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PRIVACY POLICY

We respect your privacy and are committed to protecting your Personal
Information. This policy is intended to provide you with clear information about
how we collect, use, disclose and protect your Personal Information.

It is important that you read this policy and any other privacy statement we may
provide (on specific occasions when we are collecting or processing your
Personal Information) so that you are fully aware of how and why we are using
your Personal Information.

Please also use the “Glossary” (section 8 below) to understand the meaning of
some of the terms used in this policy.



 1. WHO WE ARE AND WHAT THIS POLICY DOES
    
    1. WHO ARE WE:
       
       * Tapi is made up of different legal entities, including Tapi Limited and
         its subsidiaries.
       * If you have any questions about our privacy practices or this policy,
         please contact us:
         
         Tapi Limited
         Level 6, 7-11 Dixon Street, Te Aro, Wellington 6011, New Zealand
         hi@tapihq.com
    
    2. WHAT THIS POLICY DOES:
       
       * This policy covers our websites, products and services (Services),
         including “Maintenance Tracker”, “Invoice Automation”, “Tenant
         Concierge” chat-bot embedded on a User’s website, “Data Insights”,
         “Property Tab”, “FastPay” and “Landlord House Insurance from Tapi”.
       * We are committed to your privacy and will comply with applicable
         privacy laws, including New Zealand’s Privacy Act 2020, any applicable
         privacy codes and other laws when dealing with your Personal
         Information.
       * Our Services may contain links to third party websites or services. We
         don’t own or control those websites or services or endorse them in any
         way and, if you interact with them, you may be providing Personal
         Information directly to the third party concerned. We encourage you to
         review their privacy policies accordingly.
    
    3. CHANGES TO THIS POLICY:
       
       * We may review and make changes to this policy from time to time,
         including to comply applicable privacy laws or in respect of new or
         updated Services. We encourage you to periodically review this page for
         the latest information on our privacy practices.
       * If we modify this policy we will generally provide notice via an
         announcement on our website. For significant changes we may provide you
         with an email notification.


 2. THE INFORMATION WE COLLECT ABOUT YOU
    
    1. We collect different categories of Personal Information which we have
       grouped together as follows:
    
    2. INFORMATION YOU GIVE TO US:
       
       * Account information: When you sign up for a Service, we may require
         your name, username, address, email address, telephone and mobile phone
         numbers.
       * Property information: We collect Personal Information when you upload
         property information into our Services, which may include your
         description of the property, images of the property, ownership, tenancy
         and maintenance details.
       * Application forms: Some Services, or the services that we connect to,
         require you to complete an application form. Some of the Personal
         Information on the application form may be particularly sensitive, and
         our use of this is subject to Service specific terms (see section 7
         below).
       * Payment information: We collect financial information (like billing and
         GST number information, date, time, amounts charged) when Users make
         payments to us or third parties through the Services.
       * Communications: When you communicate with us or other Users using a
         Service, we collect Personal Information about your communication, this
         includes when you use the Tenant Concierge chat-bot or a Tapi widget
         embedded on a User’s website. If you contact us, including for customer
         support, we may keep a record of our correspondence with you.
       * Marketing preferences: We collect Personal Information about your
         preferences in receiving marketing from us, and your communication
         preferences.
       * Other information: You may otherwise provide us Personal Information
         such as when you provide feedback, respond to surveys or other research
         activities, participate in promotions, upload into our Services or use
         other features of our Services.
    
    3. INFORMATION OTHERS GIVE TO US:
       
       * Users: Other Users may provide us with your Personal Information when
         they upload content to the Services, including when identifying the
         owners and tenants of a property or the relevant supplier(s) in respect
         of a maintenance process.
       * Third party integrations: If you link or connect your account with a
         third party service (e.g. MRI Palace, MRI Property Tree, PropertyMe,
         Reapit Console Cloud), the third party service may send us Personal
         Information about you or others. The categories of information shared
         with Tapi varies and is controlled by that third party and/or by you
         via the settings and permissions at that service.
       * Public sources: To the extent permitted by applicable law, we may
         receive additional information about you from our third-party partners
         who provide us with business introductions or that is publicly
         available.
    
    4. INFORMATION WE AUTOMATICALLY COLLECT:
       
       * Usage information: We collect information about your interactions with
         our Services, including the pages and content you view, maintenance
         processes engaged with, and communications generated through the
         Services.
       * Analytics: When you use the Services we automatically collect analytics
         information when you use our Services. How much information we collect
         depends on the type and settings of the device you use to access the
         Services. For example we may collect your IP address, device
         information, approximate geographic location, web browser and/or device
         type, the web pages or sites visited just before or just after using
         the Service, the pages or other content you view or interact with on
         the Service, and the dates and times of the visit, access, or use of
         the Services.


