Privacy Policy

Purpose

This policy explains how HOW² Te Ako Charitable Trust collects, uses, stores, and protects personal information in accordance with the New Zealand Privacy Act 2020.

Information Collected

We may collect the following personal information:

• Name, email address, phone number, and address
• Driver licence details
• Booking and attendance records
• Payment information (processed by Stripe)
• VR training data (see VR Training Data section below)
• Website analytics

How Information Is Used

Personal information is used to:

• Deliver driving lessons and VR training
• Process payments and manage bookings
• Communicate about sessions and updates
• Improve training quality and safety
• Meet legal or regulatory obligations

Personal information is not sold or shared for marketing purposes.

Stripe as Third-Party Processor

Stripe collects and processes payment information directly. Stripe may collect your name, email address, billing address, and card details under its own privacy policy available here. HOW² Te Ako Charitable Trust does not receive or store full card details.

VR Training Data

VR sessions are provided using software developed by Gfactor Technologies Limited (CoDrivr). During VR sessions, Gfactor Technologies Limited may collect data including driving behaviour, reaction times, hazard perception, training progress, and biometric data such as eye tracking. This data is collected and governed by Gfactor Technologies Limited's privacy policy, which is available here. By booking a VR session, you acknowledge and accept the Gfactor Technologies Limited privacy policy in addition to this policy.

Sharing Information

Information may be shared with:

• Stripe (payment processing)
• IT service providers
• Instructors
• Government agencies (if required by law)
• Funding partners (if applicable)
• Gfactor Technologies Limited (VR session data, per their privacy policy)

Storage and Security

Information is stored securely using encrypted systems. Access is restricted to authorised staff. Reasonable steps are taken to prevent loss, misuse, or unauthorised access.

Data Retention

Information is retained only as long as necessary to provide services, meet legal obligations, and support learner progress. After this period, information is securely deleted.

Your Rights

Under the Privacy Act 2020, you have the right to request access to your personal information, request corrections to your information, and ask how your information is being used. To exercise these rights, contact our Privacy Officer.

You may also make a complaint to the Privacy Commissioner at www.privacy.org.nz if you believe your privacy rights have been breached.

Privacy Officer

Hanadi Ali
hanadi@how.kiwi

Policy Updates

This policy may be updated at any time. The latest version will always be available on the HOW² Te Ako Charitable Trust website.

Contact

For privacy queries, contact drive@how.kiwi.