ModerateHQ - Privacy Policy

Last updated: 7 July 2026 Effective date: 7 July 2026

This Privacy Policy explains how MODERATEHQ LIMITED (NZBN 9429053731234) ("ModerateHQ", "we", "us") handles personal information. It applies to our website, our customer dashboard, and our content-moderation API (together, the "Service").

We are committed to handling personal information in accordance with the Privacy Act 2020.

1. Two different roles - please read first

ModerateHQ handles two distinct kinds of information, in two different roles:

(a) Information we are responsible for (we are the "agency"). This is information about our customers, their staff who use the dashboard, and visitors to our website - e.g. account and contact details, login identifiers, and billing records.

(b) "Submitted Content" we process on behalf of our customers (we act as their agent). When a customer sends content to the API for moderation, that content - which may include text written by the customer's end users, user identifiers, and conversation history, and which may contain personal information - is processed by us on the customer's behalf and under their instructions. Under section 11 of the Privacy Act 2020, information we hold as an agent is treated as held by the customer (the principal).

If you are an end user of a product or platform that uses ModerateHQ: we do not have a direct relationship with you, and we process your content only on instructions from our customer (the operator of that product). For access, correction, or questions about that content, please contact that operator in the first instance. We will assist our customer to respond as required.

2. Information we collect

As the agency (role (a)):

• Account information - name, work email, organisation name, and the identifier issued by our identity provider (Auth0).
• Billing information - credit purchases, transaction history, and billing metadata. Card payments are processed by Stripe; we do not store full card numbers.
• Usage and technical data - API keys (stored only as a hash), request metadata (timestamps, content type, policy used, verdict, latency), IP address, browser/device data, and dashboard activity.
• Communications - messages you send us (e.g. support requests).
• Website data - cookies and similar technologies (see clause 8).

As agent for our customers (role (b)) - Submitted Content:

• The content submitted for moderation (text, and in future image/audio URLs), capped at 4,000 characters per text request.
• Optional context - platform identifier, channel type, and recent conversation history.
• An optional external user identifier supplied by the customer.
• The moderation result we generate (verdict, confidence, categories, explanation).

We retain the full request and response for each successful moderation as an audit and quality record (see clause 6).

3. How we collect it

We collect information directly from you when you register, use the dashboard, purchase Credits, or contact us; automatically when you use the Service; and, for Submitted Content, from our customers via their API calls. Where we collect personal information from someone other than the individual, our customers are responsible for the lawfulness of that collection (see clause 9).

4. How we use information

We use information to:

• provide, operate, secure, and support the Service (including generating Verdicts);
• authenticate users and protect against fraud, abuse, and security threats;
• process payments and manage Credit balances;
• enforce rate limits and quotas and maintain usage/billing records;
• improve and develop the Service, including testing model and prompt changes against historical requests and producing de-identified / aggregated analytics (we do not use this aggregated data to identify individuals);
• communicate with you about your account, security, and material changes; and
• meet our legal obligations.

We process Submitted Content only to provide the moderation service to the relevant customer and as that customer instructs, plus the limited service-operation and security purposes above.

We do not use Submitted Content to train AI models, and under our model provider's commercial terms (Anthropic) API inputs and outputs are not used to train its models.

5. Who we share it with (subprocessors and disclosures)

We disclose information to service providers who help us run the Service, under contractual confidentiality and security obligations:

We may also disclose information: to comply with the law or a lawful request; to enforce our Terms; to protect the rights, safety, or property of any person, including preserving and reporting suspected illegal material (for example, child sexual abuse material) to law enforcement or other appropriate authorities in New Zealand or elsewhere; and to a successor in connection with a merger, acquisition, or sale of assets (subject to this Policy).

We do not sell personal information.

6. Retention

• Account and billing records are kept while your account is active and afterwards as required for legal, tax, and accounting purposes (in New Zealand, generally 7 years for financial records).
• Submitted Content and moderation results: raw request and response payloads are retained as an audit and quality-assurance record for 30 days by default. Customers can choose a different retention period (from 1 day up to 12 months) in dashboard Settings, or turn content storage off entirely: from that point payloads are not stored at all, and any payloads already stored for the account are deleted immediately. Usage and billing metadata (without content) is retained for as long as needed for the account and legal record-keeping. Longer or bespoke retention and data-residency arrangements are available by written agreement (for example on Enterprise terms).
• Account deletion: customers can close their account in dashboard Settings. After a 30-day grace period (during which the deletion can be cancelled), we permanently delete the account's moderation records, API keys, and account details, and confirm by email. An anonymised record of credit purchases and usage counts, which no longer identifies anyone, is kept for the financial record-keeping period above.
• We delete or de-identify personal information when it is no longer needed for a lawful purpose.

7. Storage and security

We take reasonable steps to protect personal information against loss, unauthorised access, use, modification, or disclosure, including encryption in transit (TLS); API keys stored only as hashes, never in plaintext; encryption at rest provided by our managed database host; secrets held in managed secret stores rather than source code; least-privilege access to production systems; and application logging. No system is perfectly secure; we cannot guarantee absolute security. If a privacy breach occurs that is likely to cause serious harm, we will notify the Office of the Privacy Commissioner and affected individuals as required by Part 6 of the Privacy Act 2020.

8. Cookies and the website

Our dashboard uses cookies that are necessary for sign-in and session management (including via Auth0). We do not use advertising cookies, and our analytics sets no cookies at all: the website uses Vercel Web Analytics, a cookieless service that gives us aggregated statistics about site visits (such as page views, referrers, and country). It does not place anything on your device, and visitors are not identified or tracked across sites. You can control cookies through your browser, but disabling necessary cookies may prevent you from logging in.

9. Your responsibilities as a customer

If you are a ModerateHQ customer, you are responsible for ensuring you have the right to collect end-user content and to disclose it to us and our overseas subprocessors, and for giving your end users any required privacy notices and choices. We provide the tools; lawful collection and onward use of your end users' information is your responsibility (see Terms, clauses 4.2 and 12.3).

10. Overseas disclosure

As shown in clause 5, providing the Service involves disclosing information outside New Zealand, including to the United States. Where we disclose personal information overseas, we take steps consistent with IPP 12 to ensure appropriate safeguards (for example, contractual protections with subprocessors). By using the Service, customers authorise this disclosure and are responsible for any consents required from their end users.

11. Accessing and correcting your information

If we hold personal information about you (role (a)), you may request access to it or ask us to correct it (IPPs 6 and 7). Contact us using clause 13. We may need to verify your identity, and some requests may be subject to lawful exceptions. There is generally no charge, though we may charge a reasonable cost for certain requests as permitted by law. Customers can also delete their account and the personal information it holds at any time (see clause 6).

For Submitted Content (role (b)), because we hold it as our customer's agent, please direct access/correction requests to the relevant customer; we will assist them to respond.

12. Children

The Service is a business-to-business product not directed to children, and customers must not use the dashboard if under 16. Submitted Content may relate to end users of any age depending on our customer's platform; lawful handling of any such information is the customer's responsibility.

13. Contact us and complaints

Our Privacy Officer can be contacted at:

• Email: privacy@moderatehq.com

If you have a privacy concern, please contact us first and we will try to resolve it. You also have the right to complain to the Office of the Privacy Commissioner (New Zealand): privacy.org.nz · 0800 803 909.

14. Changes to this Policy

We may update this Policy from time to time. The "Last updated" date shows the current version, and we will give notice of material changes (e.g. by email or dashboard notice).