Privacy Policy

1. Who we are and what this covers

Manawanui Ventures Ltd, trading as Selph ("Selph", "we", "us", "our"), is an independent skin advisory service based in New Zealand. We produce personalised Skin Strategy Reports from information you provide. We do not sell products, earn commissions, or own a clinic.

This policy explains what personal information we collect, why, how we handle and protect it, who helps us process it, how long we keep it, and the rights you have. It is written to align with the New Zealand Privacy Act 2020 and its Information Privacy Principles (IPPs). By using selph.nz and submitting information to us, you agree to the handling of your information as described here.

Privacy contact: hello@selph.nz · Manawanui Ventures Ltd, trading as Selph, New Zealand.

2. The information we collect

To prepare your report, we collect only what we need:

• Questionnaire responses — your skin history, concerns, current products and routine, lifestyle factors, and hormonal history. Some of this is information about your skin and general health, which we treat as sensitive information and handle with extra care.
• Photos (optional) — clear images of your skin, only if you choose to provide them. You are never required to.
• Contact details — your name and email address, so we can deliver your report and respond to you.
• Payment information — handled directly by our payment provider (Stripe). We do not receive or store your full card details; we receive only confirmation of payment and limited transaction information.
• Basic technical information — standard website and form data such as device or browser type, used only to operate and secure the service.

We practise data minimisation: we do not ask for more than the report requires, and we do not use your information for any purpose beyond those set out in Section 4.

3. Consent — how we rely on it

You provide your information voluntarily. When you complete the questionnaire and submit it, you consent to Selph collecting and using that information to prepare and deliver your report, as described in this policy.

• You choose whether to provide photos. If you do, you consent to them being used solely to prepare your report.
• You may withdraw your consent at any time by contacting us (see Section 8). Withdrawal does not affect anything already done with your information before you withdrew, and may mean we can no longer complete or deliver your report.

4. Why we collect it and how we use it

We use your information only to:

• generate the personalised guidance, priorities, and recommendations in your Skin Strategy Report;
• deliver your report and respond to questions about it;
• operate, secure, and support the service while we prepare and deliver your report; and
• meet our legal, tax, and accounting obligations.

A Progress Review, if you choose to purchase one in future, is a fresh, standalone assessment. It is not a comparison against information we have stored, because we do not store your earlier information (see Section 6).

We do not sell your information. We do not use it for advertising or marketing to you without your separate consent. We do not share it with skincare brands, clinics, or any other party for their own purposes.

5. The service providers who help us deliver the service

Selph is a small, independent service. To run it, we rely on a limited number of trusted technology providers ("processors") who handle data strictly on our instructions and only to provide their service to us. They currently include:

Provider	What it does	Where it processes data
Tally	Hosts the questionnaire form you complete	European Union
Make.com	Moves your submission securely through our automated workflow	European Union / United States
Anthropic (Claude API)	Applies the Selph clinical framework to generate your report	United States
Google (Drive / Workspace)	Securely stores submissions and generated reports	United States
Stripe	Processes your payment	United States / global

Because some of these providers are based overseas, your information may be processed outside New Zealand. Before relying on an overseas provider, we take reasonable steps to satisfy ourselves that it protects your information to standards comparable to the New Zealand Privacy Act. This is consistent with Information Privacy Principle 12. We keep each provider's data-processing terms on file.

6. How long we keep your information

We keep your information only for as long as we need it to prepare and deliver your report, then we securely delete it. We do not retain your information for future comparison.

• Your photos and questionnaire responses: deleted as soon as your report has been successfully generated. This applies at all times, with no exception, including during the beta period described below.
• The report we generate: held for up to 48 hours after it is delivered, then deleted. This short window exists only so we can re-send your report if a delivery problem arises — except during Selph's current beta period, described immediately below.
• Payment and transaction records: kept for 7 years, because New Zealand tax and accounting law requires it. They do not include your full card details, questionnaire content, or photos.

Selph's current beta period. While Selph is in beta, our founder — a qualified dermal therapist — personally reviews a sample of generated reports to check and improve the quality of Selph's guidance before wider launch. During this period only, we retain the finished report itself for longer than the standard 48 hours, so this review can take place. This exception applies only to the finished report — never to your original photos or questionnaire responses, which are deleted as soon as your report is generated regardless of beta status. Reports retained for this purpose are accessed only by Selph's founder, used only for quality review, and kept only until [TO BE CONFIRMED — Linda to set a concrete end date or trigger, e.g. a fixed date or "beta period ends" milestone]. You can still request early deletion of your retained report at any time by emailing hello@selph.nz (see Section 8). We expect to move fully to the standard 48-hour schedule once this review period ends, and will update this policy when that happens.

We follow the schedule above for every client, whether carried out through automated systems or manually by our team, so the timing applies regardless of how the deletion is performed, other than the disclosed beta exception above.

In plain terms: your photos and questionnaire answers are never kept beyond report generation, beta or not. During beta only, the finished report itself is kept a little longer than usual so we can check the quality of what we sent you — and you can ask us to delete it early at any time.

7. How we protect your information, and what happens if something goes wrong

We take reasonable technical and organisational steps to keep your information secure, including limiting access to those who need it, using reputable providers with their own security controls, and transmitting data over encrypted connections. No online service can guarantee absolute security, but we treat your information — especially your photos and health-related detail — with appropriate care.

Privacy breaches. If a privacy breach occurs that is likely to cause you serious harm, we will notify you and the Office of the Privacy Commissioner as soon as practicable, in line with the notifiable-breach requirements of the Privacy Act 2020.

8. Your rights and choices

Under the Privacy Act 2020 you have the right to:

• Access the personal information we hold about you;
• Correct it if it is wrong or out of date;
• Request deletion of your information, including your photos. Your photos and answers are deleted as soon as your report is generated — always, with no exception. The report itself is deleted within 48 hours of delivery, except during Selph's current beta period (see Section 6), during which you can still request early deletion of your retained report at any time. The only information kept beyond these windows is payment records, kept for 7 years;
• Withdraw from the service and ask us to stop processing your information.

To exercise any of these, email hello@selph.nz. We will respond within the timeframe set by the Privacy Act (generally 20 working days). There is normally no charge.

If you are not satisfied with how we have handled your information or a request, you may complain to the Office of the Privacy Commissioner — privacy.org.nz, 0800 803 909.

9. This is guidance, not medical care

Selph provides general, educational skin guidance. It is not a medical diagnosis, a medical service, or a substitute for professional medical advice, and using Selph does not create a clinician–patient relationship. The limits of the service are set out in full in our Terms of Service and Medical Disclaimer.

10. Who can use Selph

Selph is intended for adults aged 18 and over. We do not knowingly collect information from anyone under 18. If you believe a minor has provided us with information, contact us and we will delete it.

11. Changes to this policy

We may update this policy from time to time. The "last updated" date at the top shows when it last changed. Where changes are material, we will take reasonable steps to make them known.

12. Contact

Questions about this policy or your information:
hello@selph.nz · Manawanui Ventures Ltd, trading as Selph, New Zealand.