Privacy Statement

Introduction

This Privacy Statement sets out the data practices of promana.nz (the "Information Site") and promanapeople.com (the "App Site", and together, "Promana People"). Promana People is owned and operated by Technologies Behind Coaches Ltd, a Company registered in New Zealand (NZBN 9429048977180).

The Information Site is a corporate marketing website and blog. The App Site offers behavioural assessments, access to coaching, and interpersonal and enterprise networking services.

Our data and privacy baseline

As a committed Privacy First service, Promana People chooses to treat your data with the same level of respect and protection afforded to people in the European Union by its General Data Protection Regulation ("GDPR"). Although we are not based in the European Union, we believe that the GDPR offers a higher standard or personal data protections and that all other data jurisdictions' rules fall within the high standards set by the GDPR.

Our first principles

  • You have the right to have us erase your data
  • You have the right to a copy of your data in a portable format
  • We store only the data we absolutley need to, in order to provide our service to you
  • Your assessments are about you, so you control the rights for others to gain access to your personally identifiable assessment results
  • We own the anonymised versions of all assessment results
     

Data collected by Promana People

1. App Site

When you join our App Site we collect your first and last name, your email address and your consent to our terms. We store your data securely in industry-leading cloud computing environments, using industry best practices.

Personal use

When you complete an assessment, we store the responses you make during completion of each surveys and we store your IP address while you are being assessed (to confirm your geo-location for future anonymised statistical purposes). We store the results of your assessments in anonymised form and we store your relationship to that data set. Specifically, we treat you as a Joint Data Controller when it comes to the control of the data that links you to your results.

If at any time you don't wish to be associated with the results of your assessments, you control the severance of that link. Likewise, if you are asked to respond to a third party who may wish you to complete one of our assessments for their own purposes, if that assessment is about you then you and we are the Joint Controllers of the link between you and that third party.

Therefore should you wish to sever the link between your assessment and the third party, you can, and this will leave you as the "owner" of the data you created (after all, it's all about you) and the third party with access only to the anonymised version of that data.

To sever the link between yourself and Promana's access to your data, you need to close your account, as we need that link to remain in force in order to legitimately provide our service to you.

We are the Data Controller for all other data except the data linking you to your assessment results.

Teams and enterprises

When you use Promana People to create a team and to manage your team data, you are the Data Controller when you generate invitations for your colleagues to join the platform. Promana People is the Data Processor during the invitation phase. The invitee is the Data Subject.

Once an invitee accepts their invitation, their acceptance changes that relationship and they become both a Data Subject and (together with Promana People) the Joint Data Controller of the right to expose any link between their results and assessments your request to have then share it with you. You are the Data Controller of the other aspects of your administration of the Team elements of our service. Promana People is your Data Processor for those purposes.

2. Information Site

When you complete our Information Site's Contact form, we collect personal information from you, including information about your:

  • name
  • contact information
  • location
  • computer or network
  • interactions with us

 

We collect your personal information in order to:

  • Respond to support requests and commercial enquiries

 
Providing some information is optional. If you choose not to enter your contact details, we'll be unable to provide responses to your requests for support.

You have the right to ask for a copy of any personal information we hold about you, and to ask for it to be corrected if you think it is wrong. If you’d like to ask for a copy of your information, or to have it corrected, please contact us at privacy.