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VXT Limited’s Privacy Policy

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Privacy is given serious importance at VXT Limited (“VXT”). We take steps to ensure that all relevant privacy and data protection laws are complied with when dealing with personal client information.

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We strongly encourage you to go through this Privacy Policy carefully. A thorough understanding will help you make an informed decision when giving personal information to us. Our Terms of Service should be read together with this Privacy Policy as the defined terms all share the same meaning. When you access our website   and/or engage us to provide any service,   including web services, under the Terms of Service (the “Services”), you automatically consent to the terms of this Privacy Policy and agree to be bound by it and our Terms of Service. If there is any conflict between this Privacy Policy and the Terms of Service, then the Terms of Service prevail.

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If you are primarily based in the United Kingdom or European Union and use our website and/or  Services, we have some additional terms laid out in the addendum (“GDPR Addendum”) which apply to you.

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This   Privacy   Policy   does   not   limit   your   existing   rights   under   relevant   privacy   and   data   protection laws.

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1.0 Collection of Personal Information

VXT is a provider of Services to its clients who have agreed to the Terms of Service. The Services include the collection and storage of personal information of our clients, users and other visitors to our website and/or office/s. The information collected from an identifiable individual may include that individual’s name, date of birth, country of residence, occupation, IRD (or equivalent tax) number, bank account information and contact details (physical address, email address and landline and/or mobile number or other contact details you provide us), non-voicemail audio recordings, passwords, third-party account credentials, such as Office365 or Google, place of employment, timezone, third party   phone   call   recordings,   transcripts,   call   history,   contacts   and   voicemail   data   as   well   as information   on   companies,   trusts   or   other   entities   associated   with   the   individual.   We   also   collect information about how you use our website and software application (for example, traffic volumes, time spent on pages), your IP address and/or other device identifying data, information contained in your   correspondence   with   us   or   survey   responses   and   other   information   required   to   provide   a service or information you have requested from us.

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VXT collects and holds such personal information that we may collect directly from you when you:

  • make a request for provision of our Services,
  • become a client and we provide you with the Services,
  • use our website and/or software applications as a client,
  • contact the VXT support team, or
  • visit our website and/or download our software applications.

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You may choose not to disclose this information to us. You should be aware however that it may mean we are restricted or prevented from providing our services to you.

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2.0 VXT may receive personal information from you about others

Through your use of the Services, VXT may also collect information from you about someone else where you have authorised us to do so (for example, by using our Services to record a phone call with   a   third   party)   or   where   the   information  is   publicly   available.   This   could   include   personal information collected from you as set out above or when users you have invited use our Services, website or software applications (“User Data”). If you provide VXT with personal information about someone else, you must ensure that you are authorised to disclose that information to VXT and that,vwithout VXT taking any further steps required by applicable data protection or privacy laws, VXT may collect, use and disclose such information for the purposes described in this Privacy Policy.

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This   means  that   you  must   take  reasonable  steps   to ensure   the  individual   concerned   is   aware  of and/or  consents to the various matters detailed in this Privacy Policy, including the fact that their personal information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual's right to obtain access to that information, VXT's identity, and how to contact VXT.

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3.0 VXT collects, holds, and uses your personal information for limited purposes

VXT collects the personal information to assist us in providing you with the Services that you have requested. This information may be used for purposes including to:

  • verify your identity and undertake credit checks (if necessary),
  • provide the requested Services to you,
  • market   our   Services   and   products   relating   to   these   Services.   We   may   also   send   you
    newsletters and up to date information on changes via text, email or other electronic means (you can opt out of this by contacting us at any time),
  • analyse effectiveness of marketing strategies;
  • to   assess   the   effectiveness   and   use   of   Services   and   our   products   and   other   similar purposes;
  • carry out training of our personnel in relation to the Services,
  • ensure we comply with laws and regulations in applicable jurisdictions,
  • keep open lines of communication with you, including in response to a complaint,
  • send   you  our   bills   and   to  collect   any   money   owing   to  us.   This   includes   authorising  us  to process credit card transactions,
  • train   and   improve   the   artificial   intelligence   features   such   as   speech   recognition   and understanding;
  • ensure that you are adhering to our Terms of Service, and  any other use that is authorised by you or relevant privacy laws.

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In   the   event   of   a   sale,   merger,   consolidation,   liquidation,   reorganisation   or   acquisition,   your information may be transferred.

