Privacy Policy

Libretour operates a business-to-business training and certification platform for the New Zealand tourism industry. Tourism suppliers publish training material about their products on the platform; travel agents (“Learners”) register, complete the training, and receive verifiable digital badges. The platform also makes available an AI assistant that answers questions grounded in supplier-provided content.

This Policy applies to personal information collected by Libretour in connection with the Services. It does not apply to information collected by:

1. third parties operating their own websites or services to which the Services link;
2. tourism suppliers in their capacity as independent data controllers of their own learner records (each supplier maintains its own privacy practices);
3. Libretour's employment-related personal information, which is governed by separate workforce notices.

Consistent with IPPs 1 to 4, Libretour collects only the personal information necessary for, and directly related to, the purposes described in section 4 of this Policy. We collect the following categories of personal information:

1. Account information: full name, work email address, employer or agency name, country, and (optionally) preferred display language. Accounts are created and managed directly by our own self-hosted authentication system.
2. Authentication identifiers: a unique user identifier issued by the platform and any single-sign-on identifiers you elect to associate with your account.
3. Learning activity: courses you enrol in, modules you complete, quiz responses, dwell time per chapter, language preferences, and digital badges awarded.
4. AI assistant interactions: the natural-language questions you submit to the in-platform AI assistant, the responses generated, citation metadata, and (for signed-in users) a per-question latency and source-kind audit log.
5. Voluntary feedback: star ratings and free-text feedback you choose to provide to suppliers about their training.
6. Voice samples: only where a supplier explicitly uploads an audio recording for voice cloning, the underlying audio file and any derived voice model identifier. See section 9.
7. Technical information: IP address, user-agent string, approximate geolocation (country/region), referring URL, and access timestamps, collected automatically when you access the Services.
8. Cookies and similar technologies: as described in section 13 of this Policy and in our Cookies Policy.

We do not knowingly collect government-issued identifiers, financial-account details (other than where lawfully provided by your payment provider for subscription billing), or information classified as sensitive information under the Privacy Act unless you voluntarily provide it.

We collect personal information for the following lawful purposes connected with a function or activity of Libretour:

1. to create, secure, and operate your user account;
2. to deliver, personalise, and improve the Services, including learner progress tracking, badge issuance, and the AI assistant;
3. to provide aggregated and individual-level analytics to the tourism supplier whose training you have enrolled in;
4. to communicate with you about the Services, including transactional notifications, security alerts, and updates to this Policy;
5. to respond to your enquiries, support requests, and any rights requests under the Privacy Act;
6. to detect, prevent, and respond to fraud, abuse, security incidents, and breaches of our Terms of Service or Acceptable Use Policy;
7. to comply with our legal and regulatory obligations under New Zealand law; and
8. where you have given separate, informed consent, to use voice samples to create a synthetic voice model for narration of training content.

We use the personal information described above for the purposes set out in section 4. We do not sell personal information. We do not use personal information for behavioural advertising or for unrelated secondary purposes without first obtaining your authorisation as required by IPP 10.

Where we use AI systems to process your data, we do so under arrangements described in section 8.

We disclose personal information only where one or more of the grounds in IPP 11 applies. The categories of recipient are:

1. Tourism suppliers: each supplier may access the names, email addresses, agency affiliations, course progress, badges, ratings, and AI question logs of Learners who have enrolled in that supplier's training. Suppliers are independent agencies under the Privacy Act and are responsible for their own subsequent handling.
2. Service providers: cloud infrastructure (Cloudflare, Inc.), large-language-model providers (Anthropic, PBC and, where applicable, OpenAI, OpCo, LLC), voice-synthesis providers (ElevenLabs, Inc. and others described in section 9), and email delivery (Resend, Inc.), each acting under written confidentiality and security obligations. Authentication is self-hosted by the platform and involves no third-party provider.
3. Search and citation providers: where the AI assistant is unable to answer from supplier-provided content, the assistant may use the integrated web-search capability of our large-language-model provider (Anthropic, PBC) to retrieve public sources; the question text is processed by that provider. Account-identifying information is not transmitted.
4. Professional advisers: our lawyers, accountants, insurers, and auditors, where strictly necessary.
5. Acquirers: in connection with any actual or contemplated merger, acquisition, financing, or reorganisation, subject to confidentiality obligations on the receiving party.
6. Regulators and authorities: where disclosure is required or authorised by New Zealand law, including without limitation requests by the Office of the Privacy Commissioner, the New Zealand Police, or a court of competent jurisdiction.

The Services are operated using Cloudflare's global edge network. Personal information may be stored, processed, or routed through Cloudflare data centres located outside New Zealand, including in Australia, the United States, the European Union, and the United Kingdom. AI processing under section 8 takes place on infrastructure operated by Anthropic, PBC, principally in the United States.

