www.Ilaria.co –PRIVACY POLICY
Ilaria NZBN we understands that protecting your personalinformation is important. This Privacy Policy sets out our commitment toprotecting the privacy of personal information provided to us, or collected byus, when interacting with you.
This Privacy Policy takesinto account the requirements of the Privacy Act 2020. In addition tothe New Zealand laws, individuals located in the European Union or EuropeanEconomic Area (EU) may also have rights under the General DataProtection Regulation 2016/679 and individuals located in the UnitedKingdom (UK) may have rights under the General Data Protection Regulation(EU) 2016/679) (UK GDPR) and the Data Protection Act 2018 (DPA 2018) (together,the GDPR). Appendix 1 outlines the details of the additional rights ofindividuals located in the EU and UK as well as information on how we processthe personal information of individuals located in the EU and UK.
Theinformation we collect
Personalinformation: is information or an opinion,whether true or not and whether recorded in a material form or not, about anindividual who is identified or reasonably identifiable.
The types of personal information we may collect about youinclude:
· Identity Data includingyour name, age, profession, marital status, pronouns, and gender.
· Contact Data including yourtelephone number, address and email.
· Financial Data includingbank account and payment card details (through our third party paymentprocessor, who stores such information and we do not have access to thatinformation).
· Background Verification Data including contactdetails, company number and any other background information required to becollected by law.
· Transaction Data includingdetails about payments to you from us and from you to us and other details ofproducts and services you have purchased from us or we have purchased from you.
· Technical and Usage Data when youaccess any of our websites or platforms, details about your internet protocol(IP) address, login data, browser session and geo-location data, statistics onpage views and sessions, device and network information, acquisition sources,search queries and/or browsing behaviour, access and use of our website(including through the use of Internet cookies), and communications with ourwebsite.
· Profile Data includingyour profile picture, purchases or orders you have made with us, content you post,send receive and share through our platform, information you have shared withour social media platforms, and support requests you have made.
· Interaction Data includinginformation you provide to us when you participate in any interactive features,including surveys, contests, promotions, activities or events.
· Marketing and Communications Data includingyour preferences in receiving marketing from us and our third parties and yourcommunication preferences.
· Professional data includingwhere you are a worker of ours or applying for a role with us, yourprofessional history such as your previous positions and professionalexperience.
Howwe collect personal information
We collect personal information in a variety of ways, including:
· when you interact directly with us,including face-to-face, over the phone, over email, or online;
· when you complete a form, such asregistering for any events or newsletters, or responding to surveys;
· when you apply for a job with us;
· from third parties, such as details ofyour use of any website we operate (from our analytics and cookie providers andmarketing providers. See the “Cookies” section below for more detail on the useof cookies); or
· from publicly available sources, such associal media or the New Zealand Companies Office.
Whywe collect, hold, use and disclose personal information
We have set out below, in a tableformat, a description of the purposes for which we plan to collect, hold, useand disclose your personal information.
Purpose of use / disclosure
Type of Personal Information
To enable you to access and use our software.
· Identity Data
· Contact Data
To do business with you, including to deliver our services to you, register your attendance at our events, assess your application.
· Identity Data
· Contact Data
To contact and communicate with you about our business, including in response to any support requests you lodge with us or other enquiries you make with us.
· Identity Data
· Contact Data
· Profile Data
To contact and communicate with you about any enquiries you make with us via any website we operate.
· Identity Data
· Contact Data
For internal record keeping, administrative, invoicing and billing purposes.
· Identity Data
· Contact Data
· Financial Data
· Transaction Data
For analytics (including profiling on our website), market research and business development, including to operate and improve our business, associated applications and associated social media platforms.
· Profile Data
· Technical and Usage Data
For advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you.
· Identity Data
· Contact Data
· Technical and Usage Data
· Profile Data
· Marketing and Communications Data
To run promotions, competitions and/or offer additional benefits to you.
· Identity Data
· Contact Data
· Profile Data
· Interaction Data
· Marketing and Communications Data
If you have applied for employment with us, to consider your employment application.
· Identity Data
· Contact Data
· Professional Data
To comply with our legal obligations or if otherwise required or authorised by law.
· Any relevant Personal Information
Ourdisclosures of personal information to third parties
Overseasdisclosure
Personal Information
While we store personal information in New Zealand, where wedisclose your personal information to the third parties listed above, thesethird parties may store, transfer or access personal information outside of NewZealand, including but not limited to, Australia. We will only disclose yourpersonal information overseas in accordance with the New Zealand PrivacyPrinciples.
We may store personal information overseas, including in, Australiawhere we disclose your personal information to the third parties listed above,these third parties may also store, transfer or access personal informationoutside of New Zealand, including but not limited to, Australia. We will only disclose yourpersonal information overseas in accordance with the New Zealand Privacy Principles.
