Celecom legal

Privacy policy

Celecom helps people remember occasions and send greetings, drawings, photos, stamps and, when offered, gifts. This policy explains what information Celecom collects, why we use it, when it may be shared, and the choices available to you.

In this policy, Celecom, we, us and our mean CELECOM LIMITED, a New Zealand limited company (company number 9349712, NZBN 9429052914676), with its registered office at Celecom, Flat 2, 11a Arcadia Road, Epsom, Auckland 1023, New Zealand. The service includes celecom.net, its web application, future Celecom mobile applications, emails we send, and related services that link to this policy.

1. Our privacy commitments

• We do not sell or broker personal information.
• We do not give a gift buyer a recipient's private sizes, preferences or other profile details. Where matching features are introduced, Celecom may apply those details on the recipient's behalf without revealing them to the buyer.
• We do not currently use third-party advertising trackers or general website analytics SDKs.
• We minimise the information we ask for and use it for stated purposes.
• Photos uploaded through the current web application are resized and re-encoded before upload. This also removes embedded EXIF metadata, including GPS coordinates.
• We use automated tools to assist people and moderators, but an automated content check does not make the final enforcement decision by itself.

2. Information we collect

2.1 Account and profile information

Depending on how you use Celecom, this can include:

• name, username, email address and phone number;
• password and authentication records managed by Amazon Cognito. Celecom does not store your plain-text account password in its application database;
• profile photo, biography, birthday, locale and time zone;
• business-account status, notification choices and reminder lead time;
• identity information supplied by Google when you choose Google sign-in, such as your Google account identifier, name, email address and available profile photo; and
• account verification, onboarding stage and account status.

2.2 People and occasions you add

Celecom lets an account holder create a managed profile for another person, a child, a pet, a place or a group. Information can include a name, photo, relationship, birthday, interests, description, species or place details.

Occasion information can include the occasion type, title, date, time, description, recipient, organiser, privacy setting, followers, allowed forms of participation, cover artwork, delivery zone and, if physical fulfilment is introduced, a delivery address.

Some occasion types can reveal sensitive facts, such as health, pregnancy, bereavement, religion or information about a child. We will not use those facts for advertising targeting. Features that infer or use sensitive information must have an appropriate legal basis and additional safeguards before release.

2.3 Greetings, parcels and creative content

This can include:

• recipient name and contact details supplied for delivery;
• message, salutation, closing and sign-off;
• photos, captions, drawings, signatures and drawing stroke data used to replay a drawing;
• stationery, colour, music, effects and layout choices;
• stamp and occasion references;
• seal date, time zone and locale;
• an optional parcel question hint and a salted cryptographic hash of the answer. We do not store the answer itself; and
• send, delivery, open, thank-you and unlock-attempt records.

A recipient does not need an account to open a greeting link. Anyone who has the private link may be able to open the parcel after its seal conditions are met, so recipients and senders should treat the link like a private letter.

2.4 Social and activity information

This can include accounts and occasions you follow, muted occasions, saved recipients, stamps you create or receive, stamp visibility and likes, content reports, notifications, reminder consent, unsubscribe state and interactions needed to provide the feature.

We record a parcel open and the minimum interaction information needed for the service, such as whether a delivery or action succeeded. Celecom's current email design does not use an invisible email-open tracking pixel. A link click may be recorded when it is necessary to complete the requested action and preserve a working link.

2.5 Communications and support

If you contact us, report content or request help, we collect the information in your message and the records needed to investigate and respond. Administrative and moderation records can include the action taken, the reason, the responsible administrator and a timestamp.

2.6 Technical information

Our infrastructure and security providers necessarily process information such as request time, service endpoint, authentication token metadata, error details and network information, which can include an IP address in infrastructure logs. Celecom does not currently build advertising profiles from IP addresses, use device fingerprinting, or intentionally store an IP address in its product database.

The web application uses browser local storage for authentication sessions, unfinished signup or event intent, unsent drawing recovery, sound preference and limited interface state. These are functional storage items, not advertising cookies. Clearing site data or signing out can remove some of them.

2.7 Information from other people

A sender or organiser may give us information about a recipient who does not have a Celecom account, including their name, birthday, email address, phone number or photo. We use it to provide the requested occasion, greeting or delivery feature. We do not use a non-member recipient address for unrelated marketing.

Where law requires it, we will provide or enable an appropriate notice to a person whose information was supplied by someone else. A person may contact us to ask what we hold about them and to request access, correction or deletion.

2.8 Early access requests

If you ask to join Celecom through the Early Access form on our website, we keep the email address you enter, your first name if you give it, and whether Celecom is for you or for an organisation. For an organisation, we also keep its name, your role and its size, if you give them. We record when you asked and which button on the page you used.

