Privacy Policy

1. Our Commitment to Privacy

McGen Digital Limited, referred to as “McGen Digital”, “we”, “us” or “our”, respects your privacy and is committed to handling personal information responsibly, transparently and in accordance with the New Zealand Privacy Act 2020.

This Privacy Policy explains how we collect, use, store, process and share personal information when you use our websites, landing pages, advertising campaigns, AI voice agents, communication systems and related services.

We do not sell, rent or on sell personal information to unrelated third parties for their own marketing purposes.

2. Information We Collect

We may collect personal information including:

1. Your name, email address and phone number
2. Your business name, industry and business requirements
3. Information submitted through our forms, landing pages or advertisements
4. Information provided during phone calls, SMS messages, emails, web chats or appointments
5. Call recordings, transcripts and summaries
6. Website activity, page views, clicks, form interactions and device information
7. Advertising and attribution information, including campaign source, gclid, fbclid and similar identifiers
8. Information provided to us by a client, advertising platform, integration partner or other authorised source

We only collect information that is reasonably necessary to respond to enquiries, provide our services, manage campaigns, qualify leads, arrange appointments, maintain security and improve our systems.

3. How We Use Personal Information

We may use personal information to:

1. Respond to your enquiry
2. Contact you by phone, AI generated call, SMS or email
3. Qualify your requirements and arrange appointments
4. Provide lead generation, marketing automation and attribution services
5. Operate landing pages, CRM systems and communication workflows
6. Measure and improve advertising performance
7. Train, test and improve our internal processes, subject to appropriate privacy safeguards
8. Prevent fraud, misuse and security incidents
9. Meet our legal, contractual and regulatory obligations

We will not use personal information for an unrelated purpose unless you have authorised that use or it is otherwise permitted by law.

4. AI Agents and Automated Processing

McGen Digital uses artificial intelligence and automated technologies to communicate with enquiries, qualify leads, schedule appointments, create call summaries and assist with marketing activities.

This may include an AI voice agent called Zac, as well as other AI assistants acting on behalf of McGen Digital or one of our clients.

AI interactions may involve:

1. Automated or AI generated phone calls
2. Voice recognition and voice to text processing
3. Call recording and transcription
4. Conversation summaries
5. Lead qualification and appointment scheduling
6. Automated SMS and email follow up

Where reasonably practical, our AI voice agents will identify themselves as AI assistants.

AI systems can occasionally misunderstand information or produce an incorrect response. Important business, financial or contractual decisions should not be based solely on information provided by an AI agent.

5. Third Party Technology Providers

We use specialist third party platforms to operate our websites, communications, advertising, automation and AI systems.

These providers may include:

1. Vapi
2. n8n
3. Twilio
4. TNZ
5. OpenAI and other AI model providers
6. Voice recognition and voice to text providers
7. Calendly and Cal.com
8. CRM and marketing automation platforms
9. Google, Meta, Microsoft, LinkedIn and TikTok
10. Hosting, analytics, security, payment and email providers

These providers may process personal information on our behalf.

We aim to provide third parties with only the information reasonably required for them to perform their services. We also seek to use appropriate access controls, provider settings and contractual protections where reasonably available.

6. Overseas Storage and Processing

Some of the technology providers we use operate outside New Zealand.

This means personal information, call recordings, transcripts, contact details and system data may be processed, transmitted or stored in countries including Australia, the United States, Singapore, countries within Europe and other locations used by our service providers.

Privacy and data protection laws in those countries may differ from New Zealand law.

Where required, we take reasonable steps to ensure overseas providers are subject to privacy protections that are comparable to those required under the New Zealand Privacy Act 2020.

For a current list of our material technology providers and the locations in which information may be processed, please email john@mcgendigital.com.

Provider locations and infrastructure may change from time to time.

7. Data Protection and Corporate Privacy Concerns

We recognise the major privacy and compliance concerns associated with modern data and AI systems.

