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This privacy policy explains how we collect and use personal information when you are using the Piwakawaka app, browsing our website in connection with the Piwakawaka app, or if you otherwise communicate or interact with us in relation to the Piwakawaka app.

In this policy, "personal information" means information about an identifiable individual.

Who We Are

When we say "our", "we", or "us", it means Winslade Legal Limited. We are a New Zealand company (NZBN: 9429052289613) and you can contact us about any privacy or data protection matters by emailing us at ben@winslade.legal.

This privacy policy applies only to personal information we process as part of the Piwakawaka app. It does not apply to personal information we process in the context of providing legal services to clients. If you ever have any questions, concerns or complaints about how we have handled your personal information in connection with the Piwakawaka app, please contact us using the email address above.

How We Collect Personal Information

We may collect personal information directly from you when you are using our platform (e.g. information you upload to the platform and actions you take using it).

You don't need to provide any account information to use the free version of our platform, which isn't protected by a secure log in process. You can always choose whether or not to add personal information into any documents you are generating. We recommend that you don't provide personal information to add into your documents via the Platform. We allow you to download them and add personal information (and more sensitive commercial details) later in a more secure environment.

We do not store documents containing personal information generated via the free version of our site, unless you choose to send them to a lawyer.

We may also collect personal information from you if you call or email us, fill out a form on our website, or request content or marketing from us.

In addition to information you directly provide to us, we may obtain information about individuals directly from the New Zealand NZBN register. For example, if you select a company when creating a document, we will automatically obtain information about the shareholders and directors registered with the companies office for that company and may populate that information into a document you are creating.

You must ensure you have the consent of any individuals before adding personal information about any third parties into a document you are creating, including the names of directors or shareholders of a company.

Usage Data and Cookies

We collect personal information about you automatically when you are using our website and platform. This may include your online device information, such as the IP address and ID of the device you are using, the domain name from which you are accessing the internet, the operating system and browser your device uses, the search engine you are using, your browsing behaviour and click activities, date and time of your visit, and location data based on where your browsing session originates ("Usage Data").

As well as cookies that we set ourselves (both temporary and persistent) that are necessary to provide the platform, these may include cookies set by third parties for marketing purposes. Usage Data collected via third party cookies is used by the third party pursuant to its privacy policy.

For example, we use web analytics services from Google Analytics. Google uses the Usage Data it collects via these cookies in conjunction with other data collected by Google. You can find out more about how Google processes personal information at Google's Privacy & Terms. Hotjar is another third-party provider that may set cookies on our site and/or otherwise collect Usage Data. This is not an exhaustive list, and we frequently review the third-party service providers we use.

How We Use Personal Information

We may use personal information to:

  1. provide the platform and generate documents for people using it;
  2. communicate with you in respect of our services and technology, for example, send you service messages as part of the use of our platform;
  3. respond to you if you make an enquiry;
  4. if you have agreed to receive it, send you email marketing;
  5. provide, secure, update and maintain our products and services, website, social media accounts, training materials and events;
  6. analyse, improve and develop the functionality of our products and services;
  7. support our business development and marketing activities, including analysing business opportunities and target audiences, identifying and communicating with potential customers, and providing more relevant content and advertising;
  8. prevent, detect, or investigate security concerns, including fraud; and
  9. comply with applicable laws, regulations, legal processes and genuine requests from regulators or law enforcement agencies.

We will retain personal information only for as long as is necessary for these purposes.

If you generate a document via the free version of our platform, we will not store copies of any documents generated or downloaded, unless you send a document to us for legal review. However, we may retain Usage Data and inputs and responses from our AI providers after we have aggregated it and stripped it of identifying details related to individuals or companies, for the purpose of improving the quality of document drafting or review available via Piwakawaka.

Disclosure of Personal Information

We use a range of IT service providers to support our business. We may store your personal information with these parties, who will primarily act as our agent and only process your personal information on our instructions.

If you use the platform to amend a document using personal information, that personal information will be disclosed to our third-party providers who provide the Artificial Intelligence that powers Piwakawaka. Our AI providers commit to act on our behalf as our agents or data processors. They also commit to us contractually that they will delete information they receive from us within 30 days (unless they are legally required to retain it) and will not use any data (including your personal information) to train their AI models.

Except as expressly set out above, we will only disclose your personal information to third parties to use for their own purposes in the following situations:

  1. if required, and to the extent necessary, for the purpose the personal information was collected;
  2. if required, to comply with applicable laws, regulations, or legal processes or in response to a genuine request by a regulator or law enforcement agency;
  3. to prevent, detect, or investigate security concerns, including fraud; and/or
  4. in relation to the proposed purchase or acquisition of our business or assets.

International Transfers

Your personal information may be processed by us in New Zealand (where our corporate headquarters is located) and in the location where our IT service providers who support our platform store their data. Information sent to our AI providers will be processed by them in the United States.

Except to the extent explained in this policy, IT service providers handle such information on our behalf as our agent and we remain responsible to you for their handling of personal information. This may result in your personal information being stored in a different country than where you live, which may not have the same laws in place to protect personal information.

Protecting Your Personal Information

We will take reasonable steps to protect your personal information from loss, and unauthorised access, use, modification and disclosure or other misuse. That includes appropriate technical and organisational methods to protect your personal information.

If we suffer a privacy breach in respect of your personal information, we may notify you and/or an applicable regulator, including where required under applicable laws.

Your Rights

You may request that we update or correct your personal information, opt out of marketing messages, or access the personal information that we hold about you. We will promptly respond to any such requests.

If you want to exercise any of these rights, please email us at ben@winslade.legal. If you have any concerns or complaints about how we have handled your personal information, please also raise them with us using this same address.

You can disable cookies by changing the settings on your browser or by changing your cookie preferences when using our website, but this may impact your experience. To use and get the full benefit of our platform you will need to accept cookies.

You can opt-out of Google Analytics Advertising Features here or use a browser plugin to opt-out of Google Analytics cookies here.

Changes to This Privacy Policy

We may update this privacy policy from time to time by publishing the updated version on our website.