Privacy Policy
19 April 2025
This Privacy Policy explains how Start Now Limited NZBN (9429045939068) trading as EngageNow (“we”, “us”, “our”) collects, uses, discloses, and protects your personal information when you use our platform (“Platform”) or services.
We are committed to protecting your privacy and handling your personal information in accordance with applicable privacy laws including the Privacy Act 2020 (NZ).
By accessing or using our Platform, creating an account, or engaging with our services, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy.
1. Information We Collect
1.1 Account and Registration Information
We collect information required to create and manage your account on our Platform. This includes your business name, business contact information such as name, email address, and phone number; account credentials including username and password (which we store in encrypted form); and account preferences. For Agency accounts, we also collect information about team members, including their professional qualifications and experience.
1.2 Profile Information
We collect profile information that you choose to share on our Platform. For Clients, this includes business descriptions, project requirements, and industry information. For Agencies, this includes service descriptions, capabilities, portfolio examples, team composition, and professional qualifications. This information is used to facilitate appropriate matches between Clients and Agencies.
1.3 Transaction Information
We collect information necessary to process payments through our Platform. This includes transaction amounts, dates, and associated project details. Our payment processors (currently Stripe and PayPal) collect and process your payment method details. We receive and maintain limited payment information as required for transaction processing, such as transaction identifiers and payment status.
1.4 Communication Information
We collect and store communications that take place through our Platform. This includes messages between Clients and Agencies, communications with our support team, project briefs and requirements, and Platform notifications and responses.
1.5 Behavioural Information
We collect information about how you interact with our Platform. This includes services searched, listings viewed, engagement metrics, time spent on various sections of the Platform, and interactions with AI-generated recommendations. This information helps us improve our Platform functionality and matching capabilities.
1.6 Technical Information
When you visit our Platform, we automatically collect certain technical information. This includes device information such as device type, operating system, and unique device identifiers; your IP address; browser data including browser type and version; and information about your operating system. We also collect data about your browsing patterns including pages viewed, time spent on pages, and search queries.
2. How We Collect Information
2.1 Direct Collection
We collect personal information directly from you through several interactions with our Platform. This happens when you create an account, complete your profile, engage with other users, submit project requirements, or contact our support team. We also collect information when you provide feedback about the Platform or update your account information.
2.2 Automatic Collection
We collect information automatically when you use our Platform. This includes information collected through our website analytics tools, cookies and similar technologies, and our AI matching algorithms. When you make a payment, your payment information is securely processed by our third-party payment providers, who share limited transaction details with us to facilitate the service.
2.3 Third-Party Sources
In some cases, we may receive information about you from third parties. This may include information from business verification services, professional networks, or other publicly available sources that help us verify account information or enhance our matching capabilities.
3. Purpose for Collecting Information
3.1 Platform Functionality
We collect and use your information to provide and maintain our core Platform services. This includes enabling account creation and management, facilitating connections between Clients and Agencies, processing transactions between users, and supporting communications between matched parties. This information is essential for delivering the services you expect from our Platform.
3.2 AI-Enhanced Matching
We collect and use information to power our AI-enhanced matching capabilities. Your profile information, service categories, project requirements, and historical engagement data help our systems generate appropriate matches between Clients and Agencies. This functionality is central to our Platform’s value proposition of connecting businesses with suitable professional service providers.
3.3 Transaction Processing
We collect and use transaction information to facilitate payments between Clients and Agencies, calculate and collect our commission, and maintain accurate financial records. We use this information to track successful transactions, process any applicable refunds, and fulfill our tax and accounting obligations.
3.4 Communication Facilitation
We collect and use communication information to enable interactions between users of our Platform. This includes providing messaging capabilities, sending notifications about project updates, and delivering support when needed. This information helps ensure all parties can effectively collaborate on projects arranged through our Platform.
3.5 Platform Improvement
We collect and use behavioural and technical information to enhance the functionality and user experience of our Platform. This data helps us identify areas for improvement, develop new features, optimise existing capabilities, and resolve technical issues. By understanding how users interact with our Platform, we can continuously enhance our services.
3.6 Security and Fraud Prevention
We collect and use certain information to protect our Platform, our users, and our business from fraudulent activity, security threats, and abuse. This includes verifying user identities, monitoring for suspicious activities, and maintaining the integrity of our Platform.
4. Disclosure of Information
4.1 Between Platform Users
The primary purpose of our Platform is to facilitate connections between Clients and Agencies. Accordingly, certain information you provide will be shared with other users. For Agencies, this includes profile information, service descriptions, and qualifications that are visible to potential Clients. For Clients, this includes project requirements and business information necessary for Agencies to understand potential engagements.
4.2 Service Providers
We may share your personal information with trusted third-party service providers who assist us in operating our Platform, conducting our business, and servicing you. These include payment processors who handle payment transactions, email service providers who help us send notifications, web hosting providers that maintain our infrastructure, and analytics providers that help us understand Platform usage. These service providers are authorized to use your personal information only as necessary to provide specific services to us, and they are required to maintain the confidentiality and security of your information.
