Couchdrop/Movebot Privacy Policy

Version 1.3

Effective 9 May 2024

Introduction

Couchdrop Limited (we, us, our) complies with the New Zealand Privacy Act 2020 (the Act) when dealing with Personal Information. Personal Information is information about an identifiable individual, living person, and includes personal data, personally identifiable information and equivalent information. This Couchdrop Privacy Policy is referred to as the Policy in this document.

Any word or phrase that is used in this Policy and defined in the Terms of Use has the meaning given in those Terms of Use.

This Policy sets out how we will collect, use, disclose and protect your Personal Information when you interact with us, the Website or the Service.

The service is operated under (*.couchdrop.io and *.movebot.io) domains.

This Policy does not limit or exclude any of your rights under the Act. If you wish to seek further information on the Act, see www.privacy.org.nz.

You must not provide us, or use the Website or the Service to process, any Personal Information that is regulated by:

• the Payment Card Industry Data Security Standard;
• HIPAA unless and until you have entered into a separate business associate agreement with
• CCPA unless and until you have entered into a separate CCPA data processing agreement
• EU/UK Data Protection Laws unless and until you have entered into a separate EU/UK Data

Changes to this policy

We may change this Policy by uploading a revised Policy onto the Website. The change will apply from the date that we upload the revised Policy.

This Policy was last updated on 23/April 2024.

Who do we collect your personal information from

We collect Personal Information about you:

• from you, when you provide that Personal Information to us, including via the Website and the Service, through any registration or subscription process, through any contact with us (e.g. telephone call or email), or when you buy or use our services and products, including using the Website and Service
• from third parties where you have consented to (or authorised) this
• from information that is publicly available.

If possible, we will collect Personal Information from you directly.

What personal information do we collect

The types of Personal Information we collect may include:

• names
• addresses
• contact details
• identification details
• other Personal Information that you have consented to being processed through the Website

How we use your personal information

We will use your Personal Information:

• to verify your identity
• to provide the Service to you or to provide the Service to a third party (where that third party holds your Personal Information)
• to market the Service to you, including contacting you electronically (e.g. by text or email for this purpose)
• to improve the Service that we provide to you
• to undertake credit checks of you (if necessary)
• to bill you and to collect money that you owe us, including authorising and processing credit card transactions
• to respond to communications from you, including a complaint
• to protect and/or enforce our legal rights and interests, including defending any claim
• for any other purpose advised to you before or at the time of collecting the Personal Information
• for any other purpose authorised by you or the Act.

How we protect your personal information and sensitive data

Couchdrop follows industry standards to ensure that your personal information and sensitive data is secure at all times. To learn about how the Couchdrop platform works and view our policies and controls, visit https://trust.couchdrop.io:

To protect your data we ensure that:

• Your data is encrypted at rest
• Your data is encrypted while in transit
• Access to your data is audited and logged
• Your data is logically separated and isolated from other Couchdrop customers

Couchdrop security controls are audited by an external provider for compliance and this can be viewed on our trust center - https://trust.couchdrop.io

Disclosing your personal information

We may disclose your Personal Information to:

• another company within our group
• any business that supports our Service, including any person that hosts or maintains any underlying IT system or data centre that we use to provide the Website or the Service. A list of the persons (as updated from time to time by us) is included on the Website. A business that supports our Service may be located outside New Zealand. This may mean your Personal Information is held and processed outside New Zealand
• a credit reference agency for the purpose of credit checking you
• a person who can require us to supply your Personal Information (e.g. a regulatory authority)
• any other person authorised by the Act or another law (e.g. a law enforcement agency)
• any other person consented to (or authorised by) you.

In addition, you agree that:

• we may transfer your Personal Information to third parties in connection with a disposal of assets, restructuring, merger, or sale; and
• that third party is permitted to use, disclose and process your Personal Information in the same way as us.

Protecting your personal information

We will take reasonable steps to keep your Personal Information safe from loss, unauthorised activity, or other misuse. The security standards with which we comply are listed on the Website (https://couchdrop.io).

Accessing and correcting your personal information

Subject to certain grounds for refusal set out in the Act, you have the right to access your readily retrievable Personal Information that we hold and to request a correction to your Personal Information. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the Personal Information relates.

In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the Personal Information, we will make the correction. If we do not make the correction, we will take reasonable steps to note on the Personal Information that you requested the correction

If you want to exercise either of the above rights, email us at security@couchdrop.io. Your email should provide evidence of who you are and set out the details of your request (e.g. the Personal Information, or the correction, that you are requesting).

We may charge you our reasonable costs of providing to you copies of your Personal Information or correcting that information.

Internet Use

While we take reasonable steps to maintain secure internet connections, if you provide us with Personal Information over the internet, the provision of that information is at your own risk

Cookies

We use cookies (an alphanumeric identifier that we transfer to your computer’s hard drive so that we can recognise your browser) to:

• monitor your use of the Website and Service; and
• enable you to maintain your session using the Service.

You may disable cookies by changing the settings on your browser, although this may mean that you cannot use all of the features of the Website and Service.

Google API Disclosure

Couchdrop's use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

If enabled and configured; Couchdrop will connect to and receive information from Google's APIs to provide support for Google Drive in the service. Information received from Google's APIs is limited to:

• File and folder names
• Metadata such as; last modified time, size, created time
• File data and contents

Couchdrop uses this data to provide the service (detailed at https://couchdrop.io) to allow SFTP, FTP and file transfer automation and file migration services with Google Drive.

Couchdrop will not share, sell or access your data received from the Google APIs without your explicit consent;
or use the data received from Google APIs for:

• Advertising purposes
• Illegal activities
• or any activity that is not explicity configured and visible in the service provided

Retention and/or deletion of Google API data:

Couchdrop does not retain any data obtained from the Google APIs.

Files accessed by Couchdrop stored in Google Drive are not stored in the Couchdrop service/platform or website and are only accessed in transit as part of a transfer operation.

Metadata, including file and folder names are sometimes stored in audit logs as part of the Couchdrop service and this data is retained for 180 days and can be customized by the customer on request.

Contacting Us

If you have any questions about this Policy, our privacy practices, or if you would like to request access to, or correction of, your Personal Information, you can contact us at security@couchdrop.io.