Privacy Policy

Date Last Modified: June 03, 2025

We respect your privacy and are committed to protecting your personal data. This privacy policy explains how we process personal data when you visit or use the Innovate Change website (the “Website”) and sets out your rights under the Privacy Act 2020, Privacy Regulations 2020 and other applicable laws.

Any information collected about Website visitors is referred to as “User Information”.

Innovate Change is the controller and responsible for the operation of the Website.

If you have any questions about this Privacy Policy—or if you wish to exercise any of your legal rights—please сontact us via e-mail: [email protected].  We process all privacy‑related communications.

In accordance with the New Zealand Privacy Act 2020, we are committed to responding to all valid privacy-related requests within 20 working days of receipt.

For clarity we have adopted the following defined terms (capitalised terms not defined here have the meaning given elsewhere in this Policy):

“Controller” – the natural or legal person that determines the purposes and means of processing personal data.

“Personal Data” – any information relating to an identified or identifiable natural person.

“Process/Processing” – any operation performed on Personal Data, whether or not by automated means.

“User Information” – all Personal Data and technical data collected about visitors of the Website.

Information you provide directly

Upon registering for an account on our website, we gather and handle the following personal details from you:

• Full name: Your complete
  name is necessary for the creation and customization of your account.
• Email address: We obtain
  your email address to facilitate communication regarding your account, furnish updates, share
  pertinent information, and deliver newsletter.
• Location – country.

Content of messages, surveys, public postings and feedback you choose to give

When you opt to receive our newsletters, we gather and manage the ensuing personal information:

• Email address: Your email
  address is collected for the purpose of communicating with you and delivering the newsletter.

Technical and Usage Data (collected automatically)

We automatically collect some information about how you interact with and navigate Innovate Change, as well as the device and software you use to do so:

• Information on your visit of the Website, including but not limited to traffic data, IP address, browser type and version, screen resolution, browser language, time zone, operating system, type of device, and approximate geolocation.
• Demographic indicators such as age range and gender (only where you have consented to the use of analytics / advertising cookies that collect such data).
• Information from any research or surveys you choose to complete (always voluntary).
• Information from the content of messages you submit through forms on the Website, such as feedback you write.
• Information from public postings (e.g., comments or reviews you intentionally publish on the Website). Please acknowledge that you have no expectation of privacy with respect to such content.
• Information on users’ preferences (for example, preferred games or run pages) derived from site interaction analytics.

User Information is collected only if the User has given their voluntary and informed consent, in accordance with the Privacy Act 2020.

We rely on a combination of

(i) an explicit consent checkbox shown at the point of account registration or newsletter sign-up;

(ii) a just-in-time privacy notice for each form where personal data is requested; and

(iii) a cookie consent banner that allows you to enable or disable categories of non-essential cookies.

You may withdraw your consent at any time through by submitting the Privacy Request Form.

This Policy only addresses what happens if you visit the Website and does not apply to information collected by Innovate Change offline, in the public domain, or through any other means or any third-party, including through any application or content that may link to or be accessible from or on the Website.

We process User Information for the following purposes:

1. To create and administer your account, provide personalised services and optimise communications related to your account;
2. To respond to your enquiry or request;
3. To improve the content, security and performance of the Website;
4. To conduct internal record keeping;
5. To conduct user research and analysis;
6. To customise the Website according to your interests;
7. To comply with regulatory obligations;
8. To promote our special offers, new products and services, or to provide you with any other information where you have consented to such marketing; and
9. For any other purpose that is compatible with the original purpose and permitted by applicable law.

Change of purpose

We will only use User Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Please note that we may process User Information without your knowledge or consent in the limited situations where this is required or permitted by law.

We retain the User’s personal information only for the period necessary to achieve the purposes for which it was collected, or as required by applicable law.

Personal data will be deleted:

• as soon as it is no longer needed for the purposes for which it was collected; or
• upon your request, unless we are required to retain such data under applicable law (for example, for accounting purposes, dispute resolution, or regulatory compliance).

Account data is retained for the entire duration of your account’s activity and for at least 7 (seven) years after its closure, in accordance with record-keeping requirements under New Zealand’s Anti-Money Laundering and Countering Financing of Terrorism Act 2009 and related regulatory obligations.

Service providers. We use trusted companies to host the site, process payments, analyse traffic, provide marketing tools, and deliver support. They receive only the data required to perform the task we assign, must keep it confidential, and must protect it to a standard that is at least comparable to ours.

Business changes. If our company is involved in a merger, restructure, or sale, personal information may transfer to the new owner subject to the same protections described here.

Legal situations. We may disclose information when required by law, to enforce our terms, or to protect people’s safety.

Overseas disclosures. If we need to send personal information overseas—for example, to a cloud-hosting provider—we will do so only when:

• the recipient is subject to privacy protections that, overall, safeguard the information to a comparable level, or
• we have a contract requiring that level of protection, or
• you have been told the overseas recipient may not be bound by comparable rules and you have agreed to the transfer.

