Introduction

Jasper provides investors with the opportunity to invest in financial products (as defined in the Financial Markets Conduct Act 2013) which would enable them to gain an economic exposure to commercial or industrial grade real estate through a fully digitised on-boarding, accreditation and subscription process (the Platform). At Jasper, we respect the privacy rights of our users and recognise the importance of protecting the personal information we collect about you. This Policy is designed to outline the way in which we manage the personal information we hold about our investors, prospective investors, prospective employees, and visitors to our websites and Platform. This Policy applies to our Platform and our websites. We, us, our and Jasper are defined at the end of this Policy.

Jasper is bound by the Privacy Act 1993 (Privacy Act).

In summary, ‘personal information' is information about an identifiable individual.

Why does Jasper collect personal information?

We collect personal information in order to create, manage and administer your user account, conduct our business, provide and market our services, and meet our legal obligations, including (but not limited to) in relation to our anti-money laundering and sanctions compliance obligations, as well as obligations under the Foreign Account Tax Compliance Act and Inland Revenue regulation.

What kinds of personal information does Jasper collect?

In general, and depending upon the nature of your connection with Jasper, the type of personal information we collect and hold includes (but is not limited to): 

  • your name, addresses, contact details, date of birth, tax identification number and tax status;
  • information about your bank account details and financial and personal circumstances, including evidence of source off funds (in some cases), and transactional and financial information relating to your user account;
  • in the case of prospective employees, occupation, employment history and/or details, education and qualifications, testimonials and feedback;
  • non-identifiable information relating to your use of the Platform and our websites, such as device-related information (browser type, internet protocol address) and server log information (date and time of day of your visit to the Platform and/or our websites and pages within the Platform and/or our websites that you accessed);
  • documents that verify your identity and other personal details; and 
  • other information which assists us in conducting our business, providing and marketing our services and meeting our legal obligations. 

In some cases, if personal information we request is not provided, it might adversely impact our ability to perform our obligations to you and your ability to use the Platform and/or our websites.

Jasper may collect information that is not personal information (i.e. it is not attributable to you individually). The purpose of this is to ensure Jasper can further develop existing services and investigate new services that enable Jasper to better assist with your requirements.

If we do combine non-personal information with personal information the combined information will be treated as personal information. 

Jasper may obtain and aggregate technical and other data about your use of our services, Platform and/or our websites that is non-personally identifiable with respect to you (Aggregated Anonymous Data). Jasper may use the Aggregated Anonymous Data to analyse, improve, support and operate the services, Platform and/or our websites and otherwise for any business purpose, including without limitation to generate industry benchmark or best practice guidance, recommendations or similar reports for distribution to and consumption by our users. For clarity, this does not give Jasper the right to identify you as the source of any Aggregated Anonymous Data.

How does Jasper collect personal information?

Except as otherwise permitted by law, we will collect personal information:

  • from you directly when you provide your details to us (including information that is provided to us in connection with your application to become an investor and details of transactions that are carried out through the Platform and/or our websites);
  • from you indirectly (through emails, forms, subscription applications, face-to-face meetings, interviews, business cards, telephone conversations and through the use of the services and facilities available through our websites and social media channels);
  • from third parties in some instances, for example, we may use third parties to analyse traffic at our Platform, websites and social media channels, which may involve the use of cookies. In some circumstances we might collect personal information about an individual from a third party (for example, an employment reference from another person and, including without limitation, for the purposes of our compliance with our anti-money laundering and sanctions compliance obligations); and 
  • from publicly available websites.

Links to other sites 

Our Platform and websites may contain links or references to third party websites or material. Our Policy does not apply to those websites. As such, any information collected by such third parties is governed by that third party’s privacy practices or policies. We recommend that you check any relevant privacy policies before providing your personal information to any third party, and we accept no responsibility or liability for the content of privacy practices of any third party websites.

Cookies

A cookie is a data file that is sent to your browser from a web server and stored on your computer or device, then sent back to the server by your browser each time you access certain sections of the Platform and our websites.

Like many other websites on the internet, we use cookies to store and track information about you when you are on the Platform and our websites for the purposes of:

  • providing more customised content and material to you on the Platform that better matches your interests and needs;
  • security, (including helping us to identify you when you log in to your user account); and 
  • business and marketing analysis. 

This information may be retained in an anonymous or aggregated form after we have erased personal information that identifies you from our systems. You can choose to disable cookies via your device’s website browser settings. However, if you choose to reject cookies, you may not be able to use or access some features of the services that we offer.