We use this to invite you to Celecom, to send you one confirmation email, and to understand who is asking. A copy of each new request goes to our team inbox so we can answer you. We do not keep your IP address. To stop the form being misused, we keep a scrambled code made from it, which changes every day and is deleted after a day.

To be taken off the list, reply to the confirmation email or write to hello@celecom.net.

3. Why we use information

We use personal information to:

1. create, authenticate, secure and support accounts;
2. provide profiles, occasions, follows, reminders, greetings, stamps, music, effects and delivery;
3. enforce an occasion's visibility and a parcel's seal or optional question;
4. send transactional messages requested by a user, including verification, parcel delivery, occasion reminders and service notices;
5. remember notification choices and honour unsubscribe requests;
6. personalise the service and, if introduced with the required controls, recommend relevant gifts or content;
7. generate optional writing, drawing, speech or occasion artwork when a user asks us to;
8. detect abuse, screen public images, investigate reports and protect users and the service;
9. diagnose errors, monitor reliability and maintain security;
10. comply with law, respond to lawful requests, establish or defend legal claims and keep required business records; and
11. create aggregated or de-identified statistics that are not reasonably capable of identifying a person.

For people in the European Economic Area or United Kingdom, the legal basis will depend on the activity. It may be performance of our contract, our legitimate interests in operating and securing the service, compliance with law, protection of vital interests, or consent where consent is required. We do not rely on consent where it cannot be freely refused or withdrawn.

4. AI-assisted features

Celecom currently uses OpenAI services for optional greeting suggestions, drawing generation, speech generation, occasion artwork and image moderation. Depending on the feature, the information sent can include:

• a greeting draft, recipient first name, relationship, occasion, tone and timing context;
• a drawing prompt, occasion name and orientation;
• greeting text, sender name and salutation for speech generation;
• an image URL for moderation; or
• an administrator's occasion-art prompt.

Do not place unnecessary sensitive information in an AI prompt. We return the generated result for the user to review or use. Image moderation may approve an image or refer it to a person, but it does not automatically reject or punish an account by itself.

Celecom does not currently make a solely automated decision that produces a legal or similarly significant effect on a user.

5. When we disclose information

We disclose information only as needed for the purposes above:

• People you choose to share with. Profile, occasion, greeting, stamp or participation information is shown according to the audience you select and the design of the feature. Public profiles or occasions may be visible beyond your followers. A private greeting is available to the holder of its link.
• Recipients and organisers. Information required to identify a sender, recipient, organiser, participant or delivery can be shown to the relevant people. Private recipient preferences are not disclosed to gift buyers.
• Amazon Web Services. AWS provides Cognito authentication, S3 media and audio storage, Aurora PostgreSQL databases, AppSync, Lambda, email delivery, secrets management and operational logging. Core production infrastructure is configured in the Asia Pacific (Sydney) region, Australia.
• Google. Google receives information when a person chooses Google sign-in. Google Places may process an address search if that address suggestion provider is enabled. If it is not enabled, the Photon geocoder operated by Komoot receives the address search text instead.
• OpenAI. OpenAI processes the content described in section 4 when a person or administrator invokes an AI-assisted feature, or when a public image is screened.
• Email and delivery participants. Email providers, mobile carriers and the recipient's chosen communication service process an address and message as necessary to deliver it.
• Licensed content providers. Celecom currently imports approved music into Celecom-controlled storage. The recipient does not need to contact Pixabay to play an imported track.
• Professional advisers and authorities. We may disclose information to advisers, insurers, auditors, courts, regulators, law enforcement or another person where reasonably necessary and legally permitted.
• Corporate events. If an organisation uses Celecom, authorised organisers may see event-level participation and operational information described at collection. We will not give an employer the private content of a personal greeting merely because the greeting relates to a workplace event.
• Business changes. Information may be disclosed under confidentiality in a merger, financing, acquisition, reorganisation or sale of assets, subject to applicable law and continued protection.

We do not include a provider in this list merely because we may use it later. Payment processors, gift vendors, mobile app stores and advertising partners must be added to this policy before the corresponding feature goes live.

6. Public content and private links

You control whether an occasion or stamp is public, follower-only, selected or private where the product offers that choice. Public content can be copied, indexed, saved or reshared by other people. Changing a setting may limit future access but cannot retrieve copies already made by others.

User-uploaded media is currently served from publicly readable object URLs so it can appear on event cards and greeting links. The application uses long, unpredictable paths for private parcel assets, but the storage URL itself is not an authentication boundary. This architecture must be replaced with controlled delivery before Celecom claims that every media object is access-controlled.

