Privacy Policy
Equerra Limited
Effective Date: May 1, 2026
Version: 1.0
Last Updated: April 13, 2026
Introduction
This Privacy Policy explains how Equerra Limited (Equerra, we, us, or our) collects, uses, discloses, and protects personal information when you use our software products available through Microsoft AppSource.
Who We Are:
Equerra Limited
2nd Level
40 Lady Elizabeth Lane
Wellington Central
New Zealand 6011
Email: privacy@equerra.com
What This Policy Covers:
- Personal information we collect
- How we use your information
- Who we share it with
- Your privacy rights
- How we protect your information
Related Documents:
- Terms and Conditions - Commercial terms for using our Software
- Data Processing Agreement - For GDPR customers
- Security Measures - How we protect data
- Cookie Policy - How we use cookies
1. Information We Collect
1.1 Information You Provide
Account Information:
- Name, email address, phone number
- Job title, company name
- Microsoft account details
Business Data:
- Data you enter into the Software
- Files and documents you upload
- Configurations and customizations
Communication Data:
- Support requests and correspondence
- Feedback and survey responses
1.2 Information We Collect Automatically
Usage Information:
- Features you use and how you use them
- Time, frequency, and duration of use
- Error logs and diagnostic data
Device Information:
- IP address
- Browser type and version
- Operating system
- Device identifiers
Cookies and Similar Technologies:
See our Cookie Policy for details
1.3 Information from Third Parties
Microsoft:
- Account authentication data
- Tenant configuration information
- Licensing and subscription data
2. How We Use Your Information
2.1 To Provide Services
- Deliver and maintain the Software
- Process transactions and send confirmations
- Provide customer support
- Send service-related communications
2.2 To Improve Services
- Analyze usage to enhance features
- Develop new products and services
- Conduct research and analytics
- Test and improve performance
2.3 To Communicate
- Respond to inquiries
- Send product updates and announcements
- Provide technical notices
- Send marketing communications (with consent where required)
2.4 For Legal and Security
- Comply with legal obligations
- Protect against fraud and abuse
- Enforce our Terms and Conditions
- Resolve disputes
3. Legal Basis for Processing (GDPR)
For personal data subject to GDPR, we process based on:
Contract: Processing necessary to provide services you've requested
Legitimate Interests:
- Improving our services
- Detecting and preventing fraud
- Network and information security
Legal Obligation: Complying with laws and regulations
Consent: Where required by law (you can withdraw anytime)
4. Information Sharing
4.1 With Service Providers
We share information with:
Microsoft Corporation (Azure hosting, Business Central platform)
Purpose: Cloud infrastructure and service delivery
Location: Your selected tenant region
Safeguards: Standard Contractual Clauses, Azure security
Microsoft Azure OpenAI (optional, when enabled)
Purpose: AI-powered features
Location: Your selected region (Australia, Europe, or USA)
Safeguards: No training on your data, deletion after processing
Full list: Sub-Processor List
4.2 For Legal Reasons
We may disclose information:
- To comply with legal obligations
- To respond to lawful requests from authorities
- To protect our rights and property
- To prevent harm or illegal activity
4.3 Business Transfers
If we're involved in a merger, acquisition, or sale of assets, your information may be transferred. We'll notify you before transfer.
4.4 With Your Consent
We may share information for other purposes with your consent.
4.5 We Don't Sell Your Information
We do not sell personal information to third parties for their marketing purposes.
5. International Data Transfers
5.1 Where We Process Data
Personal data may be processed in:
- New Zealand (where Equerra is based)
- Your selected Microsoft Azure region
- Locations where our sub-processors operate
5.2 Safeguards for International Transfers
European Economic Area / UK / Switzerland:
- Standard Contractual Clauses (EU Commission approved)
- Adequate security measures
- Transfer impact assessments
Australia:
- Cross-border disclosure safeguards (APP 8)
- Equivalent privacy protections
New Zealand:
- Comparable privacy protections (IPP 12)
Details: See Data Processing Agreement
6. Data Retention
6.1 Active Subscription
We retain your information while your subscription is active to provide services.
