Privacy Policy
Imperial Vaults
Our commitment to protecting your privacy and personal information.
Nz Owned & Operated
230+ Google Reviews
Biometric Scanning
Flexible Access
40+ Free Carparks
Nz Owned & Operated
230+ Google Reviews
Biometric Scanning
40+ Free Carparks
On This Page
1. The Information We Collect
2. How we collect personal information
3. Why we collect, hold, use and disclose personal information
4. Our disclosures of personal information to third parties
5. Overseas disclosure
6. Collection and Use of Biometric Information
7. Why we collect Biometric Data
8. Collection and Use of CCTV
9. Your rights and controlling your personal information
10. Storage and security
11. Cookies
12. Links to other websites
13. Amendments
Questions about this Privacy Policy?
Our team is here to help.
PRIVACY POLICY
Imperial Vault Limited (NZCN 5379521) (we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or collected by us, when interacting with you.
The information we collect
Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.
The types of personal information we may collect about you include:
- Identity Data including your name, age, photographic identification, and gender.
- Biometric Data including your fingerprints, facial recognition data, and other biometric identifiers collected through our biometric scanning systems for the purposes of secure facility access, customer identification, and authentication when accessing your safety deposit box.
- Contact Data including your telephone number, address and email.
- CCTV and Surveillance Data including continuous video recordings from security cameras positioned throughout our premises (excluding private viewing rooms), access logs with timestamps, and visual records of facility entry and exit for security, safety monitoring, legal compliance, and incident investigation purposes. CCTV footage is retained for a duration between 3 to 6 months.
- Authorised Representative Data including the names, identification details, and authorisation documentation of any individuals you formally designate to access your safety deposit box on your behalf.
- Financial Data including bank account and payment card details (through our third party payment processor, who stores such information and we do not have access to that information).
- Background Verification Data including your government-issued identification details requested as part of our onboarding process to comply with our due diligence obligations, anti-money laundering laws and related ongoing monitoring commitments.
- Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.
- Technical and Usage Data when you access any of our websites or platforms, details about your internet protocol (IP) address, login data, browser session and geo-location data, statistics on page views and sessions, device and network information, acquisition sources, search queries and/or browsing behaviour, access and use of our website (including through the use of Internet cookies or analytics), and communications with our website.
- Interaction Data including information you provide to us when you participate in any interactive features, including surveys, contests, promotions, activities or events.
- Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
- Professional data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience.
How we collect personal information
We collect personal information in a variety of ways, including:
- when you interact directly with us, including face-to-face, over the phone, over email, or online;
- when you complete a form, such as registering for any events or newsletters, or responding to surveys;
- when you apply for a job with us;
- from third parties, such as details of your use of any website we operate (from our analytics and cookie providers and marketing providers. Where we collect personal information about you from a third party source other than you (other than the personal information which we have specified will be collected by us in accordance with this Privacy Policy) we will take reasonable steps to notify you of such collection, including the fact that the information has been collected, the purpose for which the information has been collected, the intended recipients of the information, and the name and address of the agency that is holding the information, as required by law. See the “Cookies” section below for more detail on the use of cookies); or
- from publicly available sources, such as social media or the New Zealand Companies Office.
Why we collect, hold, use and disclose personal information
Personal information: We collect, hold, use and disclose your personal information for the following purposes:
- to enable you to access and use our services, including to provide you with entry to our building;
- to assess whether to take you on as a new client, including to perform anti-money laundering, anti-terrorism, sanction screening, fraud and other background checks on you;
- to do business with you, including to provide our services to you;
- to contact and communicate with you about our business, including in response to any support requests you lodge with us or other enquiries you make with us;
- to contact and communicate with you about any enquiries you make with us via any website we operate;
- for internal record keeping, administrative, invoicing and billing purposes;
- for analytics, market research and business development, including to operate and improve our business, associated applications and associated social media platforms;
- for advertising and marketing, including to send you promotional information about information that we consider may be of interest to you;
- if you have applied for employment with us, to consider your employment application; and
- to comply with our legal obligations or if otherwise required or authorised by law.
Our disclosures of personal information to third parties
We may disclose personal information to:
- our employees, contractors and/or related entities;
- IT service providers, data storage, web-hosting and server providers;
- marketing or advertising providers such as Google, LinkedIn, Facebook, Instagram or Twitter;
- professional advisors, bankers, auditors, our insurers and insurance brokers;
- payment systems operators including, but not limited to, Paypal, Stripe and Shopify Payments;
- our existing or potential agents or business partners or suppliers;
- sponsors or promoters of any promotions or competition we run;
- anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
- courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
- courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and
- third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Meta Pixel or other relevant analytics businesses; and
- any other third parties as required or permitted by law, such as where we receive a subpoena.
Overseas disclosure
Personal Information
While we store personal information in New Zealand, where we disclose your personal information to the third parties listed above, these third parties may store, transfer or access personal information outside of New Zealand. We will only disclose your personal information overseas in accordance with the New Zealand Privacy Principles.
