Privacy Policy

Effective date: 1 March 2025 | Last reviewed: March 2026 | Governed by the New Zealand Privacy Act 2020

This policy explains what information we collect, why we collect it, how we use it, and your rights under the New Zealand Privacy Act 2020. If you have questions, email hello@untangle.co.nz.

1. Who This Policy Applies To

This Privacy Policy applies to anyone who uses untangle.co.nz, creates an account, completes the OWLS Profile, or engages with our services. It applies regardless of where you are located, as long as you are accessing Untangle.

Untangle Limited is the data controller for information collected through the platform. We are subject to the New Zealand Privacy Act 2020 and its 13 Information Privacy Principles.

2. What Information We Collect

Information You Give Us Directly

  • Your name and email address when you register
  • Billing information (processed securely through Stripe — we do not store card details)
  • Your responses to the OWLS Profile
  • Information you share in community spaces or through support contact
  • Profile information you choose to add

Information We Collect Automatically

  • Technical data such as IP address, browser type, and device information
  • Usage data — which pages you visit, how long you spend, which features you use
  • Cookie data (see Section 7 for more on cookies)

A Note on Information About Your Child

📝 The OWLS Profile asks questions about your child’s behaviours and patterns. This information is provided by you (the parent or caregiver) about your child — it is your information, not your child’s. We do not directly collect information from children, and we do not knowingly allow children under 18 to create accounts.

3. Why We Collect Your Information

We collect information to:

  • Create and manage your account
  • Deliver the OWLS Profile and generate your personalised executive function profile
  • Recommend relevant courses and resources
  • Process your subscription and payments
  • Provide customer support
  • Improve the platform and develop new features
  • Communicate with you about your account, platform updates, or relevant resources
  • Maintain the security and integrity of the platform

We collect only what we need. We do not collect information speculatively.

4. Indirect Collection (IPP 3A)

From 1 May 2026, the Privacy Act 2020 requires us to notify you when we collect personal information about you from a source other than yourself.

In some cases, we may receive information about your use of the platform through third-party tools (such as analytics services) rather than directly from you. Where this occurs, we will:

  • Tell you what information was collected and from where
  • Explain why it was collected and how it will be used
  • Make this information available as early as reasonably practicable

If you have questions about indirect collection, contact us at hello@untangle.co.nz.

5. How We Use Your Information

Personalisation

Your OWLS Profile responses are used to generate your personalised executive function profile and recommend specific courses and resources. This is the core purpose of the platform. Your profile is not shared with other members.

Communications

We may contact you with:

  • Account notifications (required — cannot be turned off)
  • Platform updates and new content (you can opt out)
  • Community activity relevant to you (you can control this in settings)
  • Newsletters and educational content (opt-in only)

Platform Improvement

We use aggregated, anonymised data to understand how the platform is being used and how we can improve it. This data does not identify individuals.

Research

We may use anonymised, aggregated profile data for research purposes — for example, to improve the OWLS framework or contribute to understanding of executive function support. Individual data is never identifiable in any research context.

6. Who We Share Your Information With

We do not sell your personal information. We do not share it with advertisers. We share information only as follows:

Service Providers

We use trusted third-party services to operate the platform. These providers access only the information they need to do their job:

  • Stripe — payment processing (stripe.com/privacy)
  • WordPress / WP Engine — website hosting
  • LifterLMS — course delivery
  • BuddyBoss — community features
  • Paid Memberships Pro — subscription management
  • Engagement Bay — CRM and email communications
  • Google Analytics — anonymised usage analytics

Where these providers operate outside New Zealand, we take steps to ensure your information is protected to a standard comparable to the Privacy Act 2020. You can ask us about specific provider locations at hello@untangle.co.nz.

Legal Requirements

We may disclose your information if required by law, or if we believe disclosure is necessary to prevent serious harm to a person’s safety. We will always try to notify you if legally permitted to do so.

Business Transfers

If Untangle is acquired or merged, your information may be transferred as part of that transaction. We will notify you before your information is subject to a different privacy policy.

7. Cookies

We use cookies and similar technologies to make the platform work and to understand how it’s being used. Cookies are small text files stored on your device.

We use:

  • Essential cookies — required for the platform to function (login sessions, security)
  • Analytics cookies — to understand usage patterns (anonymised)
  • Preference cookies — to remember your settings

You can control cookies through your browser settings. Disabling some cookies may affect platform functionality. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

8. Your Rights

Under the Privacy Act 2020, you have the right to:

  • Access the personal information we hold about you
  • Correct information that is inaccurate or incomplete
  • Request deletion of your information (subject to legal obligations)
  • Object to how we use your information
  • Withdraw consent for communications you’ve opted into
  • Know whether we hold information about you

To exercise any of these rights, email hello@untangle.co.nz. We will respond within 20 working days, as required by the Privacy Act 2020.

You also have the right to complain to the Office of the Privacy Commissioner (privacy.org.nz | 0800 803 909) if you believe your privacy rights have been breached.

9. How We Protect Your Information

Our security measures include:

  • SSL/TLS encryption for all data transmitted to and from the platform
  • Secure password storage (passwords are never stored in plain text)
  • Access controls — only authorised team members can access user data
  • Payment security — card details are handled entirely by Stripe, never stored by us
  • Regular security reviews

No system is completely secure. If a privacy breach occurs that is likely to cause serious harm, we will notify you and the Office of the Privacy Commissioner as required by the Privacy Act 2020, without undue delay.

10. How Long We Keep Your Information

  • Account information — retained while your account is active, and for 2 years after closure
  • OWLS Profile data — retained while your account is active
  • Payment records — retained for 7 years as required by tax law
  • Community contributions — may be retained in anonymised form

You can request deletion of your account and associated data at any time. Some information may be retained where we have a legal obligation to do so.

11. International Data Transfers

Some of our service providers operate outside New Zealand. When we transfer your information overseas, we ensure the recipient provides privacy protections comparable to those required by the Privacy Act 2020. This is consistent with Information Privacy Principle 12.

New Zealand is recognised as providing adequate privacy protections under European Union law, which means international transfers are simplified for EU-based services.

12. Privacy Officer

As required by the Privacy Act 2020, Untangle has a designated Privacy Officer responsible for ensuring we meet our obligations under the Act.

Contact our Privacy Officer:

13. Changes to This Policy

We may update this Privacy Policy from time to time. If we make significant changes, we’ll notify you by email or in-platform notification before the changes take effect. The effective date at the top of this document shows when it was last updated.

Continuing to use Untangle after the effective date constitutes acceptance of the updated policy.

14. Questions and Complaints

If you have any questions about this Privacy Policy or how we handle your information, please contact us:

If you’re not satisfied with how we’ve responded to a privacy concern, you can contact the Office of the Privacy Commissioner:

  • Website: privacy.org.nz
  • Phone: 0800 803 909
  • Post: PO Box 10094, Wellington 6143

Untangle Limited | untangle.co.nz | hello@untangle.co.nz

Effective: 1 March 2025 | Last reviewed: March 2026 | Governed by New Zealand law