Gift Ledger

Privacy Policy

Last Updated: 7/04/2023

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1. Introduction

1.1

This Privacy Policy explains how Gift Ledger, a service provided by Analytics Limited of Taiki e! Impact House, 7 Peel Street, Gisborne 4010, New Zealand ("Gift Ledger", "we", "our", or "us"), collects, uses, and discloses information about you when you access or use our website, platform, mobile application, and other online products and services (collectively, the "Services") or when you otherwise interact with us. By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms and Conditions.

1.2

We take your privacy seriously and are committed to safeguarding the privacy of our website visitors and Service users by adhering with applicable law, including the Privacy Act 2020. We also follow the Guidelines for Trusted Data Use established by the Data Futures Partnership.

1.3

This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and platform users; in other words, where we determine the purposes and means of the processing of that personal data. This policy does not apply to:

(a) unsolicited information that you provide to us;

(b) other websites that are not operated by us, but that may be accessed via links within our website or platform.

1.4

Our platform incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via platform.giftledger.io.

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2. How We Use Your Personal Data

2.1

In this Section 2 we have set out:

(a) the general categories of personal data that we may process;

(b) the purposes for which we may process personal data; and

2.2

We may process data about your use of our website, the platform and the Services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website, the Application and the Services. The legal basis for this processing is your consent and includes our legitimate interests, namely monitoring and improving our website, the platform and the Services.

2.3

We may process your account data ("account data"). The account data may include your display name, your username and email address and any other contact information, any linked accounts that you set up and any information that you add in your profile. The source of the account data is you. The account data may be processed for the purposes of operating our website, the platform and providing our Services, ensuring the security of our website, the platform and the Services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is your consent and our legitimate interests, namely the proper administration of our website, the platform and the Services.

2.4

We may process your information included in your personal profile on our website or the platform ("profile data"). The profile data may include your name, telephone number, email address, profile pictures and other information you wish to add to your account profile. The profile data may be processed for the purposes of enabling and monitoring your use of our website, the platform and the Services. The legal basis for this processing is your consent.

2.5

We may process information that you add or upload for publication on our platform, our website or through our Services ("publication data"). The publication data may include comments, notes, stories, memories, photos, documents, website links, video links and any other information you add to your gift profiles. The publication data may be processed for the purposes of enabling such publication, sharing and administering our platform, the website and the Services. The legal basis for this processing is consent and our legitimate interests, namely the proper administration of our website, the platform and our Services.

2.6

We may process information contained in any enquiry you submit to us ("enquiry data"). The enquiry data may be processed for the purposes of improving our Services to you, or to detect security breaches or breaches of our Terms and Conditions or our policies. The legal basis for this processing is your consent and our legitimate interests, namely the proper administration of our website, the platform and our Services.

2.7

We may process information that you provide to us for subscribing to our email and phone notifications and/or newsletters or updates ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications, newsletters and/or updates. The legal basis for this processing is your consent.

2.8

We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, our platform and business and communications with users.

2.9

We may process analytical information which is the interpretation of factual information (“analytical information”). This data may include your email address, what you view, what information you share across platforms, your device information and information about how you use our platform, our website and Gift Ledger generally. The source of this data is Google Analytics. This data may be processed to help us understand how you use the Gift Ledger website and platform and how we can improve our Services. The legal basis for this processing is your consent and our legitimate interests, namely the proper administration of our website, our platform and business.

2.10

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.11

In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for:

(a) the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks; and

(b) compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.12

If you are under the age of 18, please do not supply or submit any personal information through the Gift Ledger platform. We encourage parents and legal guardians to monitor their children’s internet usage and to report any cases to us if you have reason to believe that a child under the age of 18 has provided personal information to the Gift Ledger platform.

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3. Providing Your Personal Data to Others

3.1

We share your gift profiles and other interactions on the Gift Ledger platform with other Gift Ledger users, in accordance with the privacy and circle (group) settings you have created. Depending on your profile settings, we may disclose your personal data relating to your profile information with other users.

3.2

We share our data reports, analysis and trending information with third parties, including social media, but they do not personally identify you.

3.3

We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.4

We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.5

We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.6

We generate a lot of anonymous data analysis and reports about how people use and interact with the Gift Ledger platform, such as what types of gifts are being registered and how often gifts are passed on to other. These reports may be shared with many different organisations. Any analysis and reports are anonymised and do not personally identify you.

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4. International Transfers of Your Personal Data

4.1

We store all our data on cloud-based servers using SuiteDash, which is powered by Amazon's AWS technology services. This means your data is safely stored in 'best in class' data centers around the globe every day. We take steps to ensure that transfers to and storage of your information in each of these countries is done in accordance with New Zealand privacy laws, including (where required) by ensuring that your information is subject to safeguards comparable to those provided under New Zealand's privacy laws.

