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.
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.
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:
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.
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
This means that you must take reasonable steps to ensure the individual concerned is aware of
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.
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:
In the event of a sale, merger, consolidation, liquidation, reorganisation or acquisition, your
information may be transferred.
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
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
This data may be used to:
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
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.
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
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
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
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.
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.
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
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
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.
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 firstname.lastname@example.org. 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
If appropriate and reasonable, we may charge you the cost of providing and/or correcting your
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.
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
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.
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.
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.
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: email@example.com
- Post: 71 Durham Street South, Sydenham, Christchurch, 8023
- 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.
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
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 firstname.lastname@example.org.
For the purposes of the GDPR:
As permitted under the GDPR we can process your information for the purposes described in the
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.
The GDPR grants you certain rights in relation to your personal data. These include:
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 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
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.
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.
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
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.