Govn365 Privacy Policy

1. INTRODUCTION
At Govn365, we take privacy very seriously. We’ve updated our privacy policy (“Policy”) to
ensure that we communicate with all Subscribers and authorised users of our Platform
(including the Services and Website) (“You”), in the clearest way possible. We encourage
You to read this Policy carefully. It will help You make informed decisions about sharing Your
Personal Information with us.
Govn365 provides an online business governance self-assessment and continuous
improvement service. It is intelligent governance software for business, is simple, secure and
gives business owners, CEO’s and their board real-time visibility of a business’ governance
maturity.

2. SCOPE
This Policy applies to all subscribers and authorised users of our platform / services and
otherwise any access to our Website, www.govn365.com.
Unless otherwise defined herein, all capitalised terms used in this Policy have the same
meaning as given to them in our Software as a Service Terms of Service. By accessing our
Website and/or using or accessing the Platform, You are deemed to have consented to the
terms of this Policy.

3. PRIVACY ACT 2020
Govn365 complies with the NZ Privacy Act 2020 (“Act”) when dealing with Personal
Information. This policy sets out how we will collect, use, disclose and protect your Personal
Information.
This Ppolicy does not limit or exclude any of your rights under the Act. If you wish to seek
more information on the Act, see www.privacy.org.nz.

4. PERSONAL INFORMATION
When You use the Platform, you may from time to time provide us with Subscriber Materials
and related data and information. Such information can include Personal Information.
Personal Information is information about an identifiable individual, and may include

information such as the individual’s name, email address, telephone number, age or
birthdate, occupation, details of the services you have purchased from us and any other
information relating to You.

5. COLLECTION OF PERSONAL INFORMATION
Govn365 may collect Ppersonal Iinformation about You when You:
● register to use the Platform/Service;
● use the Service;
● contact the Govn365 support team;
● visit our Website through a third party if they provide Your personal information to us
when using the Platform (see the section headed “Consent to Provide Personal
Information from Third Party” below).
You can always choose not to provide Your Personal Information to Govn365 (or to give
consent to a third party to provide your Personal Information to us), but it may mean that we
are unable to provide You with the Service.
Your information will be held by Govn365 Limited, 7 Godfrey Place, Kohimarama, Auckland
1071, New Zealand and otherwise held in accordance with this Policy.

6. CONSENT TO PROVIDE PERSONAL INFORMATION FROM THIRD PARTY
Through Your use of the Platform, Govn365 may also collect information from You about
someone else. If You provide Govn365 with Personal Information about someone else, You
must ensure that You are authorised to disclose that information to Govn365 and that,
without Govn365 taking any further steps required by applicable data protection or privacy
laws, Govn365 may collect, use and disclose such information for the purposes described in
this Policy.
This means that You must take reasonable steps to ensure the individual concerned is
aware of and/or consents to the various matters detailed in this Policy, including the fact that
their personal information is being collected, the purposes for which that information is being
collected, the intended recipients of that information, the individual's right to obtain access to
that information, Govn365’s identity, and how to contact Govn365.
Where requested to do so by Govn365, You must also assist Govn365 with any requests by
the individual to access or update the Personal Information You have collected from them
and entered into the Service.

7. USE OF PERSONAL INFORMATION

Govn365 collects Your Personal Information so that we can provide You with access to the
Platform (including the Service) and any related services that You may request. In doing so,
Govn365 may use the Personal Information it has collected from You for purposes related to
the Platform including to:
● verify Your identity;
● administer the Platform (including the Service);
● notify You of new or changed services offered in relation to the Platform (including
the Service);
● carry out marketing or training relating to the Platform (including the Service);
● assist with the resolution of technical support issues or other issues relating to the
Platform (including the Service);
● comply with laws and regulations in applicable jurisdictions, and
● communicate with You.
We may send you marketing communications and information about products and services
that we consider may be of interest to You. These communications may be sent in various
forms, including but not limited to, mail, SMS or email, in accordance with and subject to
applicable marketing laws in Your jurisdiction.
If at any stage You no longer wish to receive these notifications You may opt-out of receiving
marketing communications from us by using the opt-out facilities provided (e.g. an
unsubscribe link in a promotional email) or contacting us at support@govn365.com.
We do not provide Your Personal Information to other organisations for the purposes of
direct marketing unless expressly authorised by You.
By accessing and/or using the Platform, You consent to Your Personal Information being
collected, held and used in this way and for any other use that You expressly authorise.
Govn365 will only use Your Personal Information for the purposes described in this Policy or
with Your express permission.
It is Your responsibility to keep Your password to the Platform safe. You should notify us as
soon as possible if You become aware of any misuse of Your password, and immediately
change your password within the Platform or via the “Forgotten Password” process.
If You receive communications from us that You believe have been sent to You other than in
accordance with this Policy, or in breach of any applicable law, please contact us at
support@govn365.com.

