Privacy Policy

Last updated: 25 April 2025

Introduction

CF Business Consultant Ltd, trading as Adster ("Adster," "we," "our," or "us"), is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and share your personal information when you use our website (www.adster.co.nz) and services. It also outlines your rights under the New Zealand Privacy Act 2020 and other applicable laws. By using our website or services, you agree to the terms of this Privacy Policy.

Personal Information We Collect

We collect various types of personal information in order to operate our business and provide our services:

• Information You Provide to Us: When you fill out forms on our site (for example, our contact form or service sign-up form), we collect the information you submit. This may include your name, email address, phone number, company name, and any other details you choose to provide.

• Affiliate Program Information: If you apply to join our affiliate program, we will ask you to verify your identity. This process, which is facilitated through a third-party form provider (Jotform), involves collecting a photo of you (a "selfie") and a copy of a government-issued ID. We use this information solely to verify your identity for the affiliate program. Important: Once your identity has been verified, we delete the copy of your ID from our records.

• Payment Information: When you make payments for our services, these transactions are handled by third-party payment processors (such as PayPal). Adster does not collect or store your credit card numbers or bank account details. We receive from the payment processor a confirmation that payment was made and basic information (such as your name and the amount paid) to record the transaction.

• Information Collected Automatically: When you visit our website, our system and third-party analytics tools automatically collect certain technical information about your device and usage of the site. This includes your IP address, browser type, device type, operating system, referring website, pages you viewed, and the dates/times when you accessed the site. We may also collect information through cookies or similar tracking technologies (see Cookies and Analytics below).

Cookies and Analytics

We use cookies and similar technologies on our website to enhance your user experience and to collect usage data:

• Cookies: Cookies are small text files that websites place on your device to store data. Our site may use essential cookies for functionality (for example, to remember your preferences or keep you logged in, if applicable) as well as analytical cookies.

• Analytics Tools: We use third-party analytics services, such as Google Analytics, to understand how visitors use our website. These services use cookies and scripts to collect information about your interaction with our site, such as the pages you visit, how long you stay on each page, and which links you click. This information helps us improve our website and services. The analytics data collected is generally aggregated and does not directly identify you. However, it may include your IP address and some device information which can be considered personal information under certain laws.

• Your Choices: Most web browsers allow you to refuse or delete cookies. You can set your browser to refuse all or some cookies, or to alert you when cookies are being sent. However, if you disable or refuse cookies, some parts of our site might become inaccessible or not function properly.

How We Use Your Information

We use the personal information we collect for the following purposes:

1. Providing and Improving Services: To deliver the services or information you request, to manage our relationship with you (such as setting up and administering your account or affiliate profile), and to improve and personalize your experience with Adster.

2. Communication: To communicate with you about our services, respond to your inquiries, send important notices (such as updates about your account or changes to our terms or policies), and, where you have consented, send promotional emails about new services or offers. (You can opt out of marketing communications at any time.)

3. Affiliate Program Verification: For affiliate program applicants, to verify your identity and eligibility. The selfie and ID you provide are used strictly for fraud prevention and compliance purposes in the affiliate program.

4. Analytics and Service Enhancement: To analyze website usage and performance through tools like Google Analytics, which helps us understand user behavior and improve our website design, functionality, and content.

5. Security and Fraud Prevention: To protect our business, website, and users from fraud, malicious activity, or other illegal activities. For example, we may use certain data to detect and prevent security incidents or other harmful activities.

6. Legal Compliance: To comply with legal obligations, such as maintaining records for tax purposes or responding to lawful requests by governmental authorities.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another related purpose that is compatible with the original purpose. If we need to use your information for an unrelated purpose, we will notify you and, if required, seek your consent.

How We Share Your Information

We value your privacy and do not sell your personal information to third parties. However, we may share your information with trusted third parties when necessary to operate our business or provide our services to you, as outlined below:

• Service Providers and Partners: We share personal information with third-party service providers and business partners who help us operate our business and provide our services. For example:

  • We use third-party companies for payment processing (e.g., PayPal). When you make a payment, you are redirected to the payment processor’s platform, and the information you provide to them is subject to their privacy policies. We receive a record of your payment but do not see or store your sensitive payment details.

  • We use analytics providers like Google Analytics to collect usage data (as discussed above under Cookies and Analytics).

  • We may use cloud hosting services or IT support providers that process data on our behalf to ensure our website and systems run smoothly.

