Privacy Policy

We are committed to protecting and respecting your privacy in accordance with our obligations under the Privacy Act 1993 (Act).

This privacy policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be used and collected by us.  By “personal information”, we mean any information that can identify you either directly or indirectly (i.e. by reference to other information we have access to).  

Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.  Additionally, this privacy policy forms part of any terms in place from time to time for any distribution or use of VALE tokens. When you access our website, register to participate in any token distribution or use any VALE tokens on the platform, you agree to the terms of this privacy policy.

This privacy policy is governed by New Zealand law and is binding on you regardless of your jurisdiction or physical location.

If you do not agree with this privacy policy, you should immediately cease accessing our website, and not participate in any token distribution or use the platform.

How we collect your personal information

Personal information you provide to us

We collect personal information you provide to us when you:

  1. register to participate in any distribution of VALE tokens – we may collect information such as your name, contact information, addresses and cryptographic signatures;
  2. provide any required identity, address or other information for compliance with anti-money laundering (AML) or know-your-customer (KYC) regulations – we may collect documentation such as your passport or domestic citizenship identification document or equivalent, tax identification or registration number (in certain cases document conveying such registration), bank account information, photographs, and/or proof of address in the form of government issued documents;
  3. provide feedback or contact us – we may collect your name, contact information as well as any other content included in the communication in order to respond to you;
  4. purchase VALE tokens – we collect your billing details as necessary in order to process the transaction;

Personal information we may collect automatically

We may collect the following personal information automatically when you:

  1. access our website or the platform – we may collect technical information about your equipment, browsing actions and patterns.  This includes internet protocol (IP) address, browser type and version and time zone settings, browser plug-in types and versions, operating system and platform and other technology on the devices you use.  We collect this personal information by using cookies and other similar technologies;
  2. access our website and the platform through a location enabled device, such as your mobile phone – we collect and process real time GPS-based information about your device’s location.  If you do not consent to us collecting location based information you can either:
    1. disable the GPS or other location tracking functions from your device if your device allows you to do this; or
    2. cease accessing the website and platform.

How we use information we collect

We will use information we hold about you in the following ways:

  1. assessing your eligibility to receive VALE tokens;
  2. providing you with VALE tokens and access to the platform;
  3. dealing with your questions or concerns and other user care related activities;
  4. ensuring that content on our website is presented in the most effective manner for you and for your computer;
  5. helping us understand your needs and interests and provide you with better services.  Specifically, we use your information to communicate with you, to provide service and support and to update you on relevant services and benefits;
  6. allowing you to participate in interactive features of our website and the platform, when you choose to do so; and
  7. notifying you about changes to our website, terms and the platform.

Data collected online by us may also be combined with information you provide us through other sources.

Non-personal information is collected for reporting about our website usability, performance, and effectiveness.  It is used to improve the user experience, usability and website content.

Who we share it with

We may disclose or share your personal information with third parties in the following circumstances:

  1. With your consent.  We may share your personal information with third parties when you have provided your consent or requested us to do so.
  2. Third party service providers.  We may share your personal information with companies who provide us services (such as information processing, delivering products to you, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys) so that we can administer the platform.  We require such service providers to contractually commit to protect the security and confidentiality of personal information they process on our behalf.
  3. Commercial partners.  We may disclose your personal details to our commercial partners where you have consented or requested us to do so.
  4. Legal purposes.  Where it is required by a third party or law enforcement authority in any jurisdiction.
  5. To enforce our rights, prevent fraud and for safety.  To protect and defend our rights, property or safety or that of third parties, including enforcing our privacy policy and terms, or in connection with investigating and preventing fraud or other suspected illegality or security issues.
  6. To protect the platform.  Where it is needed to detect, prevent or address fraud, security or technical issues.
  7. Aggregated or de-identified information.  We may disclose or use aggregated or de-identified information for any purpose. For example, we may share aggregated or de-identified information with business prospects or partners.

Use of cookies

When you visit our website, you can browse the website and access information without revealing your identity.  In order to improve our website, we use cookies to track your visit. A cookie is a small amount of data that is transferred to your browser by a web server and can only be read by the server that gave it to you.  It functions as your identification card, and enables us to record your user journey. It cannot be executed as code or deliver viruses. Cookies help us to improve our website and to deliver a better and more personalised service.  Cookies enable us:

  1. to estimate our audience size and usage pattern;
  2. to store information about your preferences, and so allow us to customise our website according to your individual interests;
  3. to speed up your searches; and
  4. to recognise you when you return to our website.

Most browsers are initially set to accept cookies.  You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies.  However, if you select this setting you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our website.

Where we store your personal information

The information that we collect from you may be transferred to, and stored at, a destination outside New Zealand.  By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this privacy policy.  However, we cannot guarantee the security of your information; therefore any transmission is at your own risk.

Children’s privacy

Our services are expressly restricted to users 18 years or older.  We will never knowingly request or solicit personally identifiable information from anyone under that age without verifiable parental consent.  If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, he or she should get in touch using the contact information provided on our website.  In the event that we receive actual knowledge that we have collected such personal information without the requisite verifiable parental consent, we will delete that information from our database as quickly as is practical.

Third Person Data

In the event you provide us with the personal information of third persons you must make sure that these third persons have reviewed and understand a copy of this privacy policy.  You should only share their personal data if you have their permission to do so and you are sure that their personal data is correct.

External sites

Our website may contain links to other sites.  Please be aware that we are not responsible for the privacy practices of such other sites.  We encourage our users to be aware when they leave our website and to read the privacy policies of each and every website that collects personally identifiable information.  This privacy policy applies solely to information collected by this website.

Your rights

You have the right to ask us not to process your personal information for marketing purposes.  We will inform you (before collecting your information) if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes.  You also have the right to ask us not to contact you about product and service updates. You can exercise your right to prevent such processing by checking certain “opt out” boxes on the forms we use to collect your information.  You can also exercise the right at any time by getting in touch using the contact information provided on our website. You will not be able to opt out of service-related communications (e.g. registration verification, purchase confirmations and changes/updates to features of the platform).

Access to information

The Act gives you the right to access information held about you so that you can update or correct it.  Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page.  We encourage you to regularly check this page. Continued access of the website, participation in any distribution mechanism or use of the platform constitutes your agreement to those changes.


Questions, comments and requests regarding this privacy policy are welcomed and should be addressed as directed in the contact information available on our website.

Last updated: 27 November 2018