Privacy Policy

Last Updated: 12 October 2026

‍

1. About this policy

This policy explains how 360Surety Limited, trading as SeeEverything ("SeeEverything", "we", "us"), collects, uses, shares and protects personal information. 360Surety Limited is a company registered in New Zealand (company number 9429053283870).

SeeEverything provides an AI-enabled quality assurance, coaching and conduct assurance platform to regulated organisations, mainly financial institutions. Our customers are organisations, not individual consumers.

This policy applies when you:

  • visit our websites, including www.seeeverything.com and trust.seeeverything.com
  • contact us, book a demo or briefing, or attend one of our events
  • work for a customer, prospect, partner or supplier of ours
  • use the SeeEverything platform or our support services
  • have your work reviewed by a customer using the platform

We handle personal information in line with the New Zealand Privacy Act 2020. Where they apply to our activities, we also comply with other privacy laws. These may include the Australian Privacy Act 1988, the UK GDPR, the EU GDPR and US state privacy laws. Section 9 explains the rights these laws may give you.

This policy replaces our previous privacy policy dated 26 May 2023.

2. Our two roles

Who is responsible for your information depends on why we hold it.

Information we hold for our customers. For this information we act for the customer organisation. We are a "processor" under the GDPR and US state privacy laws, and we hold it on the customer's behalf under section 11 of the NZ Privacy Act. It includes:

  • platform content, such as evaluations, coaching records, conduct assurance findings, comments, actions, attachments and case references
  • platform accounts and the audit trail, such as user profiles, roles, permissions and the record of activity in the platform (we also use sign-in and access records for our own security purposes)

Information we are responsible for. For this information we decide how it is used. We are a "controller" under the GDPR and US state privacy laws, and the agency responsible under the NZ Privacy Act. It includes:

  • operational and security information, such as infrastructure and access logs, authentication records, error reports and system telemetry
  • product usage analytics, showing how platform features and pages are used
  • business relationship information about website visitors, sales and marketing contacts, partner and supplier contacts, billing contacts and support requests

When we act for a customer, the customer decides what information goes into the platform and how it is used. We process customer-controlled platform content only to provide the services, in accordance with our customer agreements and documented instructions. Where we process operational or security information for our own purposes, we do so as described in this policy.

If your organisation uses SeeEverything and you have a question or request about your information in the platform, please contact your organisation first. If you contact us instead, we will pass your request to them and help them respond.

The rest of this policy mainly describes the information we are responsible for. Where it describes platform content, it explains how we handle that content for our customers.

3. Information we collect and where it comes from

We collect only what we need for the purposes in section 4.

  • Contact and business details, such as name, job title, employer, work email, phone number and country. These come from you, your employer, our resellers and referral partners, events, and public business sources such as company websites and LinkedIn.
  • Account information, such as name, work email, role, team, reporting line, permissions, single sign-on identifiers and preferences. This comes from your organisation's administrator or identity provider, or from you.
  • Platform content (held for our customer), such as evaluation scores and comments, coaching notes, conduct assurance findings, goals, actions, attachments, case reference numbers and outcomes. This comes from your organisation's users.
  • Usage and device information, such as sign-ins, features used, pages viewed, IP address, browser and device type, timestamps and error reports. We collect this automatically when you use our websites or platform.
  • Support information, such as support tickets, emails, call notes and screenshots, from you or your organisation.
  • Billing information, such as billing contact details, purchase orders, invoices and payment history, from your organisation.
  • Marketing preferences, such as email subscriptions and opt-outs, event registrations and demo bookings, from you.

‍Information about people our customers serve. The platform is designed to minimise information about our customers' own customers. It typically holds reference details, such as case IDs and pass or fail results, rather than names or contact details. Combined with a customer's own records, these references can still identify someone, so we protect them as personal information.

Sensitive information. The platform is not intended for the routine collection or storage of sensitive personal information, such as health, ethnicity, religious or political information. However, customer-provided content may contain it, including in free-text fields or attachments. Customers are responsible for making sure the information they submit is permitted under their agreement with us and applicable law.

When we get your details from someone else. If we collect your contact details indirectly, for example from a partner, an event organiser or a public business source, we will tell you when we first contact you. We will explain who we are, why we have your details and how to opt out, unless a legal exception applies.

If you don't give us information. You don't have to give us your personal information. If you don't, we may not be able to provide our services, respond to your enquiry or give you access to the platform.

4. How we use personal information

We use personal information for the purposes below. If you are in the UK or the European Economic Area (EEA), the right-hand column shows our lawful basis under the UK GDPR or EU GDPR for the activities we are responsible for. For platform content we process on a customer's behalf, the customer determines the lawful basis.

