Privacy Policy

Introduction and purpose of this policy

1. TogetherAI Pty Limited and its related entities TogetherAI USA, Inc and TogetherAI UK Limited (“us”, “we”, “our”) are committed to respecting your privacy. We will collect information about you through our website https://www.togetherai.com/ (the “Website”), the togetherAI App (the “App”, or “togetherAI”), other TogetherAI websites and apps, where we display this notice, and any communications with you in relation the Website or App or our services.

2. When you use the App, you will be either a Child User or Parent/Caregiver User (each a “User”). A Child User Account must be connected to a Parent Caregiver User Account.

3. Part 1 of this Privacy Policy (the “Policy”) sets out the general provisions of this Policy, including describing how we collect, use, share or otherwise process your information, and what data protection rights you have and applies to Users regardless of where they are based. Part 2 of this Policy supplements Part 1 with details about (among other things) how we collect and process personal information from our UK, European Economic Area (“EEA”), Switzerland, Australian and New Zealand Users (respectively).

4. Our Website and App collect and use personal information relating to children including disclosing that data to their Parent/Caregiver in order to provide our services, subject to parental/caregiver consent where required by applicable law as set out in this Policy, and more specifically as follows:

For users based in the UK or EEA, TogetherAI UK Limited (registered office is Squire Patton Boggs (Uk) Llp (Ref: Csu) Rutland House, 148 Edmund Street, Birmingham, United Kingdom, B3 2JR) is the data controller of any information collected about you through the Website, App and any communications with us relating to the Website or App;
For users based in North America, TogetherAI USA, Inc (registered office is Corporation Trust Center, 1209 Orange Street, in the City of Willmington, Count of New Castle in Delaware 19801) is the data controller of any information collected about you through the Website, App and any communications with us relating to the Website or App; and
For users based in Australia and New Zealand, TogetherAI Pty Ltd (registered office is Level 2, 20 Hutchison Street, Surry Hills NSW, Australia 2010) is the data controller of any information collected about you through the Website, App and any communications with us relating to the Website or App.

5. We may update this Policy from time to time. Please check the Policy regularly for updates. If you are not happy with any of the changes, you should stop using the Website and App. When required by law, we will tell you about any changes to this Policy either directly or by posting the changes on the main page of the Website/App.

Part 1 | General

Children's data processing practices

6. Our Website and App collect and use personal information relating to children including disclosing that data to their Parent/Caregiver in order to provide our services, subject to parental/caregiver consent where required by applicable law as set out in this Policy, and more specifically as follows:

When a Child registers, they provide personal information, including demographic information (see section ‘The Types of Information We Collect About You’ below for more details);
We monitor the Child’s use of our Website, App and any third-party services (for example, we may monitor music streaming providers, social media platforms, and others) that the Child or Parent/Caregiver link to our services;
Children can respond to questions through the App (including open text response) and input information, including about how they feel and what they are thinking;
We use this information to make inferences about the wellbeing of the child (such as if they are feeling sad, happy, demotivated, excited about school, etc.), including through the use of artificial intelligence, and may share that information with the Child’s Parent/Caregiver, for example to provide tips and suggestions to the Parent/Caregiver about how to effectively communicate about the Child’s wellbeing.
If you are the Child user and/or Parent/Caregiver you may contact us as set out in Section 19 below and ask to review or delete your/your Child’s personal information at any time.

How we collect information about you

7. Information you provide to us directly. We will collect information from you when you register for an account, use the Website or App (even when you do not create an account with us) or communicate with us.

8. Information we collect from third parties. Where you are a Child User, we may collect information about you from your Parent/Caregiver when they register for an account. When you allow the App to monitor the third-party apps you have on your devices (such as your mobile phone), such as social media and messaging apps, we may collect information about you from those platforms, including the communications with other third persons. We do not control the privacy practices of those third parties. You should consult the privacy statements of those third-party services for details.

9. Information collected automatically or inferred. We may collect technical information about your use of the App, such as details of your computer or other device, your IP address and network usage details. We may also infer information about you as a Child User based on your input into the Website/App and other connected services, in particular about your wellbeing. We may also infer information about Users, based on how you use the Website/App in general, such as which features you enjoy.

10. We may combine information that we receive from these sources and use it for the purposes described below. We only use your personal information to provide you with our services through the App and as otherwise allowed by law.

The types of information we might collect

11. The types of information we may collect about you include:

Identifiers such as your name and date of birth; your contact details, such as postal address, email address, and phone number; account information, such as account number, account name, username and password; account creation date; social media identifiers (e.g., Instagram name etc.); unique personal identifier and online identifiers; and IP address. We only collect limited information about you when you only interact with us using the Website. We collect account information when you use our App.
Health data: Where you are a Child User using our App, we may collect information relating to your mental or physical health or wellbeing as part of our services.
Proof of legal guardianship or parentship for a Parent/Caregiver User to register an account in the App and confirm that the Child User is the child of a Parent/Caregiver User to allow us to provide services to you.
IT, internet, other electronic network activity information, and data about your devices, such as the devices accessing togetherAI and our Website (including information about such devices, including the operating system, type of device, browser, etc.), the amount of time you spend on togetherAI and how you use it (such as which features you use, which links you click on, etc.).
Communications data such as:
i. communications through the “companion” chatbot on the App, completing forms or surveys on the App and in-App conversations between Child Users and Parent/Caregiver Users;

ii. communications with us, including our support team, through our Website or otherwise.
Third-party apps/services data collected by our App as part of our services from external/third party apps that are linked to togetherAI such as data these third-party apps collect from your devices (e.g. sleep and exercise data), music accounts (e.g., what kind of music do you listen to), and social media and messaging apps, including communications with third parties
Inferences drawn about you as part of our services offered through the App using our algorithms and artificial intelligence to build profiles of Users and understand differences in a User’s behaviour or feelings which may have resulted from positive or negative experiences. We may also infer information about Users, based on how you use the Website/App in general, such as which features you enjoy.

12. You do not have to provide us with your personal information (in particular, identifiers, proof of legal guardianship/parentship), but, if you do not provide it, you cannot use the App (not providing some personal information, such as data from third-party apps/services will not prevent you from using the App, but may affect its effectiveness and accuracy). However, you can browse our Website, such as the pages that generally describe our services and our Contact Us page. When you submit a form on our Website or become a user of togetherAI we will need to collect personal information in order to identify you and so that we can provide you with the App and our services.

Why we use information about you

13. We will only use information about you for the purposes of providing our Website, App and our services, or as otherwise allowed by applicable laws.

14. More specifically, we may process information about you:

To provide the Website and App and maintain User account, including to communicate with Users in the context of your use of our Website and App. Where you are a Child User, we will use the information you provide when you use the App, and data we collect and infer about you, for example, from your Parent/Caregiver and from the social media, music and messaging platforms you use, to help us to understand what you are thinking and feeling. We will use that information to alert your Parent/Caregiver to any wellbeing issues that they may want to help you with and to provide them with guidance about how to approach this. Where you are a Parent/Caregiver we will use the information you provide when you use the App, and data we collect and infer about you, to offer you more personalized content and materials, including (for example) materials that relate specifically to an issue (such as bullying, anxiety) the Child User may be experiencing.
For our own internal business purposes, such as information on how you use our Website/App, to identify and repair errors that impair the functionality of our systems and improve the quality of your interactions with us (including obtaining feedback you provide) and maintain proper business records and other relevant records of your accounts and our activity. We also use your data to perform internal research, quality assurance, conduct data analysis and testing, to evaluate or audit the usage and performance of our Website and App and to improve, operate and maintain them. We may also create anonymized data and use it to develop case studies and marketing materials.
For security of togetherAI, our Users, employees, or others, by detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity. If you engage in such activity, we will process your account and other App/Website activity data.
For legal and compliance purposes, such as compliance training, investigating and responding to claims against us, due diligence purposes, tax requirements and to satisfy any other legal obligations we are subject to. We may also process your personal information for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
For marketing. We may use your personal information to market our products and services. We may analyze effectiveness of our ads using your identifiers and to customize these ads to you. We may send you commercial email, text message or other digital communications, including automated messaging. In those instances, where required by applicable laws, we may provide a specific opt-out option from receiving such communications (e.g., through an ‘unsubscribe’ link contained in such communications. You can always opt-out by contacting us using the contact information in Section 19 below. Some of our marketing materials and information may use tracking and analytics technologies to help us understand your preferences.
In connection with a transaction, such as if we, or some of our assets, are acquired by another company, including through a sale or in connection with a bankruptcy, we may share your information with that company. We may also share your information in case of a prospective or actual purchase of companies or assets by us.

