We are Cryptopia Limited (in liquidation), acting via our liquidators, Grant Thornton ("we", "us", "our"). We have created the Portal in order to contact you, verify your identity and other information you provide, with the end goal of enabling account holders ("you") to make claims for your account balances and (potentially) other entitlements (whether via the Portal or otherwise), and facilitating the distribution of any remaining assets as part of our ongoing liquidation. In connection with these purposes, we need to collect, hold, use and disclose your personal information, as explained further in section 4 below.  

The types of personal information we may collect about you when you register and use the Portal include:

• Identity information: including username, full name, date of birth and any proof of identity documents you upload (eg a copy of your passport or driver's licence).
• Contact information: including email address, residential address and phone number.    
• Financial information: including source of wealth documents (eg bank statements or IRD documents) and potentially account or payment information (for example, if reparation of your claim is facilitated via the Portal).
• Account information: including username, password and answers to questions when setting up your account.
• Claim information: including the amount/value and status of your claim and any supporting documentation which may include a detailed listing of transactions making up the balances claimed, bank confirmations, receipts or bank statements supporting fiat deposits, bank statements or credit card statements supporting receipt of requested NZDT withdrawals, blockchain transaction details with respect to cryptocurrency deposits or withdrawals and/or email correspondence with Cryptopia Limited with respect to pending transactions or transactions not processed.
• Technical information: including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Usage information: including information about when and how you use the Portal, your activity history on the portal and when you are active/inactive.
• Email information: including email correspondence with you and email tracking information (such as whether you have received, opened, read or forwarded emails from us about the Portal or your claim).
• Communications information: including your communication preferences. 

The information we request from you is generally mandatory or automatically collected. While you can opt not to provide some personal information to us, that may mean we cannot open an account for you on the Portal or process your claim.

We use different methods to collect personal information from and about you:

• From Cryptopia Limited's existing account holder database
• You may give us your personal information when creating and opening your account or corresponding with us. 
• As you interact on the Portal, we will automatically collect information about your equipment, browsing actions and patterns.  We collect this personal information by using cookies, server logs and other similar technologies.  Please see section 5 below for further details about how we use cookies.
• We will receive and exchange personal information about you from/with various third parties (Third Party Components) as set out below.
  • Sendgrid: for transactional emails and tracking information (for more information see its privacy policy available at: https://www.twilio.com/legal/privacy);
  • Outsystems: this is the platform we use for the development and maintenance of the Portal (for more information see its privacy policy available at: https://www.outsystems.com/legal/terms-of-use/privacy-statement/);
  • Google Recaptcha: to help us detect and prevent malicious software and fraudulent activity (for more information see its privacy policy available at: https://policies.google.com/privacy);
  • Google Address Finder/places autocomplete API: for address verification (for more information see its terms and privacy policy available at: https://developers.google.com/places/web-service/policies);
  • GBG via IDscan and ID3global: for electronic verification of individual identities (for more information see its privacy policy available at: https://www.gbgplc.com/privacy-policy-anz/); and
  • KYCKR: for electric verification of non- individuals such as trusts and companies (for more information see its privacy policy available at: https://www.kyckr.com/privacy-notice/).

Where these parties collect personal information about you directly, they do so in accordance with their own privacy policies, as hyperlinked above.

We need your information to:

• operate and administer the Portal, including by exchanging information with the Third Party Components listed above;
• identify you when you register and login to your account;
• create, maintain and operate your account;
• comply with our legal, regulatory, tax and/or accounting requirements (including regarding our liquidation), and in particular, our obligations under the Companies Act 1993, the Companies Act 1993 Liquidation Regulations 1994, the Trustees Act 1956 and the Trusts Act 2019 once it comes into force on 30 January 2021; 
• verify your identity, including by matching identification documents against their originating official database;
• maintain records, as required by law (eg records of liquidation required under the Companies Act 1993);
• administer the liquidation of Cryptopia Limited, including processing your claim and (potentially) distributing your entitlements;
• correspond with you;
• assist with any queries, requests or complaints that you may have;
• track your usage of the Portal and any communications in connection with it;
• keep the Portal and the documents you provide through it safe and secure, and to investigate and respond to any suspected privacy breach; and
• continually improve the Portal. 

We may need to share your personal information:

• with our agents, lawyers or authorised representatives;
• with third parties that undertake services for us in connection with the purposes listed above (eg identity verification services), including the Third Party Components; 
• with our liquidators, being Grant Thornton;
• to address any complaints you make to a third party or regulator (such as the Privacy Commissioner); and
• with anyone who we need to share information by reason of law (eg the courts, law enforcement officers and/or the Registrar of Companies).

For example, we may disclose some of your personal information to certain third parties to help us to confirm your identity, if we have reasonable grounds to believe that information provided in connection with an account holder's claim on the Portal may be relevant to an investigation or prosecution of someone for a money laundering offence; and to help us comply with any agreements between the New Zealand Government and other countries’ governments. We may also need to disclose your personal information if we are subject to a legally binding request from a court, regulator or law enforcement agency.

In some cases, we may also need to share your personal information with third parties outside of New Zealand, or the third parties listed above who we share your personal information with may share or store your personal information in other countries (such as Australia, the United Kingdom, the United States, Malaysia and/or Turkey – see the privacy policies linked above for more information), and those countries may not provide comparable safeguards to those required under New Zealand law. By using this Portal you authorise us to make such disclosures.

Cookies

We may use cookies and other interactive techniques such as pixels and web beacons to collect information about how you use the Portal to:

• provide you with a smoother and more customised experience on the Portal; 
• enable you to use certain functionality on the Portal; and 
• help us manage security and fraud risks.   

We may also use persistent cookies so that you can set your preferences for using the Portal (for example, to remember your log in details).

You can usually set the settings on your browser to let you know when you are offered cookies so that you can decide whether or not to accept them.  However, if you disable or refuse cookies, please be aware that some parts of the Portal may not function properly.

Third-Party Links
 
The Portal may include links to third-party websites, plug-ins and applications.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third-party websites and are not responsible for how they may use your personal information.

Information transmitted over the internet is not always secure, but we will use reasonable security safeguards to protect information we hold against loss, access, use, modification and unauthorised disclosure.   We have procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where required by law.

We will only retain your personal information for as long as we legitimately need it, or for as long as we are legally required to.  We will de-identify and aggregate information wherever reasonably practicable.

You have rights to access and request the correction of any personal information we hold about you.  If you want to exercise these rights, please contact us using the following details:
 
This privacy policy is governed by New Zealand law.  For more information about privacy issues in New Zealand and protecting your privacy, visit the New Zealand Privacy Commissioner's website. 

We may change this privacy policy and will provide notice of changes to this privacy policy on the Portal or via email. The changes will apply from the date that we upload the revised policy to the Portal.

This version was last updated on 4 December 2020.