In this Policy, the terms “we”, “us”, and “our” refer to Trust Codes Global Limited (“Trust Codes”), a New Zealand registered Limited Liability Company. Maintaining the security and privacy of data is a priority at Trust Codes. We will handle your data fairly and legally at all times.

This Policy provides you with information about:

• How we use data;
• What data we collect;
• How we ensure data privacy is maintained; and
• Your legal rights relating to personal data.

We may use data we have obtained through your interaction with any web content provided by Trust Codes, whether on behalf of a Customer of Trust Codes or not:

• To provide services to you where our Customers require us to;
• To provide anti-fraud capabilities and traceability to our Customers;
• To enable Trust Codes to manage any consumer enquiries and customer interactions with you; and
• Where we have a legal right or duty to use or disclose your information, (for example, in relation to an investigation by a public authority in a legal dispute).

Aside from our service providers, we will not disclose identifiable data to any third party, except as set out below. We will never sell or rent data to other organisations for marketing purposes.

We may share your data with governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so:

• To comply with our legal obligations;
• To exercise our legal rights (for example, in court cases);
• For the prevention, detection, investigation of crime or prosecution of offenders; and
• For the protection of our employees and customers.

We will not retain your data for longer than necessary for the purposes set out in this Policy.

Trust Codes does not collect identifying information about you and all the data we collect is anonymised so that it is not classed as Personally Identifiable Information. While you are in a Trust Codes provided webpage, we will not collect identifying information about you. In specific instances, for example to comply with local regulations, we may need to collect additional data for the purposes set out in this Policy and we will seek your express consent if we do so.

Our websites are not intended for children and we do not knowingly collect data relating to children.

Trust Codes is committed to keeping data safe and secure. Our security measures include:

• Anonymisation of all data
• Encryption of data;
• Regular cyber security assessments of service providers;
• Security controls which protect Trust Codes’ cloud infrastructure from unauthorised access; and
• Internal policies setting out our data security approach and training for employees.

While we do not collect personally identifiable information, or Personal Information, we reiterate the general legal rights you may have in relation to Personal Information (or information that is Personal Information in law), including:

• The right to ask for a copy of personal data that we hold about you (the right to access);
• The right (in certain circumstances) to request that we delete personal data held where we no longer have any legal reason to retain it (the right of erasure or to be forgotten);
• The right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you (the right of rectification);
• The right (in certain circumstances) to ask us to ‘restrict processing of data’; which means that we would need to secure and retain the data for your benefit but not otherwise use it (the right to restrict processing); and
• The right (in certain circumstances) to ask us to supply you with some of the personal data we hold about you in a structured machine-readable format and/or to provide a copy of the data in such a format to another organisation (the right to data portability).

We are required to set out the legal basis for our ‘processing’ of user data. Trust Codes collects and uses user data because it is necessary for:

• The pursuit of our legitimate interests (as set out below);
• The purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a Customer; or
• Complying with our legal obligations.

The normal legal basis for processing customer data, is that it is necessary for the legitimate interests of Trust Codes, including:

• Data interpretation (whether that be automated or assisted) to help identify patterns of counterfeit products or conduct
• Selling and supplying goods to our Customers to protect their brand with digital anti-counterfeit capability and provide end to end Traceability;
• Protecting our Customers, consumers of our Customers’ products, employees and other individuals and maintaining their safety, health and welfare;
• Improving existing products and developing new products;
• Complying with our legal and regulatory obligations;
• Preventing, investigating and detecting crime, fraud or anti-social behaviour, including working with law enforcement agencies;
• Handling Customer contacts, queries, complaints or disputes;
• Managing insurance claims by Customers;
• Protecting Trust Codes, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to Trust Codes;
• Effectively handling any legal claims or regulatory enforcement actions taken against Trust Codes; and
• Fulfilling our duties to our Customers, colleagues, shareholders and other stakeholders.