PRIVACY POLICY

Tui Fleming

August 2018


The Website and its content is owned by Tui Fleming (also referred to as ‘We’ or ‘Us’). The term “you” refers to the user or viewer of the Website.

Please read this Privacy Policy carefully. We reserve the right to change this Privacy Policy on the Website at any time without notice and if we do change it, we’ll always let you know via email and/or pop up prominent notice on our Website.

OUR PRIVACY POLICY: OVERVIEW

We hold the privacy of your personal information in the highest regard.

The following Privacy Policy governs the online information collection practices of Tui Fleming t/as Tui Fleming (Tui Fleming).

It outlines all of the types of information that we gather about you while you are using the tuifleming.com website (Website) and the ways in which we use this information.

For example, it describes how we collect, use, store, process and distribute your information, including Personal Data used to access this Website.

Personal Data is any information which can personally identify you, including but not limited to basic contact information such as your name, phone number, address, and email address which enables us to send information or process your product or service order and/or personal information you give us when you provide feedback, change your content or email preferences, respond to a survey, or communicate with our customer support.

It may also include your date of birth, job title, employment history, qualifications, tax file number, credit and financial details, bank account details, and any other information relevant to providing you with the Services or Products.

We will not use or share your information with anyone except as described in this Privacy Policy. We will never sell, barter, or rent your email address to any unauthorised third party – that’s just not how we do business.

OUR PRINCIPLES OF DATA PROTECTION

We respect the privacy of our online visitors. This Privacy Policy is a demonstration of our continuing commitment to the privacy of personal information provided by people and customers visiting and interacting with this Website and to the Information Privacy Principles outlined in the Privacy Act 1993 (NZ). These are our privacy principles and values:

Transparency: We are committed to being open, honest and transparent about Personal Data.

Trust: We agree to only use Personal Data for the purposes we say we will and for improving the effectiveness and efficiency of our Services.

Safety: We are committed to keeping Personal Data provided to us secure.

Responsibility: We accept the responsibility of handling Personal Data.

DATA CONTROLLER AND PROCESSORS

We are the data controllers of your Personal Data as we are collecting, storing and using your Personal Data.  We may use trusted third parties as our data processors for technical and organisational purposes, including for payments and email marketing from time to time. We use all reasonable efforts to make sure our data processors are GDPR-compliant and aware of their privacy law obligations.

INFORMATION WE COLLECT AND WHAT WE DO WITH IT

We collect Personal Data from you so that we can communicate with you and provide you with a positive experience when utilising our Website or content, improve customer service and better respond to your individual needs and effectively respond to customer requests.

The type of Personal Data we collect will depend on the circumstances of its collection and the nature of your dealing with us.

We collect Personal Data from you when you register or sign up to our Website, place an order, schedule an appointment through our online booking system, subscribe to our newsletter, respond to a survey or fill out a form. We may collect Personal Data when we run a contest, promotion or other Website feature.

When ordering, purchasing or registering on our Website, you may be asked to enter your: name, e-mail address, mailing address, phone number or credit card information.

We may send you marketing emails with either your consent or if we believe we have a legitimate interest to contact you based on your contact or question. In addition to marketing communications, we may also use your Personal Data to display targeted advertising to you online.

We collect some information about you automatically when you visit our Website or use our Services, like your IP address, device ID, computer and connection information, geolocation information and device type and we may collect data about what pages of our Website you looked at or what links you clicked on.

We use third-party browser and mobile analytics services like Google Analytics® on the Website. You can opt out of Google Analytics at any time. For more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout

We use this data to improve the Website and provide information, Products and Services that may be of interest to you.

The legal basis for processing your Personal Data as described above will typically be one of the following:

  • Your consent;
  • Performance of a contract with you or a relevant party;
  • Our legitimate business interests; or
  • Compliance with our legal obligations.

Collecting or using your Personal Data also helps us ensure that everyone is using our Website in accordance with our permitted uses, and so we can detect and prevent any fraudulent or malicious activity.

You are welcome to opt-out or request for us to delete your Personal Data at any point by contacting us at [email protected]. If you choose not to provide us with certain Personal Data, you may not be able to participate in certain aspects of our Website.

Do we use cookies or pixels?

Yes. We may use the standard “cookies” feature of major web browsers to analyse website traffic and help us provide a better website visitor experience.

Cookies are small files that a website or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognise your browser and capture and remember certain information. 

We may also use cookies and pixels to run advertisements through third party services such as Google Adwords and Facebook Adverts and compile aggregate data about Website traffic so that we can offer better online experiences and tools in the future. These ads may appear on this Website or other websites you visit.

You can control and/or delete cookies as you wish – for details, see aboutcookies.org. You can delete all cookies that are already on your computer and you can choose to disable cookies through your own web browser’s settings.

Do we collect sensitive information?

Not usually. However, we may need to from time to time if you include sensitive information in your survey, application form or if you include it in any client data you give to us. Sensitive information includes information about an individual’s mental health, disability, racial or ethnic origin, criminal convictions, religious affiliation and political affiliation. We will only collect, use or disclose your sensitive information if it is reasonably necessary to carry out our functions or activities and we have your explicit consent.

HOW WE STORE YOUR INFORMATION

We hold your Personal Data in encrypted electronic form, in secure databases or cloud-based platforms that we own and operate or that are owned and operated by our service providers.

