may contact us to request any personal information we hold about you and upon receiving your request, we will endeavour to provide you with this information in a timeframe that is convenient to us in our sole discretion.
In some limited circumstances, we may not be able to provide you with personal information requested if the provision of such information, for example, would amount to a breach of privacy of others or would amount to a breach of confidentiality. In all circumstances, we will only withhold the provision of personal information being requested if we have lawful grounds for doing so.

If you have provided any incorrect personal information to us, please ask us to correct it. Upon receipt of your request, we will make any corrections required as soon as we practically can. If a request is made for us to correct your personal information, we will require you to verify your identity.

We have an obligation under section 50 of the Anti-Money Laundering and Countering Financing Terrorism Act 2009 to keep identity and verification records for a period of at least 5 years. This 5 year period runs from the date that you close your user account with us.

If you have subscribed to our mailing list and no longer wish to receive email marketing or promotional material, you can unsubscribe at any time.

Amendments

We reserve the right to amend and update this Privacy Policy from time to time. Any changes made will result in an updated Privacy Policy and will take effect from the date published. For this reason, you agree that you will review this Privacy Policy on a regular basis.

Other important information

If you have any questions regarding our collection and use of personal information and non-personal information, you may contact us directly via the contact details provided on our site and we will endeavour to respond to you as soon as we practically can.

Further information may be obtained from the website of the Privacy Commissioner (www.privacy.org.nz) if you wish to seek further information about your rights under the Privacy Act 1993.