OwtSmart Privacy Policy

(OWTS Owners and Service Providers)

Last updated: 01/10/2026

Introduction

  1. This policy sets out how your personal information is collected, used, disclosed and protected when you visit our website or use the OwtSmart platform in any form, including via our website and any mobile app (“OwtSmart”). OwtSmart is a platform connecting owners of on-site wastewater treatment systems (“OWTS Owners”) with businesses that install, inspect, service, sample, maintain, repair and monitor those systems (“Service Providers”). This policy applies to you whether you use OwtSmart as an OWTS Owner or as a Service Provider, or on behalf of either. Personal information is information about an identifiable individual (a natural person).
  2. References to we, us and our in this policy are to OwtSmart Limited (NZ company number 9349523).
  3. We comply with the New Zealand Privacy Act 2020 (“the Act”) when dealing with personal information. This policy does not limit or exclude any of your rights under the Act. If you wish to seek further information on the Act, see www.privacy.org.nz.
  4. This policy was drafted with brevity in mind. It does not provide exhaustive details of all aspects of our collection and use of personal information. We are happy to provide any additional information or explanation. Any requests for further information should be sent to hello@owtsmart.com.
  5. Capitalised terms not separately defined in this policy have the meaning given in the OwtSmart Platform Terms of Use - OWTS Owners (“OWTS Owner Platform Terms”) or the OwtSmart OwtSmart Platform Terms of Use - Service Providers (“OWTS Service Provider Platform Terms”), as applicable (together, “the Terms”).

 Changes to this policy 

  1. We may change this policy by uploading a revised policy onto the Website. The change will apply from the date that we upload the revised policy.
  2. This policy was last updated on the 1st of October 2026.

When does this Privacy Policy apply

  1. This policy sets out how we will collect, use, disclose and protect your personal information when you visit and use our website, including all subdomains (“Website”), OwtSmart, and all related products and services, or when you otherwise deal with us or a user of OwtSmart.
  2. If you provide your personal information to another user of OwtSmart (for example, if you are an OWTS Owner and you provide personal information to a Service Provider, or you are a Service Provider and you provide personal information to an OWTS Owner), that other user will have its own privacy policy or practices relating to your personal information. Similarly, if you authorise us to share a Service Activity Summary or other information relating to your OWTS with a Regulatory Authority, that Regulatory Authority will have its own policy relating to your personal information. We cannot control, and are not responsible for, how any other user of OwtSmart, or any Regulatory Authority, uses your personal information.

Children

  1. We do not intend to collect personal information from or about children under 16. If you have reason to believe that we have collected personal information from or about a child under 16, please contact us at hello@owtsmart.com.

What personal information do we collect

Directly

  1. We collect the following information from you, when you provide that personal information to us, including via the website, OwtSmart, any mobile app used to provide OwtSmart (“App”), and any related product or service.
  2. When you contact us, register as a User with OwtSmart (whether as an OWTS Owner or a Service Provider), subscribe to our newsletter, or complete a form via OwtSmart, the website or the App, we may collect your name, email address, address, phone number, location, and professional details (where applicable) including your organisation name, work email, job title or position, industry, and the area in which you work, as well as any other information we require or ask for to fully respond to you. We may collect some of this information using third-party authentication services.
  3. If you register as a Service Provider (or an Account Member of a Service Provider), we may also collect information about the goods and services you offer, the licences, qualifications, certifications and prequalifications you hold (including any Tōtika Health and Safety Prequalification), and other information relevant to your registration and continued listing on the Platform.
  4. If you are an OWTS Owner, we also collect information about your OWTS itself, including its type and location, its servicing and maintenance history, and any consents, resource consents, building consents or other regulatory records relating to it. This information may be provided directly by you, submitted by a Service Provider as a Service Record, or obtained from a Regulatory Authority, in the circumstances described elsewhere in this policy.
  5. When you purchase a subscription to OwtSmart from us, we collect your name, email address, phone number and, where applicable, your professional details, and any other information you submit to us for subscription fulfilment purposes.
  6. If we bill you, we collect your invoicing or billing address, email address, service or product description, purchase order number (if applicable), and any other information you submit to us for billing purposes.
  7. Some of the personal information that we collect directly from you may be mandatory and some may be optional. We will let you know which of these applies at the time we collect the relevant personal information. While you do not have to provide us with any of the information that we may request, this might mean that we cannot provide all or part of OwtSmart's functionality and related services and products to you, or they may not perform as well as they should. If you require further information about the consequences of not providing us with any personal information, please contact us at hello@owtsmart.com.

