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Privacy Policy
Date: 4 May 2017

greenID Limited (New Zealand Company Number 4735299) (greenID), is a private identity verification services provider and an Intermediary service provider for the New Zealand Identity Information Confirmation Service.

greenID is an entity within the Vix Verify Global Pty Ltd (ABN 32 132 767 830) Group of companies.

greenID is committed to complying with the New Zealand Information Privacy Principles. It understands the importance of protecting the privacy of individuals. This Privacy Policy, therefore, sets out:

  • greenID’s procedures in relation to the collection, use, disclosure, storage and protection of information that greenID collects from or about individuals (personal information); and
  • the rights of individuals to seek access to and correction of personal information which greenID holds about them.

This Privacy Policy is divided into 5 principal sections:

If you would like greenID to send you a MS Word or PDF copy of this Privacy Policy (at no charge), please use the contact details at the end of this Privacy Policy to request a copy. If you require a copy of this Privacy Policy in a different format, greenID will use its reasonable efforts to comply with your request. If greenID cannot supply a copy of the Privacy Policy in the format you have requested, greenID will contact you to discuss your requirements and attempt to identify and agree an alternative format in which the copy of the Privacy Policy can be provided to you.

greenID welcomes your comments on this Privacy Policy. If you would like to make a comment, you should contact greenID using the contact details set out in the Contact Details section of this Privacy Policy.

1. Visitors

A visitor is a person who visits greenID’s website or otherwise contacts greenID but to whom greenID does not provide any goods or services or who does not undertake a trial of any products or services provided by greenID (Visitor).

greenID does not attempt to identify a Visitor when the Visitor is accessing the website or otherwise contacting greenID except where the Visitor wishes to undertake a trial of any of greenID’s services (in which case, you should refer to section 2 of this Privacy Policy). greenID will not collect personal information about any Visitor unless the Visitor expressly provides this to greenID (for example, by sending an email or completing an online registration form or online inquiry form).

If a Visitor wishes to undertake a Trial, the Visitor cannot undertake the Trial unless the Visitor provides an email address.

Where possible, greenID’s systems will allow a Visitor to communicate with greenID on an anonymous basis or by using a pseudonym.

2. Trial Users

A trial user is a person who visits greenID’s website or otherwise contacts greenID and undertakes a trial of any products or services provided by greenID or visits the public demonstration pages of greenID’s website (Trial User).

A Trial User will only be able to undertake a trial of products or services provided by greenID if the Trial User provides an email address.

This section is divided into the following subsections:

  • Why greenID collects personal information;
  • What personal information greenID collects;
  • How greenID collects personal information of an Trial Users;
  • How greenID collects personal information of Trial Users;
  • How greenID uses personal information of Trial Users; and
  • Disposal or destruction of personal information of Trial Users.

2.1 Why greenID collects personal information

greenID collects personal information of Trial Users:

  • to confirm that the Trial User is a person who wishes to use the products and services of greenID on a trial basis; and
  • for the purposes of communicating with the Trial User.

2.2 What personal information greenID collects

greenID collects only the Trial User’s email address. It is not possible to undertake a trial of any products or services provided by greenID or visits the public demonstration pages of greenID’s website unless a user provides the user’s email address. Therefore, it will not be possible for a Trial User to communicate with greenID on an anonymous basis or using a pseudonym.

2.3 How greenID collects personal information of Trial Users

greenID will collect information directly from each Trial User.

2.4 How greenID obtains consent from Trial User

In most cases, either before or at the time of collecting the personal information, greenID will obtain the consent of the Trial User to collect the personal information.

2.5 How greenID uses personal information of Trial Users

greenID will use the personal information to monitor usage patterns, to determine whether the Trial User is a genuine user of the trial products and services and to communicate with the Trial User including for the purposes of marketing.

greenID will not disclose any personal information to any individual or entity without the express permission of the Trial User unless required to do so by law (refer clause 5.4).

2.6 Disposal or destruction of personal information

greenID will delete all personal information at the conclusion of the trial arrangement except in those cases where greenID is required to maintain a record.

3. Individual Users
An Individual User is a person who visits greenID’s website or otherwise contacts greenID and to whom greenID provides products or services.

greenID’s identity verification service is a service which verifies the identity of an Individual User thereby allowing the Individual User to prove that the Individual User is who the individual says he or she is including to allow the Individual User to electronically present himself or herself to a trusted independent entity with whom the Individual User may already have a relationship.

This section is divided into the following subsections:

  • Why greenID collects personal information;
  • What personal information greenID collects;
  • How greenID collects personal information of Individual Users;
  • How greenID uses personal information of an Individual User;
  • Access to personal information;
  • Disposal or destruction of personal information.