Management of personal information

We take reasonable steps to protect the security of personal information. Jasper’s personnel are required to respect the confidentiality of personal information and the privacy of individuals. We take reasonable steps to protect personal information held by us from misuse and loss and from unauthorised access, modification or disclosure, for example by use of physical security and restricted access to electronic records. Where we no longer require your personal information, we will comply with our legal obligations in respect of that information.

How might Jasper collect, hold, use and disclose your personal information?

In general, we collect, hold, use and disclose your personal information for the following purposes:

  • to create, manage and administer your user account as agreed with you;
  • to review your eligibility to create or continue to use a user account with us;
  • to process your application to become an investor and other matters in connection with the operation of thePlatform, our websites and your account including, without limitation, transfers, deposits, payments, generating reports and record keeping of investment portfolios;
  • to conduct our business and communicate with you;
  • to provide, market and help us manage and enhance our services to you;
  • to provide joint marketing initiatives with other service providers;
  • to engage third parties on your behalf;
  • to keep you informed of investments we consider may be of interest to you, unless you ask us not to provide you with this information;
  • to perform data analysis and market research;
  • to check your identity against governmental databases, including the National Register of driver licences;
  • to check your identity against databases maintained by the New Zealand Department of Internal Affairs (including birth or death information recorded under the Births, Deaths, Marriages, andRelationships Registration Act 1995, citizenship information recorded under the Citizenship Act 1977, and/or travel document information recorded under the Passports Act 1992);
  • to check your identity against the records of the Document Verification Service (and related databases) maintained and provided by the Commonwealth of Australia; to check your identity against other governmental databases;
  • to identify, prevent or investigate any actual or suspected fraud, unlawful activity or threats to our systems; and 
  • to comply with our legal obligations, including (but not limited to) in relation to our anti-money laundering and sanctions compliance obligations, including in relation to the ForeignAccount Tax Compliance Act and general tax regulation. 

To whom might Jasper disclose your personal information?

We may disclose your personal information to:

  • your professional advisers, your authorised signatories and your agents;
  • other members of the Jasper group, including its subsidiaries (if any) and related parties;
  • other companies or individuals who assist us in providing services or who perform functions on our behalf (such as mailing houses, hosting and data storage providers and financial advisers), and other companies or individuals who perform checks that are necessary or desirable under law on our behalf;
  • other companies, agencies or individuals that maintain databases against which your identity may be verified, which may include (but is not limited to) the New Zealand Department of InternalAffairs, New Zealand Transport Agency, and the Commonwealth of AustraliaDocument Verification Service;
  • our professional advisers (such as our lawyers who assist us to ensure we are complying with our legal obligations), and banks and other financial institutions as part of our obligations when paying or receiving funds on your behalf;
  • social media sites on which we have a presence, to the extent that you interact with us via a social media site. We limit interactions on social media sites that may disclose personal information to the private messaging functions of those sites, unless you otherwise request or give permission; 
  • courts, tribunals and regulatory authorities for the purposes of making or responding to legal claims or proceedings and enforcing contractual arrangements;
  • anyone who assists us to identify, prevent or investigate fraud, unlawful activity, misconduct or threats to our systems;
  • anyone else to whom you authorise us to disclose it; and
  • where we are required to do so by law. 

Access to your personal information

You can access some of your personal information that we collect through the Platform by logging into your user account. You may request access to other personal information that we hold about you by contacting us on [email protected].

Correction

You may request that we correct factual errors in your personal information by sending us an email request that shows the error(s) to [email protected]. To protect your privacy and security, we may also take reasonable steps to verify your identity before granting access or making corrections. We may refuse access to or correction of your information for any reason of refusal permitted by law.

Complaints

If you have any questions about privacy related issues or wish to complain about the handling of your personal information by us, please contact our Privacy Officer at [email protected]. We may ask you to lodge your complaint in writing. Any complaint will be investigated by the Privacy Officer and you will be notified of the decision in relation to your complaint as soon as practicable after it is made, usually within 20 working days.

If we are unable to satisfactorily resolve your concerns about our handling of your personal information, you can contact the Office of the Privacy Commissioner at: PO Box 10-094, The Terrace, Wellington 6143, phone 0800 803 909, http://privacy.org.nz/.

Address details of Jasper

The address of Jasper, as the person collecting and holding your personal information, is:

14 Wanganui Avenue, Ponsonby, Auckland, New Zealand, 1011

Updates to this Policy

This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. The most current version of this Policy is located at www.jasper.io and a free copy can be requested by contacting our Privacy Officer on [email protected].

Definitions

In this Policy:

Jasper, we, us and our means Jasper Property Limited (New Zealand company number 6575172), its subsidiaries (if any) and its related parties.

Last updated: 20 September 2019

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