1. Syndex is committed to protecting all personal information that we collect, use, disclose and store as part of fulfilling our regulatory and legal obligations. We are committed to protecting personal information and meeting our privacy obligations. We refer to "personal information" as "Information" in this Policy, and it means any information about an identifiable individual.
2. This Policy sets out how we collect, store, process, use and disclose Information. For example, this can include:
2.1. Information that we may collect when any customers (who we refer to as "Participants") register on Syndex or utilise the services provided by Syndex.
2.2. Information we collect when individuals visit our website or contact us.
2.3. Information that we are provided by Participants and Issuers, including Information of our Issuers' customers.
3. We may need to vary this Policy from time to time. We will do so by updating our website and, where appropriate, by notifying Participants directly.
4.1. Information is collected from Issuers or Participants. For example, we collect Information when Participants register on Syndex or utilise our services.
4.2. By registering on Syndex or utilising the services provided by Syndex, Participants consent to the collection, use, disclosure, storage, processing, and disclosure of their Information as part of the registration process. This includes, but is not limited to, disclosure of Information to third parties for identity verification and customer due diligence ("CDD") purposes in respect of the requirements under anti-money laundering legislation.
4.3. Participants' Information may also be collected from third parties where Syndex believes the Participant has agreed for their Information to be disclosed to, and used by, Syndex.
4.4. This Policy applies to all instances where Information is collected from Participants or from third parties.
5. The type of Information we collect will include:
5.1. All relevant Information associated with a Participant as an individual, company, trust or other entity.
5.2. Designated bank account number.
5.3. Preference information, such as a favourites list, transaction history and marketing preferences.
5.4. All communications initiated with Syndex via writing, email or phone.
5.6. Any further Information we may request from time to time.
6. Participants authorise Syndex to collect, store, process and use Information for the purposes of:
6.1. opening, operating, administering and maintaining their account on the Exchange and any products or services provided to them by Syndex or Syndex’s related companies (whether incorporated in New Zealand or elsewhere);
6.2. confirming their identity and address, for example, electronically matching Information with identification information in third party databases;
6.3. providing them with the use of, and information about, any other of Syndex’s products and services and products and services of Syndex’s related companies (whether incorporated or constituted in New Zealand or elsewhere). This information may be sent electronically, for example, by text message or email;
6.4. improving our operations, products and services;
6.5. Syndex or its related companies (whether incorporated or constituted in New Zealand or elsewhere) complying with regulatory and other requirements (for example, liquidity requirements);
6.6. managing our relationship with Participants and Issuers, for example, so we can respond to Participants' queries;
6.7. monitoring and screening Participants' accounts, products and services for anti-money laundering and countering financing of terrorism purposes and for fraud and crime detection purposes; and
6.8. conducting market research, data processing and statistical analysis.
7. Participants authorise Syndex to obtain, and retain, Information from Syndex’s related companies (whether incorporated or constituted in New Zealand or elsewhere) or any third parties for the purposes described in clause 4.
8. Participants, Issuers and any other third parties that provide Syndex with Information, agree and warrant that they have authorisation from the individuals to whom the Information relates in order for Syndex to collect, and use, the Information in accordance with this Policy.
9. Participants agree that the Information may be disclosed to:
9.1. Syndex’s related companies (whether incorporated or constituted in New Zealand or elsewhere) that provide services to, or for, Syndex. We note that where information is transferred outside New Zealand, those third parties will be subject to privacy laws in their own jurisdiction and those privacy laws may be different to New Zealand's laws;
9.2. Syndex’s agents and other third parties (whether in New Zealand or overseas) that provide services to, or for, Syndex;
9.3. Issuers, our agents and other third parties for identify verification and customer due diligence purposes in respect of the requirements under anti-money laundering legislation;
9.4. any other registries where we are required to do so under the laws, rules or regulations applying to that party;
9.5. any regulator where Syndex is required to do so by law;
9.6. the police, certain governmental agencies, regulators or other financial institutions where Syndex reasonably believes that disclosure will assist the investigation, detection or prevention of fraud or other criminal offences or where we are required by law;
9.7. credit reporting agencies, other credit providers and debt collecting agencies;
9.8. research firms engaged by Syndex to carry out customer surveys and conduct market research;
9.9. third parties if Syndex is selling, assigning or transferring any of our assets or business or commercial operations; and
9.10. any other party authorised by the Participant.
10. The Participant further authorises the release to Syndex of any Information held by credit reporting agencies and credit providers and authorises Syndex to disclose Information held about themselves to credit reporting agencies and Syndex’s customers, when they use Syndex’s credit reporting services, for the purpose of monitoring the Participant’s on-going creditworthiness.
11. Information will be collected and held by Syndex. Participants have rights of access to, and correction of, their Information that we hold. For any requests or questions relating to privacy, please contact firstname.lastname@example.org.
12. All reasonable steps will be taken to ensure that Information is treated and kept as confidential by all third-parties who receive the Information.
13. If a Participant refuses to provide mandatory Information, they may not be able to register and may not be able to participate in any of Syndex’s markets.
14. Syndex will take all reasonable steps to ensure that Information that has been collected, used or disclosed is accurate, complete, up-to-date and stored in a secure environment protected from unauthorised access, modification or disclosure.
15. Information will be kept in accordance with applicable privacy laws.
16. Syndex may set and access Cookies on Participant computers in order to collect non-personal information including type of operating system, domain name and IP address. Cookies are small files of data sent by a website to your browser, which may then be stored on your hard drive or device so we can recognise you when you return. The information collected is anonymous and is used for the purpose of understanding Participant behaviour when using the Syndex platform.
Version 2.0 (December 2020)