Last updated: May 2022

1. Introduction

1.1. IHC New Zealand Incorporated (IHC) is committed to protecting personal information and privacy rights generally. 

1.2. IHC New Zealand Incorporated is also referred to as “IHC”, “we” and “us” in this privacy policy and when referred to, such reference includes any person or organisation to which it has licensed or assigned its rights and obligations.

1.3. When we refer to personal information throughout this privacy policy (“Privacy Policy”), we mean personal information as defined in the New Zealand Privacy Act 2020, being any information about an identifiable individual (“Personal Information”).

1.4. This policy applies to all Personal Information under the control of IHC and/or our personnel in relation to the Stand Tall game (Game) in both web and app format. It does not apply to other Personal Information collected or held by IHC that does not relate to the Game, other entities outside of our control, or to the Personal Information of our employees, contractors, directors, or officers.  We have a simplified privacy policy designed to be accessible to all users of the Game, which you can access here.

1.5. This Privacy Policy sets out how we will collect, use, disclose, and protect Personal Information collected in relation to the Game.

1.6. When dealing with Personal Information, IHC will comply with this Privacy Policy and with applicable privacy laws in New Zealand, Australia, the European Union, and California in the United States of America (together “Applicable Privacy Laws”, and separately “Applicable Privacy Law”).  If you are not in any of these locations, this Privacy Policy may not comply with the privacy regulations in your location.  If you live elsewhere in the world and choose to play the Game, you do so at your own risk knowing that you are providing us with Personal Information (which we will deal with as if you were subject to the New Zealand Privacy Act 2020).

1.7. This Privacy Policy does not limit or exclude any of rights under the Applicable Privacy Laws in the countries in which the Game is available.  For more information, see:

For Australian residents, the Australian Privacy Act 1988.

  1. For New Zealand residents, the New Zealand Privacy Act 2020.
  2. For European Union Residents, the General Data Protection Regulation (“GDPR”).
  3. For residents of California, United States of America, the California Consumer Privacy Act 2018 and the California Online Privacy Protection Act 2013.

1.8. By using the Game you agree to be bound by this Privacy Policy.

2. Collection of Personal Information

2.1. We will collect Personal Information about you in two different ways:

2.2. When you play the Game, you will be asked to fill out an optional survey at the end of the Game.  The survey will collect Personal Information including but not limited to your name, gender, age, occupation, and any learning disabilities you may have, as well as your feedback about the game.   We may amend the survey questions from time to time, in which case we will update this Privacy Policy accordingly.

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).

2.7. A cookie is a small text file that the Game website may store on your device, which helps us improve your user experience when you use the web version of the Game. Cookies will not collect identifiable information about you, but will identify your device.  Except for the purposes contemplated in this Privacy Policy, we will not disclose any such information except in aggregate (anonymised) form for analytical purposes only.

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.

3.2. We have taken reasonable steps to ensure the safety of Personal Information stored in both electronic and hard copy format, and to protect against loss, unauthorised access, use, modification, disclosure, or other misuse.  We will not divulge Personal Information except in accordance with normal legal requirements and practices, including the ways that we have covered in this Privacy Policy. 

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);

  1. to maintain and improve the Game;
  2. to respond to communications from you;
  3. to conduct research and statistical analysis (on an anonymised basis);
  4. to protect and/or enforce our legal rights and interests, including defending any claim; and
  5. for any other purpose authorised by you or Applicable Privacy Laws.

5. Consent

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:

  1. Communicating with you by (e.g. by phone or email);
  2. For internal purposes relating to maintaining and improving the Game;
  3. When you have authorised us to do so;
  4. When we reasonably believe we are required or permitted to do so by law;
  5. If we believe that the disclosure is reasonably necessary to enforce any legal rights or obligations we may have;
  6. If we sell/transfer our business to a third party;
  7. Where it is necessary to do so to resolve a complaint you make about us; and
  8. If in an emergency situation it is necessary or desirable to share your Personal Information with a civil defence or government organisation, or another emergency service.

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:

  1. take steps to ensure that we believe on reasonable grounds that the overseas agency receiving the Personal Information is subject to privacy protections that, overall, provide comparable safeguards to those provided under the Applicable Privacy Law;
  2. enter into a binding contractual agreement with the overseas agency receiving the Personal Information confirming that it will protect the Personal Information in a way that, overall, provides comparable safeguards to those provided under the Applicable Privacy Law; or
  3. obtain the express authorisation of the individual concerned to disclose their Personal Information overseas after expressly informing them that the overseas agency may not be required to protect the information in a way that, overall, provides comparable safeguards to those provided under the Applicable Privacy Law.

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  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

9.1. We will take steps reasonable in the circumstances to ensure that your Personal Information is accurate, up to date, complete, relevant, and not misleading before using or disclosing it in accordance with this Privacy Policy.

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).

12. Changes to this Privacy Policy

12.1. We may update this Privacy Policy from time to time. We will notify you of any such updates by publishing the updated Privacy Policy on our website. The revised Privacy Policy will apply from the date that we upload it to the website. We encourage you to review this Privacy Policy periodically on the website to stay informed about how we are helping to protect Personal Information. Your continued use the Game constitutes your agreement to this Privacy Policy as updated. If you do not agree with any aspects of this Privacy Policy as updated from time to time, you must immediately stop using the Game, and promptly notify us in writing. Our contact details and address are:

  • Address: IHC National Office, Level 15, 57 Willis Street, Wellington, New Zealand
  • Phone: +64 (0)800 442 442
  • Email:   

13. Making a complaint

13.1. If you have any questions, concerns, or a complaint in relation to this Privacy Policy or the protection of your Personal Information, please direct them to the Privacy Officer at the above email address. To enable us to more easily address any questions or concerns you have, it is preferable if they are made in writing.

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: