Privacy Policy

Privacy Policy

SortMe Limited - Last updated: 29 May 2024

Thank you for using our Sort Me application! We have loved developing it and hope that you are
enjoying, and benefitting from, using it. Like with all software applications and websites, it is
necessary for us to collect, use and store a range of your personal information so that we can provide
certain services to you. In this privacy policy (Policy) we set out how we collect, use, retain and store
your personal information.

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What personal information do we collect from you?

In order to allow us to provide our Services to you, we may collect the following information from
and about you:v

• your name;
• date of birth;
• email address;
• physical address;
• phone number;
• country of residence;
• passport and drivers license details;
• biometrics;
• details from accounts you connect to our application using an Integrator including:
  • bank account details, such as your bank account particulars, banking transaction
    history and credit history;
  • unique identifiers (including, as applicable, Inland Revenue Department number,
    National Insurance number, Tax File Number, Social Insurance number and Social
    Security number); and
  • insurance policy details (including insurance policy beneficiaries, your health,
    financial and insurance history and information required for processing claims)
  • any other information you provide when you communicate with us.

If you choose not to provide us with your Personal Information, we may not be able to provide
certain products or services to you.

How do we collect your personal information?

We use different methods to collect Personal Information. We will generally collect Personal
Information directly from you. If you are providing Personal Information about someone other than
yourself, you warrant that you have the right to do so, and that you have and will continue to notify
that person of their rights to access their Personal Information.

If you provide someone else with access to your account (Invitee), the Invitee will have full access to
your account including the ability to amend your account information, including your Personal
Information. You indemnify us from all liability in connection to incorrect personal information we
have collected or used as a result of an Invitee’s access to your account.

We may also collect Personal Information from:

• Integrators and SortMe Partners;
• other third parties that you have authorised or as otherwise permitted by law; and
• publicly available websites and sources.

When you access our Services, we may collect information from your device(s). If the information we
collect is personal information, we will collect, handle and use the personal information in accordance
with this Policy.

How we use Personal Information

The primary purpose for which we will use your personal information is to allow you to access, use
and get the benefit of the SortMe application. We also use your personal information for a range of
general business purposes. We provide more detail on these uses as follows:

SortMe Application: In providing you access to the SortMe application, we may use your personal
information:

• to perform services and supply products requested by you;
• to provide you with assistance in relation to our services and products;
• to enable multi-factor authentication;
• to interact and communicate with you, and to manage our relationship with you; and
• to send, receive, process, administer, and collect payments from you on behalf of merchants
  and registered users of our Services.

Business Purposes: We will also use your personal information for the following purposes:

• marketing and communications through emails and phone calls;
• to improve our Services
• for internal research and development;
• to comply with New Zealand and overseas legal obligations relating to anti-money
  laundering reporting and requirements; and
• to carry out activities that relate to legal, governmental, or regulatory requirements on us,
  or in connection with legal proceedings and crime prevention, detection, and prosecution.

We may also anonymise you personal information which we may then aggregate with other anonymised
personal information. We may use this anoyomsied and aggregated information for inclusion in reports,
improve our services data and provide insights in relation to our Services.

Who we may disclose your Personal Information to

We may provide your Personal Information to:

• Integrators and SortMe Partners and other third party service providers (such as our
  infrastructure providers);
• our employees, contractors and agents;
• credit reference entities and debt recovery entities.

We may disclose Personal Information if we consider doing so is appropriate for legal and regulatory
compliance, to facilitate court proceedings, to enforce these terms or any contract we have with you,
to protect our company, our customers, or others.

We may release personal information to third parties if instructed by you, and in other ways
permitted by law.

We may from time to time transfer your personal information to third parties situated out of New
Zealand. Where we do this, we will only do so in accordance with our obligations under the Privacy
Act and only to countries where there are comparable or more onerous privacy and data protection
regimes in force.

Access, correction and retention of your Personal Information

We will use our best efforts to keep your personal information complete, accurate and up to date and
you will inform us of any if any of personal information changes to ensure that the details we hold
about you are up to date and correct. You can update your personal details at any time through your
customer account or by contacting us at:

Email: hello@sortme.com

Attention: SortMe Privacy Officer

You are entitled to access the personal information we hold about you, and to request that we
amend it if it is incorrect. If we are not willing to correct errors that you have identified in your
personal information, you may request that we attach a statement to your personal information
noting the correction sought.

Security and Storage of your Personal Information

We use third party cloud service providers, such as Amazon Web Services and Microsoft Azure to
store data on our behalf. Those providers are generally based in Australia, Europe and the USA. As
such, we will take reasonable steps to ensure that these third parties are aware of our obligations
under this Policy and any agreement we have with them prevent them using your Personal
Information in a manner inconsistent with our obligations under the Privacy Act.

We take reasonable steps to protect personal information from misuse, loss and unauthorised access,
modification or disclosure. We take reasonable steps to protect and secure your personal
information, but we do not make any warranties in relation to the security of any information you
disclose or transmit to us, and we are not responsible for the theft, destruction, or inadvertent
disclosure of your personal information where our security measures have been breached. Any
sharing of personal information is conducted at your own risk.

We will only retain your personal information for as long as it is necessary to achieve the purposes of
this Policy, including providing you with access to our Services, or as otherwise required by law.
You can choose to delete your account at any time by using the “delete my account” feature in the
SortMe app or by emailing us at hello@sortme.com and requesting your account to be closed and
your information deleted. We will keep your personal information for 14 days following your request
to delete should you decide to reinstate your account. After that we will delete your information,
including personal information unless and only to the extent we are legally required to keep it.

Cookies

Our website may use cookies. Cookies are small files that are placed on your computer, mobile device
or any other device by a website, containing the details of your browsing history on that website
among its many uses.

We use Cookies and other third party web tracking and analytic tools to collect and track information
about you when you are using our Service for the purposes of:

• providing more customised content and material to you through our Services;
• improving our Services and your customer experience; and
• conducting business and marketing analysis.

If you do not wish to allow Cookies, you may change your browser settings to disable Cookies.
However, if you disable Cookies some parts of our Services may not function properly.

Amendments to this Policy

We may amend and update this Policy from time to time. We will notify you of any changes to this
Policy if you have an account with us. By providing your personal information to us or continuing to
use our Services after receiving notice of any change, you will be deemed to have accepted the
updates to this Policy. If you do not agree to any change:

• you must immediately notify us and cease accessing our Services; and
• we may suspend or terminate your access to our Services.

Third party websites and materials

Our Services may provide links to or references to third party materials including websites and
content. This Policy does not apply to any third party website or materials. We accept no
responsibility or liability for third party content and privacy materials.

Definitions

In this Policy:

• Integrator means third party integrators between us and financial service providers
  including, Akahu and Basiq;
• SortMe Partners means financial advisors and service providers that have been approved
  by us;
• ‘we’, ‘us’ and “our” means SortMe Limited (New Zealand company number 8392081);
• personal information has the meaning given to it in the Privacy Act (information about an
  identifiable individual);
• Privacy Act means New Zealand Privacy Act 2020;
• “you” or “your” means the user of the SortMe Application or our website; and
• Services means the services and products we provide through our website
  (www.sortme.com), the Sortme application and social media channels.