8. DATA HOSTING PROVIDER

Govn365 uses Microsoft Azure as its data hosting provider and hosts the Platform on
servers located in Australia. If You are a non-Australian resident, this means that Your
Personal Information will be transferred to Australia. You can review Microsoft Azure’s
Privacy Policy on their website. By entering Personal Information into the Platform, You
consent to that Personal Information being hosted on servers located in Australia. While
Your Personal Information will be stored on servers located in Australia, it will remain within
Govn365’s effective control at all times. The data hosting provider’s role is limited to
providing a hosting and storage service to Govn365, and we’ve taken steps to ensure that
our data hosting provider does not have access to Your Personal Information. They do not
control and are not permitted to access or use Your Personal Information, except for the
limited purpose of storing the information. This means that, for the purposes of Australian
and New Zealand privacy legislation and Australian and New Zealand users, Govn365 does
not currently “disclose” Personal Information to third parties located overseas. Where we
transfer any Personal Information outside of New Zealand for the purpose of data storage
(including to Microsoft Azure in Australia), we will comply with our obligations in connection
with sharing/transfer Personal Information outside of New Zealand pursuant to the Privacy
Act 2020 and otherwise in accordance with clause 9 of this Policy.
If You do not want Your personal information to be transferred to a server located in
Australia, You should not provide Govn365 with Your personal information or use the
Service.

9. DISCLOSURE OF PERSONAL INFORMATION
There may be times when we disclose your Personal Information to third parties. If we do
this, we will only disclose such information to:
 those who provide to us products or services that support the services that we provide,
such as our suppliers and third parties that assist us with our marketing and promotion;
 credit reference agencies, who may share your information with other organisations;
 debt collection agencies or companies, in order to collect any money owing by you to us;
 anyone we transfer our business to in respect of which you are a customer or a potential
customer;
 anyone who assists us in protecting the operation of our networks and systems, including
the use of monitoring and detection in order to identify potential threats, such as hacking
and virus dissemination;
 persons to whom we may be required to pass your information by reason of legal,
governmental or regulatory authority including law enforcement agencies;

 aggregated user statistics and other information that does not personally identify you, to
third parties such as our advertisers, customers, potential customers and partners;
 any person or organisation as authorised by the Privacy Act 2020.
By using the Website and providing your Personal Information on the Website, you consent
and agree to us passing on, transferring or sharing your Personal Information to third parties
listed above (as applicable).
From time to time, Govn365 may transfer or share your Personal Information with third
parties based outside of New Zealand for purposes such as data storage (“Overseas
Sharing of Information”). Prior to any Overseas Sharing of Information, we will ensure that
the third party that is to receive such information is either:
 subject to the New Zealand Privacy Act 2020 because that third party also does
business in New Zealand; and/or
 is subject to privacy laws that provide comparable safeguards to the Privacy Act
2020; and/or
 is under contractual obligations to protect such information in a way that is
comparable to the safeguards required under the Privacy Act 2020; and/or
 is covered by a binding scheme or is subject to the privacy laws of a country
prescribed by the New Zealand Government.
Govn365 will only disclose the Personal Information You have provided to us to entities
outside the Govn365 group of companies if it is necessary and appropriate to facilitate the
purpose for which Your Personal Information was collected pursuant to this Policy, including
the provision of the Platform (including the Service).
Govn365 will not otherwise disclose Your Personal Information to a third party unless You
have provided Your express consent. However, You should be aware that Govn365 may be
required to disclose Your Personal Information without Your consent in order to comply with
any court orders, subpoenas, or other legal process or investigation including by tax
authorities. Where possible and appropriate, we will notify You if we are required by law to
disclose Your Personal Information.
You can exercise your right to ‘opt out’ of the consent to Overseas Sharing of Information in
accordance with the above by contacting us at support@govn365.com. However, please
note that if you decide to opt out in accordance with the above, we may not be able to
provide you with our products or services on the Website.

10. TRANSFER OF INFORMATION TO THIRD PARTY APPLICATIONS

The Platform may allow You within the relevant subscription to the Platform to transfer
Subscriber Materials (and other related information and data), including Your Personal
Information, electronically to and from third-party applications.
We advise the service providers of these third-party applications to protect Your information
against unauthorised use or disclosure.
Some of these service providers may be located overseas. We take reasonable steps to
ensure that the overseas recipients of Your Personal Information do not breach the privacy
obligations relating to Your Personal Information and will ensure that we meet our
obligations in respect of sharing such information overseas in accordance with clause 9 of
this Policy.
We do not provide Your Personal Information to other organisations for the purposes of
direct marketing unless expressly authorised by You.
Subject to our obligations under the Act, you are responsible for checking the privacy policy
of any such applications so that You can be informed of how they will handle Personal
Information.

