Data Processing Addendum

Last updated: 4 July 2026
Applies to: SiliconKiwi services provided by BTIT Consulting Limited
Customer: the person, business or organisation purchasing or using SiliconKiwi services.

1. Purpose

This Data Processing Addendum explains how SiliconKiwi processes personal information on behalf of customers when providing VPS hosting, cloud servers, managed hosting, DNS, backups, support, system administration or related services.

This addendum forms part of our agreement with you. If there is a conflict between this addendum and another agreement, this addendum applies to the extent the conflict relates to processing customer personal information on your behalf.

2. Roles

For personal information that you upload, store, transmit, manage or otherwise process through SiliconKiwi services, you are generally the controller, agency, business owner or equivalent decision-maker.

SiliconKiwi acts as a processor, service provider or operational supplier where we process that information only to provide the services, follow your instructions, maintain security, comply with law, or protect the services.

For personal information SiliconKiwi collects for its own business purposes, such as account management, billing, support, fraud prevention and service administration, SiliconKiwi is responsible for that information. That processing is covered by our Privacy Policy.

3. Types of personal information

Depending on the SiliconKiwi services you use, customer personal information may include:

  • names, usernames and contact details;
  • account identifiers and customer records;
  • website, application, database or file content;
  • emails, logs, metadata and communications;
  • IP addresses, device information and network identifiers;
  • billing, transaction and support information;
  • backup data, snapshots and system images;
  • any other personal information you choose to store or process using SiliconKiwi services.

4. Processing activities

SiliconKiwi may process customer personal information to:

  • provide, operate and support SiliconKiwi services;
  • host, store, transmit, back up, restore or secure data;
  • provision VPS, hosting, DNS, storage and related services;
  • monitor service health, performance and availability;
  • troubleshoot faults and respond to support requests;
  • prevent abuse, spam, fraud, security incidents and unlawful use;
  • maintain network and platform integrity;
  • carry out actions you request through the customer portal, support desk, API or written instruction;
  • comply with legal, regulatory or law enforcement obligations.

5. Customer instructions

SiliconKiwi will process customer personal information according to your documented instructions, including the instructions in the service agreement, order, support request, portal action, API request or other authorised communication.

We may decline or suspend an instruction if we reasonably believe it is unlawful, unsafe, technically impractical, outside the scope of the service, or likely to harm SiliconKiwi, our network, another customer or a third party.

6. Confidentiality

SiliconKiwi will limit access to customer personal information to personnel, contractors and suppliers who need access to provide or support the services.

People with access are required to protect confidential information and use it only for authorised purposes.

7. Security measures

SiliconKiwi will maintain reasonable technical and organisational safeguards appropriate to the nature of the services and the risks involved. These may include, as applicable:

  • access controls and authentication;
  • network segmentation and firewalling;
  • encryption in transit where supported;
  • secure administration practices;
  • logging and monitoring;
  • backup and recovery processes;
  • vulnerability management;
  • abuse and security response processes;
  • staff access controls;
  • supplier due diligence;
  • physical and environmental controls for infrastructure we operate.

Security responsibilities may be shared. You remain responsible for securing your own applications, accounts, passwords, operating systems, code, customer data, firewall rules, access permissions and configurations unless your SiliconKiwi service agreement expressly says we manage those items for you.

8. Sub-processors and suppliers

SiliconKiwi may use sub-processors and suppliers to provide parts of the service. These may include data centre operators, connectivity providers, software vendors, payment processors, monitoring providers, email providers, support platforms and professional advisers.

We will take reasonable steps to ensure sub-processors protect customer personal information to a standard appropriate to their role.

A current list of key sub-processors may be made available on request or published on the SiliconKiwi website.

9. International processing

SiliconKiwi aims to provide New Zealand-focused hosting and infrastructure services. Some support systems, suppliers, monitoring tools, software platforms or business systems may involve processing or access from outside New Zealand.

Where customer personal information is transferred or accessed internationally, we will take reasonable steps to ensure appropriate protection is in place, having regard to the nature of the service, the supplier, the destination and the safeguards available.

Where you require data to remain in a specific country, region or facility, this must be agreed in writing as part of the relevant SiliconKiwi service order.

10. Assistance with privacy obligations

Taking into account the nature of the service and information available to us, SiliconKiwi will provide reasonable assistance where you need information from us to respond to privacy requests, access requests, correction requests, security reviews, audits, breach assessments or regulatory obligations.

This assistance may be subject to reasonable limits, security verification, confidentiality requirements and professional services charges where the work is outside normal support.

11. Privacy and security incidents

If SiliconKiwi becomes aware of a security incident affecting customer personal information that we process on your behalf, we will notify you without undue delay after confirming the nature of the incident and your involvement.

Our notice may include, where known:

  • the nature of the incident;
  • the affected service or data;
  • likely consequences;
  • actions taken or proposed;
  • recommended customer actions;
  • contact details for follow-up.

You are responsible for assessing whether you need to notify affected individuals, regulators or other parties, unless the law requires SiliconKiwi to do so directly.

12. Deletion and return of data

During the service term, you may access, export, delete or modify customer data using the tools available for the SiliconKiwi service.

After termination, cancellation or expiry of a service, SiliconKiwi may delete customer data according to our retention, backup and operational processes. Backups may persist for a limited period before being overwritten or securely removed.

If you require a formal data export, secure deletion certificate, extended retention, litigation hold or custom handover process, this must be requested before termination and may be subject to additional charges.

13. Audit and information requests

SiliconKiwi may provide reasonable information about our security, privacy and operational controls where required for your compliance obligations.

Audits must be reasonable, proportionate, protect other customers and our security, and be agreed in advance. We may satisfy audit requests through written responses, security documentation, certifications, third-party reports or structured review meetings.

14. Customer responsibilities

You are responsible for:

  • ensuring you have a lawful basis to collect and process personal information;
  • providing privacy notices to your users where required;
  • obtaining consents where required;
  • configuring SiliconKiwi services securely;
  • managing user access and credentials;
  • deciding what data is uploaded or stored;
  • complying with laws that apply to your business and users;
  • ensuring your instructions to SiliconKiwi are lawful.

15. Changes

SiliconKiwi may update this addendum from time to time. Material changes will be published on our website or notified through normal customer communication channels.