Sygmative Ltd. - NZBN 9429053428356
Level 6 - AON Building

1 Willis Street

Wellington 6011 - New Zealand

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Last updated: February 2026

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1. Introduction

This Privacy Policy explains how Sygmative Ltd. ("we", "us", or "our") collects, uses, stores, and protects personal information in accordance with the New Zealand Privacy Act 2020 and applicable international privacy standards.

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Because we offer our services to clients globally, including individuals and businesses located in the European Union (EU), European Economic Area (EEA), and the United Kingdom (UK), certain obligations under the General Data Protection Regulation (GDPR) and the UK General Data Protection Regulation (UK GDPR) may apply when we process personal information from those regions.

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By using this website or engaging our services, you acknowledge that you have read and understood this Privacy Policy.

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2. Personal Information We Collect

You are not required to provide personal information to us. However, if you choose not to, certain parts of the website or aspects of our services may not be available.

We may collect personal information including, but not limited to:

• Name, business name, and contact details

• Billing and payment information

• Information provided during inquiries or engagements

• Website usage data (such as IP address, browser type, and device information)

We collect personal information only where it is necessary for legitimate business purposes.

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3. How We Collect Personal Information

Personal information is collected when you:

• Contact us via this website or email

• Engage our consulting services

• Submit information through forms or payment platforms

• Communicate with us during an engagement

We may also collect technical information when you visit our website, including how users arrive at, navigate, and interact with the site. This may include IP address, browser type, device identifiers, and usage patterns.

Where possible, we collect personal information directly from you.

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4. Purpose of Collection

We collect and use personal information to:

• Provide and manage consulting services

• Communicate with clients

• Issue invoices and receive payments

• Conduct statistical analysis and service improvement

• Carry out research and development

• Market our services to you (where permitted)

• Meet legal, regulatory, and tax obligations

We do not sell personal information.

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4A. Information Processed on Behalf of Clients

In providing consulting services, we may process personal information on behalf of our clients. This may include information contained in operational systems, workflow documentation, analytics datasets, trading environments, or other materials provided to us during an engagement.

 

In such circumstances:

• The client determines the purposes and means of processing the personal information.

• The client remains responsible for compliance with applicable privacy laws.

• We act solely in accordance with the client’s instructions and our contractual obligations.

• We do not use personal information provided by clients for our own independent purposes, except as necessary to deliver our services or as required by law.

 

Our confidentiality obligations under applicable engagement agreements operate in addition to this Privacy Policy.

 

We do not sell, trade, or use client-provided data to train artificial intelligence systems or for unrelated commercial purposes unless expressly authorized by the client.

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5. Storage and Security

We take reasonable and appropriate technical and organizational measures to protect personal information from loss, misuse, unauthorized access, alteration, or disclosure.

 

These measures include access controls, secure cloud-based infrastructure, contractual confidentiality obligations, and limiting access to authorized personnel who require the information for legitimate business purposes.

 

Personal information is stored securely using reputable service providers. These providers may be located in New Zealand or overseas.

 

Where information is stored or processed outside New Zealand, the EU/EEA, or the UK, we take reasonable steps to ensure that overseas recipients protect the information in a manner consistent with the Privacy Act 2020 and, where applicable, GDPR or UK GDPR requirements. This may include contractual safeguards or equivalent protections.

 

6. Lawful Basis for Processing (GDPR/UK GDPR)

For individuals located in the EU/EEA or UK, we rely on the following lawful bases:

• Contract – processing necessary to provide our services

• Legitimate interests – business operations, security, and service improvement

• Consent – analytics cookies and optional communications

• Legal obligation – tax, accounting, and regulatory requirements

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7. Disclosure of Information

We generally do not disclose personal information to third parties for their own purposes. However, we may disclose information:

• To service providers who support our operations (e.g., hosting, accounting, payment processing)

• In connection with a proposed purchase, merger, or acquisition of our business or assets

• Where required by law, court order, or a legitimate request from a regulatory or law enforcement authority

These parties may only use the information for the purposes for which it was provided.

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8. Overseas Disclosure

We may use cloud-based systems or service providers that store personal information outside New Zealand.

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Where personal information is transferred outside New Zealand, the EU/EEA, or the UK, we take reasonable steps to ensure that overseas recipients protect the information in a manner consistent with the Privacy Act 2020 and, where applicable, GDPR or UK GDPR.

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​9. Access and Correction Rights

You have the right to request access to, or correction of, your personal information.

 

Before responding to a request for access or correction, we may require reasonable evidence to confirm your identity and ensure that personal information is disclosed only to the appropriate individual.

 

If you are located in the EU/EEA or UK, you also have the following rights:

• Right to erasure

• Right to restrict processing

• Right to object

• Right to data portability

• Right to withdraw consent

• Right to lodge a complaint with your local data protection authority

 

If you are not satisfied with our response to your privacy concern, you may lodge a complaint with the Office of the Privacy Commissioner (New Zealand) at www.privacy.org.nz or with your local data protection authority in the EU/EEA or the UK.

 

Requests can be made by contacting us at: connect@sygmative.com

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10. Retention of Information

We retain personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, to meet contractual obligations, or to comply with legal, tax, or regulatory requirements.

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Retention periods may vary depending on the type of information, including:

• Client engagement records and related documentation

• Financial and billing records (retained in accordance with applicable tax laws)

• Marketing and communication records (retained until you opt out or request deletion)

• Technical and website usage information (retained for operational and security purposes)

 

When personal information is no longer required, we take reasonable steps to securely delete or anonymize it.

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11. Data Breach Notification

In the unlikely event of a data breach that poses a risk of serious harm, we will:

• Take immediate steps to contain and assess the breach

• Notify affected individuals as soon as practicable

• Notify the Office of the Privacy Commissioner where required under the Privacy Act 2020

• Implement remedial actions to prevent recurrence

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12. Cookies and Analytics

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12.1 Use of Cookies

We use cookies and similar technologies to ensure the security, functionality, and performance of this website. Cookies help us understand how visitors use the site and support essential website operations.

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12.2 Types of Cookies We Use

• Essential cookies – Required for core functionality, security, and navigation

• Analytics cookies – Used to understand website usage and improve performance (activated only with consent where required)

• Functional cookies – Support optional features such as remembering preferences

• Third-party cookies – Certain tools or integrations may set their own cookies and operate under their own privacy policies

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12.3 Legal Basis

For visitors in the EU/EEA and UK:

• Essential cookies → legitimate interests

• Analytics cookies → explicit consent

For visitors in New Zealand, cookies are used in accordance with the Privacy Act 2020.

For all other regions, cookies are processed in line with applicable local privacy laws.

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12.4 Your Choices

You may accept, decline, or manage non-essential cookies through the cookie banner (where available). You can also disable cookies through your browser settings. Disabling certain cookies may affect website functionality.

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13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The most current version will be published on this website and will apply to future interactions.

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14. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your privacy rights, please contact: connect@sygmative.com

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This Privacy Policy is governed by the laws of New Zealand.