Stravis Group Limited ("Stravis", "we", "us", or "our") is committed to protecting the privacy of personal information provided to us, or collected by us, when you interact with us. This Privacy Policy sets out how we collect, hold, use and disclose your personal information, and the choices and rights you have. This Privacy Policy forms part of, and is incorporated by reference into, our Master Services Agreement and Terms & Conditions, and takes into account the requirements of the New Zealand Privacy Act 2020 and the Information Privacy Principles.

Information We Collect

Personal information is information about an identified or reasonably identifiable individual. We only collect personal information that is reasonably necessary for our business functions and for lawful purposes. The types of personal information we may collect include: - Identity Data, such as your full name, job title or role, and the company you work for. - Contact Data, such as your phone number and email address. - Financial Data, such as bank account details and tax reference numbers, where relevant to the services we provide. - Transaction Data, including details of payments between you and us, and of products or services you have purchased from or supplied to us. - Marketing and Communications Data, such as your employer, business role, and your preferences for receiving communications from us. - Technical and Usage Data, such as your IP address, browser and device information, and how you interact with our website (including via cookies). - Profile Data, such as a username and password for any platform or portal we provide, and support requests you make. - Interaction Data, such as information you provide when participating in a survey or event. - Professional Data, such as your employment history and relevant experience, where you apply for a role with us. Sensitive information is a sub-set of personal information given a higher level of protection, such as health information, biometric information, or racial or ethnic origin. We generally do not seek to collect it, but may come across it in the course of working with you, such as when reviewing a CV or arranging dietary requirements for an event.

How We Collect Your Information

We collect personal information in a variety of ways, including when you provide it to us directly (in person, by phone, by email, or online), when you complete a form such as an event registration or survey, when you use a website we operate (including through cookies and analytics tools), from third parties such as LinkedIn, while providing our services, and from publicly available sources. Where we collect your personal information from a third party, we will take reasonable steps to notify you of that collection where required by law.

Information You Provide Through Our Services

In the course of providing our services, personal information may be entered into a platform or system we operate on behalf of a client, or our services may be made available to you through a business you deal with (for example, your employer). In these cases, that business collects the personal information, and we act as a processor handling it on their behalf and in accordance with their instructions, our contractual obligations, and applicable privacy law. The business collecting your personal information is responsible for any notice or consent required before providing it to us. You should refer to that business's own privacy policy to understand how they handle your information.

Where we collect personal information directly, such as through our own website, marketing, or general business dealings with you, we act as the party responsible for that information and this Privacy Policy applies in full.

Why We Collect, Hold, Use and Disclose Your Information

We collect, hold, use and disclose personal information for the following purposes: - To provide you with access to our software, platforms and services. - To work with you as a customer or supplier and deliver our services to you. - To respond to enquiries and support requests. - For internal record-keeping, administration, invoicing and billing. - For analytics, research and business improvement. - For advertising and marketing, including sending you information that may be of interest to you. - To consider your application, if you apply for a role with us. - To comply with our legal obligations or as otherwise required or authorised by law.

Where we collect sensitive information, we will only use or disclose it for the purpose for which it was collected, a directly related secondary purpose, a purpose you have consented to, to protect the life, health or safety of you or another person, or as otherwise required or authorised by law. We take extra care to limit access to sensitive information to those who genuinely need it.

Sharing Your Information

We will only disclose personal information to third parties where necessary as part of our business, where you have consented, or where permitted or required by law. This may include: - Our employees, contractors and related entities. - IT, hosting and data storage providers who support our systems. - Marketing and analytics providers who help us run our own marketing and communications, not for their own marketing purposes. - Professional advisors such as our accountants, bankers, insurers and auditors. - Our existing or potential business partners. - Courts, tribunals, regulators and law enforcement, where required by law or to establish, exercise or defend our legal rights. If we merge with, or are acquired by, another business, or sell all or part of our assets, your information may be disclosed to the relevant advisers and any prospective purchaser as part of that process. We do not sell your personal information to third parties.

Sensitive information will only be disclosed with your consent or as required or permitted by law, and only to the categories of recipient listed above that have a genuine need for it. We do not sell your personal information to third parties.