4.3 Legal Requirements
We may disclose your personal information if required to do so by law or in response to valid requests by public authorities such as a court or government agency. We only disclose the minimum information necessary to meet these legal requirements and take steps to ensure that your privacy is protected as much as possible.
4.4 Business Transfers
If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your personal information may be transferred as part of that transaction. In such event, we will notify you via email and/or a prominent notice on our Platform of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
5. Data Storage and Security
We implement appropriate technical and organisational measures to protect the personal information we collect and process. Our security approach includes using secure connections for data transmission, storing personal information in protected databases, and limiting staff access to personal information on a need-to-know basis.
We conduct regular security assessments and updates and maintain password protection and authentication procedures to safeguard your data. While we and our service providers implement appropriate security measures, no method of electronic storage or transmission over the internet is completely secure. We cannot guarantee absolute security of your personal information.
For payment processing, we rely on industry-standard security protocols implemented by our payment processors. We do not directly handle or store sensitive payment details such as complete credit card numbers.
6. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. We apply consistent retention practices across all categories of data.
Account information, transaction records, and communication records are generally maintained for as long as necessary for business and legal purposes, including compliance with tax and accounting requirements which may require retention for up to 7 years. When personal information is no longer needed for the purposes for which it was collected, we take reasonable steps to destroy or permanently de-identify that information, unless its retention is required by law.
7. AI Technology and Data Processing
7.1 AI-Enhanced Platform
Our Platform utilises artificial intelligence technologies to enhance the matching process between Clients and Agencies. These AI systems analyse profile information, project requirements, historical performance data, and other relevant factors to generate appropriate recommendations. Our AI technology is designed to empower human relationships, not replace them, and operates in accordance with our AI Values of transparency, fairness, human oversight, privacy, and accountability.
7.2 Algorithm Transparency
We are committed to being transparent about how our AI systems make recommendations. Our matching algorithms primarily consider factors such as service categories, professional qualifications, past project success, and specific Client requirements. While our AI technology continuously learns and improves based on Platform interactions, all final decisions regarding engagement, hiring, and contracting remain entirely with the users.
7.3 Data Training and Improvement
We may use aggregated and de-identified Platform data to train and improve our AI systems. This process helps enhance the quality of matches and the overall user experience. We implement measures to ensure that any data used for AI training cannot be linked back to specific individuals or businesses.
8. Marketing and Communications
8.1 Platform Communications
We send communications necessary for Platform functionality, including account notifications, match alerts, transaction confirmations, and updates about projects. These operational communications are an integral part of our service and are not considered marketing communications.
8.2 Marketing Communications
With your consent, we may send you marketing communications about our Platform, new features, and events that we think might interest you. These communications are designed to keep you informed about improvements to our services and other news related to our
business. We may deliver these messages via email or other electronic means depending on the contact information you have provided and your communication preferences. We may also use client and agency information for case studies and marketing purposes in an anonymised or aggregated format. If we wish to use your information in a manner that would identify you specifically, we will request your explicit permission first.
8.3 Opting Out
You can choose to stop receiving marketing communications from us at any time by clicking the “unsubscribe” link found in our marketing emails, contacting us directly using the information provided at the end of this policy, or updating your communication preferences in your account settings. We respect your preferences and will process your request as quickly as possible, though please allow up to 10 business days for your preferences to be updated across all our systems.
9. Payment Processing
When you make a transaction on our Platform, the payment is processed by third-party payment providers. We do not directly process or store your complete payment details. Your payment information is transmitted securely to these payment processors in accordance with their respective security standards and protocols.
We only receive and store limited information about your transaction (such as transaction IDs and payment status) to help us manage the flow of funds between Clients and Agencies and to handle any issues that may arise.
Each payment processor has its own privacy policy explaining how they handle your payment information. We encourage you to review these policies to understand how your payment details are handled.
10. International Data Transfers
We operate globally and may transfer data, including personal information, across international borders. Such transfers are conducted in compliance with applicable data protection laws and may involve countries with varying levels of data protection. When we transfer personal information from New Zealand to other countries, we take appropriate measures to ensure that the transfer complies with applicable laws and that adequate protection for the personal information is maintained at all times. These measures may include transferring information to countries that have been deemed to provide an adequate level of protection or implementing appropriate safeguards such as standard contractual clauses.
By using our Platform, you acknowledge and consent to the international transfer of your information as necessary for the performance of our services.
11. Your Privacy Rights
Your personal information is protected by the Privacy Act 2020 (New Zealand) and potentially by other privacy laws depending on your location. In accordance with these laws, you have the following rights:
11.1 Access to Your Information
You have the right to request access to the personal information we hold about you. Upon receiving your request and verifying your identity, we will provide you with confirmation of whether we hold your personal information and access to that information unless an exception applies. We will respond to your access request within 20 working days, or if that is not reasonably practicable, as soon as practicable after that time.
