Privacy Policy

Personal information means any information that directly or indirectly allows for the identification of a natural person. It may include, but is not limited to:

• your name, physical address, email address and telephone number;
• payment information;
• support queries and requests;
• and information about your company such as the name, size and location of your company and your role within the company.

If you can’t be identified (for example, when personal information has been aggregated and anonymised) then this Privacy Policy does not apply.

We collect and use personal information provided by you when you engage us to provide services to you or through your use of the Site App Pro application (“Application”), including where you scan a Site App Pro QR code. We use the information you provide to us to provide you with the product or service you request. We will not collect personal information if it is not necessary to provide you with our services or for you to use the Application.

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When you use our services or use our website or the Application, we might ask you to provide personal information to us. The failure to provide such personal information may make it impossible for you to use the Application. In cases where the Application specifically states that some personal information is not mandatory, you are free not to communicate this personal information without consequences to the availability or the functioning of the Application. If you are uncertain about what personal information is required for full use of the Application, you are welcome to contact us.

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Wherever it is possible and practical to do so, we will collect personal information directly from you. This may be in person, over the telephone, by email, via the Application, over the internet or by completion of a form (such as an application form and including a digital form).

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When you visit our website or use the Application, we may record general information about your visit and usage for statistical purposes, such as your IP address and what features you used. Some of this information is collected using cookies. Please refer to our Cookie Policy for more information about our use of cookies. These statistics do not contain any personally identifiable information. Where such statistics do allow us to identify you, they shall be treated as personal information and this Privacy Policy shall apply.

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We may collect personal information about you from third party service providers only when you have agreed to the release of such personal information to us. We will not otherwise collect any personal information about you unless we have your permission or you knowingly give us the information.

We may use your personal information in the following ways:

• for the purpose of providing our services and communicating with you in relation to those services, such as providing support services or responding to your inquiries;
• marketing communications, in accordance with your marketing preferences (subject to your ability to opt-out of receiving marketing communications);
• operational communications, such as changes to our website, the Application, our terms of use and this Privacy Policy;
• to assist us in developing and improving our services and the Application;
• to enforce our rights where necessary, in accordance with any contract or other terms and conditions to which you are subject;
• if you provide testimonials or reviews, to publish that content on our website and social media platforms; or
• in accordance with our legal obligations.

If you can’t be identified (for example, when personal information has been aggregated and anonymised) then this Privacy Policy does not apply.

In the course of providing our services, we may need to disclose your personal information to certain third parties, including:

• other companies in the Comply Pro group of companies;
• third party services providers who assist and enable us to use the personal information, for example, our payment providers and marketing partners; and
• to such persons that you may have agreed to provide your personal information to.

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Where you have scanned a Site App Pro QR code or log in to a worksite using the Application, the personal information you provide will be made available to the relevant manager or administrator of that worksite. Any such manager or administrator is subject to Site App Pro’s Terms and Conditions of Use.

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We may not disclose your personal information to overseas third parties without your consent unless the jurisdiction of that third party provides similar safeguards to those in the Privacy Act 2020 or the Australian Privacy Act 1988 (Cth) as applicable. We are likely to disclose your personal information to Amazon Web Services (based in the USA) as part of providing our services and you consent to us doing so notwithstanding that it may not have comparable safeguards.

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We may disclose your personal information if required to do so by law. We may also disclose information about someone whose activities could cause harm to themselves or others (i.e. fraud). Where possible and appropriate, we will notify you of this type of disclosure.

We understand the importance of protecting the personal information we hold about you. The information you provide us is only made available to our staff on a 'need to know' basis and for the purposes outlined above or to third parties as outlined in this Privacy Policy who have agreed to treat that information confidentially. We take steps to ensure your personal information is free from misuse, interference, loss, unauthorised access or modification by:

• securing personal information both in physical and electronic form;
• limiting access to personal information only to those that need access to it for the purpose of providing you with our services; and
• protecting our systems with appropriate technology solutions.

While we cannot ensure or guarantee that loss, misuse or alteration of personal information will not occur, we use our best efforts to prevent this.

You have a legal right to a copy of all the personal information we hold about you. You also have a right to request access to the personal information we hold about you or request us to correct the personal information we hold about. You may exercise these rights by emailing us at privacy@complypro.co.nz

We will keep your personal information only for as long as necessary to achieve the purpose we collected it for and in all cases for such periods as we are required to in order to comply with any relevant legislation or regulations.

