Privacy Policy

Privacy Policy2018-12-10T20:19:41+00:00

The Privacy Policy sets out what personal information Token Generator (Centrality Investments Limited) collects and what we will use it for. By using our services, including Token Generator, our website and other applications, you consent to the terms of this Privacy Policy.

Protecting your personal information

Token Generator is committed to protecting your personal information. This Privacy Policy sets out how we collect, use, store and disclose your personal information, in accordance with applicable privacy and data protection laws (Privacy Laws), when you use our services, including Token Generator, our website and other applications (Services).

For example, if you are in New Zealand, we will comply with the New Zealand Privacy Act 1993 (as amended or replaced from time to time) (the Privacy Act) and if you are in the European Union, we will comply with the European Union General Data Protection Regulation (EU) 2016/679 (the GDPR).

This Privacy Policy provides you with information about our privacy practices. It does not limit our rights and obligations under Privacy Laws.

Information we collect

If you are using our Services then we may collect and store the following personal information about you:

  • Name and address
  • Email
  • Phone number
  • Identification document
  • Photo of your face
  • Address and country of residence
  • Source of fund
  • Proof of address (e.g. utility bills, bank statements)
  • Any other information that you provide to us or authorise us to collect.

We may ask for additional information to prove your identity and we may collect information from third party service providers to prove your identify (see below).

If you are just surfing and reading information on our website or applications, then we collect and store the following personal information about your visit:

  • the IP address of your machine when connected to the Internet and the domain name from which you are accessing the Internet
  • the operating system and the browser your computer uses, and any search engine you are using
  • your browsing behaviour
  • your online transactions
  • your account activity
  • the date and time you are visiting
  • the URLs of the pages you visit
  • the domain name of the page you visit after leaving our website
  • other information using cookies – see “Cookies” below for more information.

Personal information about children (under 16 years old) is subject to special protections. You confirm that you are not under the age of 16 and you acknowledge that we do not knowingly collect or maintain personal information about children under the age of 16.

How we use your information

The personal information we collect will be used to provide services you have authorised or requested.

We also use personal information to:

  • verify your identity
  • Name and address – Details are checked against Sanction lists, Crime lists, Insurance, Fraud lists etc.
  • Email – an email is sent to the mailbox and confirmation of ownership is required – emails are additionally checked for duplicate usage and any watch list activity.
  • Phone number – A SMS code is sent to the phone number to confirm ownership – phone numbers are additionally checked for duplicate usage and any watch list activity.
  • Identification document (Govt ID) – Government ID is scanned and reviewed using image recognition and machine learning scoring techniques
  • Facial recognition (biometric information) – Images are compared to photo ID to confirm identity and to detect and prevent the use of Token Generator by bots
  • Address – Residential address required for the identification
  • Source of fund – for risk analyses for investments
  • comply with mandatory legal obligations, for example to perform procedures (e.g. check of sanctions lists) that are required by any relevant legislation, such as the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (NZ);
  • assist you in case you forget your password or login details;
  • respond to any questions or correspondence from you;
  • manage and improve Token Generator and any related services;
  • carry out internal research and development;
  • conduct student satisfaction surveys via an independent agency to assist us better serve our clients;
  • provide you with information about a service that you are using (including critical updates and announcements);
  • reduce the need for you to repeatedly enter the same information;
  • customise Token Generator to suit your particular preferences and interests;
  • where you create a message using Token Generator (for the purpose of sending that message to us, or to any other recipient specified by you), to send that message;
  • analyse Mobile App usage, trends and statistics;
  • supply you (including by electronic means) with further information concerning products and services which may be of interest to you (you can opt out of or change your direct marketing preferences by notifying us); or
  • for any other purpose that is authorised by you or is notified to you at the time of collection.

We may process your personal information for the purpose of automated decision making in connection with some of our Services. If the GDPR applies to your engagement with us, you can request a manual review of the accuracy of an automated decision.

We use information you provided through surfing and reading on our website for the following purposes:

  • to measure the number of visitors to different parts of the website, as well as for different purposes connected with the provision of services, for example, to measure the effectiveness of advertising.
  • if you choose to provide us with personal information such as your email address, for example, by filling out an electronic query or order form, we will use the information in accordance with this Privacy Policy.

We may also process your personal information in relation to our legitimate business interests, and performance of, or entry into, any contract we may have with you.

If you login in to your customer profile, your account number and activity on our website and applications will be tracked. Additionally, if you do provide us with personal information via your use of this website, for example, by allowing the use of cookies or by filling out an electronic query form, we may link this information to your Centrality Investments Limited customer profile. We may also use this information to improve the website or applications for different customer profiles. See “Cookies” section below for more information on how we use cookies.

We keep your data for as long as necessary for the purpose for which it was collected, or for as long as required by local regulatory law, fraud and money laundering requirements. If you no longer consent to us retaining and processing your personal information in accordance with this privacy policy, or any other agreement we have with you, please contact us at

What are your rights and responsibilities?