These include:

1. Data sovereignty and the country in which information is stored
2. Overseas access to personal information
3. The use of subcontractors and additional technology providers
4. Unauthorised access, cyberattacks and data breaches
5. The retention of call recordings and transcripts
6. The use of information by AI model providers
7. Inaccurate AI generated information
8. Access permissions within connected systems
9. The movement of information between advertising, CRM, communication and AI platforms

We take reasonable technical and organisational measures to reduce these risks. These may include controlled access, password protection, multifactor authentication, limited user permissions, secure system integrations, staff and contractor confidentiality requirements, provider reviews and the removal of information when it is no longer required.

However, no internet based, cloud based or AI based system can be guaranteed to be completely secure.

8. Sharing Personal Information

We may share personal information with:

1. A McGen Digital client where you submitted an enquiry relating to that client
2. Technology providers operating systems on our behalf
3. Contractors who assist us in providing our services
4. Professional advisers, insurers, accountants or legal representatives
5. Government agencies or regulators where required by law
6. A purchaser or successor if our business or part of our business is sold or restructured

We do not sell or on sell personal information to unrelated organisations for their independent marketing purposes.

Anyone who receives information from us is expected to use it only for the purpose for which it was provided.

9. Call Recordings and Transcripts

Phone calls and AI interactions may be recorded, transcribed, summarised and reviewed.

We may use these records for:

1. Responding to your enquiry
2. Confirming information or appointments
3. Quality assurance
4. Staff and system training
5. Compliance and dispute resolution
6. Improving our AI agents and customer experience

Where reasonably practical, you will be informed that a call is being handled by an AI assistant and may be recorded or transcribed.

10. Retention and Deletion

We retain personal information only for as long as it is reasonably required for the purpose for which it was collected or for a related lawful purpose.

You may ask us to delete personal information that we hold about you.

We will take reasonable steps to action your request where the information is no longer required. However, we may retain information where necessary to:

1. Meet legal, tax or accounting requirements
2. Maintain evidence of consent or communications
3. Complete an active service or contract
4. Prevent fraud or misuse
5. Resolve a complaint, dispute or legal claim
6. Protect the rights and security of McGen Digital, our clients or other people

Where information cannot immediately be deleted, we may restrict its use or retain only the information reasonably required.

11. Access and Correction

You may ask us to:

1. Confirm whether we hold personal information about you
2. Provide you with access to that information
3. Correct information that is inaccurate, incomplete or misleading
4. Withdraw consent to marketing communications
5. Request the deletion of information that is no longer required

We may need to verify your identity before processing a privacy request.

To make a request, please email john@mcgendigital.com.

12. Marketing Communications

You can opt out of marketing communications at any time by:

1. Replying STOP to an SMS message
2. Using the unsubscribe link in an email
3. Asking our AI agent or team member to stop contacting you
4. Emailing john@mcgendigital.com

We will take reasonable steps to action your request promptly.

We may still contact you where necessary to respond to an active request, administer an appointment, provide an existing service or meet a legal obligation.

13. Privacy Breaches

If we become aware of a privacy breach, we will assess the nature of the incident, take reasonable steps to contain it and reduce the risk of further harm.

Where a breach has caused, or is likely to cause, serious harm, we will notify the New Zealand Privacy Commissioner and affected individuals as required by law.

14. Privacy Officer and Complaints

Privacy questions, access requests, correction requests, deletion requests and complaints can be sent to our Privacy Officer:

McGen Digital Limited
Email: john@mcgendigital.com

We will investigate privacy concerns and attempt to resolve them fairly and promptly.

You may also make a complaint to the Office of the New Zealand Privacy Commissioner if you believe your personal information has not been handled appropriately.

15. Changes to This Policy

We may update this Privacy Policy to reflect changes to our services, technology providers, AI systems or legal obligations.

The current version will be published on our website with an updated effective date.