Privacy Policy

1. Introduction

DAWNED Ltd ("we", "our", "us") is a construction consultancy providing quantity surveying, commercial management, and related professional services. We are based in Wairarapa | Wellington, New Zealand.

We are committed to protecting the privacy of individuals whose personal information we collect and hold. This policy explains how we collect, use, store, and disclose personal information in accordance with the Privacy Act 2020 (New Zealand) and the Information Privacy Principles ("IPPs").

This policy applies to information collected through our website, through our contact form, through email, through any newsletter subscription, and through the course of providing professional services to our clients.

2. Information We Collect

2.1 Through our website

When you visit our website, we may collect:

• Information you provide through our contact form, including your name, email address, phone number, and the content of your message.
• Your email address if you subscribe to our newsletter.
• Technical and usage data collected automatically through Google Analytics, including your IP address, browser type, pages visited, time spent on pages, and referring website. This data is collected using cookies and similar technologies.

2.2 Through our professional services

When you engage us as a client, we may collect:

• Contact details of individuals within your organisation (names, email addresses, phone numbers, job titles).
• Company and entity details relevant to the engagement.
• Financial information, contract documents, and project records necessary to perform our services.

2.3 Information collected from third parties

In some cases, we may receive personal information about you from a third party rather than directly from you — for example, from your employer, a head contractor, another consultant, or from project documentation. Where this occurs, we will take reasonable steps to make you aware that we hold your information, the purpose for which we collected it, and your rights in relation to it, unless an exception under the Privacy Act applies. This is in accordance with Information Privacy Principle 3A, effective 1 May 2026.

3. Why We Collect Your Information

We collect personal information only where it is necessary for one or more of the following purposes:

• To respond to enquiries submitted through our website or by other means.
• To provide professional services to our clients, including quantity surveying, commercial management, contract administration, and dispute advisory services.
• To send you our newsletter or other communications you have opted in to receive.
• To manage our business relationships, including invoicing and record-keeping.
• To improve our website through analytics.
• To comply with our legal obligations.

We will not collect more information than is reasonably necessary for these purposes.

4. Use of Artificial Intelligence Tools

We may use artificial intelligence (AI) tools, including large language models, to assist in the delivery of our professional services. This may include using AI tools to assist with document review, drafting, analysis, research, and other tasks related to our consulting work.

Where we use AI tools in connection with client work, we take the following steps to protect your information:

• We only input personal information into AI tools where it is necessary for the purpose of the work being performed.
• We take reasonable steps to use AI tools that have appropriate privacy and security measures in place.
• We remain responsible for the accuracy and appropriateness of any outputs produced with the assistance of AI tools. AI-generated outputs are reviewed by us before being relied upon or provided to clients.
• We do not use AI tools in a way that results in automated decision-making that produces legal effects or similarly significant effects on individuals without human review.

If you have concerns about the use of AI tools in connection with your information, please contact us. We are happy to advise which specific tools are being used in connection with your engagement on request.

5. Disclosure to Third Parties

We do not sell, rent, or trade personal information.

We may share your personal information with third parties in the following circumstances:

• With other professionals engaged in connection with a project or engagement (for example, lawyers, engineers, or other consultants), where disclosure is necessary for the purposes of the engagement and with your knowledge.
• With service providers who assist us in operating our business (for example, IT service providers, cloud storage providers, accounting software providers), subject to appropriate confidentiality obligations.
• Where required or authorised by law.

5.1 Overseas disclosure

Some of the service providers we use (including cloud storage and AI tools) may store or process data on servers located outside New Zealand. Where personal information is transferred overseas, we take reasonable steps to ensure it is protected by privacy standards comparable to those in New Zealand, in accordance with Information Privacy Principle 12.

6. Storage and Security

We store personal information using a combination of cloud-based storage services, local computer systems, project management and accounting software, and physical paper files.

We take reasonable steps to protect personal information from loss, unauthorised access, use, modification, disclosure, or other misuse. These steps include:

• Using password protection and encryption on digital systems.
• Restricting access to personal information to those who need it for a legitimate business purpose.
• Securing physical files in our office.

No method of storage or transmission is completely secure. While we take reasonable precautions, we cannot guarantee the absolute security of your information.

6.1 Accuracy

We take reasonable steps to ensure that personal information we hold is accurate, complete, and up to date before we use or disclose it. If you believe any information we hold about you is incorrect, please contact us so we can correct it.

7. Retention

We retain personal information only for as long as it is needed for the purposes for which it was collected, or as required by law. When personal information is no longer required, we will take reasonable steps to securely destroy or de-identify it.

For professional services records, we generally retain project files for a minimum of ten years after the completion of an engagement, reflecting the longstop limitation period under the Building Act 2004. In some cases, records may be retained for up to fifteen years, consistent with the longstop provision under the Limitation Act 2010. Tax and financial records are retained for a minimum of seven years as required by the Tax Administration Act 1994.

8. Your Rights

Under the Privacy Act 2020, you have the right to:

• Request confirmation of whether we hold personal information about you.
• Request access to your personal information.
• Request correction of any personal information that is inaccurate, incomplete, or misleading.
• Request that we stop using your personal information for direct marketing purposes (including newsletters).

To exercise any of these rights, please contact us using the contact form on our website. We will respond to your request as soon as reasonably practicable, and in any event within 20 working days.

If we decline a request, we will provide you with our reasons and advise you of your right to make a complaint to the Office of the Privacy Commissioner.

9. Cookies and Website Analytics

Our website uses Google Analytics, which places cookies on your device to collect information about how you use our website. This information is used to analyse website traffic and improve our website. Google Analytics data is processed by Google LLC.

You can control cookies through your browser settings. Most browsers allow you to refuse cookies or alert you when a cookie is being sent. If you disable cookies, some features of our website may not function as intended.

For more information about how Google processes data collected through Google Analytics, refer to Google's privacy policy at policies.google.com/privacy.

10. Newsletter

If you subscribe to our newsletter, we will use your email address to send you periodic updates about our services, industry insights, and other content we believe may be of interest to you. You may unsubscribe at any time by following the unsubscribe link in any newsletter, or by contacting us through our website. We will not share your email address with third parties for their marketing purposes.

11. Privacy Breaches

If we become aware of a privacy breach that is likely to cause serious harm to any affected individual, we will notify the Office of the Privacy Commissioner and the affected individuals as soon as practicable, in accordance with Part 6 of the Privacy Act 2020.

12. Privacy Officer

DAWNED Ltd's Privacy Officer is the director of the company. If you have any questions or concerns about this policy, or about how we handle your personal information, please contact us via the contact form on our website.

13. Complaints

If you are not satisfied with our response to a privacy concern, you have the right to make a complaint to the Office of the Privacy Commissioner:

Office of the Privacy Commissioner
Website: privacy.org.nz
Complaints: privacy.org.nz/your-rights/making-a-complaint
Phone: 0800 803 909

14. Changes to This Policy

We may update this privacy policy from time to time. Any changes will be posted on our website with an updated effective date. We encourage you to review this policy periodically.

15. Governing Law

This privacy policy is governed by the laws of New Zealand, including the Privacy Act 2020.

DAWNED Ltd