PRIVACY POLICY (as at 23/03/2021)

1. INTRODUCTION
   1. Pure Advantage Incorporated, a charity registered in New Zealand, with the registration number CC54861, and having its registered office in Auckland, New Zealand and the Site and Services (as defined in our Terms of Service) provided by Pure Advantage and any of its subsidiaries or affiliates (as the case may be) (“Pure Advantage”, “we” or “us”) are committed to protecting and respecting your privacy.
   2. This policy (together with our Terms of Service and any other documents referred to herein or the Terms of Service — (Privacy Policy) explains how information is collected, used, processed and disclosed by Pure Advantage and applies to all information collected when you use or access the Site and/or Services (as defined in the Terms of Service), or when you volunteer with and/or donate to Pure Advantage, use any available media space on the Site, attend a Pure Advantage event or otherwise interact with us. We respect the privacy rights of users and recognise the importance of protecting information collected about you.
   3. By continuing to use the Site or Services you are accepting and consenting to the terms of this Privacy Policy.
   4. Please read the following carefully to understand how we will collect, use and maintain your personal information. It also describes your choices regarding use, access and correction of your personal information.
2. CHANGES TO THIS NOTICE
   1. We may change this Privacy Policy from time to time. If we make any changes, we will notify you by revising the “Last Updated” date at the top of this Privacy Notice and adding a notification pop up on the Site which you must confirm your acceptance to before proceeding to the Site.  We may also send you an email notification. We advise you review our Privacy Policy whenever you access the Site or Services to stay informed about our information practices and to see any changes or updates to the Privacy Policy.
   2. If you disagree with any changes to this Privacy Policy and do not wish your information to be subject to the revised Privacy Policy you will need to deactivate any accounts with us and immediately cease use of the Site and Services. Your use of the Site or Services after the posting of such changes shall constitute your consent to such changes.
3. INFORMATION COLLECTED
   1. We may collect certain user information and data (including personal information and/or sensitive personal information) in the following ways:
      1. Information you provide to us: We collect information you provide directly to us including when you visit the Site, register for, use the Site or Services, receive information from us, and/or donate to, volunteer with or otherwise engage with Pure Advantage in some way. It includes information you provide when you register to use the Site or Services, use any interactive features of the Site or Services, participate in surveys, contests, promotions, sweepstakes, any activities or events arranged by us, request support, when you contact us on or report a problem, participate in discussion boards or through social media functions either provided through the Site or Services or used to communicate with us via third-party social media sites.
      2. Information we may collect directly from you includes your name, username, email address, your picture, postal address, phone number, information about your data storage preferences, employer’s name, job title, transactional information from donations, as well as any contact or other information you choose to provide. Please be aware that the information you choose to provide in any profile or registration may reveal or identify information that is not expressly stated (for example, if you choose to provide your picture, your picture may reveal your gender).
      3. We may also store Content (as defined in our Terms of Service), electronic files or other information that you upload or provide through the Site and Services.
      4. If you provide any third party information, such as names, email addresses and the like, you acknowledge that you have the authority of the third party to provide this information and that they have agreed to the terms of this Privacy Policy.
      5. Information we collect automatically when you use the Pure Advantage Services: When you access or use the Site or Services, we will automatically collect information about you, including:
         1. user activity in connection with the Site and Services and may collect information about the applications and features you use, the websites you visit, the sizes and names of the files or folders you upload, download, share or access while using the Site and Services, the Content you access and any actions taken in connection with the access or use of your Content in the Site and Services;
         2. log information about you when you access and use the Site and Services including your domain type, Internet Protocol address (“IP Address”), access times, browser type and language, Internet Service Provider (“ISP”), the web pages that you visit, the Content you use and the URL of the web page you visited before navigating to the Site or Services, download errors and length of visits to web pages that you visit, and your geographic region;
         3. if you access the Site or Services from a mobile device, we collect information about the device, including the hardware model, operating system and version, unique device identifiers, mobile network information (as allowed by the mobile network) or platform information (as allowed by the specific platform type). We may ask for or access your location based information from your mobile device with your consent through our mobile apps; and
         4. we and/or service providers use various technologies to collect information, which may include saving cookies to your computer or mobile device. Please refer to the Cookie Policy set out in clause 4 below.
      6. Information we collect from other sources: We may also obtain information from third parties and combine that with information we collect through the Site and Services. For example, we may have access to certain information from a third-party social media service if you create or log into your online account through the service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third- party social media service is in accordance with the privacy notice and authorisation procedures determined by the social media service.
4. COOKIES
   1. Our use of Cookies:  We set and access cookies and similar technology on your computer to obtain information about how you access and your use of the Sites and the Services. Unless you have adjusted your settings so that you can refuse cookies or you have not accepted the use of cookies, our system will set cookies when you load and navigate around the Site and Services. By using our Site and Services you consent to our use of cookies.
