Privacy Policy

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Last Updated: February 2, 2026

Think Walden Limited. (“the Company,” “we,” “us,” or “our”) is a New Zealand limited liability company specialising in strategy, innovation, and sales consulting. We are committed to protecting the privacy and security of the personal data we process. This Privacy Policy outlines our practices regarding the collection, use, and disclosure of information for our global clients, with particular adherence to the New Zealand Privacy Act 2020 and international standards such as the GDPR.

1. Information We Collect

We collect information that identifies, relates to, or could reasonably be linked to an individual (“Personal Information”). This includes:

• Contact Information: Name, email address, and phone number (collected via our website contact form or direct inquiry).
• Professional Information: Job title, company name, and business objectives relevant to our consulting services.
• Technical Data: IP addresses, browser types, and interaction data collected via Google reCAPTCHA and website analytics.
• Financial Data: Billing addresses and payment details processed through our accounting systems.

2. Legal Basis for Processing

We process personal data under the following legal frameworks:

• Performance of a Contract: To deliver consulting services and manage client accounts.
• Legitimate Interests: To secure our website (e.g., reCAPTCHA), improve our service delivery, and maintain business records.
• Legal Obligation: To comply with New Zealand tax and corporate reporting requirements.

3. Use of Third-Party Processors

To provide premium services, we utilize specialized technology tools. Your data may be processed by:

• Google Workspace Plus: For secure email communication, document collaboration, and cloud storage.
• Asana: For project management, task tracking, and strategy implementation.
• Xero: For secure cloud-based accounting, invoicing, and financial record-keeping.

Each of these providers maintains rigorous security standards (including SOC 2 and ISO 27001 compliance) and utilises Standard Contractual Clauses (SCCs) for international data transfers.

4. International Data Transfers

Think Walden Limited operates from New Zealand. However, because our service providers (Google, Asana) are primarily headquartered in the United States, your data may be transferred to and stored on servers located outside your home jurisdiction. We ensure that such transfers comply with Information Privacy Principle 12 of the NZ Privacy Act and Article 46 of the GDPR.

5. Data Retention

We retain Personal Information only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements (typically 7 years for financial records under NZ law).

6. Your Rights

Regardless of your location, Think Walden Limited affords you the following rights:

• Access & Correction: You may request a copy of the data we hold about you and ask for corrections.
• Deletion (Right to be Forgotten): You may request that we delete your data, subject to our legal retention obligations.
• Data Portability: You may request your data in a structured, machine-readable format.
• Objection: You may object to the processing of your data for direct marketing.

To exercise these rights, contact our Privacy Officer at: simon.mason@thinkwalden.com

7. Security Measures

We implement industry-standard technical and organisational measures to protect data, including multi-factor authentication (MFA) across our Google, Asana, and Xero accounts, as well as encrypted data transmission.

8. Governing Law and Jurisdiction

This Privacy Policy is governed by the laws of New Zealand. However, for commercial disputes arising from our Service Agreements, we may agree to an alternative jurisdiction as specified in your individual client agreement.

9. Contact Us

Think Walden Ltd.Registered in New Zealand (Company No: 9398071 | NZBN: 9429053377609) Registered Office: Level 3, 6 Show Place, Addington, Christchurch, 8024, New Zealand.

Email: simon.mason@thinkwalden.com