Privacy Policy



Last updated: 21 August 2024

1. Introduction
1.1. This Privacy Policy (Policy) outlines how your personal information is collected, held, used and disclosed when you access and use the Crouton mobile application (“App”). In this Policy, “personal information” has the meaning defined in the Privacy Act 2020, being information about an identifiable individual, and “we", “us”, "our" mean the provider of the App, being Creative Interactions Limited.

1.2. By accessing and/or using the App, or otherwise providing personal information to us, you acknowledge the collection and use of such information by us, in accordance with this Policy.

1.3. The App is a global mobile application, that can be accessed and downloaded across the world. When dealing with your personal information, we will comply with this Policy and with the New Zealand Privacy Act 2020. If you are located outside of New Zealand, this Policy may not comply with the privacy regulations in your location. If you live elsewhere in the world, we will deal with your personal information as if it was subject to the New Zealand Act.

1.4. This Policy should be read in conjunction with the terms in our End User License Agreement, which can be found here.

2. Collection of personal information
2.1. Generally, you can use and access the App without providing your personal information to us. However, there are some situations where we may collect limited forms of personal information, or non-identifiable information from you.

2.2. When accessing and using the App, we may collect technical data and related information from your device, including:

  • 2.2.1 details about your device, such as your device name, operating system version, and the configuration of the App on your device;
  • 2.2.2 details about your iCloud account (such as your iCloud storage capacity); and
  • 2.2.3 analytics and usage information about your use of the App.


2.3. When you input information into the App (either manually, via URL link, via your device camera, or through an image), this information is stored in your iCloud account, and we do not have access to this.

2.4. Our App may require access to some of your smartphone device features and applications (such as the camera and reminders application), which helps us to deliver certain features and the functionality of the App. We do not collect or store personal information from the App’s use of your device’s features and applications.

2.5. When you contact us with requests, inquiries, or questions relating to the App, we may collect personal information that you provide voluntarily to us, such as your name and contact details (including email address and/or phone number).

2.6. If you sign up for a subscription that allows you to access to certain features of the App, or if you make an in-App purchase, we do not collect or store your payment information. Your payment information is collected and stored by Apple, and is subject to their Privacy Policy, which you can find here.

2.7. You can always choose to decline to provide your personal information to us. However, this may affect us responding to you, or us otherwise carrying out our general functions.

3. How we use your personal information
3.1. Personal information will be used for the purposes of providing, operating, supporting, and maintaining the App, and for any other purpose specified in this Policy.

3.2. We may use your personal information:
  • 3.2.1 for internal administrative purposes;
  • 3.2.2 to respond to your requests, inquiries, feedback or customer service related activities;
  • 3.2.3 to improve the quality of the App, and any associated products or services we may offer in connection with the App;
  • 3.2.4 for marketing, statistical and research purposes;
  • 3.2.5 for related purposes for which you would reasonably expect us to use or disclose the information;
  • 3.2.6 where you have consented to us using or disclosing the information; or
  • 3.2.7 where we are required or otherwise permitted to do so by law.


4. Disclosure of your personal information
4.1. We do not sell, rent, lend, exchange or trade your personal information. In limited circumstances, we may disclose your personal information to third parties for purposes reasonably connected with the purposes for which we may use your personal information. For example, we may disclose your personal information to:
  • 4.1.1 third-party service providers (such as analytics providers); or
  • 4.1.2 professional services advisors.


4.2. When you use the Household Sharing function of the App, third parties may be able to see information that you enter or add into the App (and vice versa), including your name and email address.

5. Disclosure of your personal information

5.1. We will take reasonable steps to protect your personal information against unauthorised access or disclosure while it is held by us. However, we cannot guarantee the absolute security of personal information transmitted over the Internet.

5.2. The App may contain links to third party websites that are not operated by us. We suggest you review the privacy policy of every website you visit, and we have no control over or assume any responsibility for the content, privacy policies, or privacy practices of any third-party websites.

6. Retention of personal information
6.1. We will not keep your personal information for longer than we need to. In most cases, this means that we will only retain your personal information for the duration of your relationship with us unless we are required to retain your personal information to comply with applicable laws, for example record-keeping obligations.

7. Accuracy, and your right to access or correct personal information
7.1. We take all reasonable steps to ensure that the personal information we hold is accurate, up to date, complete, relevant, and not misleading

7.2. If you believe your personal information held by us is not accurate, complete, or otherwise requires amendment, please contact us on info@crouton.app.

8. Mandatory reporting of notifiable privacy breaches
8.1. If your personal information is involved in a privacy breach which we reasonably believe is notifiable or must be reported in accordance with the Privacy Act (“Notifiable Privacy Breach”), we will inform the affected individual/s and report the Notifiable Privacy Breach to the New Zealand Office of the Privacy Commissioner.

9. Privacy inquiries and complaints
9.1. If you have any questions or wish to make a complaint in relation to your handling of your personal information, please contact us on info@crouton.app.

9.2. Any complaint will be investigated and responded to as soon as practicable, and in accordance with the time frames set out in the Privacy Act.

9.3. You may contact the Office of the Privacy Commissioner if you are unsatisfied with how your personal information or complaint has been handled.

10. Changes to this Policy
10.1. We may update our Privacy Policy from time to time by posting a new version on our website.

10.2. Any change that we make applies from the date we post it on the website, and we recommend that you review this Policy periodically for any changes. Your continued use of the App constitutes acknowledgement of this Policy as updated.

Information Accessed and Use of TrueDepth API

When you use the Hands free navigation feature feature on Crouton, we use Apple’s TrueDepth API to read facial expressions in order to determine whether or not to trigger the action for swiping left and right (That is, we check if the user’s winking with their left or right eye or not, or opening their mouth). The entire processing for the hands free navigation feature is done on device and in real time. The TrueDepth data never leaves the device, is never stored on the device or stored on our server or shared with any other third party, or for any other purpose other than setting up and using hands free navigation. Furthermore, it’s an Opt-in feature, that works only with your explicit permission to use the front facing camera.

How do we use your personal information

We make use of the TrueDepth API to read facial expressions in order to determine whether or not a user is winking or opening their mouth. This information is not recorded for any further use. It is not stored for any future use. It is not shared with any third party services. And it is always processed on device

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