In accordance with IPP 12, we disclose personal information to a foreign person or entity only where:

1. the foreign person is subject to comparable privacy safeguards (whether under the law of their home jurisdiction or under binding contractual undertakings); or
2. you have been expressly informed and have authorised the disclosure.

By using the Services, you acknowledge that overseas processing as described above is necessary for the Services to function and you authorise such processing.

The Services include an AI assistant powered by third-party large-language-model providers. When you submit a question to the assistant, the following data is transmitted to the model provider for the sole purpose of generating a response:

1. the question text;
2. the operator-published training content and supplementary materials relevant to your question;
3. at most, a short context window of your conversation with the assistant on the current page; and
4. no direct account identifier (your user identifier is not transmitted).

We require model providers to process this data under enterprise terms that prohibit use of customer data for the training of generalised foundation models. Translation features and AI-generated quiz authoring follow the same prohibition. We do not warrant any particular accuracy, completeness, or fitness for any purpose of AI-generated responses; you must independently verify any information relied upon for commercial purposes.

The Services optionally permit tourism suppliers to create a synthetic voice model from an uploaded audio sample of a human speaker (the “Voice Donor”). Voice models are generated by a third-party provider (currently ElevenLabs, Inc.) and the audio sample is retained for the purpose of regenerating or updating the model.

A supplier may upload a voice sample only where:

1. the Voice Donor has provided informed, written consent to the recording, the cloning, and the subsequent commercial use of the resulting synthetic voice in supplier training materials distributed via the Services;
2. the supplier retains evidence of that consent and will produce it to Libretour on request; and
3. the Voice Donor is at least 18 years of age.

On request by the Voice Donor or by the supplier, Libretour will delete the audio sample, instruct the synthetic-voice provider to delete the underlying voice model, and remove or replace audio generated from that model in published training material, in each case within thirty (30) days of the request.

We retain personal information only for as long as is reasonably necessary for the purposes described in section 4, unless a longer retention period is required or permitted by law. Standard retention periods are:

1. account records: for the lifetime of the account, plus twelve (12) months after deletion to handle deletion reversals and security investigations;
2. learning activity, quiz attempts, and badge records: for the lifetime of the account, then retained in anonymised form for supplier analytics;
3. AI assistant logs: for twenty-four (24) months from the date of the conversation;
4. course feedback (ratings and free-text): for the lifetime of the course;
5. voice samples and voice models: until withdrawal of consent (see section 9) or termination of the supplier's subscription;
6. technical access logs: for ninety (90) days, after which they are aggregated.

Libretour takes the reasonable security safeguards required by IPP 5 to protect personal information against loss, unauthorised access, use, modification, or disclosure. These safeguards include encryption in transit (TLS 1.2 or higher), encryption at rest, role-based access controls within the platform, periodic access reviews, and contractual security obligations on each of our service providers. No method of electronic transmission or storage is, however, completely secure, and Libretour cannot guarantee absolute security.

Libretour maintains a notifiable-privacy-breach response process and will notify the Office of the Privacy Commissioner and affected individuals as required by sections 114 to 117 of the Privacy Act in the event of a notifiable privacy breach.

Under IPPs 6 and 7 of the Privacy Act you are entitled, at no charge, to:

1. request confirmation that we hold personal information about you;
2. request access to that information;
3. request correction of information that is inaccurate, incomplete, or misleading; and
4. attach a statement of correction sought but not made.

We will respond to a verified rights request within twenty (20) working days, in accordance with section 41 of the Privacy Act. To exercise these rights, contact us using the details in section 16. We may require proof of identity before actioning a request.

You may also at any time delete your account from within the Services. Account deletion triggers the retention process described in section 10. Some derived, aggregated, or anonymised data may continue to be retained where it is no longer personal information.

Libretour uses a small number of strictly necessary cookies (for authentication and language preference), together with limited first-party analytics cookies. Details, including the name and purpose of each cookie, are set out in our Cookies Policy. Where applicable law requires informed consent for non-essential cookies, we obtain that consent before setting them.

The Services are intended for use by professional travel agents and tourism suppliers and are not directed to children. We do not knowingly collect personal information from any individual under the age of sixteen (16). If we become aware that we have inadvertently collected personal information from a child under that age, we will delete it as soon as practicable.

If you believe that we have failed to comply with the Privacy Act or this Policy, please contact us first using the details in section 16. We take privacy complaints seriously and will investigate promptly.

You also have the right to make a complaint directly to the Office of the Privacy Commissioner of New Zealand:

1. online: privacy.org.nz;
2. by telephone: 0800 803 909;
3. by post: PO Box 10094, The Terrace, Wellington 6143.

Privacy questions, requests, and complaints should be directed to our Privacy Officer:

1. email: privacy@libretour.com.

We may amend this Policy from time to time. Material changes will be notified by email to all account holders and posted prominently on the Services at least ten (10) working days before they take effect. Continued use of the Services after the effective date of an amendment constitutes acceptance of the amended Policy.