Privacy Policy

Introduction

Please read the following Privacy Policy (the “Privacy Policy”) carefully to understand how and why our web servers use your personal data in order for you to access and browse this website, (the “Website”).

The Nauru Program Office is responsible for the processing of your personal data when you use our website services or submitting the application for Nauru Economic and Climate Resilience Citizenship Program. This Privacy Policy is issued on behalf of The Nauru Program Office, and references to "Program Office", "We", "Us", or "Our" refer to The Nauru Program Office as the entity responsible for your data.

The Nauru Program Office (NZ) Limited (company registration number 9272151), of New Zealand, is the agency or also the data controller and is responsible for Nauru Economic and Climate Resilience Citizenship Program and this Website.

We have structured our Website to enable individuals to browse our online content without the requirement of self-identification or the disclosure of personal information. Upon the voluntary submission of personal information, We will protect such data and use it only in the ways described below.

Objectives of this Privacy Policy

We are committed to respecting and protecting your privacy at all times. The primary objectives of this Privacy Policy are:

  • To advise you of your data protection rights.
  • To provide clear and concise information regarding the categories of personal data that We collect, and the manner in which such data is utilized;
  • To establish the basis upon which We process personal data;
  • To inform you of how We will handle your personal data;
  • To clarify Our obligations under the data protection regulations with regard to processing your personal data lawfully and responsibly.

We process your personal data appropriately and lawfully, following applicable data protection regulations such as Privacy Act 2020 and the General Data Protection Regulation EU 2016/679 (the “GDPR”).

We will comply with applicable data protection laws in the jurisdictions we operate in and to do so, the personal information we hold about you must be:

  • Used by us lawfully, fairly, and in a transparent way
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
  • Relevant to the purposes we have told you about and limited only to those purposes
  • Accurate and kept up to date
  • Kept only as long as necessary for the purposes we have told you about
  • Kept securely

This Privacy Policy should be read in conjunction with our Cookie Policy and any other Privacy Notices we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Data subject rights

As a data subject, you are entitled to exercise the following rights:

1. Right of access to information

You have the right to submit a request for information regarding the processing of your personal data by Us. This includes the right to inquire as to whether or not We are processing your personal data, as well as the purposes and methods of such processing. Requests for information should be submitted via e-mail to dpo@nr.prgoff.com. You are entitled to receive one electronic copy of the requested information free of charge. However, We reserve the right to charge a reasonable fee in cases where requests are deemed unfounded, repetitive, or excessive. In such circumstances, We may also refuse to comply with your request.

2. Right to object

You have the right to object to the processing of your personal data at any time. This right applies in cases where Our processing activities are based on the pursuit of a legitimate interest or for marketing purposes. You may exercise this right by submitting an e-mail to dpo@nr.prgoff.com. Upon receipt of your objection, We will cease to process your personal data for the specified purposes.

3. Right to correction

You have the right to request the correction of any inaccurate or incomplete personal data that We have processed. This includes the right to update any outdated information and to provide supplementary statements to ensure the accuracy and completeness of your personal data.

4. Right to erasure

You have the right to request the erasure of your personal data in cases where:

  • You withdraw your consent to processing and no other lawful basis for processing exists
  • Your personal data is no longer necessary for the purposes for which it was originally collected
  • You object to processing for marketing purposes and there are no overriding legitimate grounds for such processing
  • Your personal data has been unlawfully processed
  • Erasure is required to comply with a statutory obligation to which We are subject

5. Right to restriction of processing

You have the right to request the restriction of Our processing activities in cases where:

  • You contest the accuracy of your personal data, for a period enabling Us to verify the accuracy of such data
  • Our processing activities are deemed unlawful and you oppose erasure, requesting restriction instead
  • We no longer require your personal data for the purposes stated in this Privacy Policy, but you require it for the establishment, exercise, or defense of legal claims
  • You have objected to processing and the verification of legitimate grounds is pending

Where you may have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact dpo@nr.prgoff.com. This will not affect the lawfulness of the processing we carried out on the basis of such consent before its withdrawal. Once we have received notification that you have withdrawn your consent, we will no longer process your information for that purpose unless we have another legitimate basis for doing so in law. Withdrawal of consent may result in us having to terminate our services with you immediately.