At present, we use WordPress for our Website. WordPress.com is a platform provided by Automattic Inc. that allows the Owner to build, run and host this Website.

We use WooCommerce (a WordPress plugin) for our e-commerce requirements, Mailchimp as our email marketing provider and Soundcloud for our audio recordings however these online platforms may change from time to time. All of these platforms are based in the US.

We use our best efforts to ensure the platforms we use for data storage are encrypted and secure. You may refer to the privacy policies of these third party platforms if you are uncertain as to their terms.

We do not otherwise sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our Website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.

We may however use in a general sense (without any reference to your name), your information or Personal Data to create marketing statistics, identify user demands and to assist us in meeting customer needs generally.

Anti-Spam Policy

We hate spam just as much as you do. That’s not our approach to communication so you’ll never receive spam from us. We will always provide you with the ability to opt-out of our communications by selecting the unsubscribe link at the bottom of all e-mails. We will not share your email address without your consent.

Non-personal information

Any non-personal information, communications and material you send to this Website or to us by email, or which we obtain from third parties without promises of confidentiality, may be kept, used and disclosed by us on a non-confidential basis. We are free to use and reproduce any such information freely, and for any purpose whatsoever. Specifically, we will be free to use any ideas, concepts, know-how or techniques contained in such information for any purpose, including developing or marketing our Products or Services.

SHARING, TRANSFERRING OR DISCLOSING YOUR PERSONAL DATA

We aim to keep the Personal Data that you share with us confidential.  We may disclose such information if required to do so by law or in the good-faith belief that we need to do so to protect and defend our rights or property, to protect our users, to investigate or respond to any perceived violations of this Privacy Policy (or our other legal policies) or as otherwise requested by legal or government agencies.

Also, if there is a change of control in our business (whether by merger, sale, transfer of assets or otherwise) your Personal Data could be disclosed to a potential purchaser under a confidentiality agreement.

We may share or transfer non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

When we share data (to the extent that we do from time to time), it may be transferred to, and processed in, countries other than the country you live and if this occurs, we do all we can to protect your Personal Data. We note, however, that your Personal Data will be captured, transferred, stored and processed in accordance with their policies, practices and in compliance with their local regulatory laws.

We will only disclose your Personal Data to other third parties where we have obtained your consent and/or where required by any of the above circumstances.

DATA RETENTION

We retain your Personal Data for the minimum amount of time necessary to provide you with the information and/or Services or Products that you requested from us. We may include certain Personal Data for longer periods of time if necessary for legal, contractual and/or accounting obligations.

SECURITY

We understand that cybersecurity and online fraud is a growing concern for Website users.

We take commercially reasonable steps to protect the Personal Data you provide to us from misuse, disclosure or unauthorized access. We note, however, that data protection and security measures can never be guaranteed and technology and security breaches may occur. We therefore cannot guarantee the security of your Personal Data.

We only share your Personal Data with trusted third parties who use the same or a similar level of care in processing your Personal Data.  If we become aware of a high-risk data breach, we will notify you (and the appropriate authority) within 72 hours.

LINKS

We may link to other websites on our Website. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. We have no responsibility or liability for the content and activities of any other individual, company or entity whose website or materials may be linked to our Website or its content, and thus we cannot be held liable for the privacy of the information on their website or that you voluntarily share with their website. Please review their privacy policies for guidelines as to how they respectively store, use and protect the privacy of your Personal Data.

CHILDREN

Our Website and its content is generally directed to individuals who are at least 16 years old or older. To the extent that we receive Personal Data or information from an individual we believe to be under the age of 16, we will make reasonable endeavours to obtain consent from a parent or guardian.

HOW YOU CAN ACCESS, UPDATE OR DELETE YOUR PERSONAL DATA

You have the right to:

    1. Know what Personal Data we hold about you and to make sure it’s correct and up to date.
    2. Request information about how your Personal Data is being stored and used and request a copy of your Personal Data.
    3. Ask us not to send you marketing emails at any time by sending your request to [email protected] at any time. You can also just follow the unsubscribe instructions contained in our email or marketing communications.
    4. Request that we restrict the processing of your Personal Data if you think the Personal Data is not accurate, unlawful, or no longer needed or object to the processing of your Personal Data.
    5. Request that we amend, correct or completely erase your Personal Data.
    6. Withdraw your consent at any time to the processing of your Personal Data.
    7. Lodge a complaint with a supervisory authority if you feel we are using your Personal Data unlawfully.
    8. Receive Personal Data portability and transference to another controller without our hindrance.
    9. Not be subject to an automated decision based solely on automatic processing, including profiling, which legally or significantly affects you.

You can exercise these rights at any time by sending an email to us at [email protected] which we will respond to within 30 days.

COMPLAINTS AND DISPUTES

If you believe your privacy has been breached or you have a complaint about our handling of your personal information, please contact us using the details provided below and we will make all efforts to respond or resolve the dispute within 30 days.

You can also complain directly to the Office of the Privacy Commissioner in New Zealand. Details about how to file a complaint can be found at https://www.privacy.org.nz or you can contact the Commissioner at 0800 803 909.

CONTACT

If you have any questions about this Privacy Policy, please contact us at [email protected] and we will respond within thirty (30) days.

Last Updated: August 2018