Automatically

  1. When you access and use OwtSmart, the website or the App, or any of our related services and products, we may automatically collect information about your device and usage of that technology or services or products, including your IP address and/or other device identifying data, time spent on certain pages of the website, pages visited, and links clicked.
  2. Some of this data may be collected through third party tools and/or the use of cookies, web beacons and similar storage technologies. Please refer to the Cookies section below for more information on our use of cookies, including information on how you can disable these technologies.

From public sources and other third parties

  1. We may collect personal information about you that is publicly available, including using third party sources (for example, data brokers and providers of natural language processing and artificial intelligence services) to collect and supply to us that publicly available personal information.
  2. We may collect personal information about you from third parties where you have consented to, or authorised, this. For example, where the person who has paid to use OwtSmart to whom your OwtSmart account is connected (“Account Owner”) has added you as a user for the purposes of their account, or where you are an Account Owner and one of your users provides personal information about you to us.
  3. We may also collect personal information about you from:
    1. 22.1  other users of OwtSmart where they share your personal information with us in connection with their, or your, use of OwtSmart, the website or the App, including where an OWTS Owner includes your details in a Booking Request, or a Service Provider includes your details in a Service Record or in communications relating to a Customer Agreement;
    2. 22.2  a Regulatory Authority where you authorise us to communicate with that Regulatory Authority in relation to an OWTS owned or managed by you; and
    3. 22.3  an Approved Device Vendor, where you have asked us to enable OwtSmart to communicate with an IoT Device attached to an OWTS that you own or manage.
  4. We may link personal information collected from public sources and other third parties with personal information supplied by you or collected automatically.
  5. Payments for OwtSmart are processed independently by our third party payment provider, Stripe, Inc. (“Stripe”). We use Stripe for payments, analytics, and other business services. Stripe collects and processes personal data, including via cookies and similar technologies. The personal data Stripe collects may include transactional data and identifying information about devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us and to users of OwtSmart, including for fraud detection, loss prevention, authentication, and analytics related to the performance of its services. You can learn more about Stripe and its processing activities, and read its privacy policy, at https://stripe.com/nz.
  6. We do not have access to, or store, your credit or debit card information, or information relating to any bank account associated with any direct debit arrangement you have agreed with us.

How we use your personal information

  1. We will use your personal information:
    1. 26.1  to verify your identity and otherwise create, maintain and manage your account with us;
    2. 26.2  to provide OwtSmart, the website, the App, and other services and products, to you and to other users of OwtSmart and the website and the App (if applicable);
    3. 26.3  to geolocate an OWTS that you own or manage and/or the location of any Booking Request you submit via OwtSmart, in each case as an OWTS Owner, and to geolocate any area in which you or your organisation provides goods and services as a Service Provider;
    4. 26.4  to market our services and products to you, including contacting you electronically (e.g. by text, phone or email for this purpose);
    5. 26.5  to request information from you in connection with your use of OwtSmart;
    6. 26.6  to improve OwtSmart and any other services and products that we provide to you and/or to other users of OwtSmart, including by analysing how you interact with OwtSmart, the website and the App, and any related services or products;
    7. 26.7  to check the contents of any Booking Request, Service Provider Card, Service Record, Service Activity Summary, or other content on OwtSmart, the website or the App;
    8. 26.8  to enable users of OwtSmart and related services and products to communicate with each other;
    9. 26.9  to meet the purpose for which a party provided the information, including any purpose described in or contemplated by the Terms;
    10. 26.10  to submit reports, including Service Activity Summaries, to Regulatory Authorities when requested or authorised by you;
    11. 26.11  to resolve disputes, including any dispute between users of OwtSmart, or any dispute between a user and us;
    12. 26.12  to bill you, or the Account Owner, and to collect money that you (or the Account Owner) owe us, including authorising, verifying and processing credit and debit card transactions;
    13. 26.13  to verify a Service Provider's licences, qualifications, certifications or prequalifications (including Tōtika), for OwtSmart's own onboarding, display and record-keeping purposes;
    14. 26.14  to undertake credit checks of you (if necessary);
    15. 26.15  to respond to communications from you or the Account Owner, including complaints and enquiries;
    16. 26.16  to conduct research and statistical analysis (on an anonymised basis);
    17. 26.17  to protect and/or enforce our legal rights and interests, including checking your compliance with the Terms, enforcing our agreements with users of OwtSmart or any third party, defending any claim, and reviewing the content of any communication made available via OwtSmart by any method;
    18. 26.18  to assist in maintaining the safety, security and integrity of OwtSmart and the website, the App, and any APIs used in connection with our provision of OwtSmart;
    19. 26.19  to respond to lawful requests by public authorities, and as required by applicable law, including to comply with law enforcement requirements;
    20. 26.20  to work with you or the Account Owner as a commercial partner (where applicable);
    21. 26.21  to run promotions; and
    22. 26.22  for any other purpose authorised by you, the Account Owner, or applicable law (including the Act).
  2. We may create anonymous data records from personal information we collect or hold in relation to you, by anonymising your personal information (e.g. removing your name and contact details) from those data records. We may use this anonymous data for our own commercial purposes, including to analyse usage patterns or for other aggregate data analysis so that we may enhance the content and functionality of OwtSmart.
  3. You can unsubscribe from any marketing communications from us by following the instructions on any marketing communications sent to you. You can also exercise this right at any time by contacting us using the details at the end of this privacy policy.