7. International processing

Celecom is established in New Zealand and offers its digital service to people in multiple countries. Its main production systems are in Australia. Some providers or their support teams may process information in other countries, particularly the United States and locations used by Google and OpenAI. Provider locations and support arrangements can change. Contact us for current information about a particular provider or transfer.

Where cross-border privacy rules apply, we use appropriate contractual and organisational safeguards and assess the recipient or provider. You may contact us for more information about the safeguards used for a particular transfer.

8. Retention

We keep personal information only for as long as it is needed for the purpose for which it was collected, to operate shared history safely, to resolve a dispute, or to meet legal obligations.

We determine retention periods by considering the purpose, the expectations of the people involved, shared-history needs, security, disputes and legal obligations. This assessment covers:

• unconfirmed signups and abandoned drafts;
• sent and opened parcels;
• user uploads and replaced profile photos;
• unlock attempts, operational logs and moderation records;
• notification and delivery records;
• consent and unsubscribe evidence;
• deactivated accounts and managed profiles; and
• transaction and tax records if paid gifts are introduced.

Cancelling an occasion does not automatically erase greetings already sent by other people. We may retain a limited shared-history record while removing the cancelled occasion from discovery and stopping new activity. Where erasure is required, we will delete or de-identify information unless it must be retained for another lawful reason.

9. Security

We use measures appropriate to the nature of the information, including encrypted transport, cloud access controls, temporary upload credentials, segregated user upload paths, salted password-answer hashing, rate limiting, administrative access controls and audit records.

No online service is completely secure. Keep your account password and private parcel links confidential. Tell us promptly if you believe an account or link has been compromised.

10. Your choices and rights

Depending on your location and the circumstances, you may have rights to:

• know whether we hold personal information about you;
• request access to, or a portable copy of, your information;
• request correction of inaccurate or incomplete information;
• request deletion or de-identification;
• object to or restrict certain processing;
• withdraw consent without affecting earlier lawful processing;
• unsubscribe from non-essential messages and change notification choices;
• complain to us or an applicable privacy regulator; and
• receive information about significant automated decisions if Celecom introduces them in the future.

Profile, visibility and notification details can be changed in the service. The privacy choices centre lets an account holder download a machine-readable copy of information tied to their account, request correction and initiate account deletion. We may need to verify your identity and consider the privacy rights of other people before responding. We aim to respond within 30 days, or within any shorter period required by law.

A deletion request does not mean every record can be removed immediately. Celecom may retain or de-identify limited information where needed for another person's rights, signed stamp provenance, security, dispute handling, legal obligations or backup restoration safeguards. The request record will state what was done and explain material information that must be retained.

Australian users may complain to the Office of the Australian Information Commissioner after first giving us a reasonable opportunity to respond. New Zealand users may complain to the Office of the Privacy Commissioner. Other users may contact their local supervisory authority.

11. Children and managed profiles

Celecom supports profiles managed by an adult for a child, pet or other person. A managed profile is not automatically an account for the person it describes. The manager must have authority to provide the information and must use appropriate privacy settings.

You must be at least 16 to create an independent Celecom account. A person under 16 must not create an account. An adult may create and manage a profile about a person under 16 only where the adult is their parent, legal guardian or is otherwise authorised to do so. A managed profile is not an independent account and must use privacy settings appropriate for the person concerned.

Celecom does not direct independent accounts to children under 16. We will use age-appropriate information and safeguards where a feature involves a person under 18, and we will not use children's information for behavioural advertising. If we learn that an independent account is held by a person under 16, we may restrict or close it and work with an authorised adult where appropriate.

12. Email and notifications

We send account and service messages necessary to provide Celecom. A sender can also ask us to deliver a parcel to a recipient. We do not treat a sender's address book or a one-off delivery address as permission for unrelated marketing.

Where a non-member chooses occasion reminders, we store the exact wording they accepted, the occasion, time and withdrawal state. Each consent applies only to that occasion. Eligible messages contain sender identification and an unsubscribe method as required by law.

13. Changes to this policy

We may update this policy as Celecom changes or laws evolve. Administrative, clarifying or other non-material changes may take effect when the updated policy and effective date are posted, without individual notice. If a change materially affects how we use personal information or a person's rights, we will provide reasonable notice and seek consent where required by law. A new policy does not remove rights that have already accrued.

14. Contact us

Privacy Officer, CELECOM LIMITED

Company number 9349712, NZBN 9429052914676

Celecom, Flat 2, 11a Arcadia Road, Epsom, Auckland 1023, New Zealand

hello@celecom.net

Please include enough information for us to identify the account or record and explain what you are requesting. Do not send account passwords or a parcel's secret answer by email.