While we do not provide or market the website or mobile application to those who reside in the Europe Economic Area (the “European Union” or “EU”), if personal information is collected or processed from an individual located in the EU we will provide accommodations for the exercise of the rights provided under data protection laws of the EU, including the General Data Protection Regulation (the “GDPR”). By visiting our website or using our mobile application, you are consenting to the transfer of your information from your jurisdiction to the jurisdictions within which we operate including New Zealand, Australia, and USA.

If you are entitled to privacy rights under the GDPR, you are entitled to:

• Transparency and the right to information. Through this Privacy Policy we explain how we use and share your information. However, if you have questions or concerns you can contact us any time.
• Right of access, objection, restriction of processing, erasure, and portability. You also have the right to withdraw your consent at any time when we process your personal data based on your consent. To exercise these rights, please contact us.
• Right to opt-out to direct marketing. While we currently do not do such marketing, you have the right to opt-out at any time to receiving marketing materials from us by following the opt-out instructions in our commercial emails, by contacting us, or by adjusting your preferences on the website or using our mobile application. Please note that we reserve the right to send you other communications, including website or using our mobile application announcements and administrative messages relating to your account with us, without offering you the opportunity to opt out of receiving them.
• Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal data that may negatively impact you. We use cookies and similar technologies on our website or using our mobile application to personalize your experience on the website or our mobile application.
• Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes your privacy rights according to the European Data Protection law, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement.

We reserve the right to modify or amend this Privacy Policy including the appendices from time to time for any reason. If we make any significant changes, we will (where possible) provide you with reasonable notice of such changes via email.

If you have any questions on this Privacy Policy or on any personal information we have collected, you can contact us at privacy@complypro.co.nz

If you have a complaint about our obligations with respect to your privacy rights, please raise that with us in the first instance by email to Privacy@complypro.co.nz. We will endeavor to respond to your complaint within 20 working days. If you are not satisfied with our response, you may lodge a complaint with the New Zealand Privacy Commissioner (website: https://www.privacy.org.nz/) or the Office of the Information Commissioner (website: https://www.oaic.gov.au/) as applicable.

The information set out in this Appendix is provided to certain individuals located in the USA and whose personal information we process.

Shine the Light Law

California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits users of the website or mobile application who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year.

California residents who have an established business relationship with us may make a written request to us about whether we have disclosed any personal information to any third parties for the third parties’ direct marketing purposes during the prior calendar year.

California Consumer Privacy Act (“CCPA”)

California consumers have the right to:

• Request the categories of personal information we have collected about consumers;
• Request the categories of sources from which the personal information is collected;
• Request the business or commercial purpose of collecting or selling personal information;
• Request the categories of third parties with whom we share or sell personal information;
• Request the categories of personal information about consumers that we have sold;
• Request the specific pieces of personal information we have collected about a consumer;
• Request deletion of their personal information;
• Opt out of the sale of their information; and
• Not be discriminated against for exercising these rights.

In the twelve (12) months preceding the effective date of this Privacy Policy, we may have collected or received from users of the website or using our mobile application or from QR code scanning, and from third parties in connection with providing the same, information about California consumers in each of the following categories and disclosed the information to our service providers for business purposes:

• Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
• Categories of personal information described in subdivision (e) of Section 1798.80.
• Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
• Geolocation data.
• Audio, electronic, visual, thermal, olfactory, or similar information. Professional or employment-related information.
• Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
• Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

California residents may request a list of all third parties to whom we have disclosed any information about you. If you are a California resident and want such a list or desire that we not maintain or utilize a record of your internet usage or path to our site, please send us a written request by e-mail to privacy@complypro.co.nz. Please include “Your California Privacy Rights” in the subject line of your e-mail in the body of your request. Please include your name and full contact information. We will use our commercially reasonable best efforts to accommodate your request.

Some browsers may have settings to request that websites “Do Not Track” your activity or usage.  At this time, our website and mobile application may not accommodate these technologies and your requests may not be able to be honored on our website or using our mobile application.  We do use cookies and other technologies to track your usage and other information about your visit to our website or using our mobile application.  If “Do Not Track” settings are accommodated, your information that may be collected by your visit to the website or using our mobile application will not be saved and you may not have full functionality of the use of the website or our mobile application.

The website and our mobile application are not for general audiences. We do not offer subscriptions or services to individuals under 18 years of age. No one under the age of 18 may provide any information to or on the website or our mobile application. We do not knowingly collect personally identifiable information from individuals under 18. If you are under 18:

• Do not use or provide any information on this website, our mobile application or on or through any of its features;
• You may not register on this website or our mobile application;

• You may not use any of the features of this website or our mobile application; You may not provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.

Should an individual whom we know to be under the age of 18 sends personally identifiable information to us, we will delete or destroy it as soon as reasonably possible. If you believe we might have these kinds of personally identifiable information, please contact us.