Company-X Privacy Policy

This Privacy Policy was updated on 25 November 2020.

Company-X Limited (referred to in this Privacy Policy as “Company-X”, “we”, “us” or “our”) is committed to protecting your Personal Information and ensuring compliance with the New Zealand Privacy Act 2020 (“Privacy Act”) (if you are in New Zealand) and the European Union’s General Data Protection Regulation (“GDPR”) (if you are in a Member State of the European Union).

Our Privacy Policy applies to anyone who visits our Website, buys and uses our Services or Products or interacts with us.


Your informed consent

Please read our Privacy Policy carefully. It contains important information about how we will collect, use, disclose, store, process and protect your Personal information and the purposes for which your Personal Information will be used and disclosed. Based on this information, you can then make an informed decision on whether you wish (and continue) to visit our Website, buy and use our Services or Products or interact with us.

You can withdraw your consent at any time for any reason after it is given by not visiting our Website, buying or using our Products and Services or interacting with us. This also applies if you no longer agree with our Privacy Policy or do not agree with the changes that we make to our Privacy Policy from time to time. If you withdraw your consent, we will stop collecting your Personal Information.

For the purpose of:

  1. The GDPR, the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
  2. The Privacy Act, your Personal Information will only be used for the purpose for which it was collected in accordance with this Privacy Policy. If that purpose no longer exists or your Personal Information is no longer needed for the purpose, then we will no longer use your Personal Information.

Data Controller

The “data controller” (for the purpose of the GDPR) and the “agency” (for the purpose of the Privacy Act) that will be collecting, using, disclosing, storing and processing your Personal Information is Company-X Limited (NZCN 4187918) based in New Zealand.

You can contact us at any time by emailing or calling + 64 7 825 8606.


1. Personal information we collect

1.1 Company-X may collect from you the following Personal Information:

(a) Name and contact data: Your first and last name, email address, postal address, phone number and other similar contact information;

(b) Your Sensitive Information;

(c) Credentials: passwords, password hints, and similar security information used for authentication and account access and any information necessary to complete of fulfil our interactions with you;

(d) Demographic Information: Information such as your age, gender, country and preferred language.

(e) Payment and billing information: Information to process payments and the security information associated with your payments.

(f) Subscription and licensing: Information about your subscriptions, licenses, and other entitlements.

(g) Interactions: Information about your use of Company-X Products or Services. In some cases, such as search queries, this is information you provide in order to make use of the Products or Services. In other cases, such as error reports, this is information we generate. Other examples of interactions information include:

(i) Device and usage: Data about your device and the product and features you use, including information about your hardware and software, how our Products and Services perform, as well as your settings. For example:

A. Payment and account history: Information about the items you purchase and activities associated with your account;

B. Browse history: Information about the webpages you visit;

C. Device, connectivity, and configuration: Information about your device, your device configuration, and nearby networks;

D. Error reports and performance: Information about the performance of the Products and any problems you experience, including error reports;

E. Troubleshooting and help: Information you provide when you contact Company-X for help, and other details that help us provide support;

F. Bot usage data. Interactions with third party bots;

(h) Interests and favourites: Information about your interests and favourites, such as the programming languages you prefer. In addition to those you explicitly provide, your interests and favourites can also be inferred or derived from other information we collect;

(i) Content consumption: Information about media content (e.g., TV, video, music, audio, text books, apps, and games) you access through our Products or Services;

(j) Searches and commands: Search queries and commands when you use Company-X Products or Services with search or related productivity functionality;

(k) Voice data: Your voice data, such as the search queries or commands you speak, which may include background sounds;

(l) Images: Images and related information;

(m) Contacts and relationships: Information about your contacts and relationships if you use a Product or Service to share information with others, manage contacts, communicate with others, or improve your productivity;

(n) Location information: Data about your device’s location, which can be either precise or imprecise;

(o) Content: Content of your files and communications you input, upload, receive, create, and control through your use of our Products or Services.

(p) Feedback and ratings: Information you provide to us and the content of messages you send to us, such as feedback, survey data, and product reviews you write;

(q) Your company and work-related information including job title and work location; and

(r) Any information you choose to give us.

1.2 When you disclose your Personal Information to us it must be accurate, complete, up-to-date and not misleading. If you give us Personal Information about someone else, then you must be authorised to do so and you must tell that person about this Privacy Policy.


2. How we collect your personal information

2.1 We collect your Personal information only when needed and for lawful purposes connected with our legitimate business functions, activities, and the operation of our business. You authorise the collection of your Personal Information by us when you:

(a) Buy and/or use our Products or Services;

(b) Visit our Website on your computer, mobile, tablet, or any other electronic device through the use of cookies and other web trackers;

(c) Communicate with us; or

(d) Enter into any of our offers, promotions or events.