 1. HOW WE USE YOUR INFORMATION
    
    1. We will only use your Personal Information when the law allows us to. We
       have set out below a description of the ways we plan to use your Personal
       Information:
    
    2. FOR THE PURPOSES OF PROVIDING OUR SERVICES TO YOU:
       
       * Operations: To operate, maintain, enhance and provide all features of
         the Services, including allowing you to communicate with other Users,
         automating invoice data entry, and tracking performance indicators
         across the property maintenance process.
       * Communications: To contact you for support purposes or to address
         issues related to use of the Services.
       * Benchmarking: To personalise or enrich your experience of our Services,
         including comparing your property maintenance process with benchmarks
         for the industry (e.g. average costs of appliances and average time and
         costs of maintenance work). Any benchmarks we share with you are
         Anonymous Data (such that it can no individual can be identified from
         the information).
       * Improvements: To measure how our Services are being used and analyse
         trends to help us understand how our Services are performing, whether
         they are meeting the needs of our Users, and where we can develop new
         products, services, features and functionality. Where possible we will
         undertake data analysis and research using Anonymous Data.
    
    3. FOR THE PURPOSES OF PROTECTING RIGHTS AND INTERESTS:
       
       * Prevent harm: To keep our Services safe and to protect the rights of
         Users, third parties or us, including detecting and preventing fraud,
         spam, abuse, security incidents, and other harmful activity.
       * Compliance: To ensure we comply with the law, including under the
         Privacy Act 2020.
       * Enforce agreements: To enforce our agreements with Users or third
         parties, and investigate the use of our Services.
    
    4. FOR ADVERTISING AND MARKETING PURPOSES:
       
       * Advertising and marketing: To send you promotional messages, marketing
         or advertising about our Services. You have the ability to opt-out of
         receiving any promotional communications.
       * Measure and improve: To measure and improve our promotions and
         advertising.
    
    5. FOR ANY OTHER PURPOSE, WHERE WE OBTAIN YOUR EXPRESS CONSENT.


 2. WHO WE SHARE YOUR INFORMATION WITH
    
    1. Besides our personnel, we may share your Personal Information with the
       parties set out below for the purposes set out in section 3 above:
    
    2. TO THIRD PARTIES WITH YOUR CONSENT:
       
       * Third party integrations: We’ll share Personal information when a User
         authorises a third party service to access that Personal Information,
         for example you may authorise the Services to send data from an
         approved invoice directly to a trust account platform (e.g. MRI Palace,
         MRI Property Tree, PropertyMe, Reapit Console Cloud). The application’s
         access to Personal Information is controlled by Users via the settings
         and permissions in our Services.
       * Property Tab, Fast Pay and Landlord House Insurance from Tapi: We’ll
         share Personal information when a User authorises us to share this with
         a third party, for example where you complete an application form for
         Property Tab, FastPay or Landlord House Insurance from Tapi you
         authorise us to release the application form and other Personal
         Information to the relevant third party for assessment or otherwise
         facilitate your loan or insurance.
       * Other users and third parties: The Personal Information of a User may
         be available to other Users or third parties using the Services,
         including relevant property managers, owners, tenants and suppliers
         involved in a maintenance process. Although we allow this
         functionality, the relevant individual is solely responsible for the
         content of their messages to other Users or third parties.
    
    3. TO OUR SERVICE PROVIDERS:
       
       * Service Providers: We may need to disclose your Personal Information to
         our third party service providers in order to provide and manage our
         Services, including:
         * website, application development, hosting, maintenance providers;
         * cloud-storage providers;
         * marketing partners;
         * invoice data automation partners, and third parties that help us to
           enhance the accuracy of that automation;
         * data analytics or research partners;
         * third parties that help us to support the Services; and
         * our consultants, lawyers, accountants, insurers, and professional
           advisors.
       * Limited sharing: Each service provider’s access to your Personal
         Information is limited to the information needed to perform tasks on
         our behalf, and they are contractually obliged to use your Personal
         Information consistently with this policy.
       * International information transfers: Some of these service providers
         are located outside of New Zealand and may not be subject to New
         Zealand privacy laws. However, we use a commercially reasonable
         selection process to evaluate the provider’s security, privacy and
         confidentiality practices to confirm that the provider can protect
         Personal Information in a way that, overall, provides comparable
         safeguards to those under the Privacy Act 2020.
    
