PLEDGEME LTD 


PRIVACY AND DATA PROTECTION POLICY


Introduction


Welcome to www.pledgeme.co.nz ("site"). Thank you for visiting our platform. We help people fund the things they care about.


In this Privacy Policy, "our" "we" or "us" means PledgeMe NZ Ltd (company number 3361892). We are committed to protecting your privacy through compliance with the Privacy Act 1993 and any related privacy codes. Please read this Privacy Policy ("Policy") carefully as it outlines how we collect, use, disclose and store your personal information.


By using the services offered by PledgeMe, you are acknowledging you have read and understood this Policy. We may modify this Policy at any time, and by continuing to use our Site, you accept the Policy as it applies and as amended from time to time. Your continued use of our Site after the modification to this Policy will constitute your acceptance of such modification.


This Privacy and Data Protection Policy explains how PledgeMe Ltd (“PledgeMe Ltd”, “us”, “we” or “our”) collect, use, disclose, transfer, protect, store and otherwise process a customer’s information. It also explains a customer’s rights and options around our use of a customer’s personal information and how a customer can exercise these choices.


Scope of Privacy and Data Protection Policy


PledgeMe Ltd is committed to protecting the privacy of the individuals on PledgeMe Ltd’s websites, mobile applications, products and services, (collectively, "Services") that include a link to this Privacy and Data Protection Policy. For the purposes of this Policy, “Customer”, as the term is used here, refers to an individual or an entity (including “Pledgers”and/or “Campaigners”) that register to use our Services.


In this Privacy and Data Protection Policy, personal information means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his/her physical, physiological, economic, cultural or social identity. By registering for or using Services a customer acknowledges the collection, transfer, processing, storage, disclosure and other uses of a customer’s information, as described in this Privacy and Data Protection Policy.


  • Customer Information, being personal information relating to our Customers and (where applicable) their businesses. We collect this information so that we can provide our Services to those Customers and maintain records and contact details relating to those Services and Customers. This policy sets out how PledgeMe Ltd processes a customer’s information.


 


A CUSTOMER’S INFORMATION


In using our Services, a customer provides us with the following information which we store securely:


Account and profile information


  • Contact information such as name, email address, mailing address, phone number and country

  • Personal Identity information such as Driver’s License or Passport details (as required under the Financial Markets Conduct Act 2013 to comply with identity checks under the Anti-Money Laundering and Counter Terrorism Financing Act 2009)

  • Preferences information such as notification and marketing preferences

  • Data related to the company and its directors that is seeking to raise funds

  • any other information relating to you that you provide to us directly or indirectly through our Site, including information you provide through emails, social media, surveys and competition entry forms.




Credit Card Information


All credit card information is fully maintained by Flo2Cash, a PCI compliant company. Being PCI compliant means Flo2Cash must fulfil all credit card security requirements. It also means that PledgeMe has absolutely no access to this information - we rely on Flo2Cash to confirm whether your pledge was approved or not.




Changes to a customer’s personal details


By way of a customer’s online account profile with PledgeMe Ltd, a customer is able to change their personal details either by logging into their account and updating them, or by contacting PledgeMe in writing with a change. This activity is logged and recorded in the event PledgeMe Ltd must provide evidence of Identity verification to a regulatory body. 


Operational data


We also store information a customer uploaded through our Services, including:


  • Collected related to the pledge a customer makes

  • Data relating to the pledges being made to a customer’s company

  • Data relating to the shareholders of a customer’s company

  • Information about a customer’s business structure and related legal documents


 


Other submissions


We ask for and collect personal information from a customer when a customer submits web forms on our websites or when a customer participates in any interactive features of our Services, sends an email to [email protected] or call 021 PLEDGE 1 and request customer support, download information from one of our online platforms, communicates with us via third party social media sites, or otherwise communicates with us.


Other General Information we come to know about a customer, a customer’s business or a customer’s operation


During the course of working with a customer, we may come to learn things about a customer, a customer’s business or a customer’s financial situation. This extra knowledge is not required for us to execute our obligations under our issuer agreement, investor agreement or services agreement with a customer and as such, is not recorded in our systems or saved in any documents, although some might be included in email communications that are then held in our system.