3.1 Why greenID collects personal information

greenID collects personal information of Individual Users:

  • to provide identity verification services to the Individual Users;
  • for the purposes of communicating with the Individual User;
  • for the purpose of providing information to specific organisations with whom an Individual User has authorised greenID to communicate; and
  • to provide services related to the services and purposes described above.

To provide the greenID’s identity verification service, the information collected by greenID is compared against an information database.

greenID also collects such personal information of Individual Users as is reasonably necessary to undertake a necessary function or activity (for example, to manage and administer greenID and conduct its business).

3.2 What personal information greenID collects

greenID collects the following information about Individual Users:

  1. name;
  2. address;
  3. birthdate;
  4. time and date of use of greenID; and
  5. email address.

Additional information may be required depending on the services which the Individual User wishes to acquire from greenID and greenID will, notify the Individual User of the requirement to collect this additional information as specified in section 3.4 of this Privacy Policy.

Where possible, greenID’s systems will allow an Individual User who wishes to communicate with greenID on an anonymous basis or by using a pseudonym. However, it will not be possible for an Individual User to communicate with greenID on an anonymous basis or using a pseudonym if the Individual User requires assistance in relation to its account or the information which it has provided to greenID for the purposes of establishing or using its account.

3.3 How greenID collects personal information of Individual Users

greenID will collect information directly from each Individual User or from third parties whom the Individual User has authorised greenID to contact.

3.4 How greenID obtains consent from an Individual User

In most cases, either before or at the time of collecting the personal information, greenID will obtain the consent of the Individual User to the collection of the personal information. If greenID cannot obtain the consent of the Individual User before or at the time of collection, it will obtain consent as soon as practical after the collection.

3.5 How greenID uses personal information of an Individual User

The greenID service enables an Individual User to use the Individual User’s personal information for the Individual User’s own purposes. greenID uses the personal information of an Individual User as required to provide products and services to the Individual User. This may include disclosure of personal information to persons whom the Individual User has authorised greenID to contact or provide the personal information for the purposes of providing the verification service to the Individual User.

greenID will not disclose any personal information to any individual or entity without the express permission of the Individual User unless required to do so by law (refer clause 5.4).

3.6 Access to personal information

Individual Users may access all the personal information they have provided to greenID or which greenID has collected and may update or delete it except in those cases where greenID or an organisation to which greenID has provided the personal information as part of greenID’s provision of the verification services is required to maintain a record. This includes retention of records for compliance with the Anti-Money Laundering and Countering Financing of Terrorism Act 2014 or other laws or regulations.

3.7 Disposal or destruction of personal information

greenID will delete all personal information at the conclusion of the Individual User’s arrangements with greenID except in those cases where greenID is required to maintain a record.

4. Organisation Representatives

An Organisation Representative is a person who is dealing with greenID in his or her capacity as the representative of an organisation who has appointed greenID as its Intermediary for the purposes of the New Zealand Identity Information Confirmation Service and who is authorised to act on behalf of the organisation.

This section is divided into the following subsections:

  • Why greenID collects personal information;
  • What personal information greenID collects;
  • How greenID collects personal information of an Organisation Representative;
  • How greenID uses personal information of an Organisation Representative;
  • Access to personal information;
  • Disposal or destruction of personal information.

4.1 Why greenID collects personal information

greenID collects personal information of an Organisation Representative:

  • to provide services to the organisation which the Organisation Representative represents;
  • for the purposes of communicating with the Organisation Representative and the organisation which the Organisation Representative represents;
  • for the purpose of managing greenID’s contract with the organisation which the Organisation Representative represents; and
  • to provide services related to the services and purposes described above.

greenID also collects personal information of Organisation Representatives which is reasonably necessary to undertake a necessary function or activity (for example, to manage and administer greenID and conduct its business).

4.2 What personal information greenID collects

greenID collects the following information about Organisation Representatives:

  1. name;
  2. address;
  3. birth date;
  4. email;
  5. telephone number;
  6. fax number; and
  7. name of the organisation which the Organisation Representative is representing and other information which is required to identify the organisation including Incorporation Number, NZBN, address, telephone number; fax number and website.

Where possible, greenID’s systems will allow an Organisation Representative to communicate with greenID on an anonymous basis or by using a pseudonym. However, it will not be possible for an Organisation Representative to communicate with greenID on an anonymous basis or using a pseudonym if the Organisation Representative requires assistance in relation to greenID’s arrangements with the organisation which the Organisation Representative represents or the Organisation Representative’s account.

4.3 How greenID collects personal information of an Organisation Representative

greenID will collect information directly from each Organisation Representative.

4.4 How greenID obtains consent from an Organisation Representative

In most cases, either before or at the time of collecting the personal information, greenID will obtain the consent of the Organisation Representative to the collection of the personal information. If greenID cannot obtain the consent of the Organisation Representative, it will obtain consent as soon as practical after the collection.