4.2

SuiteDash secures your data by encrypting it during transit between you and the platform using HTTPS and Transport Layer Security (TLS) 1.2 with a 2048-bit server key length. Their state-of-the-art servers are protected by biometric locks, round-the-clock interior and exterior surveillance monitoring, and full redundancy for all major systems. SuiteDash's software infrastructure is regularly updated with the latest security patches, and their dedicated network is locked down with firewalls and carefully monitored using intrusion detection technology.

4.3

When it comes to your billing information, SuiteDash ensures that all credit card transactions are processed using secure encryption, which is the same level of encryption used by leading banks. Card information is securely transmitted one time to a 3rd party payment gateway, which then stores the card information and returns only an identifying hash (ID number) to SuiteDash. No payment information or credit card numbers are ever stored on SuiteDash's servers.

4.4

You acknowledge that personal data that you submit for publication through our website or platform may be available, via the internet, around the world. While we use various technological and organisational security measures to ensure your personal information is protected against unauthorised access, use, modification, disclosure or other misuse, we cannot prevent the use (or misuse) of such personal data by others. We have procedures to deal with any suspected privacy breaches and will notify you and any applicable regulator of a breach where required by law.

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5. Retaining and Deleting Personal Data

5.1

This Section 5 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will regularly review our information and erase or anonymise personal data when it is no longer needed.

5.3

We will retain personal data processed by us for as long as is considered necessary for the purpose(s) for which it was collected; there may also be occasions which will require data to be kept for longer, however this will typically be for legal purposes or research purposes. In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it. We will periodically review this data, to ensure that it is still relevant and necessary.

5.4

Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

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6. Amendments

6.1

We may update this policy from time to time by publishing a new version on our website.

6.2

You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3

We will notify you of significant changes to this policy by email.

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7. Your Rights

7.1

In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. You should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2

Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

7.3

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. We will supply to you a copy of your personal data, free of charge, but additional copies may be subject to a reasonable fee.

7.4

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.5

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include where the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed, you withdraw consent to consent-based processing, you object to the processing under certain rules of applicable data protection law, the processing is for direct marketing purposes, and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, or for the establishment, exercise or defence of legal claims.

7.6

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are when you contest the accuracy of the personal data, the processing is unlawful, but you oppose erasure, we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims, and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest.

7.7

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for the performance of a task carried out in the public interest or in the exercise of any official authority vested in us, or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7.8

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

7.9

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

7.10

To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.11

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.

7.12

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.13

You may exercise any of your rights in relation to your personal data by written notice to us at giftledger@awhi.app.

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8. About Cookies

8.1

Cookies are small pieces of information that are stored in a browser-related file on your device when you use the Gift Ledger platform or website. Cookies are widely used on most major websites and help us to understand how many people are using the Services and what their usage patterns are. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. You can disable cookies in your browser settings if you want to, but this may sometimes affect the functionality of the Services. Please refer to section 11 for guidance on how you can manage cookies.

8.2

Cookies do not typically contain any information that personally identifies a user (i.e. cookies do not collect personally identifiable information), but personal information that we store about you may be linked to the information stored in and obtained from cookies.

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9. Cookies That We Use

9.1

We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

9.2

We use cookies for the following purposes:

(a) authentication - we use cookies to identify you when you visit our website and as you navigate our website

(b) status - we use cookies to help us to determine if you are logged into our website

(d) security – we use cookies to help us protect user accounts, including preventing fraudulent use of login credentials and to protect our website and services generally

(e) advertising – we use cookies to help us to display advertisements that will be relevant to you

(f) analysis – we use cookies to help us to analyse the use and performance of our website and services

(g) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

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10. Cookies Used by Our Service Providers

10.1

Our service providers may use cookies and those cookies may be stored on your computer when you visit our website.

10.2

We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.

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11. Managing Cookies

11.1

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

11.2

Blocking all cookies will have a negative impact upon the usability of many websites.

11.3

If you block cookies, you will not be able to use all the features on our website.

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12. Our Details

12.1

This website is owned and operated by Awhi Analytics Limited.

12.2

We are registered in New Zealand under registration number 9429042470939, and our registered office is at Taiki e! Impact House, 7 Peel Street, Gisborne 4010, New Zealand.

12.3

You can contact us:

(a) by post, to the postal address given above;

(b) using our website contact form;

(d) by email at giftledger@awhi.app or by using the email address published on our website from time to time.

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13. Data Protection Officer

13.1

Our data protection officer's contact details are:

Contact Name: Deborah Hancock

Registered Office: Taiki e! Impact House, 7 Peel Street, Gisborne 4010, New Zealand

Email: giftledger@awhi.app

Mobile: 0273048723

Gift Ledger

Tāiki e! Impact House, 7 Peel Street, Gisborne 4010, Aotearoa New Zealand.

Documentation

Contact Us

giftledger@awhi.app