This information is simply “known” to our staff and not used in any way.  We consider this to be a customer’s private information and will not divulge it to any third parties without a customer’s consent.  Should the situation arise that any of this knowledge becomes useful for any decision-making about the services we deliver to a customer under our service agreement, we will discuss this with a customer as it arises.


Examples of this type of knowledge could be:-


A customer mentions to a PledgeMe Ltd staff member that a customer is thinking of increasing a customer’s pledge, or is considering changing a customer’s equity raise amount. This also includes any information a customer shares with PledgeMe Ltd regarding any material risks a customer’s business faces.


 


What other information do we collect and use?


 Access logs


Like most websites and services delivered over the Internet, we gather certain information and store it in log files when a customer interacts with our websites and Services. This information includes Internet protocol (IP) addresses as well as browser type, URLs of referring/exit pages, operating system, language and location preferences, time/date stamp, search history, device identification numbers and system configuration information. Occasionally, we connect personal information to information gathered in our log files as is necessary to improve our Services. If we did this, we would treat the combined information in accordance with this Privacy and Data Protection Policy.


Cookies and other similar technologies


We may use cookies and similar technologies like pixels, web beacons and local storage to collect and store personal and non-personal information about how you use our Site and our services.


Cookies are files that store information on the device on which you are using or accessing our Site. Cookies also retain your details and preferences, so you can easily continue your browsing session upon return to our Site. If you do not want to activate cookies, you can opt-out of receiving them by amending the settings of your internet browser, although you may find that some parts of our Site will consequently have limited functionality and personalisation if you do so.


We may share non-personal information with our affiliated organisations, such as advertisers and/or advertising networks to deliver advertising, and to help measure the effectiveness of an advertising campaign from time to time.


By continuing to use our Site, you consent to our use of cookies and similar technologies. We will handle any information collected by cookies in the same way that we handle other personal information described in this Policy.


Third party analytics tools


We may use third-party analytics tools to:


  • analyse usage trends on our Site, including the tracking and reporting of website traffic, ad conversion tracking, traffic analysis and marketing optimisation; and

  • collect this data in aggregate form so that it cannot identify any individual.


Third-party analytics tools collect non-personal information such as how often you visit our Site, the web pages you visit, add-ons, and other analytics data that assists us in improving our services. These tools might include, but are not limited to, Google Analytics, Google AdWords conversion tracking, Google Tag Manager, or Facebook Ads conversion tracking.


We reserve our rights to modify, add or remove any third-party analytics tools. By using our Site, you consent to the processing of any non-personal data these tools will collect in the way and for the purposes described above.




Analytics information derived from operational data


Analytics information also consists of data we collect as a result of running queries against Operational Data across our user base for the purposes of generating Usage Data. "Usage Data" is aggregated data about a category or group of features, services, or users that is not of itself personal information. It is also data about our Customers and/or their business. We may incidentally come across sensitive or personal information when we compile Usage Data.


We generally collect personal information directly from you when you:


  • share your information with us on our Site;

  • communicate with us over email, online chat systems, the phone or in person;

  • participate in one of our surveys or competitions;

  • interact with our Site and advertising;

  • purchase one of our products or services; and

  • use or access our Site and have set your internet browser to allow us to use cookies to store information from your browser or device.

  • We may also collect your personal information from third parties including:

  • service providers;

  • credit reporting bodies;

  • marketing companies;

  • referrals who may have referred you to us; and

  • organisations with whom we have an agreement to share information for marketing purposes.




By providing personal information to us, you consent to us collecting, using, disclosing and storing your personal information in accordance with this Policy. You may choose to deal with us anonymously where it is lawful or practical to do so, such as when you make a general enquiry about our products and/or services.




You can choose not to provide us with your personal information. However, this may mean that:


we will not be able to provide you with our products and/or services, or be limited in how we can do so;


  • we will not be able to interact with you;

  • we may be unable to process and open an account for you; and/or

  • we will not be able to properly investigate or resolve any complaint you submit.