4.5 How greenID uses personal information of an Organisation Representative

greenID does not anticipate disclosing the personal information of an Organisation Representative to enable greenID to provide products and services to the organisation which the Organisation Representative represents.

4.6 Access to personal information

Organisation Representative may access all the personal information they have provided to greenID or which greenID has collected and may update this information and update it or delete it except in those cases where greenID is required to maintain a record.

4.7 Disposal or destruction of personal information

greenID will delete all personal information:

  • at the conclusion of the arrangements between greenID and the organisation which the Organisation Representative represents except in those cases where greenID is required to maintain a record; or
  • when the Organisation Representative notifies greenID that it is no longer the representative of the organisation; or
  • when the organisation which the Organisation Representative represents notifies greenID that it is no longer the representative of the organisation,
    except in those cases where greenID is required to maintain a record.

5. Provisions applicable to all persons from whom greenID collects personal information

This section is divided into the following subsections:

  • Unsolicited personal information;
  • Usage patterns;
  • Cookies;
  • Disclosure of personal information by greenID;
  • Transfer of personal information outside Australia;
  • Data security and data storage;
  • Government related Unique Identifiers;
  • Concerns about personal information;
  • Response to request for access to personal information;
  • Process for accessing personal information;
  • Refusing access to personal information;
  • Quality of personal information and correction of personal information;
  • Complaints;
  • Changes to Privacy Policy; and
  • Contact details.

5.1 Unsolicited personal information

There may be situations in which greenID receives personal information about a person even though greenID has not requested any personal information about an individual or has not requested the particular information which has been received about an individual (unsolicited personal information).

If greenID receives any unsolicited personal information, it will, within a reasonable period of receipt of the unsolicited personal information, review the unsolicited personal information to determine if it is reasonably necessary for its functions. If it is, greenID will handle the information in the same way as it handles the information we collect from a person. If greenID does not need the information, greenID will destroy the information or de-identify it.

5.2 Usage Patterns

greenID’s web server collects information on the usage patterns of people visiting greenID’s website. The information is collected each time a user visits greenID’s website. Except in relation to a Trial User, it is not used to identify browsing activities of any individual user but is collected for statistical purposes. The information collected consists of:

  • the date and time of visits;
  • number of users who visit the website;
  • traffic patterns and pages viewed.

This data will be used to research greenID’s website and product and to evaluate, develop and improve its usability.

5.3 Cookies

greenID’s website uses session based cookies to keep Individual Users and Organisation Representatives logged in during a session. No other cookies or trackers are used.

5.4 Disclosure of personal information by greenID

greenID will not disclose information that identifies an individual, or enables an individual to be identified except as:

  • specified in this Privacy Policy;
  • authorised by the individual;
  • as required under applicable laws; or
  • as directed by courts, tribunals or other bodies having authority over greenID.

5.5 Transfer of personal information outside New Zealand

In providing verification services to an Individual User, greenID will be required to transfer personal information of an Individual User outside New Zealand if the Individual User provides verification information from a country other than New Zealand. In this instance, personal information will be transferred by greenID to the country from which the verification information provided by the Individual User originates. By giving greenID your personal information, you consent to such transfer and disclosure. In addition, we believe that the recipients of such information are subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the applicable New Zealand information privacy laws.

5.6 Data security and storage

All personal information held by greenID is protected from unauthorised access through the use of secure passwords and user logons and other forms of biometric verification.
greenID stores all personal information that it collects securely in a manner that is sufficient to prevent misuse and loss, unauthorised access, modification or disclosure of personal information. greenID maintains a high level of data security by implementing:

  • physical security to prevent unauthorised entry to our premises, by installing systems to detect unauthorised access and secure containers for storing paper-based personal information;
  • computer and network security to protect computer systems and networks for storing, processing and transmitting personal information;
  • communications security to protect communications via data transmission and to prevent unauthorised intrusion into our computer network
  • personnel security, through greenID’s personnel security measures and background checking procedures to limit access to personal information only by authorised staff and for only approved purposes.

5.7 Government related identifiers

greenID does not use or disclose any government unique identifier or unique identifier issued by another person or agency.

5.8 Concerns about personal information

Users can contact greenID to address any concerns that they have about their personal information.

If you would like access to the personal information which greenID holds about you or a person whom you are authorised to represent, please contact greenID using the contact details set out in the Contact Details section of this Privacy Policy. Your request should specify the format in which you wish to be provided the personal information (for example, in person, by email, by telephone, hard copy or other electronic record). This application is free of charge. However, greenID may make a reasonable charge for providing access to you in the event that there is a cost to greenID in relation to labour and materials required to make the information available to you, or any cost incurred as a result of your request being treated as urgent. If greenID wishes to charge you to access the personal information, greenID will notify you of this charge prior to making the personal information available to you.

