Effective from 1 August 2026

This Privacy Policy explains how Dairy Farm Water Management Limited, trading as Water to Grow (Water to Grow, we, us or our), collects, uses, stores and shares personal information.

It applies when you use the Water to Grow website, application and related services, communicate with us, submit an application or order, or are recorded as a customer, user, contact person or authorised representative.

Some farm, device and operational data may not be personal information by itself. We treat it as personal information under this policy where it identifies or can reasonably be linked to an individual.

1. Information we collect

Depending on your relationship with Water to Grow, we may collect:

• identity and contact information, including names, roles, email addresses, telephone numbers and postal addresses;

• customer, farm and site information, including business details, property addresses, nominated service providers and service providers;

• account and user information, including usernames, access permissions, account activity and support history;

• system and device information, including device identifiers, configuration, connectivity, status, location and diagnostic information;

• farm water and operational information, including readings, alerts, programmes, events, usage information and information generated through connected devices;

• commercial and billing information, including subscription, invoice and payment records;

• communications with us, our service providers and service providers, including enquiries, support requests, feedback and complaints;

• website, App and analytics information, including IP address, browser and device type, pages or features used, session information, cookies and similar technologies; and

• marketing preferences and records of communications sent to you.

2. How we collect information

We may collect personal information:

• directly from you through an application form, Order, the website, the App, email, telephone, support request or other interaction;

• from the customer or organisation that authorises you to use the Services;

• from a nominated service provider, dealer, installer, farm service provider or other authorised person;

• automatically through the App, website, connected Monitoring Devices, cookies, logs and analytics tools; and

• from IoT Ventures personnel and service providers involved in delivering or supporting the Services.

If you provide us with personal information about another person, you must be authorised to do so and, where appropriate, make them aware of this policy.

3. Why we use information

We may use personal information to:

• assess and process applications, Orders and subscriptions;

• establish, configure, commission, operate and administer Water to Grow accounts, systems and connected devices;

• provide monitoring, alerts, irrigation control, water management, effluent monitoring and related services;

• provide customer service, maintenance, technical support and troubleshooting;

• monitor device, network, App and service performance, security and 

• liability;

• invoice customers, process and record payments, manage subscriptions and collect overdue amounts;

• communicate with customers, Users, service providers and service providers;

• improve, test, analyse and develop our products and Services;

• produce aggregated or anonymised analytics, reporting and benchmarking;

• send product news, service information, offers and other direct marketing, where permitted;

• protect the security, integrity and lawful use of our systems and information; and

• comply with legal, regulatory, accounting, tax, insurance and dispute-management requirements.

4. Nominated service providers and third-parties

If a customer nominates a service provider, dealer, installer or consultant in an application form, Order or other communication, the customer authorises Water to Grow to give that organisation and its authorised personnel access to the customer’s account and information.

For customers allocated to them, nominated service providers may access customer and User contact details, farm and site information, account details, system configuration, device information, readings, alerts, programmes, diagnostic information and support history. This access is provided to configure, commission, administer, monitor, maintain and support the customer’s Water to Grow system and to assist with use of the Services.

A customer may ask us to change or remove a service provider’s access by contacting support@watertogrow.com. Removing access may affect the service provider’s ability to provide installation, support or other services.

5. Other parties that may handle information

We may provide personal information to people and organisations that help us operate Water to Grow, including:

• IoT Ventures group personnel who provide platform operation, engineering, administration, customer support and other services to Water to Grow;

• cloud hosting, data storage, software, connectivity and network providers;

• website and e-commerce providers, including Shopify;

• accounting, invoicing and payment providers, including Xero;

• email, SMS, communications and customer-support providers;

• analytics, security, technical-support and professional advisers;

• insurers, auditors, debt-recovery providers, regulators, courts and law-enforcement agencies where reasonably required or permitted by law; and

• another organisation in connection with a genuine sale, transfer or restructuring of all or part of our business, subject to appropriate safeguards.

We do not sell personal information.

6. Overseas storage and processing

Some of our technology service providers may store or process personal information outside New Zealand. In particular, Water to Grow application and customer data is hosted using Amazon Web Services infrastructure located in Australia.

Other providers, including website, accounting, communications and analytics providers, may also use infrastructure or personnel located outside New Zealand. Where personal information is handled outside New Zealand, we take reasonable steps to ensure it is protected by appropriate privacy and security safeguards.

7. Direct marketing

We may use contact information to send customers and Users product information, service updates, offers, news and other communications relating to Water to Grow.

You may opt out of marketing emails or messages at any time by using the unsubscribe facility provided or contacting us. We may still send operational, safety, support, billing, subscription or other service-related communications that are necessary to provide or administer the Services.

8. Website, App analytics and cookies

Our website and App may use cookies, logs, analytics tools and similar technologies to operate the Services, remember preferences, understand how the website and App are used, diagnose problems, improve performance and support marketing.

You can control some cookies through your browser or device settings. Disabling cookies may affect the operation of parts of the website or App.

9. Security

We use reasonable administrative, technical and organisational safeguards designed to protect personal information against loss, unauthorised access, misuse, alteration or disclosure.

Customers and Users are responsible for keeping account credentials secure, controlling who is authorised to use their accounts and notifying us promptly of suspected unauthorised access.

No method of electronic storage or transmission is completely secure, and we cannot guarantee absolute security.

10. Retention and deletion

We retain personal information for as long as reasonably required to provide and support the Services, administer our relationship with the customer and meet legal, accounting, tax, insurance and dispute-management requirements.

Following expiry or termination of a subscription, customers may request access to readily available Customer Data for 30 days, as described in the Terms and Conditions. After that period, information may be deleted or anonymised unless we are required or reasonably entitled to retain it.

Some information may remain in secure backups until deleted through our ordinary backup cycle. We may retain limited contact details to record marketing opt-outs and prevent unwanted communications.

11. Access and correction

You may ask for access to personal information we hold about you and request correction if you believe it is inaccurate or incomplete. We may need to verify your identity before responding.

To request access or correction, contact the Privacy Officer using the details below.

12. Privacy questions and complaints

If you have a privacy question, concern or complaint, please contact our Privacy Officer. We will review the matter and respond within a reasonable time.

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner at www.privacy.org.nz.

13. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes to our Services, practices or legal obligations. The current version will be published on our website, with its effective date. Where a change is material, we will take reasonable steps to notify affected customers or Users.

14. Contact

Privacy Officer

Dairy Farm Water Management Limited, trading as Water to Grow

Email: info@watertogrow.com

Website: www.watertogrow.com