  • Provide and operate the platform: create and administer accounts, authenticate users and run the features your organisation has bought. Lawful basis: legitimate interests in providing the services our customers have contracted for.
  • Support our customers: answer questions, fix problems and investigate errors. Lawful basis: legitimate interests.
  • Keep our services secure: monitor for misuse and attacks, keep audit logs and investigate incidents. Lawful basis: legitimate interests; legal obligation.
  • Improve our services: understand how features are used, measure performance and plan improvements using usage data. Lawful basis: legitimate interests.
  • Market our services to organisations: send product updates and event invitations to business contacts, and run demos and briefings. Lawful basis: legitimate interests; consent where the law requires it.
  • Bill and manage our customer relationships: issue invoices, collect payment and keep business records. Lawful basis: legitimate interests; legal obligation.
  • Meet legal and audit obligations: respond to lawful requests, support our ISO/IEC 27001 and SOC 2 audits, and establish or defend legal claims. Lawful basis: legal obligation; legitimate interests.
  • Sell or restructure our business: share information with a buyer or investor under confidentiality terms. Lawful basis: legitimate interests.

Where we rely on legitimate interests, we have weighed our interests against your rights and expectations. You can ask us for more detail.

Platform content. We use platform content only to provide the services to the customer that put it there, as their agreement with us allows.

AI features. Some platform features use artificial intelligence to assist with quality assurance, coaching and conduct assurance. These may include suggesting evaluation outcomes, identifying potential issues and summarising information.

These features are designed to support human reviewers. Our customers are responsible for deciding how AI-generated outputs are reviewed, verified and used in their decision-making. SeeEverything does not itself make employment, performance management or conduct decisions about the people whose information is processed through the platform.

We do not use customer platform content to train general-purpose AI models.

Marketing. You can opt out of marketing emails at any time using the unsubscribe link or by emailing us. You will still receive service and security messages if you use the platform.

We do not sell personal information. We do not use it for targeted (cross-context behavioural) advertising.

5. Who we share information with

We share personal information only as described here, and only as much as each recipient needs.

Within your organisation. Platform content and account details are visible to other users in your organisation according to the permissions your administrator sets. Administrators can view, change, export and delete information in your organisation's account.

Our service providers (sub-processors). These providers process platform data for us under written contracts that require confidentiality and security at least as strong as ours.

  • Amazon Web Services (Australia, US, and EU): hosting and infrastructure for the platform
  • Datadog (United States): monitoring of system health and performance
  • Mixpanel (United States): product usage analytics
  • Segment (United States): usage data collection and routing
  • Atlassian (United States): customer support ticketing
  • Microsoft (United States): customer support
  • Slack (United States): customer support

We keep the current list in our Trust Centre. We tell customers before adding or replacing a sub-processor, as our data processing terms describe.

Other service providers. We use other providers for our own business operations, such as email and productivity tools, customer relationship management, website hosting, and accounting.

Partners. We may share business contact details with resellers, implementation and referral partners who help us sell or deliver our services to your organisation.

Advisers and auditors. We share information with our lawyers, accountants, insurers and independent auditors, under confidentiality obligations.

Legal requirements. We may disclose information when the law requires it, to respond to a lawful request from a court, regulator or law enforcement agency, or to prevent a serious threat to someone's life or health. Where we receive a request for a customer's platform data, we will refer it to the customer unless the law prevents us.

Business changes. If we sell, merge or restructure all or part of our business, information may transfer to the new owner. They must handle it consistently with this policy.

With your consent. For example, we will publish your name with a testimonial only if you agree.

6. Where information is stored and international transfers

Platform data is hosted by Amazon Web Services in Australia. Hosting location is not the only place information is processed:

  • our team works from New Zealand, Australia, and the EU and may access information remotely from those countries, under our security policies
  • the service providers in section 5 process some information in the countries shown there, including the United States

When personal information leaves the country where it was collected, we protect it as the law of that country requires.

  • Information from New Zealand. We disclose it overseas only where the recipient is subject to comparable safeguards, usually through contract terms, as Information Privacy Principle 12 requires.
  • Information from Australia. We take reasonable steps, including contract terms, to make sure overseas recipients handle it consistently with the Australian Privacy Principles. We remain accountable for it under APP 8.
  • Information from the UK or EEA. New Zealand has adequacy decisions from the European Commission and the UK. When we transfer information to another organisation in a country without one, such as Australia or the United States, we rely on a safeguard appropriate to that recipient. This may be the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, or the EU–US Data Privacy Framework (and its UK Extension) where the recipient is certified.
  • Information from the United States. We use contract terms that require recipients to protect it to the standard in this policy.

You can ask us for more information about the safeguards we use, including a copy of the relevant contract clauses.

7. How we protect information

Our information security management system is certified to ISO/IEC 27001, and our controls for the SeeEverything platform are independently examined under SOC 2 Type 2. Our Trust Centre describes the scope of each.

