Privacy Policy

1. Overview

This Privacy Policy explains how Gateway collects, uses, stores, discloses, and protects personal information when you use our platform and Services.

By using Gateway, you agree to the handling of information as described in this policy, subject to any rights you have under applicable law.

If you do not agree, you must not use the Services.

This policy should be read alongside our Terms of Use.

2. Who We Are

Gateway is operated by Next Generation Media Limited (NZBN 9429053566256), based in New Zealand.

References to “Gateway”, “we”, “us”, or “our” in this policy refer to Next Generation Media Limited and the services it operates under the Gateway brand.

3. What We Collect

We may collect the following types of information.

Information you provide or make available to Gateway:

• your name, email address, and other profile information supplied by a sign-in provider;
• information about sign-in methods you link to your Account;
• Server details, including names, hostnames or IP addresses, ports, SSH usernames, selected regions, platform information, and Server identity information;
• Server credentials or access material you choose to provide or authorise Gateway to create and manage;
• instructions, requests, operation inputs, and other information submitted through Gateway or an authorised Third-Party Service;
• files and file metadata you transfer through Gateway;
• support requests, communications, preferences, and security choices;
• If you apply for the student offer, your legal name, school or university, student ID number, expected graduation month, and any school email address or student ID you provide (see section 26);
• billing, subscription, plan, dispute, and transaction information associated with your Account; and
• if you create or join a team, the team's name, its members and their roles, invitations, team settings, and the team's billing details, including a business name, address, and tax identifier where provided.

Information Gateway receives while performing work:

• command, operation, service, system, log, file, network, package, container, storage, process, and other Server information requested as part of work performed through Gateway;
• job status, output, results, errors, timestamps, and related operational records; and
• information needed to maintain Activity, security, audit, and abuse-prevention records.

If you use Gateway Cloud, we also receive the usage figures reported by the monitoring agent on your cloud servers, as described in section 25.

Information collected automatically:

• IP address;
• browser or user-agent information;
• session and request metadata;
• usage, reliability, performance, and security telemetry; and
• technical signals used to detect abuse, fraud, unauthorised access, or service failures.

We aim to collect only information reasonably necessary for the purposes described in this policy.

4. Your Data

You retain ownership of Your Data.

We do not claim ownership of information merely because it is stored by or passes through Gateway.

We use Your Data only as described in this policy, our Terms of Use, or as otherwise authorised by you or required by law.

5. How We Use Your Data

We use information to:

• create, authenticate, secure, and maintain your Account;
• provide, maintain, operate, and improve the Services;
• connect to and perform requested work on your Servers;
• return requested Server information and operation results to you or an authorised Third-Party Service;
• provide file-transfer functionality;
• process subscriptions, billing, payments, refunds, disputes, and account entitlements;
• maintain job, Activity, security, and audit records;
• scan transferred or submitted files for malicious content where applicable;
• detect, investigate, prevent, and respond to fraud, abuse, security incidents, and unauthorised access;
• troubleshoot failures and improve service reliability;
• respond to support requests and communications;
• comply with legal obligations; and
• enforce our Terms of Use.

We do not sell or rent personal information.

We do not share personal information with third parties for their own advertising or marketing purposes.

6. Sharing Your Data

We may disclose or make information available to:

• Third-Party Services you choose to connect to Gateway, to the extent necessary to perform requests or return results through that service;
• other members of a team you belong to, who can see the team's work;
• a destination a team chooses for exporting or delivering its audit records;
• identity providers you choose to use for sign-in;
• the service providers listed in section 7, which process information on our behalf to operate Gateway;
• professional advisers, such as lawyers and accountants, where reasonably necessary to operate, protect, or enforce the Services;
• a purchaser, successor, or relevant adviser in connection with a genuine proposed or completed corporate transaction involving Gateway or Next Generation Media Limited;
• law-enforcement agencies, regulators, courts, or other authorities only as described in section 9;
• the Canadian Centre for Child Protection, for the checks described in section 12;
• the National Center for Missing & Exploited Children, the New Zealand Department of Internal Affairs, New Zealand Police, and other authorities responsible for child protection, as described in section 9; and
• affected organisations, governments, and the responsible New Zealand authority, where we reasonably believe sanctions or export controls are being evaded, only as described in section 9.

Where a user separately and expressly enables a feature that submits file content to an external malware-analysis provider, the selected content may be disclosed to the provider identified for that feature.

We do not sell personal information.