How We Process Your Personal Information

A. The personal data we collect from you

While using this Website, you may contact our representatives and obtain information relating to the citizenship program overseen by Us. You may also contact us if you are looking for a career opportunity or wish for us to provide you with further information to support your press or media work. You may also contact us for general enquiries or if you are planning to be our suppliers.

We will collect and process the following personal data about you:

1. The information you give us

These are personal details and include your first name, last name, nationality, country of residence, e-mail address, and phone number. These information also include details about your enquiry.

Such information may be provided by you in the following circumstances:

  • Submitting an application of citizenship program
  • Filling in an enquiry form on the Website
  • Corresponding with us by post, phone, e-mail, or otherwise when you apply for our services
  • Giving us some feedback
  • Starting negotiations for or entering into a contract to supply goods and/or services to us

To the extent you engage our website service or where you might apply for a job opportunity, you may be required to provide further information. Where you are a business user, we may also require further information before we enter into a commercial relationship with you. Such additional information may include payment details such as banking information, VAT numbers, and/or tax IDs in order for us to process payments. We may also require you to provide us with information that might be needed to establish and serve as proof of your identification, such as copies of your passport or national ID card. Where you are a job applicant, you will be required to provide a copy of your up-to-date CV. Where we are collecting or processing further information, we will provide you with separate privacy notices that further describe how and why we are using your personal data.

Where we are required to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the services as agreed or we may not be able to enter into a contract with you, but we will notify you if this is the case at the time. We may have to terminate that contract with you as a result.

2. The information we collect about you from our Website

Whenever you visit our Website, we will automatically collect the following:

  • Technical information: including the IP address used to connect your computer to the internet, your log-in information, the browser type and version, the full uniform resource locators (URL), and the clickstream to, through, and from our Website (including date and time), as well as other information regarding your experience on our Website such as page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse- overs), and methods used to browse away from the page.
  • Location information: We may receive information about your location and may determine your location through your IP address and, when accessing the Website through a mobile device, by using the data that we collect from that device. This includes information about the wireless networks or cell towers near your mobile device at the time of access. Our Website uses cookies to distinguish you from other users of our Website. This helps ensure that we provide you with a good experience when you browse our Website and allows us to improve it. For detailed information on the cookies we use, and the purposes for which we use them, see our Cookie Policy.

3. Information we receive from other sources

We may receive personal data about you from various third parties and publicly available sources as set out below:

  • Technical data from Google Analytics advertising features, including Google AdWords, Google Tag Manager, Google Search Console, and other ad hoc paid media partnerships.
  • Identity, contact, and background data from publicly available sources, compliance databases, and/or compliance and due diligence service providers.

B. How We use your information

1. The information you give us

We shall use this information:

  • To oversee the Nauru Economic and Climate Resilience Citizenship Program
  • To facilitate the provision of the website services that you request and where we need to perform the contract we are about to enter into or have entered into with you
  • Where it is necessary for our legitimate interests (or those of a third party), and where your interests and fundamental rights do not override those interests
  • Where we need to comply with a legal or regulatory obligation
  • To resolve any issues that you have reported and to provide support-related services
  • To manage the supplier relationship you have with Us

2. The information we collect about you from our Website

We shall use this information:

  • To administer our Website and for internal operations, including troubleshooting, and in order to keep our Website safe and secure
  • To improve our Website to ensure that content is presented most effectively for you
  • To ensure that content displayed on the Website is presented in a user-friendly manner

3. Information we receive from other sources

We will combine information we receive from other sources with information you provide to us and information that we collect from you. We will use your information only for purposes as described in the paragraphs above.

C. Disclosure of your information

We share personal data of Nauru Economic and Climate Resilience Citizenship Program applicants with government agencies and authorities in Nauru. We may be required to share your data with local agents or other service suppliers, which is necessary for the citizenship program oversight. These local agents and suppliers store and process your data based on strict confidentiality and subject to the appropriate security measures and safeguards in place.

We may also share your data with other third parties in their capacity as data controllers such as legal, tax, real estate, immigration or other advisors and consultants, (international) banks for payment details, or third parties providing other or additional services or goods to you such as real estate agencies, owners, or developers who you might wish to engage with under separate terms and conditions between you and such third parties. These third parties will process your data in their own right as data controllers and their data protection policies and processes shall become applicable.