Our safeguards include:

  • encryption of data in transit and at rest
  • role-based access, single sign-on and multi-factor authentication for our team
  • logging and monitoring of access to production systems
  • security screening and annual security training for our team
  • security reviews of our service providers before we use them
  • regular independent penetration testing

You can find more detail and request our audit reports through our Trust Centre.

No system is perfectly secure. If we suspect a privacy breach, we will contain it, assess it promptly and follow our incident response plan.

  • Information we are responsible for. If a breach is likely to cause serious harm, we will notify affected people and the relevant regulator as the law requires. This may include the New Zealand Privacy Commissioner, the Office of the Australian Information Commissioner, or a UK or EU supervisory authority.
  • Platform content we hold for a customer. We will notify the customer without undue delay, as our agreement requires, and help them assess the breach. The customer usually decides whether to notify individuals and regulators, and we coordinate with them on any notifications.

8. How long we keep information

We keep personal information only as long as we need it for the purposes in section 4 or as the law requires. After that, we delete it or de-identify it.

  • Platform content: as the customer directs during the contract. We delete or return it within 60 days after the contract ends, and backup copies expire within a further 6 months.
  • Account information: while the account is active, then deleted with the customer's platform content.
  • Security and audit logs: 12 months.
  • Support records: 3 years after the ticket is closed.
  • Sales and marketing contacts: until you unsubscribe or ask us to delete them, or after 3 years with no engagement.
  • Billing and business records: 7 years, to meet New Zealand tax record-keeping requirements.
  • Website analytics: as set out in our Cookie Policy.

If you unsubscribe from marketing, we keep a record of your email address so we don't contact you again.

9. Your rights

Wherever you are, you can ask us to access or correct the personal information we hold about you. Depending on where you live, you may have further rights, shown below.

To make a request, email privacy@seeeverything.com. We will need to confirm your identity first. We don't charge for requests unless the law allows it and the request is clearly excessive. If your request is about platform content, we will refer it to your organisation (section 2).

New Zealand. You can access and correct your information under the Privacy Act 2020. We respond within 20 working days. The regulator is the Office of the Privacy Commissioner.

Australia. You can access and correct your information under the Australian Privacy Principles. We respond within a reasonable period, generally no more than 30 days. The regulator is the Office of the Australian Information Commissioner.

UK and EEA. You can ask for access, rectification, erasure, restriction or portability, object to processing (including an absolute right to object to direct marketing), and withdraw consent at any time. We respond within one month, extendable by two months for complex requests. The regulator is the Information Commissioner's Office in the UK, or the supervisory authority where you live or work, such as the Autoriteit Persoonsgegevens in the Netherlands.

United States. If your state's privacy law applies to you and to our processing, you can ask us to confirm whether we process your data, access, correct or delete it, receive a portable copy, and opt out of sale, targeted advertising and profiling. Rights differ between states, and many state laws do not cover information collected in a business or employment context. We respond within 45 days, extendable by 45 days, or sooner if your state requires. The regulator is your state Attorney General or privacy regulator, such as the California Privacy Protection Agency.

Complaints. You can raise a privacy concern or complaint by contacting our Privacy Officer at privacy@seeeverything.com. We will acknowledge your complaint within 30 days, investigate the circumstances, keep you informed and tell you the outcome. We will meet any shorter deadline the law sets. If you are not satisfied with our response, you can contact the regulator listed above.

10. Cookies and analytics

Our websites and platform use cookies and similar technologies.

‍Appeals (United States). If we decline your request, you can appeal by replying to our decision. We will respond within the time your state's law requires, such as 60 days in Texas. If we deny your appeal, we will tell you how to contact your state Attorney General.

  • In the platform, we use essential cookies and similar technologies to sign you in and keep your session secure. Separately, we use product analytics (Mixpanel and Segment) to understand how features are used.
  • On our websites, we use cookies to make the site work and to measure visits. Where the law requires it, we ask for your consent before setting non-essential cookies. Where UK law allows analytics without consent, we tell you about it and give you a way to object.

Our Cookie Policy lists the cookies we use and explains how to manage them.

We do not sell personal information or use it for targeted advertising. If that changes, we will honour browser opt-out signals such as Global Privacy Control where the law requires.

11. Children, changes and contacting us

Children. Our services are for organisations and are not directed at anyone under 18. We do not knowingly collect children's personal information.

Changes to this policy. We will post any update on this page with a new "Last updated" date. If we make a significant change, we will tell our customers by email or in the platform before it takes effect.

Contact us. Our Privacy Officer is responsible for this policy and for privacy requests.

  • Email: privacy@seeeverything.com
  • Post: Privacy Officer, SeeEverything, PO Box 435, Shortland Street, Auckland 1140 New Zealand

‍