You do not need to give us any of the personal information that we request from you. However, without that information we will not be able to provide you with our services (for example, may not be able to verify your identity).

Accessing and updating your personal information

You have the right to access and request correction of the personal information we hold about you where it is stored in such a way that it can be readily be retrieved.

It is important that the personal information we hold about you is up to date and complete. If you wish to make changes to your personal information, you can contact us by email at It is your responsibility to ensure that the personal information we hold about you, such as your billing address, is accurate and up to date.

If you consider that information we have about you is not correct, you believe we should not be processing your personal information, or you would like us to no longer hold your personal information, please contact us at to discuss your rights. Where the GDPR applies to our engagement with you, you may have additional rights in respect of, for example, data portability or the right to erasure of your data.

How do I unsubscribe from email marketing communications?

Follow the unsubscribe instructions in the email in writing using the contact details contained in the message.

You have the right to object at any time to the processing of your personal information and require us to stop processing your information. However, this may affect the services that we provide to you. Please contact us at to discuss your rights.

Disclosure of information to third parties

Although we may publish aggregated information about usage patterns, we will not disclose identifiable personal information about you (or your device) except with your authorisation to the following third parties for the reasons set out below in this section:

  • Any third party who buys your personal information, if you specifically agree to this in the terms and conditions of one of our services.
  • Any relevant law enforcement authority, such as the Police or the Department of Internal Affairs, if we are concerned, for example, about security issues. If this is the case, and if we think it is necessary, we may gather more extensive information.
  • Any processors that provide services to us, including any business, identification service or agency that supports our services and products, including any person that hosts or maintains any underlying IT system or data centre that we use to provide the website or other services and products.
  • Any government agency or regulatory authority who we are legally required to share your personal information with as authorised by any relevant legislation, such as the Anti-Money Laundering and Countering Financing of Terrorism Act 2009. Disclosing personal information to anyone outside of New Zealand
  • Any third party that we are working with to conduct our internal research (e.g. performance monitoring) and for the development for our services.

We may store and transfer some of your data outside of New Zealand and the European Union, where we are permitted to do so under applicable Privacy Laws.


We will take reasonable steps to safeguard your personal information against any loss, misuse, and unauthorised access, alteration, disclosure or destruction. For example, we ensure that the information collected on, or through, Token Generator is stored on a secure server. When signing in or shopping online look for the ‘padlock’ symbol at the bottom of your web browser. The ‘padlock’ symbol is a certificate of authenticity and ensures the website is secure. You can double-click the padlock symbol to view the certificate’s details. Secure Socket Layer (SSL) is the most accepted way of ensuring the security of transmitted information to and from Internet sites worldwide. On our website, it operates when you complete and send forms, but not while you are simply surfing the website.


We use cookies for advertising and analytic purposes. Our website places a cookie on the hard drive of your computer. A “cookie” is a file which allows us to track and target the interests of users. In addition, our website uses third party cookies from Google Analytics for Display Advertisers, including the following features:

  • Google Display Network Impression Reporting – which gives us additional insight into who has viewed our paid digital advertising on other websites. This will help us optimise and tailor our advertising.
  • DoubleClick Platform integrations & Remarketing with Google Analytics – the integrations between both our web analytics and paid advertising platforms work together to give us additional insight. This allows us to tailor our advertising to ensure the right types of offers are shown to you while you are using the internet outside our website.
  • Google Analytics Demographics and Interest Reporting – which gives us insight into behaviour information relating to visitor age, gender and interests on an anonymous and aggregate level. This will help us to understand browsing behaviour to give you a better experience whilst visiting our websites.
  • Cookies are used to analyse your use of our website and to serve ads when you visit our website. The information we collect and share with third parties through cookies is aggregated and therefore anonymous (it does not include personal information which is likely to identify you). The information may be used to serve you ads in relation to our products when you visit our website and third party websites. While we recommend that users enable cookies on their browsers in order to enjoy all the features of our website, the decision remains in the hands of the individual. Most browsers allow you to control management of cookies, this will be different depending on each user’s PC – refer to your browser help menu for further information.

Turning off cookies

As stated above, your internet browser should allow you to control the use of cookies. In addition, you can opt-out of Google Analytics Advertising Features here or use a browser plugin to opt-out of Google Analytics cookies here.

Third-party websites

Please note that this website contains links to other websites, which may not be governed by this Privacy Policy. We encourage you to review each website’s privacy statement before disclosing any personal information.

Changing this Privacy Policy

We may change this Privacy Policy at any time by changing or removing existing terms or adding new ones. Changes may take the form of a completely new Privacy Policy. We will tell you about any changes by posting an updated Privacy Policy on our website. Any change we make applies from the date we post it on the website. If you have any questions about our Privacy Policy please email us at


If you have any questions in relation to this Privacy Policy, or any queries or concerns about the use of your personal information, please contact our privacy officer at:

Centrality Investments Limited

Floor 5, 48 Emily Place,

Auckland, 1010, NZ

This Privacy Policy was updated on the 1 Dec 2018.