    4. TO OTHER THIRD PARTIES:
       
       * Protecting rights and interests: We may disclose your Personal
         Information to courts, law enforcement, government agencies, or third
         parties for the purposes of protecting rights and interests (as
         described in section 3.3 above), to the extent we believe that
         disclosure is appropriate or permitted by the Privacy Act 2020.
       * Tapi group companies: We may disclose your Personal Information to
         subsidiaries partly or fully owned by Tapi Limited which are governed
         by this policy.
       * Reorganisation or sale: We may disclose your Personal Information to
         third parties to whom we may choose to sell, transfer or merge parts of
         our business or our assets. In this event, we will notify you before
         your Personal Information is transferred and becomes subject to a
         different privacy policy.


 1. DATA SECURITY
    
    1. HOW DO WE TAKE CARE OF YOUR PERSONAL INFORMATION?
       
       * Security: We have put in place generally accepted industry standards to
         prevent your Personal Information from being accidentally lost, used or
         accessed in an unauthorised way, altered or disclosed. This includes
         firewalls, encryption data transfers, password protection and other
         access and authentication controls. We limit access to your Personal
         Information to those employees, agents, contractors and other third
         parties who have a business need to know, and are under suitable
         obligations of confidentiality.
       * Notification: We would notify you and the Office of the Privacy
         Commissioner if a potentially harmful data breach of your personal
         information did occur.
    
    2. HOW LONG WILL WE USE YOUR PERSONAL INFORMATION?
       
       * Retention policy: We will only retain your Personal Information for as
         long as reasonably necessary to fulfil the purposes we collected it
         for. To determine the appropriate retention period for Personal
         Information, we consider:
         * the amount, nature and sensitivity of the Personal Information;
         * the potential risk of harm from unauthorised use or disclosure of
           your Personal Information;
         * the purposes for which we process your Personal Information and
           whether we can achieve those purposes through other means; and
         * applicable legal, regulatory, tax, accounting or other requirements.
       * User accounts: Personal Information associated with a User’s account
         will be retained for as long as the account is active. We will retain
         some Personal Information where necessary for the purposes of:
         * satisfying any legal, regulatory, tax, accounting or reporting
           requirements; and
         * allowing other Users to make full use of the Services, including
           continuing to display messages you sent to other Users.
       * Marketing Preferences: If you have elected to receive marketing emails
         from us we will retain Personal Information about your marketing
         preferences.
       * Cookies: We retain Personal Information derived from cookies and other
         tracking technologies for a reasonable period of time from the date
         such information was created.
       * Anonymization or deletion: In accordance with this section 5.2, we will
         either process the Personal Information such that it becomes Anonymous
         Data or delete the Personal Information or, if this is not possible
         (for example, because the information has been stored in backup
         archives), then we will securely store your Personal Information and
         isolate it from any further use until deletion is possible.


 2. RIGHTS OF ACCESS AND CORRECTION
    
    1. YOUR RIGHTS: UNDER THE PRIVACY ACT 2020, YOU HAVE A RIGHT TO:
       
       * access the Personal Information we hold about you (Privacy Principle
         6); and
       * seek correction of any information we hold that is out of date or
         incorrect (Privacy Principle 7).
    
    2. HOW CAN YOU ACCESS AND/OR CORRECT YOUR PERSONAL INFORMATION?
       
       * Updating your information: In most cases, you may review and update the
         account information we hold about you (such as your business name,
         email address, password and phone numbers) by:
         * logging into the relevant Service and updating the information in
           your account;
         * updating the relevant information within the trust account platform
           linked to your account; or
         * contacting our customer support team.
       * Exercising your rights: If you cannot update your Personal Information
         through the Services, or you otherwise wish to exercise any of the
         rights set out in section 6.1, feel free to get in touch with us at the
         address or email address provided in section 1.1.
       * No fee usually required: Ordinarily you will not have to pay a fee to
         access your Personal Information (or to exercise your rights).
         Sometimes we'll need to charge, for example, if the request is very
         broad and the Personal Information requested is likely to take
         significant time and resources to find and prepare. In these
         situations, we'll get in touch to discuss your request and give you an
         estimate of the cost before doing anything.
       * What we may need from you: We may need to request specific information
         from you to help us confirm your identity and ensure your right to
         access your Personal Information (or to exercise any of your other
         rights). This is a security measure to ensure that Personal Information
         is not disclosed to any person who has no right to receive it. We may
         also contact you to ask you for further information in relation to your
         request to speed up our response.
       * Response period: We try to respond to all requests within 20 working
         days. Sometimes it could take us longer if your request is particularly
         complex or you have made a number of requests. In this case, we will
         notify you and keep you updated.
       * Withholding information: In some cases we may redact or withhold
         information to ensure what's released doesn't compromise an ongoing
         investigation by a government agency, create a security risk, or
         prejudice our commercial position.
       * Privacy Commissioner: You can also learn more about your privacy rights
         by talking to the Office of the Privacy Commissioner.