We may also disclose or share your data if we are under a duty to do so in order to comply with any legal obligation, judgment, or under an order from a court, tribunal, or authority. We may also disclose your data to enforce our terms of use, or to protect our rights, property, or safety, that of our partners or other users of our Website. This includes exchanging information with other companies and organizations for the purposes of anti- money laundering or KYC checks, compliance with anti-bribery or corruption laws, and/or fraud protection.

Where we share your personal data with internal or external third parties, this may involve transferring your data outside of our jurisdiction. We will transfer your personal data in accordance with compliant data protection mechanisms. We work closely with third parties to provide you with the services you request on our Website. These third parties include cloud storage providers, analytics providers, and search engine information providers. We will only work with third-party providers that comply with applicable laws in the jurisdictions in which we operate.

Legal basis for processing

We shall only process your personal data insofar as this is necessary for us to be able to oversee the Nauru Economic and Climate Resilience Citizenship Program, to provide the website services We offer and/or for the purposes indicated in this Privacy Policy.

We may also process your personal data based on any legitimate interest or in order to comply with any legal obligations. These interests and obligations may include the exercise or defense of legal claims or in order to comply with an order of any court, tribunal, or authority, or disclosure to a government or regulatory entity.

Generally, we do not rely on consent as a legal basis for processing your personal data. However, where your consent is required, we will provide you with a form requesting explicit consent to do so.

Data security

We will ensure that appropriate security measures are taken against unlawful or unauthorized processing of personal data, and against the accidental loss of or damage to personal data.

The transfer of information between our Website and your device is protected with transport layer security (TLS) certificates. When the Website is accessed using compatible browsers, that technology protects personal information using both server authentication and data encryption to ensure that personal information is safe and secure while in transit. The mainstream browser versions compatible with this technology are Internet Explorer (from version 11), the Mozilla Firefox (from version 27), Google Chrome (from version 32), and Apple Safari (from version 7).

All personal data is stored in a secure server environment that uses a firewall and other advanced technology to protect against interference or unauthorized access. The servers are located in Switzerland. Usernames and passwords are issued to persons authorized to access the personal data, such as our employees, who are bound by confidentiality not to disclose any personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data. However, where your consent is required, we will provide you with a form requesting explicit consent to do so.

Data storage

We shall only store your data as long as is strictly necessary for the purposes for which it was collected (that is, to oversee Nauru Economic and Climate Resilience Citizenship Program, to provide you with our services or to satisfy any legal, accounting, or reporting requirements). In any case, the retention successful application a date of termination or completion of the services. This period of retention enables us to use the data for defending potential legal claims, taking into account the applicable limitation periods under relevant laws, as well as, if applicable, to comply with anti-money laundering or KYC laws and regulations, anti-bribery or corruption laws and regulations, and accounting and tax laws applicable to certain jurisdictions in which we operate.

Whenever and to the extent possible, We anonymize the data that We hold about you.

Quality of website and overall experience

To improve the quality and overall user experience of the Website, we use Google Analytics advertising features.

If you would like to opt out of Google Analytics for display advertising, you may do so by using the ads preference manager.

In addition, there is a Google Analytics ‘opt-out browser’ add-on that you can download at https://tools.google.com/dlpage/gaoptout.

You may withdraw your consent given for any of the purposes listed above at any time. This does not affect the lawfulness of your personal data for these purposes prior to your withdrawal. You may send us an e-mail at dpo@nr.prgoff.com indicating your withdrawal of consent and specifying which processing activities such withdrawal relates to.

Complaints

We welcome any comments, complaints, and queries in relation to data protection. As indicated above, you may contact our data protection officer at dpo@nr.prgoff.com or use the contact details at section ‘How to contact us’ below, and we shall try our best to deal with any issue or concern you may have.

If we fail to address the concerns, you have the right to lodge a complaint with the Office of the Privacy Commissioner of New Zealand as the relevant national supervisory authority on all data protection matters.

Changes to this Privacy Policy

Any changes we make to this Privacy Policy in the future will be posted on this page, and where appropriate, notified to you via e-mail.

How to contact us

If you have any questions regarding this Privacy Policy, or if you would like to send us your comments, write to us using the details below:

Nauru Program Office (NZ) Limited
Perpetual Guardian Tower
191 Queen Street, Level 15
Auckland Central, 1010
New Zealand
+64 9 222 1324
contact@nr.prgoff.com