Disclosure of personal information

15. We may share your information with the third parties described below:

Parents and Caregivers. Where you are a Child User, we will use the information we collect about you when you use the App and Website to provide your Parent/Caregiver with tailored wellbeing suggestions and materials and to notify them about any potential issues you might be experiencing. Your Parent/Caregiver will also receive communications you send to them through in-App conversations.
Service Providers. We share your information with our service providers where it is necessary for them to assist us to provide the App and Website or support our relationship with you, such as cloud hosting providers, data modelling tools, email hosting providers, online CRM providers and error monitoring providers. We share anonymous data with analytics providers.
Our Group of Companies. We may share your information with companies in the TogetherAI group of companies, if they help us deliver services to you or for other internal administrative purposes.
For Legal, Security or Safety Purposes. We may also share your information when required to do so by law. For example, we may provide the police, another professional agency or courts with information about you because of concerns about your safety. We may also share your information with the above recipients, as well as our legal and other professional advisors, to enforce or apply our Terms of Use and other agreements; and to protect our rights and the property or safety of us, our employees and Users, or third parties.
In Connection with Corporate Transactions. We may disclose your information to buyers/sellers, their lawyers or advisors, where needed to affect the sale or transfer of business assets.

Automated functionality

16. TogetherAI includes automated functionality that evaluates a Child User’s device usage and interactions by and from the Child User through their device and assesses the likelihood of how such interactions and usage may impact the Child User’s wellbeing. This assessment impacts the creation and availability of personalised health wellbeing suggestions made available via the App to the applicable Parent Caregiver Users and Child User. For example we may analyze Child User’s answers to in-App survey, their use of third-party music, messaging and social media platforms, to try to determine whether these suggest positive or negative experiences and what behaviour or feelings they would result in.

Retention

17. We will only keep your identifiable information for as long as necessary to fulfill the purposes for which the information was collected, primarily to provide the App and our services. We will keep identifiable information about Child Users and Parent Caregiver Users for the duration of their account with us. We may keep your information for longer where we are required by law to do so, or where we need your personal information to establish, exercise or defend a legal claim. For more information on how long your information may be kept, please contact us at hello@togetherai.com.

Cookies and other tracking tools

18. We may set cookies and other tracking technologies on your device. For more information, please click here to see our Cookie Policy.

Contact details

19. Any person who wishes to contact us for any reason regarding our privacy practices or the personal information that we hold about them, to exercise their data protection rights or make a privacy complaint, may contact our Data Protection Officer at dataprivacy@togetherai.com.

Accessibility

20. We are committed to making the Website accessible to all people. That includes making the Website accessible to users who have disabilities. The Website has been designed to ensure that it meets or exceeds the requirements of World Wide Web Consortium (W3C) Web Content Accessibility Guidelines (WCAG) 2.0. It is our goal to ensure that content is posted in a format that conforms to WCAG for web content and that the Website is accessible with software designed for use by persons with disabilities. If you have comments or suggestions for the improvement of the Website, or to making it more accessible for all users, or if you encounter difficulty accessing the information on the Website, please contact us at hello@togetherai.com.

