Sign up
Sign up
Log in

Te Heke Mai Privacy Policy

Last updated: June 2026

This Privacy Policy applies to personal information (as defined in the Privacy Act 2020) that is collected as part of the Te Heke Mai Platform at tehekemai.co.nz (“Platform”) and should be read alongside the Terms and Conditions applying to the Platform.

pAI2 Limited (we/us) has developed and operates the Te Heke Mai Platform under contract with the Ministry of Social Development (MSD). Information collected through the Platform is held by us. MSD receives anonymised aggregated information about Platform users, as well as your name, date of birth, and programme entry and exit dates.

If we no longer provide the Platform, we will be required to pass your information to MSD or another provider of their choice so they can continue to run the service. You will be notified if this occurs and may opt out from sharing your data.

Personal information

Personal information collected through Te Heke Mai will be held securely by us as required by the Privacy Act 2020.

For users of Te Heke Mai, when you create an account and use the Platform we collect:

  • Identity & contact details, such as your name and email address, and where you provide them, your phone number.
  • Profile & eligibility details, such as your age group, gender, region, profile photo, and eligibility status (e.g. NZ citizen or permanent resident).
  • Content you create or upload using Platform tools, such as CVs, cover letters, goals, and your responses in coaching, onboarding, and skills/interview-practice activities.
  • Voice recordings you choose to make in practice features (which we transcribe to text).
  • Communications with us, your coach, or third parties through or via the Platform.

AI and automated features

Te Heke Mai uses artificial intelligence (AI) to support some platform features. This section explains how AI is used and what it means for your personal information.

Ruru, the Te Heke Mai AI coaching assistant

Ruru is Te Heke Mai’s AI coaching assistant. Ruru uses generative AI technology to generate coaching prompts, goal-setting support, and suggested resources based on information you provide through the Platform. Ruru’s responses are generated by an AI system; they are not written by a human coach. Your Te Heke Mai human coach may review, supplement, or override Ruru’s outputs at any time.

How your information is processed for AI features

To generate AI responses, information you provide through the Platform is sent to and processed by Microsoft’s Azure OpenAI Service. Microsoft’s servers are located in the Australia East region. The “Overseas transfers of personal information” section of this policy explains what this means for your rights.

We do not use AI to make final decisions about your eligibility for any programme, service, or level of support. AI features are tools to support your coaching journey, not automated decision-making systems. A human is involved in all material decisions affecting your programme participation.

Your choice about AI features

If you prefer not to interact with AI-powered features on the Platform, which are clearly marked via our Ruru assistant, you have the choice not to use them. You can still access coaching support—just let your coach know or contact us using the details at the end of this policy.

Use and disclosure

We will use your personal information for the purpose of providing the Te Heke Mai service to you, including through the AI-supported coaching features described above. We also use your information for communicating with users, for safety and security reasons, for analysis of Platform usage and content, and in other situations permitted under the Privacy Act 2020.

Information we share with MSD

As part of our arrangement with MSD, we provide them with reports containing anonymised information about the Platform and its users. We may provide MSD with your name, date of birth, and Platform usage data so they can evaluate and report on Te Heke Mai and understand what further support to offer you.

Information we share with service providers

To operate the Platform and deliver our services, we share information with service providers who process it on our behalf and under our instruction. These include:

  • Microsoft (Azure) – cloud infrastructure, and AI processing for text generation and speech-to-text transcription (using Microsoft’s Azure AI services, including the Azure OpenAI Service and Azure AI Speech).
  • HubSpot – coaching booking, scheduling, and communications, and analytics.
  • Google – website and product usage analytics (Google Analytics, delivered via Google Tag Manager).

These providers are required to protect your information and may only use it for the purposes we specify. We do not authorise them to use your information for their own purposes.

Except as described in this policy, we do not share your personal information with others unless you authorise us to do so, or where this is necessary for the purpose for which you gave us the information, or where the Privacy Act 2020 permits, such as when there are safety reasons for disclosing it.

Information we share at your request

We may share relevant information with other persons if you provide us with a written consent request. You can ask for that information sharing to stop at any time by contacting us in writing.

Overseas transfers of personal information

Some of our service providers, including our AI service provider Microsoft, are located overseas. When your information is processed by overseas providers it may be subject to the laws of those countries.

The primary overseas service provider that processes your personal information is Microsoft, whose Azure OpenAI infrastructure is located in the Australia East region.

We take reasonable steps to ensure our overseas service providers protect your information consistently with the Privacy Act 2020, including by using providers that have appropriate data protection commitments and security standards in place.

Analytics

We analyse non-identifiable web traffic data to improve our services and may use third-party services to do this for us. We own the data generated and use it to administer and improve the Platform. Information collected for analytics purposes includes:

  • Search terms used on the Platform
  • Pages accessed and links clicked
  • Dates and times of usage
  • Referring sites through which the Platform is accessed
  • Operating systems and browser types

The data collected is aggregated and is not personally identifiable. IP addresses are masked so they cannot be used to identify individuals. Our analytics will respect any “do not track” setting on your browser. We use cookies to allow particular features to work and to track non-personally identifiable usage data. You can opt out of our tracking cookies without affecting your ability to use the Platform.

Your rights and choices

Under the Privacy Act 2020, you have the right to:

  • Access the personal information we hold about you.
  • Request correction of any information that is inaccurate, incomplete, or out of date.
  • Know how your information is being used and who has access to it.

If you would like to opt out of AI-powered features on the Platform, which are clearly identified with the Ruru assistant, you can still access coaching. Please speak to your coach or contact us using the details below.

You can also ask to be removed from our communications at any time by contacting us.

Updates to this policy

We may update this Privacy Policy from time to time, including to reflect changes in how we use AI or to meet new legal requirements. We will communicate material changes through the Platform or by email, and will always publish the updated policy on this page with a revised “Last updated” date.

Contact us

If you have questions about this Privacy Policy, would like to access or correct your personal information, or want to discuss how we use AI, please contact us:

Te Heke Mai, operated by pAI2 Limited
Contact form: THM Support form
Email: hello@tehekemai.co.nz