11. PROTECTING YOUR PERSONAL INFORMATION
Govn365 is committed to protecting the security of Your Personal Information and we take
all reasonable precautions to protect it from unauthorised access, modification or disclosure.
Your Personal Information is stored on secure servers that have SSL Certificates issued by
leading certificate authorities, and all Subscriber Materials transferred between You, and the
Platform is encrypted.
 We will take reasonable steps to ensure that the Personal Information we collect, use or disclose
is accurate, complete, up-to-date and stored in a secure environment protected from
unauthorised access, modification or disclosure.
We will advise You at the first reasonable opportunity upon discovering or being advised of a
security breach where Your Personal Information is lost, stolen, accessed, used, disclosed,
copied, modified, or disposed of by any unauthorised persons or in any unauthorised
manner.

12. ACCESSING AND CORRECTING PERSONAL INFORMATION
It is Your responsibility to ensure that the Personal Information You provide to us is accurate,
complete and up-to-date. You may request access to the information we hold about You, or
request that we update or correct any Personal Information we hold about You, by setting
out Your request in writing and sending it to us at support@govn365.com.
Govn365 will process Your request as soon as reasonably practicable, provided we are not
otherwise prevented from doing so on legal grounds. If we are unable to meet Your request,

we will let you know why. For example, it may be necessary for us to deny Your request if it
would have an unreasonable impact on the privacy or affairs of other individuals, or if it is not
reasonable and practicable for us to process Your request in the manner You have
requested. In some circumstances, it may be necessary for us to seek to arrange access to
Your Personal Information through a mutually agreed intermediary (for example, the
Subscriber).

13. RETENTION OF PERSONAL INFORMATION
We will only keep Your Personal Information for as long as we require it for the purposes of
providing You with the Service. However, we may also be required to keep some of Your
Personal Information for specified periods of time, for example under certain laws relating to
corporations, money laundering, and financial reporting.

14. USE OF NON-PERSONALLY IDENTIFIABLE DATA
By using the Service, You agree that Govn365 can access, aggregate and use non-
personally identifiable data Govn365 has collected from You. This data will in no way identify
You or any other individual.
Govn365 may use this aggregated non-personally identifiable data to:
● assist us to understand better how our customers are using the Platform;
● provide our customers with further information regarding the uses and benefits of the
Platform;
● enhance small business productivity, including by creating useful business insights
from that aggregated data and allowing You to benchmark Your business’
performance against that aggregated data, and
● otherwise to improve the Platform (including the Service).
An example of non-personally identifiable data is cookies. In providing the Service, Govn365
utilises cookies. A cookie is a small text file that is stored on Your computer for record-
keeping purposes. A cookie does not identify You personally or contain any other
information about You, but it does identify Your computer.
We and some of our affiliates and third-party service providers may use a combination of
“persistent cookies” (cookies that remain on Your hard drive for an extended period of time)
and “session ID cookies” (cookies that expire when You close Your browser) on the Website
to, for example, track overall site usage, and track and report on Your use and interaction
with the Service.
You can set your browser to notify You when You receive a cookie so that You will have an
opportunity to either accept or reject it in each instance. However, You should note that

refusing cookies may have a negative impact on the functionality and usability of the
Platform and Website.

15. EMAIL CORRESPONDENCE
Govn365 sends billing information, product information, Platform and Service updates and
Platform and Service notifications to You via email. Our emails will contain clear and obvious
instructions describing how You can choose to be removed from any mailing list not
essential to the Platform (including the Service). Govn365 will remove You at Your request.

16. COMPLAINTS
If You wish to complain about how we have handled Your Personal Information, or have any
questions or concerns about this Policy, please contact our Privacy Officer with full details
and any supporting documentation:
· by e-mail at support@govn365.com, or
· by letter to The Privacy Officer, Govn365 Limited, 7 Godfrey place, Kohimarama,
Auckland 1071, New Zealand.
Our Privacy Officer will endeavour to provide an initial response to Your query or complaint
within 10 business days and investigate and attempt to resolve Your query or complaint
within 30 business days or such longer period as is necessary and notified to you by our
Privacy Officer.

17. CHANGES TO THIS POLICY
Govn365 may change or update this Policy from time to time.
Any amended Policy will take effect from the date that we post it to this Website and/or the
Platform. Govn365 will make every effort to communicate any significant changes to You via
email or notification via the Platform.
This Policy was last updated on 28 March 2022.