Legal

Privacy Policy

Effective: 11 February 2025 Jurisdiction: New Zealand

Waka Research Ltd ("we", "us", "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, disclose, and protect personal information in accordance with the New Zealand Privacy Act 2020 and its thirteen Information Privacy Principles (IPPs).

This policy applies to all personal information collected through our website (https://wakaresearch.com), our communications, and any services we provide.

1.1 Who We Are

Waka Research Ltd is a New Zealand–registered research and development company specialising in orbital sensing, autonomous robotics, and artificial intelligence. We are headquartered in New Zealand with research operations spanning multiple jurisdictions.

1.2 Information We Collect

We may collect the following categories of personal information:

Information You Provide Directly

• Name, email address, phone number, and organisation details when you contact us, subscribe to our communications, or enquire about our services.
• Professional information including job title, company, and area of interest when you engage with our research or partnership programmes.
• Any other information you voluntarily provide through forms, emails, or correspondence.

Information Collected Automatically

• Technical data such as IP address, browser type and version, time zone setting, operating system, and platform.
• Usage data including pages visited, time spent on pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
• Cookie and tracking data as described in our Cookie Policy.

Information from Third Parties

We may receive information about you from third parties including business partners, analytics providers, and publicly available sources, but only where we have a lawful purpose for doing so.

1.3 Purpose of Collection (IPP 1–3)

We collect personal information only for lawful purposes connected with our functions and activities. Specifically, we use your information to:

• Respond to your enquiries and provide information about our research and services.
• Communicate with you about our projects, publications, events, and developments.
• Manage and improve our website, services, and user experience.
• Comply with legal and regulatory obligations.
• Protect our legitimate business interests, including security and fraud prevention.
• Facilitate potential partnerships, collaborations, and investment opportunities.

At or before the time of collection, we will take reasonable steps to ensure you are aware of the fact and purpose of collection, the intended recipients, and your rights of access and correction.

1.4 How We Use Your Information (IPP 10–11)

We will only use or disclose your personal information for the purpose for which it was collected, or a directly related purpose that you would reasonably expect. We will not use or disclose your information for any other purpose without your consent, unless an exception under the Privacy Act 2020 applies, such as:

• Where the use or disclosure is authorised by law.
• Where it is necessary to prevent or lessen a serious threat to public health or safety.
• For the maintenance of the law, including the prevention, detection, investigation, prosecution, and punishment of offences.

1.5 Storage and Security (IPP 5)

We take reasonable steps to protect personal information from loss, unauthorised access, use, modification, disclosure, or other misuse. Our security measures include:

• Encryption of data in transit and at rest where appropriate.
• Access controls limiting personal information access to authorised personnel only.
• Regular security assessments and updates to our systems.
• Secure hosting infrastructure with reputable service providers.

We retain personal information only for as long as it is needed for the purposes for which it was collected, or as required by law. When personal information is no longer needed, we will securely destroy or de-identify it (IPP 9).

1.6 Disclosure to Third Parties

We may share your personal information with:

• Service providers who assist us in operating our website and conducting our business (e.g., hosting providers, analytics services, email platforms), under strict confidentiality obligations.
• Professional advisors including lawyers, accountants, and auditors.
• Government agencies or regulators where required by law.
• Research collaborators and partners, but only with your knowledge and where relevant to the purpose of collection.

We do not sell, rent, or trade your personal information to third parties for marketing purposes.

1.7 Cross-Border Disclosure (IPP 12)

As an international research organisation, we may transfer personal information to recipients outside New Zealand (including but not limited to Türkiye and other jurisdictions where our operations or partners are based). Before doing so, we will take reasonable steps to ensure the recipient is subject to comparable privacy safeguards, in accordance with IPP 12 of the Privacy Act 2020, including:

• Ensuring the recipient is subject to privacy laws providing comparable protections.
• Requiring the recipient to contractually agree to protect the information in a manner consistent with New Zealand privacy standards.
• Obtaining your express consent where the above safeguards cannot be met.

1.8 Your Rights

Under the Privacy Act 2020, you have the right to:

Access (IPP 6) — Request access to the personal information we hold about you. We will respond to your request within 20 working days.

Correction (IPP 7) — Request correction of any personal information that is inaccurate, incomplete, or misleading. If we do not agree that correction is required, you may request that we attach a statement of the correction sought.

Complaints — If you believe we have breached the Privacy Act 2020, you may lodge a complaint with us at hi@wakaresearch.com. If you are not satisfied with our response, you may refer your complaint to the Office of the Privacy Commissioner.

1.9 Notifiable Privacy Breaches

In the event of a privacy breach that is likely to cause serious harm to affected individuals, we will notify the Office of the Privacy Commissioner and the affected individuals as soon as practicable, in accordance with Part 6 of the Privacy Act 2020.

1.10 Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies. For detailed information about the cookies we use and your choices, please refer to our Cookie Policy.

1.11 Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites. We encourage you to read the privacy policies of any third-party site you visit.

1.12 Children's Privacy

Our website and services are not directed at individuals under the age of 16. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child without appropriate consent, we will take steps to delete that information.

1.13 Artificial Intelligence and Automated Decision-Making

As a company specialising in artificial intelligence research, we are transparent about our use of AI technologies. Where our services involve automated processing of personal information or automated decision-making, we will inform you of this and provide meaningful information about the logic involved. We are committed to responsible AI practices consistent with the Privacy Commissioner's guidance on AI and privacy (September 2023).

1.14 Data Retention

We retain personal information in accordance with the following principles:

• Contact and enquiry data: Retained for the duration of the business relationship plus two years, unless a longer period is required by law.
• Website analytics data: Retained in anonymised/aggregated form. Individual-level data is deleted within 26 months.
• Contractual and partnership records: Retained for seven years after the end of the relationship, in accordance with New Zealand tax and commercial obligations.

If you request deletion of your data, we will do so promptly unless retention is required by law.

1.15 Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date. We encourage you to review this policy periodically. Continued use of our website after changes constitutes acceptance of the updated policy.