Yourrights and controlling your personal information
Your choice: Please read this Privacy Policycarefully. If you provide personal information to us, you understand we willcollect, hold, use and disclose your personal information in accordance withthis Privacy Policy. You do not have to provide personal information to us,however, if you do not, it may affect our ability to do business with you.
Information fromthird parties: If we receive personal informationabout you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providingpersonal information about somebody else, you represent and warrant that youhave such person’s consent to provide the personal information to us.
Restrict and unsubscribe:To object to processing for directmarketing/unsubscribe from our email database or opt-out of communications(including marketing communications), please contact us using the details belowor opt-out using the opt-out facilities provided in the communication.
Access: You may request access to the personal information that we holdabout you. An administrative fee may be payable for the provision of suchinformation. Please note, in some situations, we may be legally permitted towithhold access to your personal information. If we cannot provide access toyour information, we will advise you as soon as reasonably possible and provideyou with the reasons for our refusal and any mechanism available to complainabout the refusal. If we can provide access to your information in another formthat still meets your needs, then we will take reasonable steps to give yousuch access.
Correction: If you believe that any information we hold about you isinaccurate, out of date, incomplete, irrelevant or misleading, please contactus using the details below. We will take reasonable steps to promptly correctany information found to be inaccurate, out of date, incomplete, irrelevant ormisleading. Please note, in some situations, we may be legally permitted to notcorrect your personal information. If we cannot correct your information, wewill advise you as soon as reasonably possible and provide you with the reasonsfor our refusal and any mechanism available to complain about the refusal.
Complaints: If you wish to make a complaint, please contact us using thedetails below and provide us with full details of the complaint. We willpromptly investigate your complaint and respond to you, in writing, setting outthe outcome of our investigation and the steps we will take in response to yourcomplaint. If you are not satisfied with our response, you may contact theOffice of the New Zealand Privacy Commissioner.
Storageand security
We are committed to ensuring that the personal information wecollect is secure. In order to prevent unauthorised access or disclosure, wehave put in place suitable physical, electronic and managerial procedures, tosafeguard and secure personal information and protect it from misuse,interference, loss and unauthorised access, modification and disclosure.
While we are committed to security, we cannot guarantee thesecurity of any information that is transmitted to or by us over the Internet.The transmission and exchange of information is carried out at your own risk.
Cookies
We may use cookies on our website from time to time. Cookies aretext files placed in your computer's browser to store your preferences.Cookies, by themselves, do not tell us your email address or other personallyidentifiable information. However, they do recognise you when you return to ouronline website and allow third parties to cause our advertisements to appear onyour social media and online media feeds as part of our retargeting campaigns.If and when you choose to provide our online website with personal information,this information may be linked to the data stored in the cookie.
You can block cookies by activating the setting on your browserthat allows you to refuse the setting of all or some cookies. However, if youuse your browser settings to block all cookies (including essential cookies)you may not be able to access all or parts of our www.ilaria.co
Cookie - session_id
Purpose - Keeps you logged in during your visit
Cookie - language
Purpose - Remembers your language preference
Cookie - consent
Purpose - Remembers your cookie preferences
Cookie - _ga
Purpose - Tracks visits via Google Analytics
Linksto other websites
Our website may contain links to other party’s websites. We do nothave any control over those websites and we are not responsible for theprotection and privacy of any personal information which you provide whilstvisiting those websites. Those websites are not governed by this Privacy Policy.
Amendments
We may, at any time and at our discretion, vary this Privacy Policyby publishing the amended Privacy Policy on our website. We recommend you checkour website regularly to ensure you are aware of our current Privacy Policy.
Forany questions or notices, please contact us at:
Ilaria NZBN
Email: jure.brkan@ilaria.capital
Last updated: 6.8.2025
Under the GDPR individuals located in the EU and the UK have extrarights which apply to their personal information. Personal information underthe GDPR is often referred to as personal data and is defined as informationrelating to an identified or identifiable natural person (individual). ThisAppendix 1 sets out the additional rights we give to individuals located in theEU and UK, as well as information on how we process the personal information ofindividuals located in the EU and UK. Please read the Privacy Policy above andthis Appendix carefully and contact us at the details at the end of the PrivacyPolicy if you have any questions.
Whatpersonal information is relevant?
This Appendix applies to thepersonal information set out in the Privacy Policy above. While the PrivacyPolicy refers to ‘special categories of data’ (also known as SensitiveInformation under the GDPR), the client does not currently expect to collectsuch information. If sensitive data is collected in the future, it will be handledin accordance with applicable privacy laws.