Third party links

21. When using our Website/App you may come across third party links to external sites or other online services, including those embedded in third party advertisements. We do not control and are not responsible for such third parties’ privacy practices. You should consult the privacy statements of those third-party services for details.

Part 2 | Specific information for EU, UK, NZ, Australian & US users

Additional information for individuals residing in the UK, Switzerland or EEA

22.The following paragraphs 23 – 30 of this Policy apply to Users and other persons residing in the UK, Switzerland or EEA, or to whom UK, Swiss or EEA data protection rules (including UK Data Protection Act 2018 (including the UK GDPR), as amended; Swiss Federal Act on Data Protection, as revised; and the EU General Data Protection Regulation (EU) 2016/679, as amended – we refer to these collectively as ‘GDPR’) otherwise apply.

Data protection rights

23. If you are based in the UK, Switzerland or EEA, you have the following rights under the GDPR in relation to the personal information we hold about you, to request:

Access to the personal data we hold about you (commonly known as a "data subject access request") including a copy of it;
The correction of the personal information that we hold about you if it is incomplete or inaccurate, although if you hold an account with us, you may be able to do this in certain cases yourself by updating your account information on our Website or App;
The deletion or removal of personal data we hold about you where there is no good reason for us continuing to process it, you withdrew your consent with our processing, existing processing is unlawful or deletion is required by law, or where you have exercised your right to object to processing (see below);
For our processing of your personal information to be restricted in certain circumstances; and
Where we are processing your personal data on the basis of our legitimate interests, you can object to such processing and we must stop, unless we believe we have an overriding legitimate reason to continue processing your personal information or if we need to process it for the establishment, exercise or defence of legal claims.
To obtain a copy of the personal information you’ve provided us with and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.
If you are not happy with how we have handled your personal data, you have the right to make a complaint to your data protection regulator in particular in the country of the EEA, Switzerland or the UK where you reside, or where the issue that is the subject of the complaint occurred. In the UK, this is the Information Commissioner's Office (ICO). You can make a complaint to the ICO by calling their helpline on 0303 123 1113 or on their website at www.ico.org.uk/concerns. You can find contacts of EU supervisory authorities at https://edpb.europa.eu/about-edpb/about-edpb/members_en and contact Swiss FDPIC at https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or, (and if you’re based outside of the UK, your data protection regulator), so please do contact us in the first instance.
Where it is necessary for us to perform our contract with you. For example, where you are a Parent/Caregiver User (entering into contractual relationship with us on your/your Child’s behalf) or a Child User old enough to enter into a contract, to provide our services, to comply with our End-User Licence Agreement and set up and maintain your account on the App;
In case we ask for your consent to processing, you are free to refuse to give consent and you can withdraw your consent at any time without any adverse negative consequences. The lawfulness of any processing of your personal information that occurred prior to the withdrawal of your consent will not be affected.

24. We may ask you for proof of your identity before dealing with your request, as a security measure to protect your data.

Legal basis

25. If you are based in the UK, Switzerland or EEA, we will only use your information where we have a lawful basis to use it. We will only use your data:

where it is necessary for us to perform our contract with you. For example, where you are a Parent/Caregiver User (entering into contractual relationship with us on your/your Child’s behalf) or a Child User old enough to enter into a contract, to provide our services, to comply with our End-User Licence Agreement and set up and maintain your account on the App;
in a way which might reasonably be expected as part of our legitimate interest in running our business and which does not materially impact your interests, rights or freedoms. For example, for safety and security reasons, such as the processing of personal information to verify accounts and activity, to monitor suspicious or fraudulent activity, and to identify violations of our policies and to provide users with the wellbeing services contemplated by the App. This also includes our other internal business purposes outlined in Section 14(b) above, and our marketing activities (for example by sending you digital direct marketing related to similar products/services we have provided to you), unless consent is required under applicable laws. Please get in touch with us using the contact details provided above if you would like further information about this;
where it is required to comply with our legal obligations. For example, to pass on details related to fraud or safeguarding concerns;
where it is necessary to protect your or another individual’s vital interests. For example, where you are a Child User, we may share information about you (including health data, which is categorized as ‘special category data’ under data protection laws) with your parent/caregiver, the police or another agency if it is necessary to protect your vital interests; or
where you have consented to our use of your information. For example, where you are a Child User, we will only process information about you (including health data) where you have explicitly consented or where your Parent/Caregiver has done so on your behalf.
where we need to process your personal data for the establishment, exercise or defence of legal claims.

