1. Introduction

• Manuka Health New Zealand Limited (we, usor our) is a leading New Zealand natural health company. We manufacture and sell New Zealand bee products in a range of countries.
• “You/you” and “Your/your” means any visitor to our website, any user of the website, or any purchaser of products from the website or shop.
• We are committed to the privacy and security of any personally identifiable information provided to us by our customers and users. Personally identifiable information is any information that can be linked to a specific individual (e.g. name, address, phone number and email).
• This privacy policy explains how we handle and protect your personally identifiable information. We do this in accordance with the Privacy Act 1988 (Cth) (Act).
• The current version of this Privacy Policy posted on our websites will apply to your use of our websites and our use of your personal information.
• We reserve the right to modify or amend this policy at any time and for any reason. Any material changes to this privacy policy will be posted prior to their implementation. Questions regarding this policy should be submitted via email to privacyofficer@manukahealth.co.nz.

2. Acknowledgements

You acknowledge and agree:

• This Privacy Policy applies to all personal information submitted to or collected by us or any third party providers engaged by us for the purpose of conducting our business (Third Party Providers). By submitting personal information to us (including by purchasing our products), you accept the terms of this Privacy Policy, and you consent to collection, use, disclosure and retention of personal information by us or any Third Party Providers as described in this Privacy Policy.
• If you provide us with any personal information that relates to another individual, you must ensure that you have all necessary consents from that individual to allow us to use that information in accordance with this Privacy Policy.
• If you do not provide us with personal information we request or require, we may not be able to provide certain (or any) products or services to you nor allow you to order products from us or take part in provision of any services by us.
• Our websites may contain links to third party websites or applications. We are not responsible for the privacy practices or content of third party websites or applications.

3. How we collect your personal information

• Cookies
• Cookies are small files of data sent by a website to your browser, which may then be stored on your hard drive or device so we can recognise you when you return. We use cookies for a number of purposes, including to:
• better understand your preferences, including for our products, so that we may enhance your online experience by presenting you with content that is relevant to you;
• improve our products and services; and
• monitor the use of our website, including collecting data on web traffic and activity, to operate it more efficiently and functionally.
• You may adjust your browser settings to notify you when you receive a cookie and, if you wish, to reject it. If you do reject our use of cookies, you may be unable to access certain parts of our Website.
• You can change cookie settings using the Cookie Settings [insert link to cookie settings].
• Directly from you:
• When we operate our business and our websites, we collect, store, process, use and disclose personal information belonging to a range of people. These include our customers, suppliers, people visiting our website and people engaging with us (youor your).
• We may collect your personal information when you use:
• any websites or applications operated by us;
• our social media sites and applications such as Facebook, Instagram, Pinterest, Twitter and TikTok;
• our services to purchase our products from us; or
• our services to engage with us.
• Third Parties: We may also collect personal information from third parties including:
• information provided on your behalf with your consent; and
• from any person who has referred you to us or to whom you are referred.

4. The type of information we collect

• We may obtain a wide range of personal information from you when you engage with us or create a user account with us.
• The personal information we collect includes, but is not limited to:
• your name, email address, delivery address, phone number and/or other contact details if you provide these to us;
• your personal preferences of products you have viewed on our websites or orders of products you have made from our websites;
• your payment information, such as your credit card or billing details, if you make an order from our websites or through our customer service representatives;
• your current location when you use our websites;
• information about your use of our websites, including the time you use or visit our websites, how long you use our websites and what pages you view within our websites;
• information about the device you use to access our websites, including your IP address and information about your device;
• survey information and spend data for our loyalty programmes; and
• any other personal information you otherwise provide to us.
• We collect personal information in a number of ways, including but not limited to:
• when you browse our websites, make enquiries or place orders for our products;
• when you email us or send us messages via our websites, email or our social media sites and applications;
• when you phone us, as telephone conversations with our staff may be recorded;
• when you complete surveys or questionnaires about us or our products;
• when you provide a product or service to us or otherwise work for or with us;
• when you enter any promotions or competitions run by us; and
• in face-to-face meetings with you or at events or conferences.

5. How we use the personal information we collect

We may use your personal information for a variety of reasons and purposes, including but not limited to:

• responding to your enquiries about us or our products;
• taking orders for our products from you and fulfilling those orders;
• measuring, managing, monitoring, developing and improving our websites and services;
• contacting you about our websites, any orders you make or products you may be interested in;
• sending you promotions or special offers from us that we think you may be interested in, including sending electronic messages such as text messages and emails;
• preparing and using data about interest in our products; and
• doing anything else required or permitted by laws, rules or regulations.

