Privacy Policy

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Volition Solutions Limited ("we", "our", "us") operates the Volition application ("App") and associated services.

We act as both a data controller and data processor under the Privacy Act 2020 and the Health Information Privacy Code 2020 (HIPC).

This Privacy Policy explains how we collect, use, store, and protect your personal information, and your rights to access and correct it. It should be read in conjunction with our Terms of Service.

By using the App, you agree to this Privacy Policy.
 

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1.    Our Commitment to Privacy

 

1.1  We are committed to protecting your privacy and ensuring the security of your personal information.

 

We comply with the Privacy Act 2020 and all other applicable laws. Volition’s Privacy Officer can be reached at privacy@volition.org.nz.

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2.   How We Use Your Information

 

2.1   We use your personal information to:

• Respond to inquiries and manage your registration of interest

• Improve the functionality and usability of our App

• Conduct analytics and research (using anonymised or aggregated data)

• Maintain records for legal and accounting purposes

• Ensure compliance with legal obligations

• Personalise your experience within the App

• Send relevant notifications and updates (with your consent).

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We may use trusted third-party platforms for analytics to help us improve our services.
We will not use your information for any other purpose unless authorised or required by law.

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3.   Information We Collect

 

We may collect the following categories of information:

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3.1   Personal Information:

• Name

• Email

• Phone number

• NHI number

• Personal preferences​

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3.2  Transactional Information:

• Payment records processed through Stripe 

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3.3   Automatically Collected Information:

• IP address

• Device data

• Browser type

• Activity logs

• App usage data 

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4.   Children's Privacy

 

4.1   Intended Users: Volition is designed for adults with learning disabilities or cognitive impairments, and those supporting them.

We do not knowingly collect personal information from children under 13 without parental 

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4.2   Use by Minors: Children under the age of 13 wanting to use the app must have parental consent.

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5.    Cookies and Tracking Technologies

 

5.1   We use cookies, SDKs and similar technologies for functionality and analytics.
You can manage preferences through your browser or device settings. Disabling cookies may affect App performance.

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6.    Sharing of Information

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We do not sell or rent your personal data. We may share information with:

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6.1    Service Providers: Such as Stripe and Propagator Limited (ISO27001 certified) for payment and integrations.

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6.2    Legal Authorities: Where required.

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6.3    Successors: in the event of a business merger or acquisition.
 

Users can share data within their Circle of Support or from their Volition account at their discretion.

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7.    International Data Transfers

 

7.1   Hosting: Data is hosted in multiple AWS regions including the United States (N. Virginia) and Asia Pacific (Sydney). We ensure that all overseas data processors adhere to privacy protections substantially similar to the NZ Privacy Act 2020.

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7.2   GDPR: Volition is not currently available in jurisdictions governed by the European Union’s General Data Protection Regulation (GDPR) until compliance expansion is completed.

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8.    Your Rights

 

8.1   Under the Privacy Act 2020, you have the right to access, correct, or delete your personal data, and to request data portability. Requests must be made in writing and may require proof of identity.

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8.2   Data deletion requests are processed within seven working days, with backups retained up to 12 months for audit purposes.​

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9.    Data Retention

 

9.1   Volition retains personal data only as long as necessary to fulfil its purpose or as required by law. Personal data will be permanently deleted 12 months after account closure. Aggregated, anonymised data may be retained for research or product improvement.

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9.2   User account and profile information:  Will be retained for the period that it is active plus twelve months. It will be deleted permanently after this retention period.

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9.3   Transactional records:  Will be retained for seven years for accounting and legal compliance.

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9.4   Aggregated Anonymised Data:  Will be retained indefinitely and used for research and service improvement.

 

9.2   Back up Data:  Will be retained for up to 12 months and retained for disaster recovery and audit purposes.

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10.  Data Security

 

10.1  We apply reasonable and appropriate safeguards to protect personal information, including encryption of data at rest and in transit, regular penetration testing, and security audits.

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11.  Third Party Links

 

11.1  Our App may contain links to third-party websites or applications. We are not responsible for the privacy practices or content of those sites or apps. We encourage you to review the privacy policies of any third-party websites or applications you visit.

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12.  Changes to this Policy

 

12.1  We may update this Privacy Policy periodically. Changes will be communicated via in-app notices or email, with the latest version always available within the App.

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13.  Contact Us

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​13.1  Contact us: If you have any questions about this Policy, You can contact our Privacy Officer at Privacy@Volition.org.nz