6.2 After Termination
30-day retrieval period: Data available for export
Production deletion: After 30 days
Backup deletion: Within 90 days
Legal holds: May retain if required by law
6.3 Retention Criteria
We determine retention periods based on:
- Legal and regulatory requirements
- Business purposes
- Legitimate interests
- Your instructions
7. Your Privacy Rights
7.1 Rights for Everyone
Access: Request copies of your personal information
Correction: Request correction of inaccurate information
Deletion: Request deletion of your information
Objection: Object to certain processing
Restriction: Request restriction of processing
Portability: Receive your data in machine-readable format
To Exercise Rights: Email privacy@equerra.com
Response Time: Within 30 days (may extend to 60 days for complex requests)
7.2 Additional Rights (GDPR)
If you're in the EEA, UK, or Switzerland:
- Right to withdraw consent
- Right to lodge a complaint with your supervisory authority
Supervisory Authorities:
- EEA: Your local Data Protection Authority
- UK: Information Commissioner's Office (ICO)
- Switzerland: Federal Data Protection and Information Commissioner
7.3 Additional Rights (New Zealand)
Privacy Commissioner: You may complain to the NZ Privacy Commissioner
Website: www.privacy.org.nz
Email: enquiries@privacy.org.nz
7.4 Additional Rights (Australia)
OAIC: You may complain to the Office of the Australian Information Commissioner
Website: www.oaic.gov.au
Email: enquiries@oaic.gov.au
8. Data Security
We implement appropriate security measures to protect your information.
Highlights:
- Encryption in transit (TLS 1.2+) and at rest (AES-256)
- Access controls and authentication (MFA)
- Network security and monitoring
- Regular security assessments
- Employee training and background checks
Full Details: Security Measures
9. Children's Privacy
Our Software is not directed to children under 16. We don't knowingly collect information from children. If you believe we've collected a child's information, contact privacy@equerra.com and we'll delete it.
10. Marketing Communications
10.1 What We Send
- Product updates and new features
- Tips and best practices
- Industry insights and resources
- Event invitations
10.2 Your Choices
Opt-Out: Click "unsubscribe" in any marketing email
Note: You'll still receive essential service communications (billing, security, etc.)
11. Cookies and Tracking
11.1 What We Use
- Essential cookies (required for service operation)
- Analytics cookies (understand usage)
- Functional cookies (remember preferences)
11.2 Your Choices
Most browsers allow cookie management. Note that disabling cookies may affect functionality.
Full Details: Cookie Policy
12. Privacy Policy Updates
We may update this policy to reflect:
- Changes in our practices
- Legal or regulatory requirements
- New features or services
Notice: We'll post updates here and notify you of material changes via email.
Your Acceptance: Continued use after updates constitutes acceptance.
13. Privacy Officer
Contact Information:
Privacy Officer
Equerra Limited
2nd Level
40 Lady Elizabeth Lane
Wellington Central
New Zealand 6011
Email: privacy@equerra.com
Phone: +64 4 4626852
Responsibilities:
- Overseeing data protection compliance
- Handling privacy inquiries and complaints
- Coordinating data subject requests
- Managing data breach responses
14. Compliance with Privacy Laws
14.1 New Zealand Privacy Act 2020
We comply with the 13 Information Privacy Principles (IPPs), including:
- Lawful collection and use
- Direct collection where practicable
- Transparency about processing
- Secure storage and protection
- Individual access and correction rights
- Retention limitations
- International transfer protections
Key Date: IPP 3A (indirect collection notification) effective May 1, 2026
14.2 Australian Privacy Act 1988
We comply with the 13 Australian Privacy Principles (APPs), including:
- Open and transparent management
- Collection with consent and notice
- Use and disclosure limitations
- Cross-border disclosure safeguards
- Security of personal information
- Access and correction rights
14.3 GDPR (EU / UK / Switzerland)
We comply with GDPR requirements for:
- Lawful basis for processing
- Data minimization
- Purpose limitation
- Storage limitation
- Integrity and confidentiality
- Accountability
Detailed Terms: Data Processing Agreement
14.4 California Consumer Privacy Act (CCPA)
For California residents:
- We don't sell personal information
- We use personal information only to provide services
- You have rights to know, delete, and opt-out
15. Questions and Complaints
15.1 Contact Us
General Privacy Questions: privacy@equerra.com
Data Protection Officer (GDPR): privacy@equerra.com
Privacy Officer (NZ/AU): privacy@equerra.com
15.2 Complaints
If you're not satisfied with our response:
New Zealand: Privacy Commissioner (www.privacy.org.nz)
Australia: Office of the Australian Information Commissioner (www.oaic.gov.au)
EEA/UK/Switzerland: Your local supervisory authority
Version History
| Version | Date | Changes |
|---|---|---|
| 1.0 | May 1, 2026 | Initial release - comprehensive NZ/AU/GDPR compliance |
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