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Privacy Policy

Privacy Policy

 

Tickrs Pacific Limited (TPL) and its related companies (as that term is defined in the Companies Act 1993) (“us”, “we” or “our”) has instituted this Privacy Policy (“Policy”). This Policy provides information in relation to the basis upon which we collect, hold, use and disclose your Personal Information. In this Policy, “you” or “your” means the individual providing Personal Information to us (including a registered user of our services) and Personal Information has the same meaning as in the Privacy Act 2020 (Act). In essence, it is information relating to an individual which can be used to identify that individual or which is linked to an identified individual.

This Policy applies to the use of our application (App) and our website, www.tickrs.nz (Website), including the use of all software and services provided by us via the App and Website. By submitting your Personal information and/or registering to use our software or services you agree to the terms of our Policy.

If you have any questions about this Policy or related matters, please contact us as follows:

Website: www.tickrs.nz

Email: info@tickrs.nz (for general inquiries)

Email: IT@tickrs.nz (for queries relating to the App and Website)

  1. Updates to this Policy
    1. We will review this Policy from time to time to make sure it takes into account new laws and technology, and any changes to how we operate.
    2. Should we decide to change our Policy we will post all changes on the Website so that you are always kept up to date.
    3. Use and disclosure of Personal Information collected from you is subject to the Policy in effect at the time such Personal Information is collected, unless otherwise agreed.
  2. Collection of Personal Information
    1. The Personal Information we collect and hold includes (but is not limited to): your name, gender, nationality/country of legal residence, ID documentation, contact details, address, date of birth, account login information, account preferences, payment information, a photo of you captured by the camera on your smartphone or computer and banking details (to allow for transactions to and from your account with us). We are also required to take a copy of documents verifying your banking details, including bank account numbers. We may also collect any personal information contained in the content of your email and other communications with us, including voice recordings of telephone enquiries you may make and feedback on our services.
    2. Additionally, the Website or App may automatically log certain information, including IP address, browser type, sites you visited prior to visiting our Website, clicks and device identifiers.
    3. We collect your Personal Information the first time you sign up with us, as part of our customer due diligence process, when you use the App or Website, when you contact us (including to update your Personal Information) and when you interact with the marketing communications we send you.
    4. Your Personal Information may also be collected from your organisation (where we permit it to have an account with us which you operate on behalf of the organisation), where you authorise it to provide such information, or as otherwise permitted by the Act.
    5. Your Personal Information may also be collected from third parties you authorise us to contact, or by agents who are authorised by you to provide such information, or as otherwise permitted by the Act.
    6. The App or Website may state other ways in which we collect information from you.
    7. If you access the App or Website from outside of New Zealand, you agree that any Personal Information you provide us is subject to this Policy and the Act.
  3. If you do not provide the personal information we ask you to provide at the time it is requested (or within any time period we specific for providing it), or the information is incorrect, you may not be able to log into your account, we may restrict the functions of your account (such as the ability to deposit and withdraw funds) and we may not be able to provide the requested services, process transactions, respond to an enquiry, or contact you.
  4. Anti-Money Laundering and Countering Financing of Terrorism Act 2009
  5. We are required by the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 and associated regulations (AML/CFT) to meet the requirements for client due diligence, which involves requesting information from you to (i) understand the nature and purpose of your engagement of our services, and (ii) verify your identity and undertake other identity related checks, and (iii) verify source of wealth or source of funds if required. Our processes to verify your identity also require us to capture a photo of you. This may require access to your camera and photo roll on your device. Any access to your camera or photo roll will be specifically requested at the time.
  6. The AML/CFT also requires us to take a copy of documents verifying your identity, including your full name and date of birth. In some circumstances, we are required to take a copy of documents verifying your residential address. If these documents are not provided to us, you will not be able to use the App or Website to establish an account with us.
  7. We use the requested information (AML information) for the following identity related checks:
  8. To check that the AML information matches the information in the relevant government databases, e.g. passport databases. This includes accessing the New Zealand and Australian document verification services. We have arrangements in place to work with third parties to use the third party systems to undertake the information matching process. These third parties include Verifi Identity Services (Cloudcheck) and Refinitiv (World-Check). We provide an information match request, and receive an information match result and other information match data from these services. The information involved will be transmitted to and from Australia when accessing the Australian document verification service.
  9. To check we are not prohibited from accepting you as a customer under the AML/CFT, we use services provided by Verifi Identity Services and Refinitiv to undertake these checks. These services involve accessing a number of databases, many of which are outside of New Zealand, in order to undertake these checks.
  10. When we use these services we upload your Personal Information to enable the check to be undertaken. We can then download the check results, the information verified, stating against which sources and when. You authorise those providers to provide this information to us. That information will form part of the AML information.
  11. All such use of the AML information when accessing those databases is limited to compliance with our obligations under the AML/CFT and any other applicable law.
  12. Verifi Identity Services is located in New Zealand. Refinitiv is a part of LSEG (London Stock Exchange Group) and is headquartered in the United Kingdom. To understand the ways each of them collects, holds, uses and discloses such Personal Information, please read their privacy policies, which are available:
  13. in respect of Verifi Identity Services, here;
  14. in respect of Refinitiv, here (with its general privacy statement available here).
    1. Third Parties
    2. If you are an employee of an organisation that has (or is creating) an account with us and you provides Personal Information relating to the organisation’s individuals who are able to access the organisation’s account, you warrant you are authorised to do so and that the organisation has ensured the individual is aware of the information in this Policy. If you provide us Personal Information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