 3. SERVICE SPECIFIC TERMS
    
    1. This section outlines certain Service’s use and disclose of Personal
       Information, including extra restrictions on our use of Personal
       Information and User data:
    
    2. LANDLORD HOUSE INSURANCE FROM TAPI:
       
       * Insurance application: We understand that Personal Information in your
         insurance application form may be particularly sensitive. We will only
         use or disclose this information for purposes related to the relevant
         Service. We won’t use this information for purposes unrelated to
         Landlord House Insurance from Tapi, without your permission, unless
         this is required for fraud prevention, law enforcement purposes or by
         law.
       * Insurer and underwriter: Insurance is provided by Open Insurance Ltd
         (NZ Company Number 7969816) (Open) on behalf of Tower Limited (NZ
         Company Number 143050) (Tower). Tapi, Open and Tower may each collect
         and hold your Personal Information when:
         * you navigate around and use the Landlord House Insurance from Tapi
           website;
         * submit in an application for insurance; or
         * make an insurance claim.
       * Further privacy terms: We encourage you to review the privacy policies
         of Open and Tower accordingly.


 1. GLOSSARY
    
    1. IN THIS POLICY, UNLESS DEFINED OTHERWISE, TERMS HAVE THE FOLLOWING
       MEANING:
       
       * Anonymous Data means Personal Information that has been processed such
         that it can no longer be associated with a specific individual.
       * Personal Information means information about an identifiable
         individual, as defined in the Privacy Act 2020, and does not include
         Anonymous Data.
       * Tapi, us, we, or our means: (a) Tapi Limited (NZ company number
         6365153); and any entity that Tapi Limited ultimately partly or fully
         owns that provides a Service to which this policy applies.
       * User means anyone accessing and using the Services, including as a
         property manager, owner, tenant or supplier.

The effective date of this policy is [●] 2023.

Last updated: 23 October 2019

This privacy policy (Policy) applies to all personal data (Data) processed by
Tapi Limited (Tapi, us, we, or our).

Thank you for your interest in our website (www.tapihq.com) (Website),
applications, dashboards, embedded widgets, chat-bots and other services
provided by us (together our Platform).

This policy is intended to provide you with clear and transparent information
about the Data we collect, why we collect it, how we use and disclose it, how we
safeguard your Data, when your Data will be deleted, and your privacy rights.



 1. CHANGES AND UPDATES
    
    1. We may be required to review and make changes to this Policy from time to
       time to comply with Data Protection Laws, utilise new technologies or to
       improve your experience. Please revisit this page periodically to stay
       aware of any changes.
    2. If we modify this Policy we will make it available through the Platform
       and indicate the date of the latest revision. Your continued use of the
       Platform after the revised Policy has become effective indicates that you
       have read, understood and agreed to the current version of the Policy.


 2. PEOPLE WE PROCESS DATA FROM
    
    1. We collect different types of Data from people who have access to the
       restricted areas of the Platform (End Users), and other people who
       interact the public areas of the Website, engage with us, who we target
       our Platform to, or whose Data is submitted to the Platform by End Users
       (Visitors).
    2. End Users includes property managers, landlords, tenants and property
       maintenance contractors who have been authorised (by Tapi or by another
       End User) to access or otherwise use the Platform.


 3. THE INFORMATION WE COLLECT
    
    
        INFORMATION YOU GIVE US
    
    1.  When you access or otherwise use the Platform, whether as an End User or
        as a Visitor, you may provide Data to us in various ways. For example,
        when you:
        1. register for an account on the Platform;
        2. send emails or other messages via the Platform, or respond to such
           emails or messages (from Tapi or an End User) via the Platform;
        3. use a Tapi widget embedded on an End User’s website; or
        4. engage with Tapi’s chat-bot.
    2.  Examples of such Data includes name, residential address, email address,
        telephone and mobile phone numbers, property information (including
        ownership and maintenance details), information contained within
        invoices issued via the Platform, and the billing information (of our
        customers only).
    3.  If you contact us, including for customer support, we may keep a record
        of our correspondence with you.
    
