Privacy Policy

Last updated: December 23, 2025

Effective date: December 23, 2025

1. Information We Collect

Personal Information You Provide

We collect information you voluntarily provide when you:

• Create an account: Name, email address, phone number (optional)
• Use our coaching tools: Health metrics, mood data, habit tracking, calendar events
• Contact us: Name, email, message content
• Make payments: Billing information (processed securely by third-party providers)

Automatically Collected Information

• Usage data: Pages visited, time spent, features used
• Device information: Browser type, operating system, IP address
• Cookies: Session cookies for functionality (no tracking cookies)

2. How We Use Your Information

Primary Purposes

• Service delivery: Provide wellness coaching and tracking tools
• Account management: Maintain your account and preferences
• Communication: Respond to inquiries and provide support
• Improvement: Enhance our services and user experience

Legal Basis (GDPR)

• Contract performance: Providing coaching services you've requested
• Legitimate interest: Improving services and preventing fraud
• Consent: Marketing communications (opt-in only)
• Legal obligation: Compliance with New Zealand and international laws

3. Information Sharing and Disclosure

We DO NOT sell your personal information

We may share your information only in these limited circumstances:

• Service providers: Trusted partners who help operate our platform (hosting, payment processing)
• Legal requirements: When required by law or to protect rights and safety
• Business transfers: In case of merger or acquisition (with notice)
• Your consent: When you explicitly authorize sharing

4. Data Security

Security Measures

• Encryption: All data transmitted using SSL/TLS encryption
• Access controls: Strict employee access on need-to-know basis
• Secure hosting: Data stored on secure servers in New Zealand
• Regular audits: Ongoing security assessments and updates

5. Your Rights and Choices

Your Privacy Rights

• Access: Request a copy of your personal data
• Correction: Update or correct inaccurate information
• Deletion: Request deletion of your personal data
• Portability: Receive your data in a portable format
• Objection: Object to processing based on legitimate interests
• Restriction: Request limitation of processing

How to Exercise Your Rights

Contact us at info@kowhaicoaching.nz or use your account settings to:

• Update your profile information
• Download your data
• Delete your account
• Manage communication preferences

6. Data Retention

We retain your information for as long as necessary to provide services and comply with legal obligations:

• Account data: Until account deletion + 30 days
• Health tracking data: Until account deletion
• Communication records: 7 years (business records requirement)
• Payment records: 7 years (tax and legal requirements)

7. International Data Transfers

Your data is primarily stored in New Zealand. If transferred internationally, we ensure adequate protection through:

• Adequacy decisions by relevant authorities
• Standard contractual clauses
• Certification schemes

8. Children's Privacy

Our services are not intended for children under 16. We do not knowingly collect personal information from children under 16. If you believe we have collected such information, please contact us immediately.

9. Cookies and Tracking

We use essential cookies only:

• Session cookies: Required for login and security
• Preference cookies: Remember your settings
• No tracking cookies: We don't use analytics or advertising cookies

10. Changes to This Policy

We may update this policy to reflect changes in our practices or legal requirements. We will:

• Notify you of material changes via email
• Post updates on our website
• Provide 30 days notice for significant changes

11. Contact Information