   2. What are Cookies:  Cookies are text files containing amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website during your browsing session or on each subsequent visit, or to another website that recognises that cookie. The cookies we set do lots of different jobs, like help us to improve the Site and Services and to deliver a better and more personalised service, remembering your preferences and generally improving the user experience. You can find more information about cookies at https://developer.mozilla.org/en-US/docs/Web/HTTP/Cookies.
   3. Cookies can be categorised in accordance with the categories found as set out below.
      1. Strictly necessary cookies: These cookies are essential in order to enable you to move around a website and use its features and enable services you have specifically asked for. Consent is generally not required for these cookies.
      2. Performance cookies: These collect information about how visitors use a website, for example, by recording which page users go to most often (usually on an anonymous basis).
      3. Functionality cookies: These cookies allow a website to remember the choices a user makes, such as a user name or language preference.
      4. Targeting or advertising cookies: These collect information about a user’s browsing habits and are usually placed by advertising networks with the website operator’s permission.

Cookies can also be categorised in accordance with how long they are saved on your device: “Session cookies” are short-term cookies that are only saved on the computer’s memory for the duration of a user’s visit to the website, whereas “Persistent cookies” remain saved in the computer’s memory for a set period of time, even after the browser session has ended.

1. 1. The Cookies we use:  The following cookies are set on the Site and/or Services:

1. 1. The use of cookies by third parties that you may have signed in from into the Site or Services and/or third party applications, is not covered by our Privacy Policy. We do not have access or control over such cookies.
   2. A third party partner may employ clear gifs (a.k.a Web Beacons/Web Bugs), images, and scripts that help them better manage content on our Site. We do not tie the information gathered to your personal information.
   3. We use Local Shared Objects (“LSO”) such as HTML5 to collect and store information in order to provide certain features on our website. Third parties with whom we partner may also use LSOs in order to provide certain features on our website or to display advertising based upon your Web browsing activity. Various browsers may offer their own management tools for removing HTML5 LSOs.
   4. We may partner with third parties to manage our advertising on other websites. Our third parties may use tracking technologies such as cookies to gather information about your activities on the Site and from the Services and other websites you visit in order to provide you advertising based upon your browsing activities and interests.
   5. Refusing or restricting cookies:  You may refuse to accept cookies by activating the setting on your browser which allows you to reuse the setting of cookies. The “Help” or “Internet Settings” functions within your browser should tell you how. Alternatively, you may wish to visit http://www.allaboutcookies.org/ which contains detailed information on cookies and to delete, restrict or block them on a wide variety of browsers. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.
   6. Please be aware that if you select to refuse or restrict cookies you may be unable to access certain parts of the Site or use certain parts of the Services.
   7. Some browsers offer a “do not track” (“DNT”) option. We will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
2. USE OF INFORMATION
   1. We may use the information collected to perform a variety of purposes, including to:
      1. provide, operate, maintain and improve the Site and Services;
      2. assess, onboard and/or engage potential volunteers, researchers, contributors and/or advocates;
      3. take and solicit  donations;
      4. enable you to access and use the Site and Services, including for providing or accessing Content;
      5. send you technical notices, updates, security alerts and support and administrative messages;
      6. to carry out our obligations arising from the Terms of Service, and to provide you with the information, products and services that you request from us;
      7. to notify you about changes to the Site and Services;
      8. to ensure that content from our Site is presented in the most effective manner for you and for your computer;
      9. respond to your comments, questions, and requests and provide support;
      10. communicate with you about services, features, surveys, newsletters, offers, opportunities, promotions, contests and events, and provide other news or information about Pure Advantage, our select partners and any third parties in accordance with the terms of this Privacy Policy;
      11. process and deliver contests entries and rewards;
      12. ensure you are a suitable person (as determined in our sole discretion) that you are suitable to use, or receive the Services or the Site;
      13. conduct any investigation we may deem appropriate into your suitability pursuant to ((l)) above;
      14. monitor and analyse trends, usage, and activities in connection with the Site and Services and for marketing or advertising purposes;
      15. to administer the Site and Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
      16. to improve the Site and Services to ensure that content is presented in the most effective manner for you and for your computer;
      17. to allow you to participate in interactive features of the Site and Services when you choose to do so;
      18. as part of our efforts to keep the Site and Services safe and secure;
      19. investigate and prevent fraudulent transactions, unauthorised access to the Site and Services, and other illegal activities;
      20. personalise and improve the Site and Services, and provide content, features, and/or advertisements that match your interests and preferences or otherwise customise your experience on the Site and Services;
      21. to send push notifications from time-to-time in order to update you about events or activities related to the site and Services. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we collect certain information about your device such as its operating system and user identification information;
      22. link or combine with other information we receive from third parties to help understand your needs and provide you with better service;
      23. combine third party information, the information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive); and
      24. for any other purpose we may notify you about from time to time.
   2. You agree that we have the right to share your personal information with selected third parties, including:
      1. analytics and search engine providers that assist us in the improvement and optimisation of our Site and Services;
      2. in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business assets; and/or
      3. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms — or terms and conditions for Pure Advantage events and other agreements, or to protect our rights, property, or safety and that of others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
   3. PROCESSING
   4. Pure Advantage is a registered charity in New Zealand and all information is transferred to New Zealand and/or the United States of America.