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When we collect and process User Data we act as an agent of you for the purposes of the New Zealand Privacy Act 2020 and any other relevant privacy laws. If applicable, we also act as the controller of the data for the purposes of the General Data Protection Regulation of the European Union and the UK Data Protection Act 2018 (“GDPR”). Such User Data will only be processed in accordance with this Privacy Policy and in compliance with all applicable privacy laws.

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By   using   our   website/software   applications   or   asking   us   to   provide   you   with   the   Services,   you consent to your personal information being collected, held and used in this way and for any other use you authorise VXT will only use your personal information in the ways outlined in this Privacy Policy or if we have your express permission. If you have any personal information related to your engagement with our Services such as a password, it is your responsibility to keep that safe. If you become aware of any breach of your security, you should contact us immediately and change your password.

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4.0 VXT can collect your non-personally identifiable data

When   you   use   our   Services,   you   are   agreeing   to   VXT   accessing,   aggregating   and   using   non-personally   identifiable   data   collected   from   you.   This   data   does   not   identify   you   nor   any   other
individual.

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This data may be used to:

  • help us understand how our clients and users are engaging with our Services, website and software   application,   for   example,   the   busiest   days   of   the   month,   quantity   and   timing   of payments and most popular web pages;
  • train   and   improve   the   artificial   intelligence   features   such   as   speech   recognition   and understanding;
  • provide   clients   and   users   with   further   information   regarding   the   uses   and   benefits   of   our Services;
  • increase   business   productivity   as   the   aggregated   data   can   provide   relevant   business insights; and
  • otherwise improve our website, software application and Services.

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5.0 Transfer and storage of personal information

All information that you provide to us or is entered into our website, software applications, phone system or collected from your visiting our website or downloading/using our software applications or our phone system is automatically transferred to the VXT system. When you use our Services, you consent to your personal information being held by our system as outlined in this Privacy Policy.

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The website, software application and Services may be supported by businesses that are outside of your   country.   If   you   are   situated   within   the   European   Economic   Area   (EEA) or the United Kingdom,   please   refer   to   the GDPR Addendum. This will outline how personal data is transferred from the EEA or the United Kingdom.

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We will not sell or rent your personal information to others. As at the date of this Privacy Policy, our system is hosted by the Google Cloud Platform, Amazon Web Services, and Microsoft Azure so we cannot   guarantee   the   location   where   the   personal   information   is   stored.   Please   see  here  for   a current list of sub processors.

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Your personal information will be transmitted through and stored on, those systems as part of the Services.   If   the   systems   change   in   the   future,   we   will   update   this   Privacy   Policy.   We   would encourage   you   to   frequently   review   our   Privacy   Policy   so   you   are   aware   of   any   changes.   Your personal information may be stored in locations outside the direct control of VXT.

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VXT is based in New Zealand and may access your personal information from New Zealand.   New Zealand is recognised by the European Commission as a country that ensures an adequate level of data   protection.   This   decision   provides   our   basis   for   transferring   personal   information   to   New Zealand.

By providing your personal information to VXT, you consent to us storing your personal information on systems   hosted   by   Google   Cloud   Platform,   Amazon Web Services,  and  Microsoft Azure and accessing your personal information from New Zealand. If your personal information is to be stored on systems located in other countries, it will remain within VXT's effective control at all times. The system host’s role is limited to providing a hosting and storage service to VXT, and we’ve taken steps to ensure that our system hosts do not have access to, and use the necessary level of protection for, your personal information.

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If you are not comfortable with your personal information being transferred to a system in another jurisdiction, you should not provide VXT with your personal information or use our website or software applications.

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5.1 Transfer and storage of personal information from mobile devices

Contacts from mobile devices are used locally on that mobile device for the purpose of showing contact names instead of phone numbers. These contacts are not uploaded to our servers, unless you have explicitly opted-in to uploading your contacts (called “contact syncing”). Uploaded contacts are not shared with any third parties. If you have opted-in to uploading your contacts then we take measures to help protect this information, for example, we use HTTPS while your contacts are being transmitted and your uploaded contacts are encrypted at-rest.

When you download an audio file from the VXT mobile app to your mobile device, we request permission to access your device’s files. We use this permission solely for downloading the audio file to your device, we do not access any of your other files or upload any of your files.

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6.0 VXT is committed to protecting your personal information

VXT   will   at   all   times   work   to   ensure   that   we   are   taking   all   the   steps   to   protect   your   personal information. Despite our best efforts, the internet itself cannot be trusted as a secure environment.