Collection and Use of Biometric Information
Imperial Vault Limited collects and uses biometric information as part of our security and customer identification systems. This section provides specific information about our biometric data practices in accordance with the Biometric Processing Privacy Code 2025:
What biometric information we collect:
- We collect biometric identifiers including fingerprints and facial recognition data through our biometric scanning equipment installed at our facilities.
Biometric information is collected directly from you during:
- Your initial account registration and onboarding process;
- each occasion when you access our facility and your safety deposit box; and
- any subsequent re-verification processes we may require.
We collect and use your biometric information to:
- verify your identity and ensure that only authorised individuals can access our secure facilities and safety deposit boxes;
- maintain the highest standards of security for our customers and their stored valuables;
- prevent unauthorised access and protect against fraud or theft;
- create audit trails of facility and vault access for security purposes; and
- comply with our security obligations and best practice standards for high-security storage facilities.
Limits on Use of Biometric Information
We do not use your biometric information for biometric categorisation purposes. This means we do not use your biometric information to:
- Infer or detect your emotions, mood, mental state, intentions, or personality characteristics
- Categorise you based on demographic characteristics such as age, gender, ethnicity, or sexual orientation
- Profile you or make predictions about your behaviour, preferences, or characteristics
Retention of biometric information:
We retain your biometric information for the duration of your relationship with us and for 14 days after the termination of your account, or as otherwise required by law. Biometric information is securely deleted in accordance with our data retention and destruction policies once the retention period expires.
Security of biometric information:
Biometric data is encrypted and stored separately from other personal information using industry-standard security measures. Access to biometric data is strictly limited to authorised personnel who require such access to perform their duties. We regularly review and update our security measures to protect your biometric information from unauthorised access, use, or disclosure.
By providing your biometric information to us, you expressly consent to our collection, use, storage and disclosure of that information as described in this Privacy Policy. You may withdraw your consent at any time by contacting us using the details provided in this Privacy Policy, however, please note that withdrawal of consent may prevent us from providing you with access to our services and facilities.
We will never sell, lease, or trade your biometric information. We will not disclose your biometric information to third parties except:
- to our IT service providers and data storage providers who are bound by confidentiality obligations and process the information solely on our behalf;
- as otherwise permitted or required by law; and
- with your express written consent.
Why we collect Biometric Data
We have assessed alternative access control methods including physical keys, PIN codes, and access cards. Biometric processing is necessary because: [explain why – e.g., physical keys can be duplicated or lost, PIN codes can be shared or observed, cards can be stolen or cloned]. Biometric characteristics provide a higher level of security that cannot be transferred or duplicated, which is essential given the high-value items stored in our facilities.
If you are unable or unwilling to provide biometric information, we may not be able to provide you with access to our services and facilities. If you have concerns about biometric processing, including cultural concerns, please contact us to discuss your situation.
Proportionality Assessment
We have assessed that biometric processing is proportionate, considering:
Privacy Risks: Potential unauthorized access, security breaches, surveillance concerns, and risks of misuse of biometric information.
Privacy Safeguards: Encryption and separate storage, strict access controls, audit logging, staff training on privacy obligations, incident response procedures, regular security audits, biometric template protection, and data retention policies.
Cultural Impacts on Māori: We recognize that biometric information may have cultural significance relating to whakapapa, wairua, and personal tapu. We are committed to engaging respectfully with Māori clients who have cultural concerns about biometric processing. Clients with such concerns are encouraged to contact us to discuss accommodations.
Benefit Analysis: The security benefit to clients in protecting high-value stored items substantially outweighs the privacy risks, particularly given our comprehensive safeguards.
Our proportionality assessment, which evaluates the privacy risks and benefits of biometric processing and includes our assessment of cultural impacts on Māori, is available on request. To request a copy of this assessment (or a summary), please contact us at [email protected].
Collection and Use of CCTV
We operate continuous CCTV surveillance throughout our premises for security and safety purposes. This includes:
What we record: Visual footage from security cameras positioned in common areas, corridors, vault access points, and external areas of our facility. CCTV does not operate within private viewing rooms or inside safety deposit boxes.
Why we record: To maintain facility security, prevent unauthorised access, investigate incidents, create audit trails of access, protect our customers and staff, and comply with our security and legal obligations.
How long we retain footage: CCTV footage is retained for a minimum of 3 months and a maximum of 6 months, after which it is securely deleted unless required for ongoing investigations or legal proceedings.
Access to footage: Access to CCTV footage is strictly limited to authorised security personnel and management. Footage may be disclosed to law enforcement when required by valid legal instrument or in connection with investigations of suspected criminal activity.
Your rights and controlling your personal information
Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to do business with you.
Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.
Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you may contact the Office of the New Zealand Privacy Commissioner.
Storage and security
We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.
Cookies
We may use cookies on our website from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
Links to other websites
Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.
Amendments
We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.
For any questions or notices, please contact us at:
Imperial Vault Limited (NZCN 5379521)
Email: [email protected]
Last update: 18 December 2025