Privacy Policy

Last updated: September 24, 2025

1. About This Privacy Policy

1.1 This Privacy Policy explains how Finlayconn Ventures Limited (trading as "Unicorn Factory") collects, uses, stores, and protects your personal information when you use our freelancer discovery platform. This policy complies with the Privacy Act 2020 (New Zealand) and other applicable privacy laws.

1.2 By using our platform, you agree to the collection and use of information as described in this Privacy Policy. This Privacy Policy should be read together with our Terms of Service.

1.3 We are committed to protecting your privacy and handling your personal information responsibly and transparently.

2. Information We Collect

2.1 We collect information that you provide directly to us, information collected automatically through your use of our platform, and information from third-party sources.

2.2 Personal Information You Provide:

  • Contact details (name, email address, phone number)
  • Profile information (skills, experience, portfolio items, business description)
  • Communication content (inquiry messages, support requests)
  • Account credentials and preferences
  • Payment information for premium services (processed by third-party providers)
  • Any other information you choose to provide

2.3 Information Collected Automatically:

  • Device information (IP address, browser type, operating system)
  • Usage data (pages visited, time spent, click patterns, search terms)
  • Location information (general geographic location based on IP address)
  • Cookies and tracking technologies data
  • Referral source information

2.4 Information from Third Parties:

  • Social media profile information (if you connect social accounts)
  • Analytics data from our service providers
  • Marketing and advertising platform data
  • Public business information for verification purposes

3. How We Use Your Information

3.1 We use your personal information for the following purposes:

3.2 Platform Services:

  • Provide and maintain our discovery platform
  • Facilitate contact between clients and freelancers
  • Process account registrations and premium subscriptions
  • Provide customer support and respond to inquiries
  • Verify identity and prevent fraud

3.3 Communication:

  • Send service-related notifications and updates
  • Deliver marketing communications (with your consent)
  • Respond to your questions and requests
  • Send platform updates and policy changes

3.4 Analytics and Improvement:

  • Analyze platform usage and performance
  • Improve our services and user experience
  • Conduct research and development
  • Generate statistical insights (anonymized)

3.5 Marketing and Advertising:

  • Display personalized advertisements
  • Conduct remarketing campaigns
  • Measure advertising effectiveness
  • Promote our services on social media and other platforms

3.6 Legal and Business Operations:

  • Comply with legal obligations and court orders
  • Protect our rights and prevent misuse
  • Conduct business transactions (mergers, acquisitions)
  • Maintain records for regulatory compliance

4. Legal Basis for Processing (Privacy Act 2020)

4.1 We process your personal information based on the following lawful grounds:

4.2 Consent: You have given clear consent for processing your personal information for specific purposes (e.g., marketing communications, cookies).

4.3 Contract Performance: Processing is necessary to provide our platform services and fulfill our contractual obligations to you.

4.4 Legitimate Interests: Processing serves our legitimate business interests (e.g., platform improvement, fraud prevention) while considering your privacy rights.

4.5 Legal Compliance: Processing is required to comply with New Zealand laws and regulations or court orders.

5. Information Sharing and Disclosure

5.1 We share your personal information in the following circumstances:

5.2 Freelancer Discovery: Client inquiry information is shared with relevant freelancers to facilitate initial contact and service discovery.

5.3 Service Providers: We share information with trusted third-party service providers who help us operate our platform, including:

  • Webflow: Website hosting and content management
  • Google Analytics: Website analytics and performance monitoring
  • Airtable: Database management and record keeping
  • Make.com: Workflow automation and integrations
  • Glide Apps: Mobile application functionality
  • MailerSend & MailerLite: Email delivery and marketing communications
  • OpenAI, Anthropic, Perplexity: AI-powered features and customer support

5.4 Advertising Partners: We share information with advertising and marketing platforms:

  • Google Ads: Advertising campaigns and remarketing
  • Facebook/Meta: Social media advertising and analytics
  • Instagram: Social media marketing and engagement

5.5 Business Transfers: Information may be shared during mergers, acquisitions, or other business transactions.

5.6 Legal Requirements: We may disclose information to comply with laws, court orders, or protect our rights and safety.

5.7 With Your Consent: We may share information for other purposes with your explicit consent.

6. Cookies and Tracking Technologies

6.1 We use cookies, web beacons, and similar tracking technologies to enhance your experience and analyze platform usage.