  • For our affiliate program, we use Jotform to collect your application (including your ID documentation). Jotform acts as a data processor by transmitting your information to us and may temporarily hold that data on their servers. We have agreements or assurances in place with such providers to ensure your information is handled securely and only for the intended purpose.

• Legal Compliance and Protection: If necessary, we may disclose your information for legal reasons or safety concerns (see Legal Compliance and Disclosures below for details).

• Business Transactions: In the event that our company is involved in a merger, acquisition, sale of assets, or other business transaction, personal information held by us may be among the assets transferred to the buyer or new owner. If such a transfer occurs, we will ensure the new owner is bound to respect your personal information in a manner consistent with this Privacy Policy.

• With Your Consent: We will disclose your personal information to a third party if you have given us your explicit consent to do so for a specific purpose. For example, if you instruct us to share your contact details with one of our partners in order to facilitate a service or consultation, we will share it as directed by you.

All third parties with whom we share personal data are required to handle your data in a manner consistent with this Privacy Policy and to use it only for the purposes of providing their services to us (or to you on our behalf).

International Data Transfers

Adster is based in New Zealand, but the personal information we collect may be transferred to and stored in countries outside of New Zealand. This can happen, for example, when we use cloud storage or service providers that are located overseas (such as web hosting services, or tools like Google Analytics and Jotform which may store data on servers in the United States or other countries).

When we transfer your personal information to an overseas recipient, we will ensure that your information is afforded a comparable level of protection as it is under New Zealand's Privacy Act 2020. We will do this by, for example:

• Only transferring your data to countries that have robust data protection laws; or

• Entering into contracts with the receiving party that require them to protect your information to New Zealand privacy standards; or

• In some cases, relying on your explicit consent where the transfer is necessary for the service we provide to you (we will inform you and obtain your consent in those situations).

By using our services or providing us with your personal information, you consent to the transfer of your information outside New Zealand in the ways described above. Regardless of where your information is processed, we will take all reasonable steps to ensure it is treated securely and in accordance with this Privacy Policy.

Data Retention

We will retain your personal information only for as long as it is needed to fulfill the purposes for which it was collected (as described in this policy), or as required by law.

• Client and Service Data: If you are a client or user of our services, we will retain your personal data for the duration of our relationship with you, and then for up to 12 months after you cease to use our services. This retention period allows us to conclude any ongoing obligations, resolve potential disputes, or answer any questions you may have about the services you received. After this period, we will securely delete or anonymize the personal data, unless we are legally required to retain it for longer.

• Affiliate Program Data: Personal information collected for the affiliate program (such as your ID verification documents) is retained only as long as necessary to verify your identity and set up your affiliate account. We delete copies of identity documents (e.g., your photo ID) promptly after verification. Other affiliate-related information may be kept for the duration of your participation in the program and for a reasonable period (up to 12 months) after it ends, similar to other client data.

• Legal Obligations and Disputes: In certain cases, we may need to retain some information for longer than the periods above. For example, we might retain records if we are required to by law (such as for tax compliance, audits, or legal filings), or if we need to preserve information for an ongoing or potential legal dispute. In such cases, we will retain only the information necessary for those purposes and for only as long as required.

Once we no longer have a legitimate business need or legal obligation to keep your personal information, we will securely delete it or anonymize it so you can no longer be identified.

Data Security

We take the security of your personal information seriously and implement reasonable measures to protect it from loss, misuse, unauthorized access, alteration, or disclosure. These measures include physical, technical, and administrative safeguards:

• Access Controls: We limit access to personal information to employees and contractors who have a need to know it for their role, and we ensure they are subject to confidentiality obligations.

• Encryption: Our website uses SSL/TLS encryption (indicated by the "https://" and padlock symbol in your browser’s address bar) to protect data transmitted between your device and our servers. We also employ encryption and other security protocols where appropriate on our backend systems and databases.

• Security Practices: We maintain up-to-date security software, firewalls, and intrusion detection systems to guard our IT infrastructure. We also regularly review our information collection, storage, and processing practices to prevent unauthorized access and update them in line with new threats or best practices.

• Third-Party Security: When using third-party service providers (such as web hosts, payment processors, or form collection tools), we choose reputable providers and require that they have appropriate security measures in place to protect personal information.

While we strive to protect your data, no method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security. In the event of a data breach that poses a risk of serious harm, we will notify you and the New Zealand Privacy Commissioner as required under the Privacy Act 2020, and we will take all necessary steps to mitigate the breach and prevent future occurrences.