Personal information included in Booking Requests, Service Records, Service Provider Cards and other communications

  1. If you add a Booking Request, update a Service Provider Card, submit a Service Record, or add any other publicly available message to OwtSmart, the information that you include will be available to other users of OwtSmart to the extent contemplated by the Terms. You should ensure that, when setting up any Booking Request, Service Provider Card or other communication of that kind, or when a person is doing so on your behalf, it only includes information that you wish to be available to other people.
  2. If you participate in any chat, messaging, record-keeping or other communication service made available via OwtSmart, the website or the App, the information that you include in those communications will be available to us and to third parties, including any recipient of that message and any provider of intermediary communication services. You should ensure that, when using any chat, messaging, record-keeping or other communication service, your messages only include information that you wish to be available to other people.
  3. We do not accept any responsibility to monitor all communications made via OwtSmart or the website or the App, but we reserve the right to access, monitor and review those communications, regardless of whether or not they are publicly available, in the circumstances and for the purposes described in the Terms or otherwise where necessary for us to confirm compliance by any person with the terms governing their use of OwtSmart.

General disclosure of your personal information

  1. We may disclose your personal information to:
    1. 32.1  the Account Owner and their other permitted users;
    2. 32.2  another company within our group;
    3. 32.3  any business that supports, services or maintains an IoT Device that you have requested we connect OwtSmart to, in order to establish and maintain that connection and otherwise for the purposes contemplated by the Terms;
    4. 32.4  any Regulatory Authority at your or the Account Owner's request or with your or the Account Owner's consent (e.g. where we submit a Service Activity Summary to the council that has authority over your OWTS, that summary may include your personal information);
    5. 32.5  any business that supports OwtSmart, the website or the App, or any other services and products we make available to you or other users of OwtSmart, including any person that hosts or maintains any underlying IT system or data centre that we use to provide OwtSmart, the website or the App, or those other services and products, including (but not limited to) content delivery services, site security and monitoring services, marketing services and customer relationship management services;
    6. 32.6  other users of OwtSmart in the circumstances described in, or otherwise contemplated by, the Terms or as otherwise reasonably contemplated by your use of OwtSmart. For example, if you include personal information in a Booking Request or related communication, we will make that personal information available to the relevant users of OwtSmart. If you are a Service Provider, any personal information you include in a Service Record, an update to your Service Provider Card, or when claiming or otherwise responding to a Booking Request, will be disclosed to the recipient of that information and may be disclosed to other users;
    7. 32.7  Service Providers and OWTS Owners, for the purpose of geolocating each other's locations in the manner contemplated by the Terms, including to connect OWTS Owners submitting Booking Requests with Service Providers who offer relevant goods or services in the area contemplated by the Booking Request;
    8. 32.8  any Users who are parties to a dispute. If there is a User Dispute, or a User contacts us about a dispute, we will share the details of the dispute and the contact details of the relevant Users between those Users in the manner contemplated by the Terms;
    9. 32.9  a credit reference agency, for the purpose of credit checking you (if necessary);
    10. 32.10  third parties, for anonymised information (whether statistical or otherwise);
    11. 32.11  professional advisers, e.g. accountants, lawyers or auditors;
    12. 32.12  >a person who can require us to supply your personal information;
    13. 32.13  any other person authorised by the Act or another law (e.g. a law enforcement agency), or where we believe in good faith that disclosure is necessary to: (i) satisfy our legal obligations; (ii) detect, prevent or otherwise address fraud, security or technical issues in connection with OwtSmart, the website, the App, or our products and services; or (iii) protect against imminent harm to the rights, property or safety of us, our users, or the public at large; and
    14. 32.14  any other person with your or the Account Owner's consent.
  2. You acknowledge and agree that any credit card, direct debit bank account, and billing and payment information that you provide to us may be shared by us with companies who work on our behalf, including payment processors and/or credit agencies, for the purposes of checking credit, effecting payment to us, and servicing your account.
  3. If an OWTS Owner transfers any records in OwtSmart relating to an OWTS to a third party, the personal information of any person included in those records will be transferred alongside those records.
  4. If you access or use OwtSmart in your capacity as an Account Member, or otherwise as an officer, employee, consultant, contractor or agent of an organisation, we may also disclose your personal information to any person we believe to be an authorised representative of that organisation. If you have questions about that organisation's access to, and use of, your personal information, please contact the relevant person in that organisation.
  5. We may transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition.