Purposesand legal bases for processing
We collect and process personal information about you only wherewe have legal bases for doing so under applicable laws. We have set out below,in a table format, a description of all the ways we plan to use your personalinformation, and which of the legal bases we rely on to do so. We have alsoidentified what our legitimate interests are where appropriate. Note that wemay process your personal information for more than one lawful ground dependingon the specific purpose for which we are using your data. Please reach out tous if you need further details about the specific legal ground, we are relyingon to process your personal information where more than one ground has been setout in the table below.
Purpose of use / disclosure
Type of Data
Legal Basis for processing
To enable you to access and use our software.
· Identity Data
· Contact Data
· Performance of a contract with you
To do business with you, including to deliver our services to you, register your attendance at our events, assess your application.
· Identity Data
· Contact Data
· Performance of a contract with you
To contact and communicate with you about our business including in response to any support requests you lodge with us or other enquiries you make with us.
· Identity Data
· Contact Data
· Profile Data
· Performance of a contract with you
To contact and communicate with you about any enquiries you make with us via our website.
· Identity Data
· Contact Data
· Legitimate interests: to ensure we provide the best client experience we can offer by answering all of your questions.
For internal record keeping, administrative, invoicing and billing purposes.
· Identity Data
· Contact Data
· Financial Data
· Transaction Data
· Performance of a contract with you
· To comply with a legal obligation
· Legitimate interests: to recover debts due to us and ensure we can notify you about changes to our terms of business and any other administrative points.
For analytics including profiling on our website, market research and business development, including to operate and improve our business, associated applications and associated social media platforms.
· Profile Data
· Technical and Usage Data
· Legitimate interests: to keep our website updated and relevant, to develop our business, improve our business and to inform our marketing strategy
For advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you.
· Identity Data
· Contact Data
· Technical and Usage Data
· Profile Data
· Marketing and Communications Data
· Legitimate interests: to develop and grow our business
To run promotions, competitions and/or offer additional benefits to you.
· Identity Data
· Contact Data
· Profile Data
· Interaction Data
· Marketing and Communications Data
· Legitimate interests: to facilitate engagement with our business and grow our business
If you have applied for employment with us, to consider your employment application.
· Identity Data
· Contact Data
· Professional Data
· Legitimate interests: to consider your employment application
To comply with our legal obligations or if otherwise required or authorised by law.
· To comply with a legal obligation
If you have consented to our use of data about you for a specificpurpose, you have the right to change your mind at any time, but this will notaffect any processing that has already taken place. Where we are usingyour data because we or a third party have a legitimate interest to do so, youhave the right to object to that use though, in some cases, this may mean nolonger doing business with us. Further information about your rights isavailable below.
DataTransfers
The countries to which we send data for the purposes listed abovemay be less comprehensive that is what is offered in the country in which youinitially provided the information. Where we transfer your personal informationoutside of the country where you are based, we will perform those transfersusing appropriate safeguards in accordance with the requirements of applicabledata protection laws and we will protect the transferred personal informationin accordance with this Privacy Policy and Appendix 1. This includes:
· only transferringyour personal information to countries that have been deemed by applicable dataprotection laws to provide an adequate level of protection for personalinformation; or
· includingstandard contractual clauses in our agreements with third parties that areoverseas.
Data retention
We will only retain your personal information for as long asreasonably necessary to fulfil the purposes we collected it for, including forthe purposes of satisfying any legal, regulatory, tax, accounting or reportingrequirements. We may retain your personal information for a longer period inthe event of a complaint or if we reasonably believe there is a prospect oflitigation in respect to our relationship with you.
To determine the appropriate retention period for personalinformation, we consider the amount, nature and sensitivity of the personalinformation, the potential risk of harm from unauthorised use or disclosure ofyour personal information, the purposes for which we process your personalinformation and whether we can achieve those purposes through other means, andthe applicable legal, regulatory, tax, accounting or other requirements.
Extrarights for EU and UK individuals
You may request details of the personal information that we holdabout you and how we are process it (commonly known as a “data subjectrequest”). You may also have a right in accordance with applicable dataprotection law to have your personal information rectified or deleted, torestrict our processing of that information, to object to decisions being madebased on automated processing where the decision will produce a legal effect ora similarly significant effect on you, to stop unauthorised transfers of yourpersonal information to a third party and, in some circumstances, to have personalinformation relating to you transferred to you or another organisation.
If you are not happy with how we are processing your personalinformation, you have the right to make a complaint at any time to the relevantData Protection Authority based on where you live. We would, however,appreciate the chance to deal with your concerns before you approach the DataProtection Authority, so please contact us in the first instance using thedetails set out above in our Privacy Policy above.
Forany questions or notices, please contact us at:
Email: jure.brkan@ilaria.capital