  • By providing us with your personal information and data, you expressly consent and allow for us to provide, sell and commercialise your data to a third party for which we will obtain a benefit – including third party marketing and affiliate companies.




HOW PLEDGEME LTD USES A CUSTOMER’S INFORMATION


We are continually striving to improve PledgeMe Ltd. Being able to identify how people are using our services plays a big part in helping us to make our software better and improve user experiences. We may use information about a customer for purposes such as:


·        Enabling a customer to access and use our Services


·        Verify a customer’s identity


·        Displaying historical sale information


·        Measuring, customising and improving the Services and developing new products


·        Sending to a customer service, support and administrative messages, reminders, technical notices, updates, security alerts and information requested by a customer


·        Investigating and preventing fraudulent transactions, unauthorised access to Services, and other illegal activities


·        Sending a customer information about us, our Services, or general promotions for business partner campaigns and services. A customer can unsubscribe or opt-out from receiving these communications at any time by clicking the “Unsubscribe” link in any email we send a customer


 


Where we need a customer’s personal information for any other purposes, it will be obvious from the circumstances as to the purposes for which we require that personal information from a customer.


SHARING & DISCLOSURE OF A CUSTOMER’S INFORMATION


When a customer uses the Services, we may share a customer’s information only as described below:


PledgeMe Ltd blogs, forums and wikis


Our websites may offer publicly accessible community services such as blogs, Facebook, LinkedIn or Twitter. A customer should be aware that any information a customer provides in these areas may be read, collected, and used by others who access them. A customer’s posts may remain even after a customer cancels their account. To request removal of a customer’s personal information from a PledgeMe Ltd community service, please contact us using the information listed below. In some cases, we may not be able to remove a customer’s personal information, in which case we will let a customer know if we are unable to and why.


Service providers, business partners and others


We use and work with third party service providers and our trusted Business Partners to provide application development, hosting, website, infrastructure, maintenance, backup, payment processing, customer relationship management, marketing, accounting, human resources, business intelligence and analytics, data enrichment, customer support and other services for us. These service providers may have access to or process a customer’s information for the purpose of providing those services for us. Please note that a customer is providing a customer’s information to these third parties acting on behalf of PledgeMe Ltd. These third parties are located in countries which may be outside of a customer’s location.


We also share a customer’s contact information with select trusted Business Partners, such as our partners who integrate with PledgeMe Ltd services, to enable them to contact a customer about their services (as they relate to a customer’s PledgeMe Ltd Services).





Links to third party sites


Our Services may contain links to other sites. We have no control over, and take no responsibility for, the privacy practices or content on other sites. A customer is responsible for checking the Privacy and Data Protection Policy of any such sites so that a customer can be informed of how they handle personal information.


Social media widgets


Our Services may include social media features, such as the Facebook “Like” button and widgets, and the “Share” button or interactive mini-programs that run on our site. These features may collect a customer’s IP address, which page a customer is visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. A customer’s interactions with these features are governed by the Privacy and Data Protection Policy of the company providing the feature.


Compliance with laws and protection of rights


In certain situations, we may be required to use and disclose a customer’s information (including personal information) to a third party if we believe the disclosure is reasonably necessary:


·        To comply with any applicable law, legal process (for example, subpoenas and warrants) or governmental request


·        To enforce and administer our agreements, policies and terms of use


·        To protect the property, rights, and safety of PledgeMe Ltd, our Customers or the public from harm or illegal activities


·        For fraud prevention, risk assessment, investigation, customer support, product development or debugging purposes


·        To protect the rights, property or personal safety of PledgeMe Ltd, its users or members of the public


·        To establish or exercise our legal rights or defend ourselves against any third-party claims or allegations


 


Business transfers


If PledgeMe Ltd undertakes or is involved in any merger, acquisition, reorganisation, sale of assets or bankruptcy or insolvency event, then we may transfer or share some or all of our assets, including a customer’s personal information. In this event, we will notify a customer before a customer’s personal information is transferred and becomes subject to a different Privacy and Data Protection Policy.