26. If you wish to exercise the above data protection rights, make a privacy complaint with us, or have any questions regarding this Policy you may contact our Data Protection Officer at dataprivacy@togetherai.com.

International transfer of Personal Information

27. As we are a global business, it may be necessary for the personal data that we collect from you to be transferred to, or accessed from outside the UK, Switzerland or the EEA in order for us to provide the Website and App. For example, it may be accessed by our Australian group company, TogetherAI Pty Ltd, in limited circumstances, for example, for internal administrative purposes, or by our service providers who are located or access personal data from outside the UK/Switzerland/EEA.

28. If we do this, we have measures in place to ensure your data is protected in accordance with GDPR. Where we transfer your personal information to countries deemed to provide an adequate level of data protection by the EU/Swiss/UK authorities, we rely on that decision to transfer your personal information. For transfers to group companies and service providers outside the UK, Switzerland or the EEA where no adequacy decision applies, we use standard contractual clauses or other transfer tools, such as Binding Corporate Rules provided for in the applicable data protection legislation to protect your personal information. Any transfer of your personal data will follow applicable laws and we will treat the information according to the principles set out in this Policy.

29. If you would like further information or a copy of the transfer mechanism we use, please get in touch with us using the contact details provided above.

Representative in the EU

30. Since TogetherAI UK Limited, acting as controller of your personal information, is not established in the EU, it has appointed The DPO Centre Europe Ltd (Alexandra House, 3 Ballsbridge Park, Dublin, DOC4c 7H2, contact details +353 631 9460 europe@togetherai.com), as its EU representative for data protection in accordance with Article 27 of the GDPR.

Additional information for individuals residing in Australia

31. The following paragraphs 32 – 44 of this Policy apply to Users and other persons residing in Australia pursuant to the Privacy Act 1988 (Australia).

Consents

32. When a User first accesses their user account on TogetherAI, they are provided with our privacy collection notice. The privacy collection notice is made in accordance with Australian Privacy Principle (APP) 5, which notifies the User (among other things) of the circumstances under which we collect their personal information, the purpose for the collection and the likelihood that their personal information will be disclosed to overseas recipients.

33. Users must provide the relevant privacy consents and authorisations required by law in order for the personal information that is entered into TogetherAI to be collected, disclosed and otherwise processed by us for the purposes set out in this Privacy Policy.

How we collect personal information

34. Our policy is to not collect personal information by means that are unfair or unreasonably intrusive in the circumstances. We only collect personal information (as described in Part 1 above) that is necessary to provide the functionality of the App, the services and to otherwise operate our business.

How we hold and secure personal information

35. We hold and store personal information that we collect in our offices, computer systems and third party owned and operated hosting facilities. We take reasonable steps to protect personal information that we hold using such security safeguards as are reasonable in the circumstances to protect against loss, unauthorised access, modification and disclosure and other misuse, and we implement technical and organisational measures to ensure a level of protection appropriate to the risk of accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal information transmitted, stored or otherwise processed by us.

