Last updated: May 2022
1.1. IHC New Zealand Incorporated (IHC) is committed to protecting personal information and privacy rights generally.
For Australian residents, the Australian Privacy Act 1988.
2. Collection of Personal Information
2.1. We will collect Personal Information about you in two different ways:
2.3. If, as a result of the information provided in the survey, you then talk to us or meet with us to give us feedback about the Game (for example by email, or if we have a zoom meeting).
2.4. If when filling out the survey you tell us that you are under 18 years old, we will also ask for you parent or guardian’s contact details (name, phone number, and/or email address).
2.5. Where possible, we will collect Personal Information directly from the individual concerned.
2.6. We will also collect information that does not identify you for the purposes of improving the Game. This information will identify your computer or mobile device, including brower type and version, mobile device type and operating system. We do this by using analytical tools to collect information about the Game and its performance, Game interactions, and Game play analysis. We use Amazon Web Services and/or Firebase analytical tools which will store non-personal data on their servers. Amazon Web Services and Firebase have their own privacy policies which you can read here (AWS) and here (Firebase).
2.8. 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 web version of the Game. 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.
3. Storage and security of Personal Information
3.1. We take the security of your Personal Information seriously, and ensure that all of our staff comply with their legal obligations to protect your Personal Information, except in a limited number of circumstances as required by the Applicable Privacy Laws.
4. How we may use Personal Information
We may use Personal Information:
4.1. to contact you to talk about your experience with the Game and/or your feedback about the Game (this may include contacting you as a parent or guardian of someone who played the Game, if they are under 18 years old);
5.1. If there are additional purposes (other than those identified above) for which we propose to use your Personal Information, the purposes will be specifically notified to you and your consent requested to the proposed use, either when we collect your Personal Information for that specific use or when that additional purpose arises (if it does so after the Personal Information has already been collected).
5.2. We will always give you the option to decline to provide your Personal Information or to decline to allow us to use that Personal Information for the purposes for which we have proposed to use it, and will comply so long as doing so does not prevent us from meeting our legal obligations under Applicable Privacy Laws.
How we use aggregate information and statistics
5.3. IHC may use aggregated information from the Game to improve the quality the Game and for statistical purposes. This aggregated information is not associated with any individual person. We may use this data in aggregate form as a statistical measure, but not in a manner that would identify any individual personally.
6. Disclosing Personal Information
6.1. We will not sell, lend, or trade Personal Information to any third party.
6.2. We will not disclose Personal Information to any third party, except for the purposes for which it was collected, and for directly related purposes (including those required by Applicable Privacy Laws), including but not limited to:
6.3. We will primarily collect and process Personal Information in New Zealand. However because the Game can be played outside of New Zealand, Personal Information will be collected from people playing elsewhere in the world. It may therefore be stored and/or accessed in those countries. That Personal Information is collected and transferred pursuant to and in accordance with Applicable Privacy Laws (except as described in paragraph 1.4 where you live in a location to which the Applicable Privacy Laws do not apply). If at any time we need to send Personal Information outside of a country in which we operate to an overseas agency that may use the information for its own purposes, we will:
7. Accessing and correcting Personal Information
7.1. Subject to certain grounds for refusal set out in the Applicable Privacy Laws, you have the right to access your readily retrievable Personal Information that we hold, and to request a correction to your Personal Information.
7.2. In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the Personal Information, we will make the correction. If we do not make the correction, we will take reasonable steps to note on the Personal Information that you requested the correction.
7.3. You have the right to object to our processing of your Personal Information, in certain conditions. You also have the right to request that we transfer your Personal Information to another organisation, or directly to you, under certain conditions.
7.4. If you want to exercise your rights in respect of your Personal Information, please email us privacy@IHC.org.nz. Before you exercise these rights, we will need evidence to confirm that you are the individual to whom the Personal Information relates.
7.5. We may charge you our reasonable costs of providing to you copies of or correcting your Personal Information.
8. Retention and destruction of your Personal Information
8.1. We will only retain Personal Information for as long as is required for the purpose/s for which it may lawfully be used. Once Personal Information is no longer required, we will securely destroy it or otherwise delete all identifying details information so that only anonymised data is retained.
8.2. You have the right to request that we erase your Personal Information, or restrict the processing of your Personal Information, under certain conditions.
9. Accuracy of Personal Information
10. Mandatory reporting of notifiable privacy breaches
10.1. We have an active management plan for actual, likely, and suspected privacy breaches, including a data incident response plan as required by Applicable Privacy Laws.
10.2. If your Personal Information is involved in a privacy breach which we reasonably believe is notifiable / must be reported in accordance with Applicable Privacy Laws (“Notifiable Privacy Breach”), we will inform the affected individual/s and report the Notifiable Privacy Breach to the relevant supervisory authorities as required by Applicable Privacy Laws (such as the New Zealand Office of the Privacy Commissioner, the Australian Office of the Australian Information Commissioner, the supervisory authority in the relevant European Union Member State, and the Attorney General in California, United States of America).
11. California Residents
11.1. We do not disclose personal information to third parties for direct marketing purposes.
11.2. The California Online Privacy Protection Act requires us to disclose how we respond to “do not track” (DNT) signals from browsers and the other mechanisms we use to give you a choice about the collection of personally identifiable information about your online activities. You can enable or disable DNT in your web browser’s settings. We will not be tracking or collecting any personally identifiable information about your online activities such as cookies (we refer you to paragraph 2.4 above).
13. Making a complaint
13.2. The Privacy Officer will investigate any complaints that are received and respond to you as soon as possible.
13.3. If you are not satisfied with how we have handled your complaint, you can contact the relevant supervisory authority: