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.