The site is intended only for people aged 18 or over—or the minimum legal gambling age in the user’s jurisdiction, if higher. We do not knowingly collect personal information from anyone under that age and will delete any such information that comes to our attention. All collection methods are designed so they do not unfairly intrude on young people’s privacy.

Every Website User, consenting to the Terms of Use of the Website and this Privacy Policy, is entitled to the following:

• Right of access – You can request us to provide you with copies of your personal data. We will provide the first copy free of charge and additional copies may be subject to a reasonable fee.
• Right to rectification – You can request us to correct any information you believe is inaccurate or complete information you consider incomplete.
• Right to erasure (“right to be forgotten”) – You can request that we erase your personal data, subject to certain legal exceptions.
• Right to restrict processing – You can request the restriction of processing of your personal information under specific conditions.
• Right to object / right to opt-out – In circumstances where we rely on legitimate interests or conduct direct marketing, you have the right to object to processing or, for California residents, to opt-out of the sale or sharing of your personal information.
• Right to data portability – You can request that we transfer the data we have collected to another organization or directly to you, where technically feasible.
• Right to withdraw consent – Where we rely on your consent, you may withdraw it at any time.
• Right not to be discriminated against for exercising your rights.

We aim to respond to any written request within 20 working days. If we need more time, we will let you know and explain why.

If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner.

Submit a request by the Privacy Request Form in your account settings. Please provide enough information for us to verify your identity and locate the data. There is no charge for a standard request. A reasonable fee may apply for repeated or complex requests, and we will tell you about any fee in advance.

9.1 Introduction

This Cookies Policy sets forth the manner in which Innovate Change (“we”, “us”, or “our”) employs cookies and similar technologies when individuals visit our Website. By utilizing the Website, users acknowledge and consent to the utilization of cookies and similar technologies as described in this policy.

9.2 Definition of Cookies

Cookies refer to small text files that are placed on a user’s computer or mobile device when they access a website. These files are commonly utilized to enhance website functionality and provide information to the website’s owners. Cookies can be categorized as either “persistent” or “session” cookies, wherein persistent cookies remain on the user’s device after they go offline, while session cookies are deleted upon the user’s web-browser closure.

9.3 Purpose of Cookies Usage

We utilize cookies and similar technologies for various purposes, including but not limited to:

• Authentication: Cookies are employed to recognize users and retain their preferences when they visit our Website.
• Security: Cookies aid in detecting and preventing security risks and abuses.
• Analytics: Cookies gather information about user visits to our Website, such as frequently accessed pages, enabling us to enhance Website functionality and performance.
• Advertising: We may use cookies to deliver personalized advertisements based on users’ interests and browsing behavior.

9.4 Types of Cookies Utilized

• Essential Cookies: These cookies are essential for the proper functioning of our Website and cannot be disabled within our systems. They are typically set in response to user actions, such as configuring privacy preferences, logging in, or completing forms.
• Analytics Cookies: These cookies enable the collection of information about user interactions with our Website, facilitating improvements in performance and functionality. These cookies do not collect personally identifiable information.
• Advertising Cookies: These cookies facilitate the delivery of advertisements tailored to users’ interests. Third-party advertisers may utilize these cookies to track user browsing activity across our Website and other platforms.
• Social-Media Cookies: These cookies allow users to share Website content on social-media platforms or connect their social-media profiles to our Website.

9.5 Cookie Management

Users possess various methods for controlling and managing cookies. However, disabling cookies may result in certain parts of our Website functioning improperly.

• Browser Settings: Users can modify their web-browser settings to refuse cookies or to receive alerts when cookies are being sent. Procedures differ depending on the browser; users should consult their browser’s Help menu for specific instructions.
• Third-Party Opt-Out: Certain third-party advertising networks and analytics service providers offer opt-out tools to disable tracking across multiple websites. For detailed information, users can visit the relevant third-party websites.

9.6 Amendments to the Cookies Policy

This Cookies Policy may be amended periodically. Any modifications will be posted on this page. Users are encouraged to review this policy periodically to stay informed about our cookie usage.

9.7 Contact Information

For inquiries regarding this Cookies Policy, please submit a request via the
Privacy Request Form available on our Website.

Personal information may be processed on servers located outside New Zealand (for example, in the EU or the United States). Before transferring data, we ensure the overseas recipient is either:

• subject to comparable privacy laws,
• bound by contractual terms that require comparable safeguards, or
• specifically authorised by you after being informed of any differences in protection.

We apply technical, organisational, and physical safeguards—such as TLS encryption, role-based access controls, and vetted supplier contracts—to protect personal information against loss, misuse, unauthorised access, or disclosure. If a privacy breach occurs that is likely to cause serious harm, we will notify both the Office of the Privacy Commissioner and the affected individuals as soon as practicable, and we will guide you on the steps you can take to protect yourself.

We may update this Privacy Notice from time to time.