This policy sets out how your personal information will be handled by Green Light Escrow Limited (or “GLE”, “we”, “us”, and “our”), with registered address Suite 4, 322 New North Road, Kingsland, Auckland, 1021, New Zealand.
Last updated: 4 April 2023
Your privacy rights
What personal information do we collect about you?
- In general, and depending upon the nature of your connection with GLE, the type of personal information we collect and hold includes (but is not limited to):
- name and contact details (including your email address, phone number and postal address);
- date of birth;
- profile photos;
- bank account information;
- income and expense information; and
- employment status and place of work.
- In some cases, if personal information we request is not provided, it might adversely impact our ability to supply the relevant products and/or or services to you.
- Except as otherwise permitted by law, we will collect personal information from you directly when you provide your details to us or register for an account on the Platform, or from you indirectly (for example, through our Website enquiry form.
How we use and disclose information that we collect about you
- to provide you with access to and use of the Platform and our Services;
- to communicate with you (for example to provide customer support or to ask you for feedback about our Platform and Services);
- to verify your identity and complete background checks (as may be required to comply with our legal obligations under the Anti-Money Laundering and Counter Financing of Terrorism Act 2017 and any similar or replacement regulations);
- to comply with our internal operational requirements and processes and undertake administrative functions associated with our business;
- to comply with any other legal or regulatory obligations we are subject to or for any purposes otherwise permitted by the Privacy Act 2020; and
- subject to you providing your consent (in accordance with the Unsolicited Electronic Messages Act 2007), sending you electronic messages to promote and market our Services and/or the services of our trusted business partners.
Who we may disclose your personal information to
- We may disclose your personal information to:
- our service providers that we have engaged to provide a service to us in relation to the Platform or any product or service that we have agreed to provide you;
- our professional advisors, including accountants, insurers and lawyers;
- courts, tribunals, and regulatory authorities; and/or
- any other person or organisation that you have authorised us to disclose your information to.
- We generally manage your information in New Zealand. To the extent we disclose personal information to third parties outside of New Zealand, we will take reasonable steps to ensure such third party is subject to comparable privacy laws as those in the Privacy Act or is otherwise required to protect the information in a way that, overall, provides comparable safeguards to those under the Privacy Act.
Access, correction and retention of your personal information
- You are responsible for ensuring that any information you give to us is accurate, correct and up to date. Please inform us as soon as possible if any of your personal information changes, to ensure that the details we hold about you are up to date and correct.
- You must inform us if any of your personal information changes, to ensure that the details we hold about you are up to date and correct.
- Subject to the exceptions set out in the Privacy Act, you are entitled to access the personal information we hold about you, and to request that we amend it if it is incorrect.
- Where we no longer required your personal information, we will comply with our legal obligations in respect of that information.
Security of information
- We take reasonable steps to protect the security of personal information. We do not make any warranties in relation to the security of any information you disclose or transmit to us and we are not responsible for the theft, destruction, or inadvertent disclosure of your personal information where our security measures have been breached.
- We will generally store your information in New Zealand and/or use secure third-party cloud providers to store information on our behalf.
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