1. Data Controller Information
The data controller responsible for your personal data is Sproutclearing, located at 2 Plimmer Steps, Wellington Central, Wellington 6011, New Zealand. You may contact us regarding privacy matters at hello@sproutclearing.world or by telephone at +64 4 471 1404.
We operate the website sproutclearing.world, which provides general informational content about meal organisation, consulting guidance, educational products, and related programs. This policy applies to all personal data processed through our website and associated services.
2. Scope and Applicable Law
This Privacy Policy is designed to comply with the General Data Protection Regulation (GDPR) where applicable to our processing activities, the New Zealand Privacy Act 2020, and other relevant international data protection frameworks. Where local law provides you with rights beyond those described here, those rights shall apply.
By using our website or submitting information through our contact form, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our data practices, please refrain from using our services or contact us to discuss your concerns before proceeding.
3. Categories of Personal Data We Collect
3.1 Information You Provide Directly
When you complete our contact form, we may collect your name, email address, message content, and confirmation of consent to data processing. If you engage our consulting or educational services, we may additionally collect scheduling preferences, household size information relevant to meal planning discussions, and billing details necessary for payment processing.
3.2 Information Collected Automatically
When you visit our website, we may automatically collect technical data including your IP address, browser type and version, operating system, referring URL, pages viewed, time spent on pages, and general geographic location derived from IP address. This data is collected through cookies and similar technologies as described in our Cookie Policy.
3.3 Information We Do Not Collect
We do not intentionally collect sensitive personal data such as medical records, health diagnoses, genetic information, or government identification numbers through our website. We ask that you do not submit health-related information through our contact form, as our services relate to general meal organisation guidance only.
4. Purposes of Data Processing
We process personal data for the following specific purposes:
- Responding to inquiries submitted through our contact form or email
- Delivering consulting sessions, personalised planning documents, and educational programs you have requested
- Processing payments and managing billing records for paid services
- Improving website functionality, content relevance, and user experience
- Complying with legal obligations, including tax and accounting requirements
- Protecting our website and services against fraud, abuse, and security threats
- Communicating service updates, policy changes, or administrative notices where necessary
We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects.
5. Legal Bases for Processing (GDPR)
Where the GDPR applies, we rely on the following legal bases for processing your personal data:
- Consent: When you submit our contact form, accept cookies, or explicitly agree to receive communications
- Contractual necessity: When processing is required to deliver services you have purchased or requested
- Legitimate interests: For website security, analytics to improve our content, and direct communication about services you have engaged
- Legal obligation: When retention or disclosure is required by applicable law
You may withdraw consent at any time where processing is consent-based, without affecting the lawfulness of processing conducted prior to withdrawal.
6. Data Retention Periods
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected:
- Contact form submissions: retained for up to 24 months from the date of last communication, unless a longer period is required for ongoing service delivery
- Client service records: retained for up to 7 years following the completion of services, in accordance with New Zealand record-keeping requirements
- Payment and billing records: retained for up to 7 years for tax and accounting compliance
- Cookie consent preferences: stored locally in your browser until cleared or until consent is renewed
- Analytics data: aggregated and anonymised where possible; raw logs retained for up to 14 months
When retention periods expire, personal data is securely deleted or anonymised so that it can no longer be associated with you.
7. Data Sharing and Third Parties
We do not sell your personal data to third parties. We may share data with the following categories of recipients where necessary:
- Website hosting and infrastructure providers who process data on our behalf under data processing agreements
- Email service providers used to send and receive communications
- Payment processors for handling transactions related to paid services
- Analytics providers, only where you have consented to analytics cookies
- Legal or regulatory authorities when required by applicable law
All third-party processors are required to implement appropriate technical and organisational measures to protect your data and process it only according to our instructions.
8. International Data Transfers
Some of our service providers may be located outside New Zealand or the European Economic Area. Where personal data is transferred internationally, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission, adequacy decisions, or equivalent mechanisms recognised under applicable law.
9. Security Measures
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:
- HTTPS encryption for all data transmitted between your browser and our website
- Access controls limiting personal data access to authorised personnel only
- Regular review of security practices and third-party processor compliance
- Secure storage of physical and digital records containing personal data
- Procedures for identifying and responding to potential data breaches
While we take reasonable steps to protect your data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security but commit to notifying affected individuals and relevant authorities of breaches where required by law.
10. Your Rights
Depending on your location, you may have the following rights regarding your personal data:
- Right of access: Request a copy of the personal data we hold about you
- Right to rectification: Request correction of inaccurate or incomplete data
- Right to erasure: Request deletion of your data where no compelling reason exists for continued processing
- Right to restrict processing: Request limitation of processing in certain circumstances
- Right to data portability: Receive your data in a structured, commonly used format where technically feasible
- Right to object: Object to processing based on legitimate interests or for direct marketing purposes
- Right to withdraw consent: Withdraw consent at any time where processing is consent-based
- Right to lodge a complaint: File a complaint with a supervisory authority, such as the Office of the Privacy Commissioner in New Zealand or your local data protection authority
To exercise any of these rights, contact us at hello@sproutclearing.world. We will respond within 30 days, or within the timeframe required by applicable law.
11. Children's Privacy
Our website and services are not directed at individuals under the age of 16. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us immediately and we will take steps to delete such information.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. The date at the top of this page indicates when the policy was last revised. Material changes will be communicated through a notice on our website. Continued use of our services after changes take effect constitutes acceptance of the updated policy.
13. Contact Information
For privacy-related inquiries, data subject requests, or concerns about our data practices, please contact:
Sproutclearing
2 Plimmer Steps, Wellington Central, Wellington 6011, New Zealand
Email: hello@sproutclearing.world
Phone: +64 4 471 1404