2.2 You provide some of this Personal Information directly, however we also obtain information from you indirectly and automatically by collecting information about your interactions, use, and experiences with our Services and Products. The Personal Information we collect depends on the context of your interactions with Company-X and the choices you make, including your privacy settings and the Products and Services you use.

2.3 We may also collect your Personal Information from publicly available sources or from Third Parties from time to time. Any information that we collect from a third party will only be for one or more of the Purposes set out in our Privacy Policy.


3. How we will use and disclose your personal information

3.1 You authorise Company-X to use and disclose your Personal Information for the following Purposes:

(a) to provide you with our Services and Products, including to:

(i) communicate with you, such as sending you promotional emails about new services, special offers, promotions or information about our Services and Products;

(ii) update, secure, and troubleshoot our Products and Services as well as providing support.

(iii) share information, when it is required to provide the Service or carry out the transactions you request;

(iv) improve and develop our Services and Products;

(v) personalise our Products and Services and make recommendations.

(vi) respond to your queries regarding the Website, our Services or Products;

(vii) verify your identity when you contact us;

(viii) provide you with a good user experience when you visit our Website or use our Services or Products;

(ix) to bill you and to collect money that you owe us, including authorising and processing credit card transactions or undertaking credit checks (if necessary);

(x) develop new Services, Products, features and/or Content; and

(xi) keep you updated on things that are happening at Company-X;

(b) to run and maintain our Website, Services and Products, such as ensuring our Website and network system are secure;

(c) for our internal record keeping purposes;

(d) tracking and monitoring adverse events for health and safety purposes;

(e) to allow for the operation of Company-X’s legitimate business activities and functions which includes analysing our performance, developing our workforce and doing research;

(f) the sale of all or substantially all of Company-X’s business or assets;

(g) to comply with Company-X’s legal obligations; and

(h) for any other purposes you authorise.

3.2 From time to time, Company-X may disclose your Personal Information to third party service providers, in both New Zealand and overseas, whom we engage to assist Company-X in its business functions and activities (for example providing customer services, sending marketing communications, and providing maintenance services for our Website, Products and Services). We will require our third-party service providers to comply with the terms of our Privacy Policy.

3.3 In some cases, we may remove personal identifiers from your Personal Information and maintain it in an aggregate form. We may combine this information with other information that we hold to produce anonymous, aggregated statistical information (e.g. number of visitors, originating domain name of the internet service provider), which is helpful to us in improving our Products and Services. Once Your Personal Information is anonymised, it may no longer be capable of identifying, or being re-linked, to you.


4. Cookies

4.1 Cookies are small text files placed on your computer, mobile, tablet, or any other electronic device to store data that can be recalled by a web server in the domain that placed the cookie. This data often consists of a string of numbers and letters that uniquely identifies your computer, but it can contain other information as well. Some cookies are placed by third parties acting on our behalf. We may use cookies and similar technologies to store and honour your preferences and settings, enable you to sign-in, provide interest-based advertising, analyse how our Products perform, and fulfil other legitimate purposes described in clause 2.

4.2 Company-X may use Cookies and similar technologies for several purposes, depending on the context, Product or Service including:

(a) to help us understand your preferences based on previous or current site activity, which enables us to tailor our Product and Service offerings to you;

(b) to help us to understand and improve how our Products and Services perform;

(c) to help us compile aggregate data about site traffic and site interaction so that we can offer you a better user experience;

(d) to authenticate you when you use our Products or Services;

(e) to process information that helps us secure our products, as well as detect fraud and abuse.

4.3 To enable some of the features and functionality of our Website, Products and Services, you will need to permit Company-X to place cookies on your device. If you choose not to, then those features and functionality will not be available to you. You can remove or block cookies by using the settings in your browser but it may affect your ability to use our Website, Products or Services.


5. Processing personal information on behalf of customers

Where you authorise Company-X to process Personal Information on your behalf or authorise Company-X to subcontract the processing of personal data to a third party, you confirm that you have obtained the informed consent of your end-user (from whom Personal Information will be collected) to the data processing. You also agree to implement a privacy policy on the same or similar terms as this Privacy Policy and notify your end-user of your privacy policy.


6. Third party links

Occasionally, at our discretion, we may include or offer third party products or services on our Website, or through our Products or Services. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Website, Products and Services and welcome any feedback about these third-party sites.


7. How long Company-X holds your personal information

Company-X will hold your Personal Information for as long as your Personal Information is required for the Purposes and for as long as is necessary to comply with our legal obligations, including monitoring the safety of our Products and Services.


