Privacy Policy

Introduction

Clasp NZ Limited (we, us, our) complies with the New Zealand Privacy Act 2020 (the Act) when dealing with personal information. We encourage you to read this policy carefully. Personal information means information about an identifiable individual (a natural person). This policy sets out how we collect, use, disclose and protect your personal information.

This policy does not limit or exclude any of your rights under the Act. If you wish to seek further information on the Act, see www.privacy.org.nz.

Changes to this policy

We may change this policy by uploading a revised version onto our website. The change will apply from the date we upload the revised policy.

This policy was last updated on 17 June, 2025.

Personal information we collect

We collect personal information in the following ways:

• Information you provide to us: This includes details such as your name, contact information, and account credentials when you sign up or communicate with us. We may also collect billing details required for payment processing.
• Information collected through service usage: Our services may capture data entered by users, including incidental personal information in free-text fields such as Drill Notes. We may also gather statistical insights on service interactions to improve performance and user experience.
• Information collected automatically: We use cookies and similar tracking technologies (e.g. pixels and web beacons) to analyse usage, improve our services, and maintain security. These tools may collect data such as:
  • IP addresses
  • Device and browser information
  • Interaction data (e.g. pages visited, time spent on the site)
  • Referring websites or links

We currently use third-party analytics services, including Google Analytics and Posthog, to process this data.

How we collect personal information

We collect personal information:

• Directly from you when you provide it through our website, services, registration or subscription processes, or when you contact us (e.g. via email or phone).
• Through automated tracking when you interact with our website or services, via cookies and analytics tools.
• From third parties where you have authorised this or where the information is publicly available.

Where possible, we collect personal information directly from you.

How we use your personal information

• To verify your identity.
• To provide and administer your account and enable access to our services.
• To deliver, improve, and secure our services, including analysing user behaviour to enhance functionality, performance, and user experience.
• To market our services to you, including contacting you electronically (e.g. by text, email, or social media), subject to your preferences.
• To process payments and manage our accounts, including authorising and processing credit card transactions.
• To respond to your enquiries, feedback, or complaints.
• To conduct research and statistical analysis on an anonymised basis.
• To protect and enforce our legal rights and fulfil regulatory obligations.
• To ensure the trust and safety of children and service users.
• Where applicable, to support professional development by allowing educators and mentors to access lawful content for assessing performance and compliance with professional obligations.
• For any other purpose authorised by you or required under applicable laws.

Lawful basis for processing

Under the Privacy Act 2020, we only collect, use, and disclose personal information where we have a lawful basis to do so. This may include where:

• You have provided your express or implied consent.
• The collection is necessary for the performance of a contract with you.
• We are required or authorised by law to collect the information.
• The collection is necessary for a legitimate purpose connected with our functions or activities.

Disclosing your personal information

We may disclose your personal information to:

• Service providers who support our services and business operations, including:
  • Client relationship management (HubSpot)
  • Payment processing (Stripe)
  • Cloud hosting and storage (Amazon Web Services)
  • Analytics services (Google, Posthog, Facebook, LinkedIn, HubSpot)
  • Team collaboration tools (Atlassian)
• Third parties for anonymised statistical purposes.
• Regulatory authorities or other legal entities when required by law.
• Law enforcement or other government agencies when legally obligated.
• Other entities as authorised by you.
• Business partners and acquirers in the event of a sale, merger, or reorganisation.

Some of our service providers are located outside of New Zealand. Where your personal information is transferred overseas, we take reasonable steps to ensure that it is protected by comparable safeguards to those required under New Zealand law.

We also share information with analytics, customisation, and advertising partners who may use cookies and tracking technologies to collect data about your interactions with our website over time. You can manage these preferences in the Cookies and Tracking section below.

Protecting your personal information

We take reasonable steps to protect your personal information from loss, unauthorised activity, or other misuse. These include access controls, encryption, secure storage, staff training, and other technical and organisational safeguards.

Accessing and correcting your personal information

You have the right to access the personal information we hold about you and to request corrections, subject to certain legal grounds for refusal. Before we process your request, we may require proof of your identity.

If you request a correction and we believe it is reasonable and feasible to update the information, we will do so. If we cannot make the correction, we will take reasonable steps to note that you have requested it.

To exercise these rights, please contact us at clasp.nz@gmail.com with details of your request. We may charge reasonable costs for providing copies of your personal information or making corrections.

Cookies

We use cookies (an alphanumeric identifier that we transfer to your computer's hard drive so that we can recognise your browser) to monitor your use of the website. You may opt out of cookies on arrival at the website. You may disable cookies by changing the settings on your browser, although this may mean that you cannot use all of the features of the website.

We use Google Analytics to understand how visitors engage with our website and products. This collects information such as your IP address, device type and operating system, referring URLs, location, and pages visited. If you do not want Google Analytics to be used in your browser, you can install the Google Analytics Opt-Out Browser Add-On provided by Google.

We use PostHog analytics to understand how you interact with our website (clasp.co.nz) and application (app.clasp.co.nz). PostHog helps us capture behavioural metrics, heatmaps, and session replays to improve our products and services. We collect this data using first-party cookies only—no third-party tracking services are involved. For more information, see the PostHog Privacy Policy.

Managing your preferences

• Cookies: When first visiting our website, you can choose whether to accept or reject non-essential cookies. If you reject them, you may need to log in again each visit, and some features may not function as intended.
• Marketing Communications: When you provide your details to access content or register for events, you can opt into marketing updates. You can update your preferences or unsubscribe from these emails at any time.

Internet use

While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.

If you follow a link on our website to another site, the owner of that site will have its own privacy policy relating to your personal information. We suggest you review that site's privacy policy before you provide personal information.

Contacting Us

If you have any questions about this privacy policy, our privacy practices, or if you would like to request access to, or correction of, your personal information, you can contact us at clasp.nz@gmail.com.