36. We;

only use reputable cloud hosting providers to host personal information;
implement passwords and access control procedures, anti-virus, firewall and security controls for email and other applicable computer software and systems;
maintain files, in both hardcopy and electronic form, at our offices and other access-controlled premises;
operate online records managements systems on secure networks;
regularly perform security testing;
regularly carry out security audits of our systems which seek to find and eliminate any potential security risks in our electronic and physical infrastructure as soon as possible;
maintain physical security measures in our buildings and offices such as visitor access management, cabinet locks, surveillance systems and alarms to ensure the security of information systems (electronic or otherwise);
require our employees, agents and contractors to comply with privacy and confidentiality provisions in their employment and subcontractor agreements that we enter into with them;
use SSL encryption on our systems;
have data backup archiving and disaster recovery processes in place;
if appropriate in the circumstances (taking into account the state of the art, the costs of implementation and the nature, scope, content and purpose of the processing), we will encrypt personal information; and
with respect to personal information that we no longer require or where we are otherwise required to destroy it under applicable law, we ensure that such personal information is securely destroyed.

Offshore disclosure

37. We may transfer your personal information to our contractors and service providers offshore who assist us with the supply and provision of togetherAI to you, and to assist us with the operation of our business generally, where we consider it necessary for them to provide that assistance. We will take reasonable steps to ensure that such recipients do not breach the APPs in relation to personal information or other relevant State and Territory laws (as applicable).

How to access and correct personal information held by Us

38. Users who wish to access and correct the personal information held by us about them should contact us. Prior to contacting us or submitting a request for access to correct any personal information held about them, Users can update their personal information by logging into their account on togetherAI. Multi-factor authentication is required when you update your personal information.

39. Once an account is deleted, we may still be required to retain the data in accordance with our data retention obligations. It is our policy to retain personal information in a form which permits identification of any person only as long as is necessary for the purposes for which the personal information was collected; and for any other related, directly related or compatible purposes if and where permitted by applicable law. We will only process personal information that you provide to us for the minimum length of time permitted by applicable law and only thereafter for the purposes of deleting or returning that personal information to you (except where we also need to retain the data in order to comply with our legal obligations, or to retain the data to protect your or any other person’s vital interests).

40. Unless we are required to retain personal information for a longer period in the circumstances described in paragraph 39, personal information will be stored for 7 years and any data that is no longer required for the maintenance of active Users will be deleted after this period. We will only keep personal information (including health information) for longer periods than specified above, where required under applicable law.

41. As an alternative to deleting personal information, we may elect to de-identify it where permissible by law. We may use personal information that we de-identify for the purpose of improving togetherAI and for provision to third parties for marketing and research purposes (such as to map usage trends to improve subsequent usage experiences, to understand User profiles and to develop more relevant and engaging experiences on togetherAI).

42. Where you require your personal information to be returned, it will be returned to you at that time, and we will thereafter delete all then remaining existing copies of that personal information in our possession or control as soon as reasonably practicable thereafter unless applicable law requires us to retain the personal information, in which case we will notify you of that requirement and only use such retained data for the purposes of complying with those applicable laws.

43. We will handle all requests for access to personal information in accordance with our statutory obligations. You can request to receive a copy of your personal information by emailing dataprivacy@togetherai.com. We may require payment of a reasonable fee by any person who requires access to their personal information that we hold, except where such a fee would be contrary to applicable law. We will not charge you for the making of any such request. We will endeavour to provide a response to any request for access to personal information within 72 hours from the time a request is made.

Complaints to Australian Information Commissioner

44. We endeavour to resolve any privacy complaint with the complainant within a reasonable time frame given the circumstances. This may include working with the complainant on a collaborative basis or otherwise resolving the complaint. If the complainant is not satisfied with the outcome of a complaint or they wish to make a complaint about a breach of the APPs, they may refer the complaint to the Office of the Australian Information Commissioner who can be contacted using the following details:

Australian Information Commissioner
‍Telephone: 1300 363 992
Email: enquiries@oaic.gov.au
Address: GPO Box 5218, Sydney NSW 2001

Additional information for individuals residing in New Zealand

45. The following paragraphs 46 – 59 of this Policy apply to Users and other persons residing in New Zealand that may be collected by us that is governed by the Privacy Act 2020 (New Zealand).