5.9 Response to request for access to personal information

If you make a request to access personal information, greenID will respond to your request as soon as reasonably practicable and in any case within 20 working days of receipt of your request. If greenID cannot respond within this period, greenID will notify you of the delay, the reasons for the delay and the date by which greenID will provide a response.

5.10 Process for accessing personal information

If greenID agrees to give you access to your personal information, the following process will apply:

  • No charge for access – greenID will notify you of its decision and (where you have requested that the information be provided to you by email, hard copy or other record that can be delivered to or sent to you), greenID will also provide the personal information to you at the same time (except as set out below)
  • Access charge – greenID will notify you of its decision and the proposed charge for giving you access and the payment terms and method of payment. If you wish to discuss the proposed charge with greenID, you should contact the greenID representative nominated in the notice. Once you have paid the access charge), greenID will provide the personal information to you (except as set out below).
  • Form of access if different from format requested – If greenID concludes acting reasonably, that it is not possible or practicable for greenID to provide the personal information in the format you have requested (for example because of the volume or nature of the personal information or your needs), greenID will contact you to agree a format in which greenID can give you access to the personal information. If you have requested access by in person or by telephone, greenID will contact you to arrange the time and place at which you may access the personal information.

5.11 Refusing access to personal information

greenID is entitled to refuse a request for access in the circumstances specified in Part 4 of the New Zealand Privacy Act. If greenID decides to refuse your request, greenID will notify you of its reasons (except where it is permitted to refuse to provide reasons). greenID will consult with you to identify an alternative means of giving you access to the personal information which may include reducing the scope of request or giving you access through an agreed intermediary.

If you disagree with greenID, you may make a complaint as described in the Complaints section of this Privacy Policy.

5.12 Quality of personal information and correction of personal information

greenID makes reasonable efforts to ensure that the information that it collects is accurate, up-to-date, complete and relevant both at the time of initial collection and during the period that greenID holds the personal information.

If you consider that any personal information that greenID holds about you is inaccurate, out-of-date, incomplete, irrelevant or misleading and you wish to have the information corrected, you should contact greenID using the contact details set out in the Contact Details section of this Privacy Policy. greenID will respond to your request within 20 working days of the date of receipt of the request. This application is free of charge.

If greenID accepts the request, it will take such steps as are reasonable in the circumstances to correct the information to ensure that, having regard for the reasons for which the information is held, the information is inaccurate, out-of-date, incomplete, relevant and not misleading.

If greenID refuses the request:

  • greenID will send you a written notice explaining the reasons for the refusal (except where it is unreasonable to provide an explanation), the complaint mechanism which you may follow and other matters which greenID is required to include; and
  • you may request that greenID associate with the personal information a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading. greenID will take reasonable steps (given the circumstances) to associate the statement in such a way to make it apparent to users of the information.

5.13 Complaints

If you wish to make a complaint about:

  • this Privacy Policy;
  • the manner in which greenID has implemented this Privacy Policy; or
  • any other matter relating to the personal information greenID holds about you or your dealings with greenID in relation to your personal information,

please contact greenID using the contact details set out in the Contact Details section of this Privacy Policy. All complaints will be considered by greenID’s privacy officer who may contact you to obtain further details of your complaint and to better understand your complaint so that it resolved as quickly as possible.

greenID aims to resolve all disputes in a manner which is satisfactory to both you and greenID. There may be circumstances where you are not satisfied with the manner in which greenID has resolved your complaint. If you are not satisfied with the manner in which greenID deals with your complaint, you may complain to the New Zealand Office of the Privacy Commissioner (see http://www.privacy.org.nz).

5.14 Changes to this Privacy Policy

greenID reserves the right to change this Privacy Policy as required to maintain compliance with the New Zealand Information Privacy Principles and other applicable laws, to comply with changes in technology or to facilitate changes in its business. greenID will, if possible, give prior notice of its intention to change this Privacy Policy. If greenID considers it necessary, it will consult with the New Zealand Office of the Privacy Commissioner or other appropriate government representatives and other representative groups before implementing any change to this Privacy Policy. However, there may be circumstances where greenID considers that prior notice or prior consultation is not required or where it is not possible for greenID to give prior notice of a change to this Privacy Policy or undertake consultation before changing this Privacy Policy.

When this Privacy Policy is updated, those updates will appear on this page. greenID will ensure that changes to this Privacy Policy are identified in each update. greenID will also ensure that prior versions of the Privacy Policy can be accessed.

5.15 Contact details

If you have any questions or comments about this Privacy Policy, would like to request a copy, request access to personal information held about you or make a complaint, please contact:

The Privacy Officer
greenID Limited
PO Box 4863
Sydney NSW 2001
AUSTRALIA
e-mail: info@vixverify.com

© 2017 VIX Verify Pty. Ltd. All rights reserved. ABN 67 111 307 361.