6.2 Types of Cookies We Use:

  • Essential Cookies: Required for platform functionality and security
  • Analytics Cookies: Help us understand how users interact with our platform
  • Marketing Cookies: Enable personalized advertising and remarketing
  • Preference Cookies: Remember your settings and preferences

6.3 Third-Party Cookies: Our service providers may place their own cookies for analytics, advertising, and functionality purposes.

6.4 Managing Cookies: You can control cookie settings through your browser preferences. However, disabling certain cookies may limit platform functionality.

6.5 Remarketing: We use Facebook Pixel, Google Ads remarketing, and similar technologies to show relevant advertisements across the internet.

7. Data Security and Protection

7.1 We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction.

7.2 Security Measures Include:

  • Encryption of data in transit and at rest
  • Access controls and authentication systems
  • Regular security audits and monitoring
  • Staff training on privacy and security practices
  • Secure data storage with reputable service providers

7.3 Data Breach Response: In the event of a data breach, we will notify affected individuals and relevant authorities as required by the Privacy Act 2020.

7.4 Limitations: No method of transmission or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

8. Data Retention and Deletion

8.1 We retain personal information only as long as necessary for the purposes outlined in this policy or as required by law.

8.2 Retention Periods:

  • Account Information: Retained while your account is active and for 7 years after closure for legal compliance
  • Contact Inquiries: Retained for 3 years to facilitate business relationships and support
  • Analytics Data: Aggregated data retained indefinitely; individual data retained for 2 years
  • Marketing Data: Retained until you unsubscribe or for 5 years, whichever is sooner
  • Support Communications: Retained for 5 years for service improvement and legal purposes

8.3 Secure Deletion: When retention periods expire, we securely delete or anonymize personal information using industry-standard methods.

9. Your Privacy Rights

9.1 Under the Privacy Act 2020, you have the following rights regarding your personal information:

9.2 Right of Access: Request access to personal information we hold about you, including details about how it's used and shared.

9.3 Right of Correction: Request correction of inaccurate or incomplete personal information.

9.4 Right of Deletion: Request deletion of your personal information in certain circumstances.

9.5 Right to Object: Object to processing of your personal information for direct marketing purposes.

9.6 Right to Portability: Request transfer of your personal information in a structured, commonly used format.

9.7 Right to Withdraw Consent: Withdraw consent for processing based on consent (this may limit service availability).

9.8 Exercising Your Rights: Contact us at community@unicornfactory.nz to exercise these rights. We will respond within 20 working days as required by law.

10. International Data Transfers

10.1 Some of our service providers are located outside New Zealand, which means your personal information may be transferred to and processed in other countries.

10.2 Countries Where Data May Be Processed:

  • United States (Google, Facebook, OpenAI, Anthropic, various cloud providers)
  • Europe (some hosting and analytics services)
  • Australia (regional data processing)

10.3 Transfer Safeguards: We ensure international transfers comply with Privacy Act 2020 requirements and that recipient countries provide adequate protection for personal information.

10.4 Service Provider Agreements: Our contracts with international service providers include appropriate privacy and security obligations.

11. Marketing Communications

11.1 We may send you marketing communications about our services, platform updates, and relevant industry information.

11.2 Consent: Marketing emails are sent only with your consent, typically obtained during account registration or through explicit opt-in.

11.3 Opt-Out: You can unsubscribe from marketing communications at any time by:

11.4 Service Communications: Important service-related communications (security updates, policy changes) may still be sent even if you opt out of marketing.

12. Children's Privacy

12.1 Our platform is not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18.

12.2 If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly.

12.3 Parents or guardians who believe their child has provided personal information to us should contact community@unicornfactory.nz.

13. Changes to This Privacy Policy

13.1 We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or business operations.

13.2 Notice of Changes: We will provide at least 30 days' notice of material changes via email and prominent platform notice.

13.3 Effective Date: Changes take effect on the date specified in the updated policy. Continued use of our platform after changes indicates acceptance.

13.4 Policy Versions: We maintain records of previous policy versions. The current version supersedes all previous versions.

14. Contact Information and Complaints

14.1 Privacy Officer Contact:

14.2 Response Times: We acknowledge privacy inquiries within 5 business days and aim to resolve issues within 20 working days as required by the Privacy Act 2020.

14.3 External Complaints: If you're not satisfied with our response, you may lodge a complaint with the Privacy Commissioner:

14.4 Company Information:

  • Legal Entity: Finlayconn Ventures Limited
  • Company Number: 5969335
  • Trading Name: Unicorn Factory
  • Website: unicornfactory.nz

This Privacy Policy is designed to help you understand how we collect, use, and protect your personal information. We are committed to maintaining your trust through transparent and responsible data practices.

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