7. Service Providers

The following service providers help us run Gateway and process information on our behalf to do so:

• Cloudflare (Cloudflare, Inc.): infrastructure, storage, and security;
• Stripe (Stripe New Zealand Limited): payments;
• Postmark (ActiveCampaign, LLC): email delivery;
• Amazon Web Services (Amazon Web Services New Zealand Limited): infrastructure, including Amazon EC2;
• Microsoft (Microsoft Regional Sales Pte Limited): malware detection (Microsoft Defender for Endpoint and its cloud protection service);
• Leaseweb (Leaseweb USA, Inc.): hosting of Gateway's malware scanning server in the United States;
• Leaseweb (Leaseweb UK Limited): hosting of Gateway's malware scanning server in the United Kingdom;
• Onidel (Onidel Pty Ltd): hosting of Gateway Cloud servers;
• Anthropic (Anthropic, PBC): automated assistance with support requests, as described below; and
• Gateway classifier: an automated service that checks commands for safety before they run. It does not keep commands or use them for training.

Support requests. When you contact support, the content of your request, any attachments you include, and the Account, Server and job information relevant to it may be processed by Anthropic's Claude models to draft a first reply and to help our staff understand and prioritise the request. Anthropic processes this information on our behalf and does not use it to train its models. This may include requests about compliance, sanctions or abuse, including documents you upload for a compliance review. Decisions about compliance, sanctions or abuse, and any decision about your Account, are always made by a person.

These are all of the service providers that help us run Gateway and process information on our behalf. We name each of them, except providers of security and screening services, which we describe without naming so that they're harder to circumvent. If this list changes, we will update this policy.

Identity providers you choose to use for sign-in, Third-Party Services you choose to connect, such as ChatGPT, and any external malware-analysis provider you separately authorise are not on this list. They receive information because you choose to use them, as described in sections 6, 10, and 12.

8. Service Providers' Own Legal Obligations

Our service providers are independent companies. They remain subject to the laws of the jurisdictions in which they operate.

A request made directly to a service provider, rather than to us, is governed by that provider's own legal obligations and policies.

9. Government & Legal Requests

When a government, law-enforcement agency, regulator, court, or other authority requests customer information, we disclose it only where we are required to do so by a valid and legally binding order.

Before we respond to a request, we verify:

• that it is authentic;
• that the issuing authority has jurisdiction over us; and
• that it is no broader than the law requires.

We challenge requests that are invalid or overbroad.

We notify affected customers before disclosing their information in response to a request, unless we are legally prohibited from doing so.

Next Generation Media Limited is a New Zealand company, and we respond only to orders that are enforceable in New Zealand. A foreign government, court, or agency seeking customer information from us must use New Zealand's mutual legal assistance processes, and its request must be recognised by a New Zealand court.

Sanctions and export-control reports

Where we reasonably believe that the Services are being used to evade sanctions or export controls, we may disclose limited information to affected organisations or governments, or to the New Zealand authority responsible for administering those sanctions, so that they can meet their own legal obligations.

Any such disclosure is limited to the information reasonably necessary to identify and stop the evasion, such as the relevant account identifier, Server addresses, and the technical details that show the evasion. It never includes Server credentials, stored secrets, or the contents of files or jobs, beyond specific identifiers such as domain names or network addresses that show the evasion.

We do not notify customers of sanctions or export-control reports.

Child sexual abuse material

Where we find, or are told about, material on Gateway that we reasonably believe is child sexual abuse material, we report it to the National Center for Missing & Exploited Children (NCMEC) in the United States and the Department of Internal Affairs in New Zealand. We may also report it to New Zealand Police and to other law-enforcement or child-protection authorities with jurisdiction. We make these reports without waiting for a legal order, and they are not limited by the rules for government requests above.

A report may include the account's details, such as its email address, name and billing country; sign-in IP addresses and times; the addresses and names of the Servers involved; details of the files involved, such as names, sizes, hashes and transfer times; and the files themselves.

Gateway staff do not open or view suspected material. We preserve it, with the related records, for as long as the law requires or the relevant authority asks.

We do not notify customers of these reports.

We do not disclose who uses Gateway to anyone, except as necessary to operate Gateway as described in this policy, for a sanctions, export-control or child sexual abuse material report described in this section, or as required by law.

10. Third-Party Services

Gateway may connect to Third-Party Services at your request, including ChatGPT.

When you authorise a Third-Party Service to use Gateway, requests from that service may cause Gateway to access your Servers, and information or results requested through that connection may be returned to the Third-Party Service.