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Consequently, we are unable to give an absolute promise that your information will always be safe. Sharing of personal information over the internet is to be done at your own risk. You should only give out your personal information to the website/software applications within a secure environment.

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If we become aware of any security breach relating to your personal information, we will advise you as soon as we can.

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7.0 VXT will only release your Personal Information in limited circumstances

The Personal information which you provide to us will only be disclosed if it is necessary, appropriate and   achieves  the   outcome   for  which  you engaged   our   Services  and   as  outlined   in  our   Terms   of Service.   We   may   share   information   collected   from   you   with   third   parties   in   order   to   provide   the
Services to you and to improve, evaluate and optimise the Services we provide to you.  

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Unless there is a sale, merger, consolidation, liquidation, reorganisation or acquisition, Vxt will not disclose   your   personal   information   to   a   third   party   unless   we   have   your   express   consent.   It   is important to note however, that we may have to do so without your consent to comply with any court orders, subpoenas, or other legal process or investigation including by tax authorities, required by law.   If   it   is   possible   and   appropriate,   we   will   endeavour   to   notify   you   to   let   you   know   this   has occurred.

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Your   personal   information   is   not   controlled,   accessed   or   used   by   the   third   parties   who   host   our systems, except for the intended use of storing that information.

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Our   advertising   and   analytics   partners   may   receive   information   about   your   use   of   our website/software application through cookies, web beacons and similar storage technologies. More information on this can be found in the Cookies section of this Privacy Policy.

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8.0 VXT does not store your credit card details

If you need to use your credit card for any of our Services, your credit card details will not be stored online and cannot be accessed by our staff. However your credit card details may be encrypted and securely stored by our chosen payment provider. This will enable VXT to automatically bill your credit card on a recurring basis.

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9.0 Requesting access to your personal information

It is up to you to ensure that the personal information you provide is accurate, complete and up-to-date.   Unless   there   are   certain   legal   grounds   for   refusing,   you   may   ask   to   access   the   personal information   we   have   that   is   readily   available.   You   may   also   ask   us   to   update   or   correct   any information we have about you. This may be done by requesting in writing and sending it to us at 71 Durham Street South, Sydenham, Christchurch, 8023 or by email to info@vxt.co.nz. You will need to prove that you are the individual to whom the personal information relates.

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We  will   process  your   request   as   soon  as   reasonably   practicable,   unless   there   are  legal   grounds preventing us from doing so. We will explain why if we are unable to do so. One example for refusal would be if access would unreasonably impact  the privacy of  another  individual.  If you request  a correction and we have to refuse, reasonable steps will be taken to note down that you requested that correction.

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If   appropriate   and   reasonable,  we   may   charge   you   the   cost   of   providing and/or correcting your personal information.

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Your personal information will only be kept for as long as it is needed. There may be circumstances however where we have to keep the information for a specified amount of time to meet various legal and reporting requirements.

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10.0 VXT uses cookies

A cookie is a small text file that is stored on your computer for record-keeping purposes. It does not identify you personally or contain any other information about you but it does identify your computer. VXT''s website/software application uses these cookies.

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Along  with  some of  our affiliates  and third-party  service providers,  VXT may use a combination of “persistent   cookies”  (cookies  that   remain   on  your  hard   drive  for  an  extended   period   of   time)   and “session   ID   cookies”  (cookies   that   expire   when  you  close  your   browser)   on  our   website/software application.   Amongst   other   purposes,   these   can   be   used   to   track   how   the   website/software application is being used and the level of engagement with ads.  

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You have the ability to get your browser to send you an alert when you receive a cookie. This then gives you the chance to accept or reject it. If you refuse a cookie, this can have a negative impact on how the website/software application is used or functions. Note, VXT does not respond to or honour “Do Not Track” requests at this time.

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Performance and targeting cookies may be used when you visit our website/software application. Performance cookies serve to collect information on how you use the website/software application. This can tell us about our most popular pages, and if you have received any error messages while on   the   pages. No identifying personal information is gathered via these cookies. Instead, these cookies only work to improve the usage of the website/software application. As a   result of the cookies, VXT may be sent reports showing aggregate numbers and trends from third party analytics partners.