6. Who we disclose personal information to

• Other than as set out above, we will not normally disclose your personal information to anyone except our staff, contractors or suppliers who need that information in order to provide or facilitate the provision of our products and services to you.
• We may be required by law to disclose information you provide us with for the purposes of obtaining products or services, in which case we only disclose information to the extent we are required to disclose it and only to those to whom we are required to disclose it, or if necessary to our legal advisors for the purposes of obtaining legal advice. We may also disclose information about someone whose activities could cause harm to others (for example, fraud).
• If we are required by law, or if necessary for debt collection reasons or other purposes, or where you consent, your personal information may be disclosed to a third party, including to third parties based overseas, including New Zealand and the United States of America.
• By agreeing to this Privacy Policy, you will be consenting to the disclosure of your personal information to recipients located, or that store data, outside of Australia, including New Zealand and the United States of America.
• Other than in the circumstances outlined above or as otherwise specifically permitted under the Act, the information you supply to us remains stored confidentially on our secure servers and is not shared with third parties.

7. Security of your personal information

• We take reasonable precautions to make sure that we keep your personal information secure. However we do not provide any warranties or guarantees that your personal information collected when you engage with us or use our website is safe from unauthorised access.
• Where you have authorised us to disclose your personal information to a Third Party Provider, we will take reasonable precautions to ensure your personal information is treated securely and maintained in accordance with this Privacy Policy.
• You acknowledge and agree that our websites are not designed for the processing of sensitive or special categories of personal information, or data that is subject to special regulatory schemes, such as protected health information under relevant legislation. You are responsible for risks that may arise if you enter this kind of information into a search field or take other actions that create or submit information of this type for processing by us or any Third Party Providers.

8. Privacy Breach

• If we believe that there has been a privacy breach involving your personal information, we will identify the issue and take steps to minimise any harm.
• If we believe that the breach has caused, or is likely to cause, serious harm, we will contact the appropriate regulator and take all steps to meet our legal obligations. If appropriate, we will also contact you and anyone else affected by this privacy breach.
• If you believe there may have been a privacy breach, please contact us as soon as possible.

9. Communications with you

• We will (and any authorised Third Party Provider may) send you emails throughout the ordering and purchasing process.
• We will send out promotional material in our newsletters promoting material related to our company and our business. We use email as a means of receiving feedback from you, and we encourage you to email us with your questions or comments.
• We will preserve the content of any email you send us if we believe we have the legal requirement to do so. Your email message content may be monitored by us for trouble shooting or maintenance purposes or if any form of email abuse is suspected.
• From time to time we may send you, and you agree to receive, emails and other promotions relating to services or goods offered by us and our related companies, partners and customers.
• You may opt out of receiving those emails and other promotions at any time by following the opt-out instructions provided in the relevant communication.

10. Accessing or correcting your personal information

• You have the right to request access to your personal information that is held by us at any time and ask that we correct that personal information.
• You can ask for access or correction by contacting us and we must respond within 30 days. If you ask, we must give you access to your personal information, and take reasonable steps to correct it if we consider it is incorrect, unless there is a law that allows or requires us not to.
• We will ask you to verify your identity before we give you access to your information or correct it, and we will try to make the process as simple as possible. If we refuse to give you access to, or correct, your personal information, we must notify you in writing setting out the reasons.
• If we make a correction and we have disclosed the incorrect information to others, you can ask us to tell them about the correction. We must do so unless there is a valid reason not to.

11. What if you’re in Europe

Addendum – European Union General Data Protection Regulation ("GDPR")

• This Addendum applies to the collection and processing by us of your personal data (Personal Data) in accordance with this Privacy Policy if you are located in a country that is a member of the European Economic Area (EEA); being either a member state of the European Union or the European Free Trade Association. It explains particular rights you have in relation to the processing of your Personal Data in addition to those already set out above in this Privacy Policy.
• Manuka Health New Zealand Limited is a data controller for our Website, services provided through our websites, and all other services provided by us.
• If you are in a country that is a member of the EEA, you have the following additional rights in relation to your Personal Data held by us:
• Right to erasure of your information: you have, in certain circumstances, the right to request that the Personal Data that we collect from you is erased. If we refuse any request you make in relation to this right, we will tell you why in writing and how you can make a complaint about our decision.
• Right to object to or restrict processing of your information: you may request that further processing of your Personal Data is restricted in certain circumstances, including while we investigate your concerns with this information.
• Right to object to data processing and right to data portability: you have in certain circumstances the right to request that the further processing of your information is restricted or to object to its processing and the right to data portability (to receive and have transferred the information provided). If we refuse any request you make in relation to this right, we will write to you to explain why and how you can make a complaint about our decision.
• Right to withdraw consent: you may withdraw consent where provided or object to the further processing of your Personal Data under certain circumstances. If we refuse any request you make in relation to this right, we will write to you to explain why and how you can make a complaint about our decision. The withdrawal of your consent will not affect the processing of your information that you had consented to.

12. How to make a complaint

• If you wish to contact us about your privacy, including for any of the purposes outlined in this Privacy Policy or to make a complaint about how we handle your personal information, you can contact us at privacyofficer@manukahealth.co.nz.
• If you have a complaint and feel that this has not been resolved by us to your satisfaction, you may take your complaint directly to the relevant data protection authority in your country (for example in the place you reside or where you believe we have breached your rights). You are not required to let us try to resolve your complaint first before escalating this further.