The Third-Party Service's own terms and privacy policy apply to information it receives.

We are not responsible for the privacy practices of Third-Party Services.

You should review the privacy terms of services you connect to Gateway.

11. Server Credentials & Access

Gateway handles Server credentials and access material only to provide authorised access to Servers you connect.

Your Server credentials are not disclosed to ChatGPT as part of normal Gateway operation.

If you provide a Server password during setup, Gateway may encrypt and retain that password for up to 24 hours where necessary to complete or retry setup, after which it expires from normal use.

Gateway may create and retain other Server access material, such as SSH identity material, for as long as the Server remains connected or until that access is replaced or revoked.

If you give Gateway a secret for use by your agents, including a sudo password for a Server, Gateway stores it encrypted. A secret you choose to save is retained until you delete it. A one-time secret is deleted after the job that uses it, or within 24 hours if no job uses it. If you ask Gateway to keep your Server setup password for sudo, it is retained as a saved secret on the same terms.

We restrict access to Server credentials and access material and use them only for authorised Gateway operations, security, recovery, or other purposes necessary to provide the Services.

You should not place Server passwords, private keys, or other credentials directly into a ChatGPT conversation when Gateway provides a dedicated setup or secret-entry flow for that information.

12. Files & Malware Scanning

Files transferred through Gateway may be temporarily stored to provide file-transfer functionality.

Gateway may scan transferred files to protect users, our infrastructure, and third parties.

Files you store or transfer through Gateway, and files you attach to support requests, are scanned for malware by Microsoft Defender for Endpoint, a commercial anti-malware engine, running on servers that Gateway operates and rents from Leaseweb. Files stored in or transferred through Gateway may be scanned in either the United States or the United Kingdom.

The contents of your files are never sent to Microsoft. To identify threats, Microsoft's cloud protection service receives information about each scanned file, such as its hashes and other file metadata. This is part of how the engine works and cannot be turned off.

Images and videos you store or transfer through Gateway, including those inside archives, and images and videos attached to support requests, are checked for known child sexual abuse material (CSAM). To do this, Gateway sends each such file to Shield by Project Arachnid, a service operated by the Canadian Centre for Child Protection Inc. (C3P), a registered Canadian charity. C3P compares the file against its database of known CSAM and harmful-abusive material and tells us whether it matches.

Files sent to C3P may be processed in Canada and the European Economic Area. Under C3P's terms, C3P may retain files it receives and share them with the child-protection organisations it works with, solely to detect, classify and remove CSAM. C3P is an independent organisation and handles that information under its own privacy policy.

Files that remain on your Servers, including Gateway cloud servers, are not checked.

Proactive scanning of files already present on a connected Server is performed only where the relevant Account setting authorises that behaviour.

Submission of file content to an external malware-analysis provider requires separate authority and is not implied merely because ordinary Gateway file scanning is enabled.

A malware scan or absence of a detection is not a guarantee that a file is safe.

13. Data Storage & Security

We use reasonable technical and organisational measures intended to protect information handled by Gateway, including:

• encryption in transit;
• encryption or other protective controls for sensitive stored information where appropriate;
• access controls and authentication safeguards;
• restricted internal access to customer information;
• separation of sensitive credential handling from ordinary user-facing access; and
• monitoring for abuse and unauthorised access.

No system is completely secure.

Data breaches. If we become aware of a data breach that affects your personal information, we will endeavour to notify you within about 72 hours of becoming aware of it. This is in addition to our obligations under the Privacy Act 2020 to notify the Office of the Privacy Commissioner and affected individuals of notifiable privacy breaches.

You are responsible for maintaining the security of your own Account, sign-in methods, Servers, and systems outside our control.

14. Data Retention

We retain different categories of information for different periods according to the purpose for which the information is required.

Current operational retention includes:

• job output and detailed job records: generally retained for seven days after the job finishes;
• temporary transferred-file artifacts: generally retained for up to 24 hours;
• Server setup passwords: where supplied, retained for no more than the temporary setup period described above, generally up to 24 hours, unless you ask Gateway to keep it for sudo, in which case it is a saved secret;
• stored secrets, including sudo passwords for a Server: one-time secrets are deleted after the job that uses them, or within 24 hours if unused; saved secrets are retained, encrypted, until you delete them;
• Server records and durable access material: retained while the relevant Server remains connected, subject to security, replacement, and deletion processes;
• Activity, security, abuse-prevention, and audit records: retained for as long as reasonably required for account history, service integrity, security, fraud prevention, dispute resolution, legal compliance, or other lawful purposes;
• billing and transaction records: retained for as long as reasonably required for accounting, tax, dispute, fraud-prevention, and legal obligations;
• Account and identity information: retained while your Account is active and for a reasonable period afterwards where required for security, legal, billing, dispute, or operational purposes;
• Student offer applications: legal name, student ID number and school email deleted when the application is decided; uploaded student ID deleted at the decision unless retained for the support attachment period; keyed fingerprints kept for one year after the later of the expected graduation month and the application, or while an abuse block stands;
• jobs and files on team Servers: retained for the same periods as the equivalent personal information above;
• material reported as child sexual abuse material, and records relating to it: preserved for as long as the law requires or the relevant authority asks, even where a shorter period above would otherwise apply; and
• optional paid features: where you choose longer file retention, or a team subscribes to Extended audit retention, the periods described in section 25 apply to the information those features cover. No other period above changes.

Where you use Gateway Cloud, the periods described in section 25 apply to the monitoring agent's reports and to your cloud servers' transfer totals.

Removing a Server does not necessarily remove Activity, security, billing, or audit history relating to that Server.

We may retain information for longer where required or permitted by law, or for a shorter period where it is no longer reasonably required for a lawful purpose.

Where possible, information that no longer needs to identify an individual may be deleted, aggregated, or de-identified.

15. Access, Correction, Deletion & Control

You may request access to or correction of personal information we hold about you, subject to applicable law.

You may update certain Account information and security settings directly through Gateway.

You may remove connected Servers and revoke access using the controls we provide.

Exporting your data. You may download a copy of the personal information associated with your Account from your Account settings. The copy is generated when you ask for it and is available to download for 24 hours, after which we delete it. It does not include passwords, keys, tokens, stored secret values, or other credentials, or information we hold for security, fraud prevention, or legal compliance. We may limit how often you can generate a copy.

Deleting your Account. You may ask us to delete your Account from your Account settings, or by contacting hey@trygateway.sh. We will ask you to sign in again and confirm the request, and a member of our staff reviews it before it takes effect. When it takes effect, we:

• remove your connected Servers and revoke Gateway's access to them, and delete any Gateway Cloud servers with their disks;
• cancel your paid subscriptions;
• end your sessions, your connections to Third-Party Services, and your team memberships; and
• remove your name, email address, and sign-in methods from your Account.

Removing a Server does not remove the public key Gateway added to it. We will tell you which keys to remove from your Servers.

If you are the only owner of a team, you must transfer ownership or delete the team first. We may be unable to act on a deletion request made through your Account settings while your Account is under review or subject to a payment dispute or legal obligation, and in that case we will help you through support.

Deletion is subject to information we must or may lawfully retain, for the periods described in section 14, for purposes including:

• billing and accounting;
• fraud, abuse, and security prevention;
• audit integrity;
• resolving disputes or enforcing legal rights; and
• complying with legal obligations.

We may need to verify your identity before acting on an access, correction, or deletion request.

16. Cookies & Tracking

Gateway uses essential cookies or similar technologies for authentication, session management, security, and user preferences.

We may process limited technical information through infrastructure and security providers for reliability, performance, fraud prevention, and abuse detection.

We do not use advertising trackers to build behavioural advertising profiles, and we do not sell behavioural data.

If we introduce non-essential analytics or tracking that requires consent under applicable law, we will provide appropriate notice and controls.

17. Children

You must be at least 13 years old to use Gateway.

If you are under 18 years old, you must have any permission from a parent or legal guardian required by our Terms of Use or applicable law.

We do not knowingly offer Gateway to children under 13.

If we become aware that we have collected personal information from a person under 13 in circumstances where we should not have done so, we will take reasonable steps to delete or otherwise address that information.

18. Legal Basis - EEA & United Kingdom

If the GDPR or UK GDPR applies to our processing of your personal information, we rely on one or more of the following legal bases as appropriate:

• contract: processing is necessary to provide Gateway and perform our agreement with you;
• legitimate interests: processing is necessary for legitimate interests such as service reliability, security, fraud prevention, abuse prevention, support, and improving Gateway, where those interests are not overridden by your rights;
• consent: you have given consent for a particular processing activity where consent is the appropriate basis; and
• legal obligation: processing is necessary to comply with applicable law.