Collection of personal information

46. We will only collect personal information for a lawful purpose which is connected to a function or activity of our businesses to the extent that it is necessary for such purpose. Where possible, we will collect personal information from the individual concerned. Before we obtain information from a third party, we will obtain consent from the individual for such collection.

47. Before we collect personal information from an individual or as soon as it becomes practicable to do so, we will disclose to the individual:

The fact that the information is being collected;
The purpose for which the information is being collected;
The intended recipient of the information;
The consequences for that individual if all or part of the requested information is not provided; and
e. The rights of access to and correction of information provided by the Information Privacy Principles (IPPs).

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Provision of personal information to third parties

48. Where it is necessary for personal information to be given to a third party in connection with the provision of services that they provide to us, we will do everything reasonably within our power to prevent unauthorised use or unauthorised disclosure of the information by them. The specific personal information that we collect, how we collect it, how we use it and who we disclose it to is set out above in this Policy.

Storage and security of personal information

49. If we hold personal information about you, we will ensure that the information is protected by such security safeguards as are reasonable in the circumstances to take against loss, access, use, modification, unauthorised disclosure and other misuse. If it is necessary for the information to be given to a person in connection with the provision of a service to us, everything reasonably within our power is done to prevent unauthorised use or unauthorised disclosure of the information.

Requests for access to and correction of personal information

50. Individuals whose personal information is governed by the Privacy Act (New Zealand) are entitled to seek access to and correction of it in accordance with that legislation.

51. Any person who wishes to access personal information about them that we hold should contact us. You may request urgent access to your personal information in accordance with section 41 of the Privacy Act (New Zealand) and state why the request should be treated as urgent. We will on receipt of such request, consider the request and reasons, determine the priority given to it and ensure that we provide reasonable assistance to a person who makes such a request.

52. We will also take such steps as are reasonable in the circumstances to ensure that personal information that we hold are accurate, up to date, complete and not misleading.

53. In the event that a person wishes to access their personal information and it is readily retrievable by us, they can also request from us either of the following: (a) to obtain confirmation from us as to whether or not we hold such personal information; (b) access to the personal information; and (c) be advised if they can correct such personal information.

54. We will, as soon as possible and in any event no later than 20 working days from the date on which the request is made, decide to grant or refuse the request and provide the person who requested with, or post to them, our decision. We may in our discretion charge a reasonable fee for making information available in compliance with the request or for correcting any information in compliance with a request (in whole or in part) or for attaching a statement of any correction sought but not made, subject to our compliance with the New Zealand Information Privacy Principles.

55. If a person submits a request to access their personal information to us, we may refuse their request where permitted by the Privacy Act (New Zealand).

56. Where we hold personal information governed by the Privacy Act (New Zealand) about an individual, they are entitled to request correction of the information and request that there be attached to the information a statement of the correction sought but not made.

57. We will only hold personal information for as long as is required for the purposes for which the information may lawfully be used.

Complaints

58. If you are not satisfied with our response to any privacy-related concern you may have, you can contact the NZ Privacy Commissioner:

Office of the Privacy Commissioner
‍PO Box 10-094, Wellington, New Zealand
Phone: 04 474 7590 / Fax: 04 474 7595
Enquiries Line (from Auckland): 302 8655 / Enquiries Line (from outside Auckland): 0800 803 909
Email: enquiries@privacy.org.nz

Additional information for individuals residing in US

59. We collect information (or permit third parties to directly collect information on our website), via cookies, web beacons, pixels, tags, session replay tools, or other tracking technologies. These cookies and other technologies may be used to track you across time, devices, and services. Our Website does not respond to “Do Not Track” signals.

60. California Shine the Light: We do not share personal information subject to California Civil Code § 1798.83 (the “Shine the Light law”) with third parties for their direct marketing purpose

61. If you are a Nevada resident, you may contact us at dataprivacy@togetherai.com to exercise your opt-out rights under Nevada Revised Statutes §603A et seq.