    
        INFORMATION THAT OTHERS GIVE US
    
    4.  Where reasonably practical we aim to collect Data directly from the
        person who is the subject of the Data. However End Users may provide
        Data about you when they submit content to the Platform. For example, we
        may receive your Data from a property manager when they designate you as
        a tenant of a property that they manage.
    5.  We may receive information about you when an End User integrates
        third-party services with the Platform. For example, a property manager
        may authorise the integration of the Platform with their trust account
        platform, allowing Tapi to process Data within that service.
    6.  The Data we receive when an End User integrates the Platform with a
        third-party service depends on the settings and permissions of that
        third-party. You should always check the privacy settings and notices of
        these third-parties to understand what Data may be disclosed to us or
        shared with the Platform.
    7.  If you provide us with Data about someone else or authorise an
        integration of the Platform with a third-party service, then you must
        ensure that you are authorised to disclose that Data to us in accordance
        with applicable Data Protection Laws.
    8.  We may obtain Data from third party providers of business information
        and publically available sources including mail addresses, job titles,
        email addresses, phone numbers and social media profiles, for the
        purposes of targeted advertising of services that may interest you,
        delivering personalised communications, event promotion and profiling.
    
    
        INFORMATION WE OBSERVE
    
    9.  We collect Data when you interact with the Platform. This includes the
        features of the Platform you use and the links you click on. We also
        collect information about the other End Users and Visitors you engage
        with via the Platform and how you work with them.
    10. When you use the Platform we may automatically record certain Data from
        the End User’s or Visitor’s device by using various types of technology.
        How much Data we collect depends on the type and settings of the device
        you use to access the Platform. For example we may collect your IP
        address or other device address or ID, approximate geographic location,
        web browser and/or device type, the web pages or sites visited just
        before or just after using the Platform, the pages or other content you
        view or interact with on the Platform, and the dates and times of the
        visit, access, or use of the Platform.
    11. Tapi and our third-party partners, such as our advertising and analytics
        partners, use cookies and other tracking technologies (e.g., web
        beacons, device identifiers and pixels) to provide functionality and to
        recognize you across different services and devices. You may block
        cookies by activating the setting on your browser that allows you to
        refuse the setting of all or some cookies. However, if you use your
        browser settings to block all cookies (including essential cookies) you
        may not be able to access all or parts of our website (or, as
        applicable, our third party partners’ websites).


 1. RIGHTS OF ACCESS AND CORRECTION
    
    1. Pursuant to your rights under the Privacy Act 1993 (NZ), you have the
       right to:
       1. access any of your Data; and
       2. request correction of any of your Data,
       held by us by contacting us using the details given at clause 9 8. We
       will respond to your request in accordance with the Privacy Act.
    
    
       RIGHTS FOR EU
    
    2. Under the GDPR, if you are an EU-based person you have the right to:
       1. access and correct your Data;
       2. in certain circumstances, have your Data erased;
       3. restrict the processing of your Data;
       4. move, copy or transfer your Data easily for your own purposes across
          different services in a safe and secure way;
       5. object to processing where we relying on legitimate interests as the
          basis for processing and at any time to processing of Data for direct
          marketing purposes; and
       6. withdraw your consent to our processing of your Data if your consent
          is being relied on by Tapi.
    3. Please note that in certain circumstances we may refuse to respond to a
       GDPR rights request where we have the right to do so under the GDPR, for
       example, where a request is manifestly unfounded or excessive.


 2. GENERAL
    
    1. For the purposes of this Privacy Policy, Data Protection Laws means the
       data protection and privacy laws applicable to the processing of Personal
       Data that we are committed to comply with, including:
       1. the Privacy Act 1993 (New Zealand);
       2. the Privacy Act 1988 (Cth, Australia);
       3. all applicable United States federal and state privacy laws;
       4. the General Data Protection Regulation (EU); and
       5. any other applicable privacy legislation.
    
    
       CONTACT US
    
    2. If you wish to contact us in relation to this Policy, our privacy
       standards, or our Data-handling practices please contact us using the
       details below:
       Address: 19 Edward Street, Te Aro, Wellington 6011
       Email: hi@tapihq.com

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