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Alternatively, targeting cookies provide you with personalised advertisements that are related to you and   your   interests.   They   can   determine   how   often   you   see   a   particular   advertisement   and   can measure whether the advertising campaign has been effective. They will remember that you have visited the website/software application and may share this information with other parties such as advertisers.   As   a   result,   you   may   see   advertisements   about   our   Services   in   other   areas   of   the internet.   When   you   use   our website/software application, third party providers may display advertisements   relevant to your interests. This information will have been generated by your previous use of the website/software application and other browsing history. Your browser collects information about your internet use. Third party providers then use this information to place ads on websites throughout the internet that may relate to you and your interests.

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It is possible to opt-out of targeted advertising at http://www.youronlinechoices.eu/.   You can learn more  about  interest-based  advertising  and opt  out  of  interest-based advertising  from participating online advertising companies at the following links:

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Digital Advertising Alliance EU (EDAA) – http://www.youronlinechoices.com/
DAA AppChoices page – http://www.aboutads.info/appchoices
Network Advertising Initiative (NAI) – http://optout.networkadvertising.org/
Digital Advertising Alliance (DAA) – http://optout.aboutads.info/

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You should be aware that opting out will not stop the advertising all together. You will instead be served with generic ads.

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11.0 You may opt out of any email communications

VXT uses email to send out various information relating to billing, marketing our services and general communication. There are clear instructions on the emails explaining how to remove yourself from our   mailing   list.   If   you   choose   to   opt   out,   this   will   not   remove   you   from   receiving   emails   about breaches (if relevant) or any changes to the Privacy or Terms of Service policies.

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12.0 Your responsibility in transferring your data to third-party applications

Our website/software application may have links or ads that get you to follow a link to a third-party application or website.  It is your responsibility to be vigilant when giving out personal information on these links as VXT has no control, and takes no responsibility for these websites and applications.

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13.0 Privacy complaints process & Privacy Officer

If you are unhappy with how we have handled your personal information, you may send a complaint.
Please provide us with the full details of your complaint along with any supporting documentation to our Privacy Officer:

- Name: Luke Campbell
- Email: info@vxt.co.nz
- Post: 71 Durham Street South, Sydenham, Christchurch, 8023

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We will:

- Send you an initial response to your query or complaint within ten (10) business days; and
- Look into and seek to resolve the issue within twenty (20) business days. If necessary, we
may need a longer period to do this but will notify you of this delay.  

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14.0 This Privacy Policy may be updated

VXT reserves the right to change this Privacy Policy at any time. The amended Privacy Policy will be considered effective as soon as it is posted to this website.   If you continue to access and use our website and/or receive our Services, you will be considered to have accepted the amended Privacy Policy.

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This Privacy Policy was last updated on 14 August 2023.

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GDPR Addendum

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If you are located in the United Kingdom (“UK”) or the European Union (“EU”), and wish to use our website and/or Services, the GDPR applies to you. These additional terms (“GDPR Addendum”) apply to this and make up part of our Privacy Policy.

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The UK Data Protection Act 2018 (“DPA”) and the EU General Data Protection Regulation (“EU GDPR”) were   set up to control the collection, processing and transfer of UK and EU individuals’ personal data (as defined in the GDPR). The personal information described in the VXT Privacy Policy comes under the personal data in the GDPR.  It is important to us that we comply with the GDPR when dealing with the personal data of UK and EU-based visitors to our website.

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This GDPR Addendum was drafted to be concise and easy to understand.    It does not outline in exhaustive detail all aspects of our collection and use of personal data.   If you wish to have more information   or   need   an   explanation,   please   contact   us.   Your   request   should   be   sent   to   Luke Campbell, CEO of VXT, at info@vxt.co.nz.

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For the purposes of the GDPR:

  • VXT is the data controller (as defined in the GDPR) when processing personal information.
  • Google Cloud Platform is the data processor when processing personal information.

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1.0 Processing personal data

The personal information outlined in this Privacy Policy is the personal data that VXT may process.
Any processing done will be to achieve the purposes set out in this Privacy Policy.

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As permitted under the GDPR we can process your information for the purposes described in the body of the Privacy Policy by relying on one or more of the following lawful grounds: (a) you have
agreed   with   us   explicitly   that   we   may   process   your   information   for   a   specific   reason;   (b)   the processing of personal information is necessary to perform the agreement we have with you (or to
take steps to enter into an agreement with you); (c) the processing is necessary for us to comply with  our  legal  obligations;   or  (d)   the  processing  is  actually  necessary  for   our   legitimate   interests,
which include: (i) to protect our business interests; (ii) to ensure that complaints are appropriately investigated; (iii) to evaluate, develop or improve products and services we offer; or (iv) to keep you
informed of relevant products and services, unless you indicate that you do not wish us to be kept updated.   While   we   will   generally   rely   on   your   specific   consent   to   process   special   categories   of personal   data   (i.e.,   ‘sensitive   information’),   in   some   cases   (for   example,   relating   to   an   alleged offence),   we   may   need   to   use   some   information   to   comply   with   our   legal   obligations.  