   5. By accessing or using the Site or Services or otherwise providing information to us, you consent to the processing and transfer of information between countries and territories globally, which may have different privacy laws from your country of residence.
   6. Your information will be processed by staff or volunteers who work for us or for one of our suppliers located in New Zealand. This includes staff engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
   7. All information you provide to us is stored In New Zealand on secure third-party servers that may at any time be located in the United States of America, Taiwan, Singapore, Ireland, the Netherlands, Finland, Belgium and Chile.
   8. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our sites and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
3. SHARING AND DISCLOSURE OF INFORMATION
   1. We will not share personal information about you or any Content you provide with any third parties otherwise than as set out in this Privacy Policy. For example, we may share personal information about you including as follows:
      1. with third-party vendors, consultants and other service providers who are working on our behalf and require access to your information to carry out that work, such as to the process billing, know your client requirements, provide support, etc. These service providers are authorised to use your personal information only as necessary to provide services to Pure Advantage and/or the Site and Services;
      2. Pure Advantage may provide the ability to connect with various third-party applications, services and providers. If you choose to use any such third-party applications or services, we may share information about you including your username and any Content you disclose in connection with those applications and services, and such third parties may contact you directly as necessary. This Privacy Policy does not apply to your use of such third-party applications and services, and we are not responsible for how those third parties collect, use and disclose your information and Content (if any). We encourage you to review the privacy policies of those third parties before connecting to or using their applications or services to learn more about their information and privacy practices;
      3. we may disclose your information to a third party, if:
         1. we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request;
         2. to enforce our agreements, policies and Terms of Service;
         3. to protect the security or integrity of the Site and/or Services;
         4. to comply with our obligations as a charitable organisation and maintain charitable status;
         5. to protect Pure Advantage, our stakeholders or the public from harm or illegal activities;
         6. to respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person; or
         7. to any other third party with your prior consent; and
         8. any information aggregated or pseudonymised, anonymised information with third parties that does not directly identify you.
4. SECURITY
   1. While no service is completely secure, Pure Advantage will endeavor to protect information about you from loss, theft, misuse, unauthorised access, disclosure, alteration and destruction.
   2. The servers on which personal information is stored are kept in a controlled environment with limited access. While we will endeavor to guard personal information we knowingly collect directly from you, no security system is impenetrable. In addition, we cannot guarantee that any passively-collected personal information you choose to include in documents you store on our systems are maintained at levels of protection to meet specific needs or obligations you may have relating to that information.
   3. You may access your account information only through the use of an individual user ID and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been misused. In addition, always logout and close your browser when you finish your session. Please note that we will never ask you to disclose your password in an unsolicited phone call or email.
   4. If you have any questions about the security of your personal information, you can contact us at info@puradvantage.org.
5. YOUR RIGHTS
   1. You have the right to access the personal information we hold about you, where it is stored, and if it is held in such a way that it can be readily retrieved. If the personal information we hold about you is not accurate or complete, then you may ask us to correct it.
   2. You may update, correct or delete information about you at any time by logging into your online account and modifying your information or by emailing us at info@puradvantage.org.
   3. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy. If you wish to deactivate any account that has been established, please email us at info@puradvantage.org, but note that we may retain certain information as required by law or for legitimate business or charitable purposes. We may also retain cached or archived copies of information about you for a certain period of time. We will respond to your access request within 30 days.
   4. We will retain your information for as long as your account is active or as needed to provide you Services. We will retain and use your information to comply with our legal obligations, resolve disputes and enforce our agreements.
   5. We will retain personal information necessary to comply with its legal and tax obligations, resolve disputes and enforce its rights.
   6. Upon request, Pure Advantage will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information that we are aware of. To request this information, contact us at info@puradvantage.org.
   7. You may opt out of receiving promotional and newsletter emails from Pure Advantage by following the opt-out instructions provided in those emails. You may also opt-out of receiving promotional emails and other promotional communications from us at any time by emailing info@puradvantage.org with your specific request. If you opt out, we may still send you non-promotional communications, such as security alerts and notices related to your access to or use of the Site and Services or those about your online account or our ongoing business relations.
   8. The right to request that we transfer or port elements of your data either to you or another service provider.
   9. The right to complain to your data protection regulator.  In New Zealand this is the Privacy Commissioner.
6. SOCIAL MEDIA FEATURES AND WIDGETS
   1. The Services may include social media features. These features may collect your IP address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on a Pure Advantage Service. Your interactions with these features are governed by the privacy notice of the company providing it.
7. COMMUNITY FORUMS AND BLOGS
   1. The Site may offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them.
   2. To request removal of your personal information from our blog or testimonials, contact us. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
8. LINKS TO THIRD PARTY WEBSITES
   1. We may place links on or through the Site and Services. When you click on a link to a third party website from our website, your activity and use of the linked website is governed by that website’s policies, not by those of Pure Advantage. We encourage you to visit their websites and review their privacy and user policies.