19. Your Rights - EEA & United Kingdom

Where the GDPR or UK GDPR applies, and subject to the conditions and exceptions in applicable law, you may have rights including:

• access to personal data we hold about you;
• correction of inaccurate personal data;
• deletion of personal data;
• restriction of processing;
• objection to certain processing;
• data portability; and
• withdrawal of consent where processing is based on consent.

To exercise these rights, contact hey@trygateway.sh.

We may need to verify your identity before completing a request.

20. Data Location & International Processing

Gateway is operated from New Zealand but uses global and regional infrastructure.

Information may be stored or processed in New Zealand and in other jurisdictions, including locations where our infrastructure providers, payment providers, identity providers, connected Third-Party Services, or regional Gateway infrastructure operate.

The region selected for a Server may affect where certain Server operations or temporary file transfers are processed. Selecting a Gateway region does not necessarily mean that all Account, billing, security, or control-plane information is stored exclusively in that region.

Where an Account or team has a static egress IP, Gateway's connections to its Servers in that region leave from that address on Gateway's network in that region.

A Private Region provides dedicated Gateway infrastructure as described by the Service, but does not create a general data-residency commitment unless we expressly agree otherwise.

Malware scanning: files stored in or transferred through Gateway may be scanned in either the United States or the United Kingdom. File contents are never sent to Microsoft.

Images and videos checked for child sexual abuse material are sent to the Canadian Centre for Child Protection and may be processed in Canada and the European Economic Area. Reports of child sexual abuse material are sent to NCMEC in the United States and to the relevant New Zealand or other authorities.

Gateway Cloud servers are hosted in the city you choose: Sydney or Melbourne in Australia, Amsterdam in the Netherlands, or New York in the United States. Backups of a cloud server, where you add them, are stored by our hosting provider and may be kept in a different country from the cloud server.

Support requests processed by Anthropic may be processed in the United States or other countries where Anthropic operates.

Where New Zealand privacy law applies to an overseas disclosure of personal information, we take steps required by the Privacy Act 2020, including using applicable safeguards, legal mechanisms, or informed authorisation where required.

21. Data Controller

For the purposes of the GDPR and UK GDPR, where applicable, the controller responsible for the processing described in this policy is:

Next Generation Media Limited
NZBN 9429053566256
New Zealand

Contact: hey@trygateway.sh

22. Complaints

If you have a privacy concern, please contact us first at hey@trygateway.sh so we have an opportunity to investigate and respond.

If you are in New Zealand, you may also make a complaint to the Office of the Privacy Commissioner.

If you are in the EEA or United Kingdom and applicable law gives you that right, you may complain to the relevant local data-protection authority.

23. New Zealand Privacy Act

We handle personal information in accordance with the Privacy Act 2020 where that Act applies.

This includes obligations relating to lawful and necessary collection, reasonable security, access and correction, retention, use, disclosure, overseas disclosure, and notification of notifiable privacy breaches.

24. Teams

A team lets an organisation use Gateway together. A team's Servers, stored secrets, files, jobs, and subscriptions belong to the team rather than to any one member.

What other members can see. Within a team:

• Owners and Admins can see every team Server, and the jobs, job output, files, and activity relating to those Servers;
• Members and Viewers can see the jobs, job output, files, and activity relating to the team Servers they have been given access to;
• work run on a team Server is attributed to the member who ran it, including where it was started through a Third-Party Service, and there are no private jobs on team Servers;
• members can see each other's names, email addresses, and roles in the team; and
• Owners and Admins can see pending invitations, including the email addresses invited.

Stored secrets that belong to a team can be used on the team Servers a member has access to. Gateway never shows their values to any member in the app or its API, but a member who can run jobs on a Server can use those secrets in a job there, and so could print them.

Your personal Servers, jobs, files, and secrets are not visible to a team because you are a member of it. A personal Server becomes visible to a team only if you move it into the team, and only from the time you move it.

Team audit log. Gateway keeps an audit log for each team. It records membership and role changes, server access grants and removals, invitations, members leaving or being removed, Servers moved into or out of the team, ownership transfers, and changes to team settings, together with who made each change and when. The audit log is visible to the team's Owners and Admins, and is retained as an audit record as described in section 14.

Sign-in domains. If a team's Owners require members to sign in with an email address on chosen domains, Gateway checks the verified email address of your sign-in method against those domains when you join the team and when you use it.

Team emails. We send billing emails about a team to its Owners, and platform notices, account holds, and security emails about a team to its Owners and Admins.

Billing and screening. A team's billing details are used to issue its invoices and, together with each member's details, for the sanctions screening described in our Terms of Use.

