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Vxt Limited’s Privacy Policy

‍
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.

‍
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.

‍
If you are primarily based in  the 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.

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

‍
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.

‍
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.

‍
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,
without 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.

‍
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.

‍
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.

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

‍
When we collect and process User Data we act as an agent  of you for the purposes of the New
Zealand Privacy Act 1993 and any other relevant privacy laws. If applicable, we also act as the data
processor   for   the   purposes   of   the   General   Data   Protection   Regulation   of   the   European   Union
(“GDPR”).   Such   User   Data   will   only   be   processed   in   accordance   with   this   Privacy   Policy   and   in
compliance with all applicable privacy laws.

‍
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.

‍
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.

‍
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.

‍

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.

‍
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),   please   refer   to   the
GDPR Addendum. This will outline how personal data is transferred from the EEA.

‍
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.

‍
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.

‍
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.

‍
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.

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

‍
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.  

‍
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.

‍
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.

‍
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.

‍
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
Level   6,   University   of   Canterbury   Centre   for   Entrepreneurship,   Rehua   Building,   University   of
Canterbury, Ilam, Christchurch, 8041 or by email to info@vxt.co.nz. You will need to prove that you
are the individual to whom the personal information relates.

‍
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.

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

‍
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.

‍
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.

‍
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.  

‍
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.

‍
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.

‍
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.

‍
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:

‍
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/

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

‍
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.

‍
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.

‍
13.0 Privacy complaints process

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:

‍
- Email: info@vxt.co.nz
- Post: 4 Highfield Lane, Rangiora, Rangiora, 7400, New Zealand

‍
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.  

‍
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.

‍
This Privacy Policy was last updated on 11 October 2021.

‍

GDPR Addendum

‍
If you are located in 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.

‍
The   EU   General   Data   Protection   Regulation   (“GDPR”)   was   set   up   to   control   the   collection,
processing and transfer of 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 EU-based
visitors to our website.

‍
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.

‍
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.

‍
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.

‍
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.  

‍
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.

‍
2.0 Your rights

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

‍

  • 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.

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

‍
If you wish to exercise any of your rights  listed above, please contact Luke Campbell.  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.

‍
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.

‍
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   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.

‍
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   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.

‍
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.

‍
6.0 Contacting us

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

‍

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