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It is possible to use access and use our website without providing us with data. However some of our services will require you to provide us with your name and email address, for example if you sign up to any newsletters. If you choose not to divulge that information, we will be unable to provide you with our full services.

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2.0 Your rights

The GDPR grants you certain rights in relation to your personal data. These include:

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  • right of access - you have the right to ask, and we have the obligation to confirm, if we are processing your personal data. We can also provide you with a copy of that data.
  • right to rectification  – if we hold inaccurate or incomplete personal data about you, you may   ask  to   have  it   corrected   or   completed.   Once  notified,   we  will   do  all   that   we  can  to ensure the information is made right. We will also endeavour to pass on the correction if possible to any third parties with whom we have shared your personal data.
  • right to erasure – your personal data is deleted once it has fulfilled its intended purpose. Provided it does not contravene any applicable laws, we will also delete your personal data if you send a request. If we have shared your personal data with any third parties, we will take reasonable steps to inform them of your request.
  • right   to   withdraw   consent  –   as   mentioned   above,   our   legal   basis   for   processing   your personal data is your consent. Therefore if you wish for us to stop processing your personal
    data, you may withdraw your consent at any time.
  • right   to   restrict   processing  –   you   have   the   right   to   ask   us   to   restrict   or   stop   the processing of your personal data in certain circumstances. We will pass this request on to third parties where possible.
  • right to object to processing – at any point you may also request that we stop processing your personal data all together. We will do this to the extent required by the GDPR.
  • rights related to automated decision making, including profiling –  At the time of this GDPR Addendum, VXT does not make any automated decision making or profiling using the personal information. If this were to change, you have the right to not be subject to a decision based solely on this automated processing, including profiling which can have a significant   legal   impact.   The   exceptions   to   this   occur   where   such   automated   decision
    making is necessary for entering into, or fulfilling a contract with you, where relevant laws authorise it and when you have given explicit consent.
  • right to data portability – we will give you any personal data that you have requested from us   in   a   commonly   used,   machine   readable   and   interoperable   format   to   ensure   you   can access it. Where possible, and if you have requested, we will send your personal data to another data controller.
  • the right to complain to a supervisory authority – if you have any concerns about the way in which we have  dealt  with your personal data,  you may contact  the relevant   data protection supervisory authority.

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If your personal data is used or obtained for direct marketing purposes, you have the right to object.

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If you wish to exercise any of your rights  listed above, please contact our Privacy Officer.  If you are dissatisfied   with   how   we   deal   with   your   request,   you   may   refer   your   query   to   your   local   data protection supervisory authority e.g. in the United Kingdom, this is the Information Commissioner’s
Office.

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3.0 Children

It is not our intention to collect personal data from children under the age of 16. If you believe that a child   under   16   has   given   us   their   personal   data   either   through   our   website   and/or   by   using   our Services, please contact our Privacy Officer.   If they can access it, then it is your responsibility to obtain the consent of any Guardian of any children who can access the website or the Services and you agree to do so.

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4.0 International transfer of data

As we are based in New Zealand, the personal information that we collect through our website and our Services will be transferred to, and stored in, a country operating outside the United Kingdom or the European Economic Area (EEA). According to the GDPR, this transfer may only take place if the European Commission has decided that the country maintains an adequate level of protection. If this adequacy status is not granted to us we may transfer the personal data, so long as there are suitable safeguards.

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The VXT Privacy Policy states that some of the personal information we collect is processed by third party data processors in other countries, including Australia. We will only transfer this data outside the United Kingdom or the EEA if that country has been given the adequacy status mentioned above, or if we have approved transfer instruments set up to protect your personal data. If you wish to know more, please contact us using the details in our Privacy Policy.

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5.0 Data Retention Privacy Policy

We will only keep personal information for as long as is needed to achieve its purpose, or to comply with relevant law, whichever is longer.

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6.0 Contacting us

Please contact us via the details as set out in our Privacy Policy.

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