    3. We may also use social media services like Linkedin, WeChat and Facebook. Your use of these third party services is entirely optional. We may make use of any information that you make public relating to our business, when you use any such third party services, for the purposes of our business.
    4. All third party services are governed by the privacy policies and/or practices of the relevant third party, for which we are not responsible. If you do not want to provide Personal Information to any of those third parties, or make information publicly available, you should not use their particular service.
    5. Purposes for which we collect and use your personal information
    6. We may collect and use your Personal Information for the following purposes:
    7. to provide you with the services you have requested, for example creating an account and providing you access to the App or Website, managing your account and the investments from your transactions, facilitating transactions using the App or Website, and supporting the App and Website;
    8. to verify your identity, and undertake identity related checks as outline in section 3 of this Policy;
    9. to optimise your experience as a user of the App and/or user of our Website;
    10. to keep you updated with our services and to let you know about our special offers and promotions;
    11. to communicate with you, which includes responding to any message or enquiry you send us and identifying you when you want to communicate with us;
    12. to conduct our business, which may include reviewing, analysing and improving our own processes;
    13. to take any action in order to recover any amount you owe us;
    14. to take any action in any case of dispute, or legal proceeding of any kind between you and us, or between you and any other person with respect to our business;
    15. to otherwise protect our interests in our property, our legal rights, or those of others, including to detect, investigate, prevent or address fraud, security or technical issues, or if we have good reason to believe there is an imminent threat of death or injury or a serious threat to health and safety;
    16. to comply with our legal obligations; and
    17. any other purpose made known to you when collecting the Personal Information.
    18. We may also collect and use your Personal Information in any circumstances authorised by the Act, or in any other manner with your consent. We and any of our related companies may also disclose any Personal Information collected by it to us (where collected by a related company) and any related company, each of whom may use it in accordance with this Policy.
    19. Cookies and Similar Technologies
    20. Our Website or App may use cookies or similar technologies. A cookie is a small data file stored on a device with a web browser (e.g. computer, iPad or smartphone). It can contain information about your device, your IP address, your session, and the online activity on the Website of anyone using your device.
    21. We currently use functional/required cookies to help in establishing your identity and to monitor your logged in status for your account. Functional and required cookies are always used, which allow us to provide the functionality of the Website or App to you.
    22. If you do not agree to the use of cookies, or would like to block some or all of the cookies on our Website or App, you can manually disable or reject the use of cookies through your web browser or via the relevant setting on your smartphone.
    23. If you disable or reject the use of cookies, some functionality on the Website or App may not be available.
    24. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org.
    25. Other Disclosures of Personal Information
    26. You agree that we may disclose your Personal Information for the above purposes (and any specific purpose set out below) to any of the following persons:
    27. to any third party to identify or verify your identity and/or to undertake anti-fraud or money-laundering and terrorism financing checks as outlined in section 3 of this Policy;
    28. to any governmental agency or financial services provider if required to complete your transaction or where required in accordance with relevant regulations;
    29. to other third party providers (including technology providers, storage service providers and providers of software tools used by us in our business) to perform services on our behalf, to process the information for us, or hold it on our behalf, including Shenzhen Shidai Huasheng Network Technology Co. Ltd who we currently use for the purpose of improving, maintaining and repairing the Website and the App for our benefit;
    30. to any third party for the purpose of conducting a credit check where we consider your proposed transaction or transactions carries a level of risk that justifies a credit check; and
    31. to any business or person that is considering buying an interest in our business or assets, or to any person we are considering merging with.
    32. These entities may be located in New Zealand or overseas.
    33. We do not otherwise share your Personal Information without your consent, except where permitted by the Act, unless we believe it is necessary:
    34. to enforce our terms and conditions, or where we are legally required to do so;
    35. for us or other authorised agencies to detect, investigate, prevent or address fraud, security or technical issues; or
    36. to otherwise protect our property, legal rights, or that of others.
    37. We may use and disclose your Personal Information for any of these purposes, in any circumstances authorised by the Act, or in any other manner with your consent.
    38. Except as otherwise stated in this Policy, your Personal Information we collect is held by us. Our address is set out below.
    39. Access, Correction and Retention of Your Personal Information
    40. You agree that any information you give to us will be accurate, correct and up to date, and that when providing Personal Information about others, you are authorised to give such information to us.
    41. 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.
    42. Your Personal Information is currently stored on third party servers located in Singapore. Where you have provided us with physical copies of any documents containing Personal Information, we store this Personal Information at our offices, the details of which are found below.
    43. Primarily, we will retain your Personal Information for as long as it is required to achieve the purposes of this Policy. We may also retain your Personal Information for as long as needed to manage backups of your Personal Information in accordance with our security practices, to be able to address any claim that might be made after we stop providing services to you, or to meet any legal obligations we have to retain such information, including managing our obligations to you in respect of these services. Where we no longer require your personal information for a permitted purpose under the Act, we will take reasonable steps to return, delete or destroy it.
    44. You have the right to access, and request correction of, your Personal Information.
      1. To request correction of any of your Personal Information, please submit an application requesting any corrections via email info@tickrs.nz.
      2. To request access to any of your Personal Information, please contact our Security Department as follows:

Email: info@tickrs.nz

Address: Tickrs Pacific Limited, Unit C, Level 16, AIG Building, 41 Shortland Street, Auckland, 1010, New Zealand

    1. We endeavour to ensure that the Personal Information we hold is accurate, complete and up-to-date. If any of the Personal Information that you have provided to us changes we encourage you to contact us to update that Personal Information.
    2. If a dispute arises between us and we cannot resolve it with you, then you may wish to contact the Office of the Privacy Commissioner on investigations@privacy.org.nz.
    3. Governing Law
    4. This Policy is governed by the laws of New Zealand.