Introduction and Scope

At GDT, we believe that doing what is right to protect the privacy of every individual we engage with is fundamental to the integrity of our business. This includes respecting the privacy of our employees, shareholders, customers, suppliers, vendors, and all other stakeholders from whom we collect Personal Information.

This Privacy Statement applies to GlobalDairyTrade Holdings Limited and each of its subsidiaries whereover located ("GDT", “we”, “us” or “our”).  Our main office is in Auckland, New Zealand, but we operate in various offices around the world, and we partner with Service Providers across the globe.

GDT is committed to protecting your privacy and complying with obligations established by the European Union’s General Data Protection Regulation (GDPR) and New Zealand Privacy Act 2020 (Privacy Act).

Application of This Statement

This Statement applies to GDT’s websites, domains, applications, services, and products.

It applies to you when you:

• Make use of our applications and services as an authorised user
• Visit any of our websites that link to this Privacy Statement
• Receive any communication from us including newsletters, emails, calls, or texts / SMS
• Provide us with any Personal Information.

It does not apply to third-party applications, websites, products, services, or platforms that may be accessed through non-GDT links we may direct you to. These sites are owned and operated independently from GDT, and we do not accept liability for the actions or policies of these parties.

Collection and Use of Your Personal Information

GDT only collects Personal Information that is necessary for a lawful purpose. This means we:

• Only collect and use Personal Information for lawful and relevant purposes,
• Only collect information that we need, and
• Make every effort to keep all information confidential.

Personal Information GDT may collect, and hold includes:

• When you register online or with our sales team - We collect your full name, email address, telephone number and other contact details.
• Your communications with us
• When you use or view our website or our Applications - We collect your Personal Information used on our applications including preferences and interaction information and aggregated data on usage which we may collect using various mechanisms, such as cookies.
• When you purchase our services – We collect details such as your banking information and order history.
• From third parties including the results of criminal or credit checks and the results of business or tax conduct related obligations. We may need this information for the assessment and acceptance of customers, suppliers, and business partners.

Obtaining Your Consent

When collecting your Personal Information, GDT will obtain your consent and inform you whether the requested information is voluntary to provide. If you choose not to provide certain information, this may impact your use of certain services.

Use of Your Personal Information

GDT processes your Personal Information lawfully and may use it for several purposes, which include:

• Assessing your eligibility for our services and completing your registration including communicating with third parties for this purpose
• Communicating with you
• Sending you offers and marketing
• To enable us to provide our products and services to you
• Managing our relationship with you
• Managing and improving our products and service offering
• Maintaining GDT's business interests including fraud prevention, debt recovery maintaining system security and compliance with our legal obligations

Cookies

What Are Cookies?

A web cookie is a small file with information that your browser stores on your device. Information in this file is typically shared with the owner of the site in addition to potential partners and third parties to that business. The collection of this information may be used in the function of the site and/or to improve your experience.

How We Use Cookies

To provide you with the best experience possible, we collect analytics data about the types of visitors to our site in order to improve our website services. The data we collect includes which web pages have what percentage of visitors, the number of clicks people make on a particular web page, and the percentage of visitors coming from different countries. Please note, cookies are not set at an individual customer-level. These cookies are set by our service providers (e.g., Google Analytics). Google utilises the data it collects via cookies on our websites with data collected across other Google services. To find about more about how Google collects and processes data, see Google's Privacy & Terms.

How to Control Your Cookies

You may be able to change your browser settings to manage and control cookies. See detail in GDT Cookies Statement.

Data Security, Integrity, and Retention of Your Personal Information

GDT holds Personal Information in the form of both electronic and physical copies, that we retain only for as long as we have a lawful purpose. GDT has established appropriate technical and organisational protocols to enhance cyber security within GDT.

Privacy Breaches

A privacy breach is any unauthorised or accidental collection, access, use, alteration, destruction, or disclosure of Personal Information and extends to circumstances where Personal Information is shared without the individual’s explicit consent. Should GDT experience a privacy breach that has caused (or is likely to cause) serious harm to individuals, we commit to complying with our legal obligations. This includes notification of privacy breaches to the relevant privacy authorities and to impacted individuals of the breach.

Sharing Your Personal Information

General Information About Disclosure of Personal Information

We will not disclose Personal Information to any third parties without your consent, except when required or permitted by law, including situations where the disclosure is one of the purposes (or directly related purposes) for which we obtained the information. This includes disclosure of Personal Information to or for:

• Our Agents, Services Providers and Suppliers - When we work with our Service Providers.
• Business Transitions - In the event we undergo a business transition that involves another company, information we have collected from or about you may be disclosed to such other entities as part of the due diligence or business integration process and will be transferred to such entity as one of the transferred assets.
• Legal and Regulatory Requirements - To the extent required by relevant, applicable law or regulation, we may be obligated to disclose Personal Information to government authorities or to third parties.

Data Transfers

GDT operates globally and may transfer Personal Information to or store your Personal Information at GDT’s third parties in locations around the world for the purposes described in this statement.

Your Personal Information will be protected by reasonable security safeguards when it is stored or processed by us, and any Personal Information transferred overseas to GDT's third parties will be protected in a way that overall provides comparable safeguards to applicable privacy laws, including those in the Privacy Act. 

Your Rights

GDT undertakes to respect your rights regarding your Personal Information. Under this statement, you have the right to:

• Request access to your Personal Information
• Request correction of the Personal Information that we hold about you
• Request erasure of your Personal Information - When there is no good reason for us to continue processing it
• Object to processing of your Personal Information - We provide GDT customers the ability to exercise certain controls and choices regarding our use and sharing of your Personal Information.
• Withdraw your consent on the use of your Personal Information

If you are unable to perform these actions, please contact us so we can assist you.

Exercising Your Rights

You may exercise your rights of access, rectification, cancellation, or make a complaint by contacting us and we will endeavour to respond to your request as soon as possible and within 20 working days. Please note, we may ask you to verify your identity before responding to such requests.

GDT may in certain circumstances decide to withhold Personal Information in accordance with relevant laws and regulations. GDT will outline the type of information that is being withheld and the reason why.

To view any Personal Information we hold about you, or if you have any concerns or questions about the Personal Information that we hold and wish to request a correction, please contact GDT’s Privacy Officer by email at: privacy.officer@globaldairytrade.info

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information.

Changes to this Privacy Statement

We may modify this statement at any time. If we make changes to it, we will post an updated version to this webpage. When using our services, you will be asked to review and accept our statement. In this manner, we may record your acceptance and notify you of any future changes to this statement.

Appendix – Privacy Terms