Leaving a team. When you leave or are removed from a team, your access to it ends immediately. Work you did and things you added remain with the team, attributed to you, for the periods described in section 14.

A team's Owners act for the organisation in requests about the team's information. You keep your own rights over your personal information, including to access and correct it.

25. Optional Paid Features

Some optional features change what Gateway keeps or how it connects. They apply only where you choose them or, for a team, where its Owners do.

Cloud storage. Every Account and every team has a cloud storage allowance for files kept in Gateway: 25 GiB on Free, and the amount included with your plan on paid plans. Files staged temporarily to move them between Servers do not count towards it. Files in cloud storage are retained as described in section 14, or for the longer period your plan includes, unless you choose a longer file-retention option, in which case they are retained for the period you choose, 7, 30 or 90 days, or until you delete them, if sooner. If a longer file-retention option ends, or you move to a plan with a shorter period, we keep your files for a further 7 days so you can download anything you need. After that, your files follow the default period again, and files already older than it are deleted.

Extended audit retention (teams). Where a team subscribes to Extended audit retention:

• job metadata for the team's jobs, being who ran the job, the tool used, the Server, when it ran, and its exit status, is retained for 365 days;
• the command text of jobs is retained for the same period only if one of the team's Owners chooses to keep it. Command text can contain secrets or personal information, and Gateway warns the Owner of this before it is turned on;
• job output is never retained beyond the period described in section 14, which is seven days;
• the team can export these records, or have them delivered to a destination it chooses, such as its own security monitoring system. That destination's handling of the records is the team's responsibility; and
• if the subscription ends, the records remain available to the team for 30 days, so it can export them or subscribe again. After that, records older than seven days are deleted.

Static egress IP. Where an Account or team has a static egress IP, Gateway assigns it a dedicated IP address on Gateway's network in the region chosen. Gateway's connections to that Account's or team's Servers in that region leave from that address, so that they arrive from it. The connection between Gateway and the Server remains encrypted, and using the address does not cause Gateway to store anything extra about those connections or their contents. Files moved directly between Servers still go directly between them.

Gateway Cloud. Where you buy a cloud server, it is hosted for us by Onidel, which stores and processes whatever you put on it. Every cloud server runs a monitoring agent, gateway-cloud-agent, that reports to us its processor and memory use, network bytes sent and received, the number of new outbound SSH connections it makes (never their destinations), changes to its SSH host keys, the agent's version, and when the cloud server shuts down or restarts. The agent does not read your files and does not collect process names, commands, logs, file contents, or the addresses your cloud server communicates with.

• we keep only the agent's most recent report for each cloud server, replacing the one before it, and delete it when the cloud server is deleted;
• each cloud server's monthly transfer totals are kept with your billing records, as described in section 14; and
• we do not scan the disks, backups, or files of your cloud servers.

Deleting a cloud server destroys its disk and any backups. If the law requires us to preserve information, we may keep a copy for as long as the law requires.

26. Student Offer

If you apply for the student offer, we collect your full legal name, your school or university, your student ID number, your expected graduation month, and, if you give them, a school email address and a copy of your student ID or proof of enrolment.

We use this information only to decide your application, to check that each student receives the offer once, and to prevent abuse of the offer.

Your legal name, student ID number and school email address are deleted from your application when it is decided. Any student ID or proof of enrolment you upload is deleted when your application is decided, unless we need to keep it for the same period as other support attachments, for example to deal with a dispute or suspected abuse.

To detect duplicate applications, we keep one-way keyed fingerprints of your school or university combined with your student ID number, of your school email address, and of your legal name combined with your school or university. These fingerprints cannot be turned back into the original information without a secret key that only Gateway holds. We keep them for one year after the later of your expected graduation month and the date of your application. If we end your student offer because of abuse, we may keep them for as long as that decision stands.

We compare these fingerprints across accounts. If an application matches a person who already receives the offer, or who was blocked from it, the application may be declined automatically. We do not tell an applicant why an application was not approved.

We do not use Stripe Identity or any other third-party identity verification service for the student offer.

27. Changes to This Policy

We may update this Privacy Policy from time to time.

If changes are material, we will provide reasonable notice, for example by email or through Gateway.

The updated policy will apply from the stated effective date.

Your continued use of Gateway after that date constitutes acceptance of the updated policy to the extent permitted by law.

28. Contact

For privacy-related enquiries, requests, or complaints, contact:

Next Generation Media Limited
hey@trygateway.sh
New Zealand