8. How Company-X stores and protects your personal information

Company-X will use reasonable care to protect your Personal Information from unauthorised access, use, modification, disclosure, and loss. Company-X will take reasonable steps to ensure that our Third Parties whom we disclose your Personal Information to also take reasonable steps to protect your Personal Information in accordance with this Privacy Policy and the law.


9. We may transfer your personal information to other countries

9.1 In order to provide you with our Products and Services, we may need to disclose and transfer your Personal Information to third parties located outside New Zealand. Company-X will ensure that those third parties provide the same level of protection as required under our Privacy Policy and the Privacy Act.

9.2 If you are in a Member State of the European Union, your Personal Information may be transferred to or stored in a geographic region that imposes different privacy obligations than the country you are currently in. Company-X will only transfer your Personal Information to a “secure third country”, such as New Zealand, or to a third country or international organisation where appropriate safeguards are provided in accordance with the GDPR.


10. Request access to your personal information

You have the right to request access to Personal Information that Company-X holds about you. If Company-X does not give you access to the Personal Information that you have requested, then Company-X will let you know the legal reasons for not disclosing your Personal Information. If you are not happy with the legal reasons provided, then you have the right to complain to the New Zealand Privacy Commissioner:


11. Request correction of your personal information:

You have the right to request correction of the Personal Information that Company-X holds about you. Company-X will correct your Personal Information if it is necessary to ensure that your Personal Information is accurate, up to date, complete and not misleading. If Company-X decides that it is unnecessary to correct your Personal Information, Company-X will let you know the legal reasons for its decision. If you are not happy with those reasons, then you have the right to complain to the New Zealand Privacy Commissioner:


12. Minors

Company-X does not knowingly collect Personal Information from or about children (as defined by local laws) and does not target its Website, Products and/or Services towards children.


13. Privacy complaints

If you think that your privacy rights have been breached, You can make a written complaint to Company-X ’s Privacy Officer by email at, or otherwise contact the NZ Privacy Commissioner at


14. GDPR

14.1 If you are in a Member State of the European Union, you have the following rights with respect to your Personal Information:

(a) Lodging complaints: You have the right to lodge a complaint with a ‘supervisory authority’ established by a Member State under Article 51 of the GDPR.

(b) Right of rectification: You have the right to obtain from Company-X without undue delay the rectification of inaccurate Personal Information. We may seek to verify the accuracy of the Personal Information before correcting it.

(c) Right to restrict processing: You have the right to limit the ways in which we use your Personal Information, in particular where:

(i) you contest the accuracy of your Personal Information;

(ii) the processing is unlawful and you oppose the erasure of your Personal Information;

(iii) we no longer need your Personal Information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or

(iv) you have objected to the processing of your Personal Information and pending the verification of whether the legitimate grounds of Company-X override your own by a supervisory authority.

(d) Right of access and portability: You have the right to request certain copies of your Personal Information held by us. You may also be entitled to request copies of Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider nominated by you (where technically feasible).

(e) Right to be forgotten: You have the right to obtain from Company-X the erasure of your Personal Information without undue delay where one of the grounds set out in Article 17(1) of the GDPR apply. Please note that:

(i) we may retain some of your Personal Information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety;

(ii) we may retain and use your Personal Information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting, auditing and regulatory compliance obligations; and

(iii) because we maintain our Website and Products to protect from accidental or malicious loss and destruction, residual copies of your Personal Information may not be able to be removed from our backup systems.

15. Privacy policy changes

15.1 We may from time to time change our Privacy Policy. These changes may reflect, among other things, changes in applicable laws or regulations, changes to our data collection practices, and/or changes to our business, Services or Products. We will post any updated policies on our Website. The updated Privacy Policy will take effect 14 days after the date it is posted.

15.2 If you continue to use our Products and Services, visit our Website or interact with us after the updated Privacy Policy comes into effect, then you consent to the updated Privacy Policy. We encourage you to review our Privacy Policy periodically for any changes.

15.3 If you don’t agree with the changes to the Privacy Policy, then you should not give your consent and cease using our Products and Services or not visit our Website.


16. Definitions

“Content” means all content delivered via the Website, Products and Services including all text, software, hardware, scripts, graphics, photos, sounds, music, videos, audio-visual works or combinations of works, live streaming, interactive features and other materials;

“including” means “including without limitation”;

“Personal Information” means any information that can be used to directly or indirectly to identify an individual, and includes Sensitive Information, and references to “your Personal Information” also includes any Personal Information that you provide to Company-X about someone else;

“Products” means any product supplied by Company-X;

“Purposes” means the purposes for which your Personal Information is used and disclosed as specified in this Company-X Limited Privacy Policy;

“Sensitive Information” means information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health or sexual orientation;

“Services” means any services, software, Content, features, functionalities and any other services provided to you by Company-X;

“Website” means the website operated by Company-X from time to time.