Non-identifying or aggregated data


We may share aggregated or other non-personal information that does not directly identify a customer with third parties in order to improve our Services.


A customer’s Choices and Privacy Rights


Disclosure and destruction of personal information


You may contact us to correct or update your personal information by emailing us at [email protected] . We may need to obtain proof of your identity before implementing your request and may refuse to provide you with certain information where permitted or required by law.


We may disclose your personal information to the following third parties for the purposes described in this Policy, such as:


  • our employees, related entities and employees of those entities;

  • our business partners;

  • our professional advisers, dealers and agents;

  • third parties and contractors who provide services to us, including customer enquiries and support services, manufacturing services, shipping and freight services, debt-recovery functions, information technology service providers, marketing and advertising services;

  • payment systems operators;

  • our sponsors or promoters of any competition which we conduct;

  • any third parties authorised by you to receive information held by us; and

  • government, regulatory and law enforcement agencies as required, authorised or permitted by law.


Opting out of promotional communications


A customer may opt out of receiving promotional communications from PledgeMe Ltd by using the unsubscribe link within each email or contacting us via our contact from. Even after a customer opts out from receiving promotional messages from us, a customer will continue to receive transactional messages from us regarding Services (e.g., account verification, information of queries regarding a pledge they may have made, technical and security notices).


Age limits on use of the services


Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from persons under 18. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If a customer becomes aware that a child has provided us with personal information, please contact us at [email protected]


Data security and third-party information


We hold your personal information in electronic form in secure databases owned and operated by our third-party service providers. We manage the security of your personal information by using SSL encryption.


While we take reasonable steps to ensure your personal information is protected from loss, misuse, unauthorised access, modification or disclosure, security measures over the internet can never be guaranteed. This means that we cannot guarantee the security of your personal information. In the event of a breach, we will attend to the required reporting arrangements. We cannot accept responsibility for the misuse, loss or unauthorised access to your personal information where the security of information is not within our control.


Our Site may contain links to websites, other apps and social media platforms operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless stated otherwise, we are not responsible for the privacy practices of, or any content, on those linked websites, and have no control over or rights in them. The privacy policies that apply to third-party websites may differ substantially from this Policy, so we encourage you to read those privacy policies before using those websites.


If you are visiting the Site from outside New Zealand, please be aware that you are sending information (including personal information) to Australia where our servers are located. Such information may then be transferred within Australia or back out of Australia to other countries outside of your country of residence, depending on the type of information and how it is stored by us. These countries (including Australia) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage and use of your personal information will at all times continue to be governed by this Privacy Policy.


Information retention


Where we process a customer’s Customer Information, we retain personal information we collect from a customer where we have an ongoing legitimate business need to do so (in connection with the purposes set out above. For Information about how long any of our Customers retain a customer’s personal information, please contact that Customer.


When we have no ongoing legitimate business need to process a customer’s personal information, we will either delete or anonymise it or, if this is not possible (for example, because a customer’s personal information has been stored in backup archives), then we will securely store a customer’s personal information and isolate it from any further processing until deletion is possible.


Updates to our Privacy and Data Protection Policy


PledgeMe Ltd reserves the right to change this Privacy and Data Protection Policy from time to time, and if we do we will post any changes on this page. A customer’s continued use of the Services will be deemed acceptance of any updated policy.


If you have further questions


Thanks for reading! If a customer has any questions about this Privacy and Data Protection Policy or PledgeMe Ltd’s privacy practices, please contact us at  [email protected]


 


 


 

Warning statement about equity crowdfunding

Equity crowdfunding is risky.

Issuers using this facility include new or rapidly growing ventures. Investment in these types of business is very speculative and carries high risks.

You may lose your entire investment, and must be in a position to bear this risk without undue hardship.

New Zealand law normally requires people who offer financial products to give information to investors before they invest. This requires those offering financial products to have disclosed information that is important for investors to make an informed decision.

The usual rules do not apply to offers by issuers using this facility. As a result, you may not be given all the information usually required. You will also have fewer other legal protections for this investment.

Ask questions, read all information given carefully, and seek independent financial advice before committing yourself.