International transfers of personal information

  1. We store Content (including personal information) in secure servers located in New Zealand and Australia only and may access that Content from those locations from time to time.
  2. Some of the businesses that support OwtSmart, including our cloud hosting and other technology service providers, hold and process Content solely on our behalf and under our instructions, for example to store and safeguard it. Making Content available to those providers for that limited purpose is not, in itself, a disclosure of your personal information to them, and we remain responsible for that Content. This is different from situations where we disclose your personal information to another business or person for that other business or person's own purposes, which are addressed below.
  3. A business that supports OwtSmart, the website, the App, and/or our services and products may otherwise be located outside New Zealand (being the country where OwtSmart Limited is incorporated) and outside the country where you are located. This may mean that personal information we collect is held and processed in countries outside New Zealand and may be held and processed in countries outside the country where you are located.
  4. We will only disclose your personal information to a person or organisation outside New Zealand (including in Australia) if:
    1. 40.1  you authorise us to do so, after we have expressly informed you that the recipient may not be required to protect your information in a way that, overall, provides comparable safeguards to those in the Act;
    2. 40.2  we believe on reasonable grounds that the recipient is carrying on business in New Zealand and, in relation to your information, is subject to the Act;
    3. 40.3  we believe on reasonable grounds that the recipient is subject to privacy laws that, overall, provide comparable safeguards to those in the Act;
    4. 40.4  we believe on reasonable grounds that the recipient is a participant in a prescribed binding scheme (within the meaning of the Act);
    5. 40.5  we believe on reasonable grounds that the recipient is subject to the privacy laws of a prescribed country (within the meaning of the Act), and the disclosure is not precluded by any limitation or qualification prescribed in respect of that country; or
    6. 40.6  we otherwise believe on reasonable grounds that the recipient is required to protect your information in a way that, overall, provides comparable safeguards to those in the Act, for example under an agreement we have entered into with the recipient (which may include model contract clauses or equivalent data protection terms).
  5. This reflects the requirements of Information Privacy Principle 12 of the Act.

Protecting your personal information

  1. We will take reasonable steps to keep your personal information safe from loss, unauthorised activity, or other misuse.
  2. You can play an important role in keeping your personal information secure by maintaining the confidentiality of any password and accounts used in relation to OwtSmart and any other products and services, and by limiting the personal information you include in Service Records, Booking Requests, any updates to Service Provider Cards, and any other communications relating to, or made via, OwtSmart or the website or the App. Please notify us immediately if there is any unauthorised use of your account or any other breach of security.

Accessing and correcting your personal information

  1. Subject to certain grounds for refusal set out in the Act, you have the right to access your readily retrievable personal information that we hold and to request a correction to your personal information. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.
  2. In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the personal information, we will make the correction. If we do not make the correction, we will take reasonable steps to note on the personal information that you requested the correction.
  3. If you want to exercise either of the above rights, email us at hello@owtsmart.com. Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information, or the correction, that you are requesting).
  4. Subject to applicable law, we may charge you our reasonable costs of providing to you copies of your personal information or correcting that information.

Internet use

  1. While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.
  2. If you follow a link on the website or in the App to another site, the owner of that site will have its own privacy policy relating to your personal information. We suggest you review that site's privacy policy before you provide personal information.

Data retention policy

  1. The personal information that we collect and use will not be kept longer than necessary for the purposes for which it is collected, or for the duration required for compliance with applicable law, whichever is longer. We may use any aggregated or anonymous data derived from your personal information after your personal information itself is no longer retained by us, but not in a manner that would identify you personally.

Cookies

  1. We use cookies (an alphanumeric identifier that we transfer to your computer's hard drive so that we can recognise your browser, in the case of web cookies, or that are installed directly on your device and run locally, in the case of mobile cookies) to monitor your use of the website or the App. You may disable cookies by changing the settings on your browser and your device, although this may mean that you cannot use all of the features of the website or the App.

Contacting us

  1. If you have any questions about this privacy policy or our privacy practices, or if you would like to request access to, or correction of, your personal information, you can contact us at hello@owtsmart.com.