PRIVACY POLICY (we, us or our) respect your right to privacy and understand that protecting your personal information is important. We comply with the New Zealand Privacy Act 2020 (Privacy Act) when handling personal information. This Privacy Policy explains how we collect, hold, use, disclose and protect your personal information and sets out various rights you have in relation to your personal information. We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website at (Website). We recommend you check our Website regularly to ensure you are aware of our current Privacy Policy.  By continuing to use the Website or any of our services, you consent to any such modifications or amendments. The information we collect  Personal information means information about an identifiable individual (a natural person). The types of personal information we may collect about you include: 
  • your name; 
  • your location information (for example your GPS location); 
  • your social media handles; 
  • your age and/or date of birth; 
  • your preferences and/or opinions; 
  • information you provide to us through customer surveys; 
  • your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour; 
  • information about your access and use of our Website, including through the use of Internet cookies, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider; 
  • additional personal information that you provide to us, directly or indirectly, through your use of our Website, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and 
  • any other personal information requested by us and/or provided by you or a third party. 
We may also collect any other personal information you may choose to provide to us, or authorise other persons to provide to us. How we collect personal information  We collect personal information in a variety of ways, including:  
  • Directly: We collect personal information which you directly provide to us, including through the ‘contact us’ form on our Website or when you request our assistance via email, or over the telephone.
  • Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our Website, in emails, over the telephone and in your online enquiries. 
Collection and use of personal information  Personal information: We may collect, hold, use and disclose personal information for the following purposes:  
  • to enable you to access and use our Website;  
  • to enable you to access and use our associated applications; 
  • to contact and communicate with you about our Website; 
  • for internal record keeping, administrative, invoicing and billing purposes; 
  • for analytics, market research and business development, including to operate and improve our Website, associated applications; 
  • for advertising and marketing; 
  • to comply with our legal obligations and resolve any disputes that we may have;  
  • if you have applied for employment with us; to consider your employment application; and 
  • if otherwise required or authorised by law. 
Disclosure of personal information to third parties  We may disclose personal information to:  
  • third party service providers for the purpose of enabling them to provide their services, to us, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, couriers, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators; 
  • our employees, contractors and/or related entities; 
  • our existing or potential agents or business partners; 
  • anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred; 
  • courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you; 
  • courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and 
  • any other third parties as required, with your authorisation, or authorised by law. 
Overseas disclosure: For the purposes above, we may transfer your personal information to parties located outside New Zealand which may not have an equivalent level of data protection laws as those in New Zealand. Before disclosing any personal information to an overseas recipient, we will comply with Information Privacy Principle 12 and only disclose the information if you have authorised the disclosure after we expressly informed you that the overseas recipient may not be required to protect the personal information in a way that, overall, provides comparable safeguards to those in the Privacy Act, or we believe the overseas recipient is subject to the Privacy Act, or we believe that the overseas recipient is subject to privacy laws that, overall, provide comparable safeguards to those in the Privacy Act, or we believe that the overseas recipient is a participant in a prescribed binding scheme, or we believe that the overseas recipient is subject to privacy laws in a prescribed country or we otherwise believe that the overseas recipient is required to protect your personal information in a way that, overall, provides comparable safeguards to those in the Privacy Act (for example pursuant to a data transfer agreement entered into between us and the overseas recipient).  Your rights and controlling your personal information  Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Website to you and your use of our Website.  Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.   Access and Correction: Subject to certain grounds for refusal set out in the Privacy Act, you may request access to, and correction of, the personal information that we hold about you. Please contact us using the details below. We will deal with your request in accordance with the Privacy Act:
  • if you request access to, or a copy of, your personal information, we will provide you with a copy of the personal information we keep about you, then subject to any lawful grounds for withholding the information, if that information is held in a way that it can be readily retrieved. However, we reserve the right to charge you a reasonable amount for providing copies of any personal information you request, to take into account the time, cost and effort involved; and
  • if you request a correction to your personal information and we agree that your personal information needs correcting, an amended record of your personal information will be provided back to you. If we do not agree to your request for a correction, you may request that we take reasonable steps to attach to the information a statement of correction sought but not made.
Retention: We will not keep your personal information for longer than is required for the purposes for which your personal information may lawfully be used.  Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint.  Storage and security  We are committed to ensuring that the personal information we collect is secure. We have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.  While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.   Cookies   We may use cookies on our Website from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our Website and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our Website with personal information, this information may be linked to the data stored in the cookie.  You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our online services.  For further information on cookies and how to switch them off see Links to other websites  Our Website may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.  More information about our Website, and the terms of use applicable to it, can be found at Additional terms that apply to some residents of the European Economic Area (EEA) In addition to the rights already recorded above, if you are based in the EEA, you may have the following additional rights in relation to the personal information we hold about you: Right to erasure You can ask us to delete or remove your personal information in some circumstances, such as where we no longer need it or, if we are relying on your consent to process the information, you withdraw your consent.  If you are entitled to erasure, we will comply with your request.  If we have shared your personal information with others, we will let them know about your request where reasonably possible.  If you ask us, where it is reasonably possible and lawful for us to do so, we'll also tell you who we've shared your personal information with so that you can contact them directly. Right to restrict processing You can ask us to 'block' or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you do not want us to erase your information but require restriction of processing instead.  If you are entitled to restriction of processing of your personal information, and we have shared your personal information with others, we will let them know about the restriction where it is reasonably possible for us to do so.  If you ask us, where it is reasonably possible and lawful for us to do so, we will also tell you who we've shared your personal information with so that you can contact them directly. Right to data portability You have the right, in certain circumstances, to obtain personal information you have provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice. Right to object You can ask us to stop processing your personal information, and we will do so, if we are: –    relying on our own or someone else's legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or –    processing your personal information for direct marketing purposes. Right to withdraw consent If we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. Right to lodge a complaint with the supervisory authority If you have a concern about any aspect of our privacy practices, including the way we've handled your personal information, you can report it to the relevant Supervisory Authority in the EEA. Please be aware that some of these rights may be limited or unavailable where we have an overriding interest or legal obligation to continue to process the data, or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations. Last updated: 18/1/23