Your Rights and Choices

Under the New Zealand Privacy Act 2020, as well as other applicable data protection laws, you have certain rights regarding your personal information. These include:

• Right to Access: You have the right to request confirmation of whether we hold personal information about you, and to request a copy of that information. We will provide you with access to your personal data that we have, unless an exception under the law applies. We will respond to access requests within a reasonable time frame.

• Right to Correction: You have the right to request that we correct or update any personal information we hold about you that is inaccurate, incomplete, or outdated. Upon request, we will correct the information if we agree it is wrong, or if we do not agree, we will mark on our records that a request to correct was made.

• Right to Deletion: You can ask us to delete the personal information we hold about you in certain circumstances. For example, if the information is no longer necessary for the purposes for which it was collected, or if you withdraw your consent (where consent was the basis for collection). We will take reasonable steps to erase your data upon request, provided there is no legal requirement or compelling reason for us to retain it.

• Right to Restrict Processing: You have the right to request that we limit the processing of your personal information if you have a specific reason, such as you contest the accuracy of the data or object to us processing it. When processing is restricted, we can store the data but will not use it further until the issue is resolved (unless we have your consent or there are legal grounds to continue).

• Right to Withdraw Consent: If we are processing any personal information based on your consent, you have the right to withdraw that consent at any time. For example, you may withdraw consent for receiving marketing emails by unsubscribing.

• Opt-Out of Marketing: If you no longer wish to receive marketing communications from us, you can opt out by using the unsubscribe link in our emails or by contacting us to request removal from our marketing list. Please note that even if you opt out of marketing messages, we may still send you transactional or service-related communications (such as billing invoices or service notifications).

To exercise any of these rights, please contact us using the details provided in the Contact Us section below. We may need to verify your identity before fulfilling certain requests to ensure we do not disclose information to the wrong person. We will not charge you a fee for making a request unless it is unfounded or excessive, in which case we will inform you of the fee and explain why it's applicable.

We will endeavor to respond to all legitimate requests as quickly as possible, and within the timeframes set by the Privacy Act 2020. If we cannot comply with your request (for example, if fulfilling it would infringe on the rights of another person or if we have a legal obligation to retain certain data), we will explain the reasons in our response.

Children’s Privacy

Our website and services are not intended for individuals under the age of 18. We do not knowingly solicit or collect personal information from children under 18. If you are under 18, please do not use our website or provide any personal information to us.

If we learn that we have inadvertently collected personal information from someone under 18, we will delete that information as soon as possible. If you are a parent or guardian and you believe we might have collected information from your child, please contact us immediately so we can investigate and take appropriate action.

Legal Compliance and Disclosures

We may disclose your personal information to third parties if we believe such disclosure is necessary to:

• Comply with the law: We will share information if we are required to do so by New Zealand law or other applicable laws and regulations. This includes complying with court orders, subpoenas, or other legal processes.

• Respond to lawful requests: If we receive a valid request from law enforcement or other government authorities (such as the New Zealand Police or regulatory agencies) relating to national security, criminal investigations, or alleged illegal activity, we may release whatever information is required.

• Enforce our rights and agreements: We may disclose information in order to enforce or apply our Terms and Conditions and other agreements, or to investigate potential violations of those terms.

• Protect rights and safety: We may share information as necessary to protect the rights, property, or safety of Adster, our employees, our users, or others. For example, we might share information to prevent harm or in connection with efforts to investigate or stop fraudulent or illegal activities.

When disclosing information for the above purposes, we will only provide the data that we believe is reasonably required to fulfill the relevant obligation or request. We will always take your privacy into account and comply with applicable privacy laws when making such disclosures.

Changes to This Privacy Policy

We reserve the right to modify or update this Privacy Policy at any time. We may revise this policy to reflect changes in our practices, to clarify our procedures, or to ensure compliance with legal requirements. When we make changes, we will update the "Last updated" date at the top of this policy. If the changes are significant, we will provide a more prominent notice (such as a notification on our website or an email to affected users).

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal information. Your continued use of our website and services after any modifications to this Privacy Policy will signify your acceptance of the changes.

Contact Us

If you have any questions or concerns about this Privacy Policy or about how your personal information is handled, please contact us:

CF Business Consultant Ltd (trading as Adster)
Email: info@adster.co.nz

We will respond to your inquiries as soon as reasonably possible.

If you are not satisfied with our response, and you are in New Zealand, you have the right to lodge a complaint with the Office of the New Zealand Privacy Commissioner. For more information on how to make a complaint, you can visit the Privacy Commissioner's website at www.privacy.org.nz or contact their office at 0800 803 909.