SonicPhonics Limited (NZCN 9277314) (we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or collected by us, when interacting with you.

The information we collect

Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

The types of personal information we may collect about you include:

● Identity Data including your name, age, school, and gender.
● Contact Data including your telephone number, address and email.
● Financial Data including bank account and payment card details (through our third party payment processor, who stores such information and we do not have access to that information).
● Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.
● Technical and Usage Data when you access any of our websites or platforms, details about your internet protocol (IP) address, login data, browser session and geo-location data, statistics on page views and sessions, device and network information, acquisition sources, search queries and/or browsing behaviour, access and use of our website (including through the use of Internet cookies or analytics), and communications with our website.
● Profile Data including your username and password for SonicPhonics, profile picture, purchases or orders you have made with us, content send receive and share through our platform, information you have shared with our social media platforms, and support requests you have made.
● Interaction Data including information you provide to us when you participate in any interactive features, including surveys, contests, promotions, activities or events.
● Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
● Professional data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience.

Children’s Privacy

Our app is designed for young children, particularly those learning to read. We collect only essential information from child users, limited to first names and learning progress data. This information is used solely to personalise the learning experience and improve our app. For users under 13, we require verifiable parental consent before collecting or using any personal information. Parents or guardians have the right to review, delete, or refuse further collection of their child’s information by contacting us using the details provided in this policy. We implement robust security measures to protect children’s data and retain it only as long as necessary. We do not use children’s information for marketing purposes or share it with third parties for commercial use.

How we collect personal information

We collect personal information in a variety of ways, including:

● when you interact directly with us, including face-to-face, over the phone, over email, or online;
● when you complete a form, such as registering for any events or newsletters, or responding to surveys;
● when you apply for a job with us;
● from third parties: we may collect personal information from third parties, such as details of your use of our website from our analytics and cookie providers and marketing providers. Where we collect personal information about you from a third party source other than you (other than the personal information which we have specified will be collected by us in accordance with this Privacy Policy) we will take reasonable steps to notify you of such collection, including the fact that the information has been collected, the purpose for which the information has been collected, the intended recipients of the information, and the name and address of the agency that is holding the information, as required by law.); or
● from publicly available sources, such as social media or the New Zealand Companies Office. Why we collect, hold, use and disclose personal information
Personal information: We collect, hold, use and disclose your personal information for the following purposes:
● to enable you to access and use our software, including to provide you with a login where required;
● to contact and communicate with you about our business, including in response to any support requests you lodge with us or other enquiries you make with us;
● to contact and communicate with you about any enquiries you make with us via any website we operate;
● for internal record keeping, administrative, invoicing and billing purposes;
● for analytics (including profiling on our website), market research and business development, including to operate and improve our business, associated applications and associated social media platforms;
● for advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you;
● to run promotions, competitions and/or offer additional benefits to you;
● if you have applied for employment with us, to consider your employment application; and
● to comply with our legal obligations or if otherwise required or authorised by law.

Our disclosures of personal information to third parties:

Google Analytics: We have enabled Google Analytics Advertising Features. We and third-party vendors may use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together. These cookies and identifiers may collect Technical and Usage Data about you. You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.
To find out how Google uses data when you use third party websites or applications, please see here.

Overseas disclosure

Personal Information
While we store personal information in New Zealand, where we disclose your personal information to the third parties listed above, these third parties may store, transfer or access personal information outside of New Zealand, including but not limited to Australia and New Zealand. We will only disclose your personal information overseas in accordance with the New Zealand Privacy Principles. Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this

Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to do business with you. Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

Complaints

If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you may contact the Office of the New Zealand Privacy Commissioner.

Storage and security
We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

Cookies
We may use cookies on our website from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Use of Artificial Intelligence (AI)
Overview: We use artificial intelligence and machine learning technologies, including AI Technologies provided by third parties (AI Technologies) in our business operations and the provision of our Services. We will only use AI Technologies when legally permitted and necessary for our business operations.

How we use AI Technologies: We may use AI Technologies for the following purposes:
● to conduct analysis and processing;
● to generate learning prompts;
● to listen and interpret data collected by your device’s microphone;
● to improve and optimise our services and operations;
● to personalise your experience with our services;
● for quality assurance purposes; and
● to assisting with customer support and queries.

Data Protection and Security: Where we use service providers who provide AI Technologies to us,we will take reasonable steps to ensure that such service providers handle your personal information according to privacy law, including by ensuring that we have contracts in place requiring the service provider to protect personal information.
We may input your personal information into platforms provided by AI Technology service providers which may then be used to train the service provider’s AT Technology model based on that information.

Your Rights and our Commitments: We will treat information generated or inferred by the AI Technologies about individuals as personal information and you maintain all rights over your personal information as outlined in this privacy policy, regardless of whether AI Technologies are used in processing. When using AI Technologies with your personal information:

● Transparency and control: we will inform you when AI Technologies are being used to make decisions that may significantly affect you. We will implement processes to verify the accuracy of AI-generated outputs and we will take reasonable steps to maintain human oversight and review of significant AI-generated decisions. Our staff are trained to understand the limitations of AI systems and verify outputs before they are relied upon.

● Security: we implement appropriate technical and organisational measures to ensure that our use of AI Technologies maintains the security and integrity of your personal information. This includes regular testing and monitoring of AI outputs for accuracy and reliability.

● Risk mitigation: We regularly assess and document the risks associated with our use of AI Technologies in processing personal information and implement appropriate mitigation measures. This includes ongoing monitoring of AI Technologies and regular reviews of their performance and impact.

Links to other websites

Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

For any questions or notices, please contact us at:
SonicPhonics Limited (NZCN 9277314)
Email: contact@sonicphonics.co.nz
Last update: 01.04.2025
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