Overseas Disclosure

We use skills, technology and service providers from around the world to deliver our services, including cloud hosting, software and support providers based outside New Zealand. We also engage contractors based overseas as part of our team, and many of our customers and business contacts are themselves based outside New Zealand. As a result, your personal information may be disclosed to, or accessed by, people outside New Zealand.

By entering into our Master Services Agreement, Terms & Conditions, or otherwise engaging with us or using our services, you acknowledge and accept that your personal information may be disclosed to, or accessed by, people outside New Zealand in the circumstances described above. This Privacy Policy, as incorporated into those agreements, serves as our notice to you of this practice for the purposes of Information Privacy Principle 12 of the Privacy Act 2020, so that we do not need to seek a separate authorisation from you each time such a disclosure occurs. Where practicable, we also take reasonable steps to ensure any overseas recipient is required to protect your information to a standard comparable to the Privacy Act 2020, including through data protection agreements where appropriate.

Storage and Security

We are committed to keeping the personal information we hold secure. We have technical and operational controls in place to protect it from misuse, interference, loss, and unauthorised access, modification or disclosure. However, no method of transmission over the internet, or electronic storage, is completely secure, and we cannot guarantee absolute security. Any transmission of information to or by us over the internet is at your own risk.

Your Rights and Choices

You do not have to provide personal information to us, though this may affect our ability to work with you as a customer or supplier. If you provide us with personal information about someone else, you confirm that you have their consent to do so. Your rights include: - Unsubscribe: opt out of marketing communications at any time using the unsubscribe link in any email, or by contacting us below. - Access and correction: request access to, or correction of, the personal information we hold about you. We will respond within a reasonable timeframe in line with the Privacy Act 2020. - Complaints: contact us with full details if you're unhappy with how we've handled your information. If you remain unsatisfied, you may contact the Office of the New Zealand Privacy Commissioner.

User-Generated Content

Where we allow you to post reviews, comments or other content, anything you choose to submit publicly may be accessible by anyone, including third parties. We are not responsible for how others may use or misuse information you make publicly available.

Cookies and Analytics

Our website may use cookies, tracking pixels and similar technologies to store your preferences, recognise you when you return to our site, and support essential website functionality. On their own, cookies and tracking pixels do not identify you personally, but if you provide us with personal information, it may be linked to data stored by these technologies.

You can block or disable cookies through your browser settings, and block tracking pixels using browser extensions or your email provider's image-blocking settings, though parts of our website may not function as intended if you do so.

We may use Google Analytics to understand website usage, including Google Analytics advertising features. You can opt out of this using the Google Analytics Opt-out Browser Add-on below.

Google Analytics Opt-out Browser Add-on

We may also use tools provided by Meta, such as the Meta Pixel, to measure ad performance and deliver relevant ads on Meta platforms. You can manage this through your Meta account settings, or read Meta's Privacy Policy below.

Meta Privacy Policy

Links to Other Websites

Our website and platforms may link to, or integrate with, third-party websites. We have no control over those websites and are not responsible for their privacy or data practices. You should refer to their own privacy policies.

Single Sign-On Accounts

If you connect to any of our platforms using a single sign-on account (such as Microsoft or Google), we will collect personal information from that provider in accordance with the privacy settings you have chosen with them, such as your name, email address and profile picture, in order to set up your account with us. Authentication is managed by your identity provider, and we do not store your password.

Use of Artificial Intelligence

We may use artificial intelligence and machine learning tools, including tools provided by third parties, in our business operations, for example to support analysis, improve our services, automate routine tasks, assist with quality assurance, and support customer queries. We assess AI tools before deployment, select reputable providers, and take reasonable steps to ensure personal information processed by these tools is protected in line with this Privacy Policy and applicable privacy law. We do not input your personal information into any third-party AI tool that uses that information to train its models. You retain all the same rights over information generated about you by an AI tool as you do over any other personal information we hold.

Amendments

We may update this Privacy Policy from time to time by publishing an amended version on our website. We recommend checking this page periodically to stay informed of how we protect your information.

Contact Us

If you have any questions about this Privacy Policy, wish to access or correct your information, or want to make a complaint, please contact our Privacy Officer at info@stravis.co.