Privacy Policy

Introduction

Trail 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 (a natural person).

This policy sets out how we collect, use, disclose, and protect personal information when you use Trail (including our website and CRM platform). 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.

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.

Financial advisers and client data

Trail provides CRM software to financial advisers and their organisations. Advisers may enter information relating to their own clients into the Trail platform.

In respect of client information entered into Trail by an adviser, Trail processes that information to provide the CRM service to the adviser and their organisation. The adviser (and/or their organisation) is responsible for ensuring they have the appropriate authority to collect and use their client’s information.

Where information is collected indirectly, the adviser is responsible for providing any required notices under Information Privacy Principle 3A.

What personal information do we collect

Depending on how you use Trail, we may collect:

• Account and contact details: such as your name, email address, phone number, role/occupation details, organisation details, and login/security information.
• Platform usage information: such as device/browser details, IP address, pages/screens used, diagnostic information, and support interaction history.
• Client information entered by advisers: (if you are a client of a financial adviser using our software), which may include information about financial circumstances, living situation, and health/medical information.
• Google Workspace data: (only if you connect Google) such as Gmail and Google Calendar information authorised for features inside Trail.

Google account integration

If you choose to connect your Google account to Trail, we may access certain Google Workspace data (such as Gmail and Google Calendar information) that you authorise in order to provide related features within the Trail platform, such as sending emails, synchronising communications, and displaying relevant calendar events.

Trail’s use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

We use Google user data only to provide and improve user-facing features within the Trail platform. We do not use Google user data for advertising purposes, and we do not sell or transfer Google user data to third parties, except to service providers who process data on our behalf to operate and secure our systems.

Who do we collect your personal information from

We collect personal information about you from:

• You, when you provide information to us directly.
• Your organisation (for example, where your organisation administers your Trail account).
• Third parties where you have authorised this or where the information is publicly available.
• Google, only if you choose to connect your Google account.

If we collect personal information about you from a third party (indirect collection), we will take reasonable steps to ensure you are notified of the collection as soon as practicable, unless an exception under the Act applies (e.g., where you are already aware of the collection).

How we use your personal information

We use personal information to:

• Verify your identity and authenticate access.
• Operate and maintain the Trail platform and requested features.
• Provide customer support and diagnose technical issues.
• Improve our products, including usability and security.
• Bill and collect payments.
• Protect our legal rights and comply with legal obligations.

Disclosing your personal information

We do not sell personal information. We only disclose information where necessary to:

• Service providers who host, support, or secure our systems under strict confidentiality.
• Payment processors to handle transactions.
• Regulators or law enforcement where required or permitted by law.
• Any other person authorised by you.

Where information is processed outside New Zealand, we ensure recipients are subject to comparable privacy safeguards as required by the Act.

Protecting and storing your personal information

We take reasonable steps to keep information safe from loss or misuse. Data is encrypted in transit and at rest. We only retain personal information for as long as it is required for lawful purposes, including service delivery and legal compliance.

Accessing and correcting your personal information

You have the right to access and request correction of your personal information. We may require evidence of your identity before processing these requests. To exercise these rights, please email support@gettrail.com.

Internet use and cookies

We use cookies to operate our website and understand usage. You may disable cookies in your browser settings, though some features may be limited. While we maintain secure connections, providing information over the internet is at your own risk.