Effective Date: March 1, 2025
Last Revised: March 1, 2025 (Version 1.0 – Initial Release)
Introduction / Scope
GRASPLR (“we,” “us,” “our”) is committed to protecting the privacy of users of our website (https://grasplr.com) and related services (the “Services”).
This Privacy Policy explains:
- What information we collect
- How we use, store, disclose, transfer, and protect that information
- Your rights regarding your information
- How to contact us
This Policy applies to anyone who accesses or uses our Services, including visitors, registered users, and customers. By using our Services or providing information to us, you accept the practices described here.
Categories of Personal Data Collected
We may collect and process the following types of personal data:
- Identifiers and Account Data: Name, email address, username, password hash, mailing address, telephone number.
- Transactional and Payment Data: Billing address, invoice records, payment references (e.g., last 4 digits of card), subscription status.
- Usage and Analytics Data: IP address, timestamps, device identifiers, browser and operating system details, pages visited, session duration, clickstreams, referrer URLs, crash logs, feature usage metrics.
- Support and Communication Data: Emails, chat transcripts, feedback provided by you.
- Marketing and Preference Data: Newsletter opt-in, marketing preferences, email engagement (clicks, opens).
- Third-party, Social, or Public Data: Profile information from connected accounts (if enabled), public social media details.
- Derived or Aggregated Data: Aggregated, anonymized data and inferred interests.
We do not intentionally collect sensitive personal data (such as health or biometric data). If you choose to provide such information, it will be processed only with your explicit consent and appropriate safeguards.
Legal Basis for Processing
We rely on the following lawful bases when processing personal data:
- Performance of a contract: To fulfill subscriptions, billing, or support needs.
- Legal compliance: To meet obligations such as recordkeeping or reporting.
- Legitimate interests: For fraud prevention, analytics, service improvement, or security, provided these interests do not override your rights.
- Consent: For activities like marketing or the use of certain cookies, when required by law.
Under New Zealand’s Privacy Act 2020, data collection and use must be lawful, necessary, and consistent with the Information Privacy Principles.
Cookies, Tracking, and Similar Technologies
We and our partners use cookies and similar tools for authentication, analytics, personalization, and marketing.
Types of cookies include:
- Strictly necessary (e.g., login sessions)
- Performance/analytics
- Functional (user preferences)
- Advertising/targeting
Where required by law, we seek your consent before using non-essential cookies. You can manage or withdraw consent at any time. Some cookies may be placed by third parties, such as analytics or advertising providers.
For further details, please see our Cookie Policy.
Use of Personal Data
We use personal data to:
- Register and manage accounts
- Authenticate and maintain sessions
- Process subscriptions, billing, and payments
- Send transactional emails (confirmations, receipts)
- Provide customer support and resolve disputes
- Send marketing communications (with consent or as permitted by law)
- Personalize user experiences
- Monitor, analyze, and improve Services
- Detect and prevent fraud or security issues
- Comply with legal obligations
- Aggregate or anonymize data for analysis
We will not use your data for purposes incompatible with the original reason for collection unless we notify you and obtain consent where required.
Third-Party Sharing and Disclosures
We may share data with:
- Service providers (e.g., hosting, analytics, payment processing, support) under contractual safeguards
- Affiliates or subsidiaries for internal operations
- Legal or regulatory authorities if required by law
- Business partners in the event of mergers, acquisitions, or reorganizations
- The public, in the form of aggregated or anonymized data
We do not sell personal data for third-party marketing unless you explicitly opt in.
AI-Generated and PLR Content
Some materials provided through GRASPLR are generated or assisted by AI systems or distributed as Private Label Rights (PLR) content. Users are responsible for reviewing, editing, and ensuring compliance of any such content before use, redistribution, or resale.
International Transfers
Your data may be transferred outside your home jurisdiction. We ensure such transfers comply with applicable law and are safeguarded (e.g., using Standard Contractual Clauses under GDPR). Under New Zealand law, overseas disclosures require either your consent or assurance that comparable protections are in place.
Data Retention
We retain personal data only as long as necessary for business or legal reasons:
- Account data: while active, plus up to 3 years after deactivation
- Billing records: up to 7 years for tax/legal obligations
- Support logs: typically 2 years after resolution
- Analytics data: may be retained in anonymized form for up to 5 years
- Marketing preferences: until consent is withdrawn
Security Measures
We use safeguards such as:
- Encryption in transit and at rest
- Access controls and role-based permissions
- Firewalls and intrusion detection
- Secure backups and redundancy
- Regular testing and staff training
While strong protections are in place, no system can guarantee absolute security.
Breach Notification Procedures
If a data breach occurs, we will:
- Assess and contain the incident
- Notify affected individuals and authorities where required
- Provide information on the breach and protective steps
- Document the incident and corrective measures
User Rights
Depending on your location, you may have the right to:
- Access personal data held about you
- Correct or update inaccurate information
- Request deletion of your data (subject to legal obligations)
- Restrict or suspend processing
- Request data portability
- Withdraw consent for consent-based processing
- Opt out of marketing communications
- Lodge complaints with a privacy regulator
Requests can be made via the contact information below. Identity verification may be required.
Privacy Officer / Contact Information
Email: sjbrough@gmail.com
Address: 5/160 Simeon Street, Spreydon, Christchurch 8024, NZ
Governing Law
This policy is governed by the laws of New Zealand. You agree to submit to the jurisdiction of New Zealand courts. Local laws in your jurisdiction may also apply.
Changes and Revision History
We may update this policy from time to time. Updates will be reflected in the “Last Revised” date above, and we may notify users where appropriate. Continued use of the Services indicates acceptance of updates.
Revision History:
- March 1, 2025 — Version 1.0: Initial release