11.2 Correction of Information
You have the right to request correction of any personal information we hold about you that is inaccurate, incomplete, or out-of-date. If we agree the information needs correction, we will make the change. If for any reason we decline to make the requested correction, you may provide a statement of the correction sought which we will attach to the information in a manner that ensures it will be read with the information.
11.3 Information Use and Disclosure
You have the right to know why we collect your personal information and how we use or disclose it. This Privacy Policy provides this information, but you may also contact us for specific clarification about how your personal information is being used.
11.4 Collection Practices
You have the right to know what personal information we collect and how we collect it. We will take reasonable steps to ensure you are aware of the collection of your personal information, the purpose of collection, and the consequences if the information is not provided.
11.5 Information Storage and Security
You have the right to expect that your personal information will be protected by reasonable security safeguards against loss, unauthorised access, use, modification, or disclosure.
11.6 Retention and Disposal
You have the right to expect that we will not keep your personal information for longer than necessary for the purposes for which it may lawfully be used.
11.7 Use of Unique Identifiers
Where we assign a unique identifier to you (such as an account number or user ID), you have the right to expect that we will restrict the use of this identifier to what is necessary for carrying out our functions efficiently.
11.8 Overseas Transfers
You have the right to be informed about overseas transfers of your personal information. As detailed in section 10 of this Privacy Policy, we may transfer your information internationally as part of our global operations. We take reasonable steps to ensure that the overseas recipient is bound by privacy protections comparable to those under New Zealand law.
11.9 Right to Complain
If you believe we have breached your privacy rights or the Privacy Act 2020, you have the right to make a complaint. We encourage you to first contact us directly to resolve your concern. If you are not satisfied with our response, you may lodge a complaint with the New Zealand Privacy Commissioner (www.privacy.org.nz).
11.10 Exercising Your Rights
To exercise any of these rights, please contact us using the email address provided at the end of this policy. We will respond to your request within 20 working days. We may ask you to verify your identity before we can act on your request to ensure we are protecting your data security.
11.11 Data Deletion
You can request deletion of your personal data through the self-service options available in your account Dashboard. Please note that certain information may need to be retained for legal, regulatory, or business purposes even after a deletion request. When you delete your
account, we may retain anonymised or aggregated data derived from your account information.
11.12 International Privacy Frameworks
If you are located outside New Zealand, you may have additional or different rights under your local privacy laws. Where applicable, we are committed to honouring those rights in accordance with relevant international privacy frameworks, including:
(a) For Australian users, the Australian Privacy Principles under the Privacy Act 1988 (Cth); (b) For users in the European Economic Area, the General Data Protection Regulation (GDPR); (c) For users in California, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).
While we primarily operate under New Zealand privacy law, we recognise that users from other jurisdictions may have rights under their local privacy laws. We will consider such rights where applicable to our operations.
Where there is a conflict between these various privacy frameworks, we will generally apply the framework that provides the highest level of protection for your personal information.
12. Cookies and Tracking Technologies
Our Platform uses cookies and similar technologies to enhance your browsing experience and analyse Platform usage. These digital tools help us provide essential features, remember your preferences, analyse our performance, and deliver more relevant content.
12.1 Types of Cookies
We use the following types of cookies:
Essential Cookies: These cookies are required for the basic functionality of our Platform. They enable core features such as user authentication, account management, and secure transactions.
Functional Cookies: These cookies remember your preferences and settings to enhance your experience. They help our Platform remember choices you have made, such as your preferred settings or recently viewed profiles.
Analytics Cookies: These cookies collect information about how visitors use our Platform, including which pages are visited most frequently and how users interact with different features. This data helps us improve our Platform’s performance and ensure we are meeting our users’ needs.
12.2 Managing Cookies
You can manage cookies through your web browser settings. Most browsers allow you to delete existing cookies from your device, block new cookies from being set, and receive notifications when new cookies are being sent to your device.
Please note that disabling certain cookies, particularly essential cookies, may limit your ability to use all features of our Platform.
13. Changes to Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. For significant changes, we may also notify you via email or through a notice on our Platform.
The updated version will be effective as of the date stated at the top of this Privacy Policy. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.
14. Data Breach Response
We take the security of your personal information seriously and have procedures in place to respond to potential data breaches. If we become aware of a data breach that is likely to result in serious harm to individuals whose personal information is involved, we will take immediate action.
Our response includes taking prompt steps to contain the breach and prevent further unauthorised access. We will conduct a thorough assessment of the likely risk of serious harm to affected individuals based on the type of information involved and how it could be misused.
When required by applicable law, we will notify affected individuals promptly about the breach and provide information about what happened, what information was involved, and steps they should take to protect themselves. We will also notify relevant regulatory authorities as required by law.
15. Contact Information
If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us via email: support@engagenow.ai