Privacy Policy
At Whitcoulls Business, we are committed to protecting your privacy.1. Privacy Notice Overview
Whitcoulls 2011 Limited (Whitcoulls, us, we, our) is a trusted Kiwi brand which recognises the importance of protecting and securing personal information.
This Privacy Notice outlines our commitment to protecting your personal information and to give you reassurances of our integrity in how we handle personal information. We respect and value the information provided to us, and we will only use personal information in accordance with applicable privacy laws.
This Privacy Notice applies to personal information we collect, hold, and use about you when we carry out our business activities, such as when you purchase our goods and services, visit our websites or other digital platforms, communicate or interact with us, enter any competitions or complete any surveys or enter our stores.
We may update our Privacy Notice from time to time. Amendments will be published on our web pages www.whitcoulls.co.nz and www.whitcoullsbusiness.co.nz
2. Personal information we collect
We collect personal information to carry out our business activities. The type of information we collect includes name, address, email, phone number, your shopping and marketing preferences, your purchases, delivery information and any other information that you provide to us during our interactions. If you have an online account, we will keep your login details and password.
In most instances, we collect personal information directly from you such as:
- The information you supply when enquiring about or purchasing a product or service (by phone, in person or electronically), when you interact with us via our customer service centre, phone, email, mail, website, complete any survey/application forms, enter any of our competitions or special promotions/activities or when you deal with team members in our stores.
- When you engage with us on social media (such as via Facebook or Instagram).
- When you are present in our stores or surrounding areas, we may collect images and video surveillance of you. In circumstances where there may be suspected unlawful activity we may collect physical appearance details and other information about the incident.
- When visiting any of our websites we may collect the following information: the IP address, domain name, the date, time and duration of visits, the pages and documents accessed, the previous site accessed (i.e. the referring URL), the type of browser being used. See also Cookie, identifiers and remarketing section on other information we may collect.
- If there is an incident/accident while visiting our stores, we may ask you to complete a Health and Safety form.
- When you ‘email a friend’ on one of our products on our websites.
We may also collect personal information from third parties such as from other retailers and the Police to prevent and detect crime and to keep our community safe.
3. The purposes for collecting personal information and who we may share information with
3.1 Use of information
We collect personal information for the primary purpose to market, promote, advertise, sell, and deliver our products and services. In addition, we collect personal information:
- To improve and personalise your experience with us, such as when you are in store, on-line or when otherwise interacting with us.
- To communicate with you and answer any questions or provide information or advice.
- To run competitions, carry out surveys and research analysis. We may run competitions and promotions (either on our own or with third parties) and you may be asked to provide personal information to be eligible to participate. We (and any other third party) will use this information to administer the competition, notify winners and for any other purpose set out in the relevant terms and conditions.
- For warranty and product recall purposes.
- For marketing and retargeting purposes including to market, promote and advertise the products and services of our selected business partners. This includes displaying to you customised or targeted promotional material or advertising (based on your past activity on our websites and other websites) and remarketing our services to you (see below for further information on remarketing). For details on direct marketing, see the Whitcoulls Rewards Members section below.
- To undertake our administrative and operational functions.
- To detect and prevent fraud, criminal or disorderly behaviour and theft and to monitor and ensure the safety of people in our stores.
- To comply with laws or regulations or to comply with any directions given by regulators or authorities.
- Investigate a breach of any of our terms and conditions or any suspected unlawful or criminal activity.
- Administer Whitcoulls Rewards and Business Account Member Card and your Rewards Member Account.
- Target and personalise relevant Whitcoulls advertising for products and services through digital marketing channels including but not limited to Facebook and Instagram, digital display networks, video networks such as Youtube and search services such as Google. This is done through matching customer contact details (e.g. a customer’s email address) with a third party (e.g. the email associated with a Facebook account) through the use of a secure hashing algorithm. This algorithm (known as SHA256) irreversibly hashes a customer’s contact details and ensures that only ‘matched records’ are visible to the third party.
- Promote and market to you the products and services we sell and provide and the products and services of our selected business partners. To do this we may use a third-party service provider to check whether you are a current customer with our selected business partners.
If we are unable to collect personal information, we may not be able to carry out the specific activity or task, such as provide the products or services as requested.
3.2 How we share your personal information
We may disclose your personal information to undertake any of the purposes set out above, or where permitted or required by law or as otherwise detailed in this Privacy Notice. Recipients of your personal information may include:
- Our employees, contractors, or service providers, to the extent reasonably necessary for them to carry out their duties/obligations. This may include internet service providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, research agencies, adtech and martech service providers, lawyers, and business advisors.
- Suppliers of products and services for delivery, product warranty and recall purposes.
- Any person where we are required or permitted by law to disclose information to. This may include the police service, ambulance service, or government departments or regulators within New Zealand in connection with law enforcement activities and emergency services.
- Other retailers and the Police.
Cookie information and browsing history is also shared with third parties – see section below on Cookies, identifiers, and remarketing.
4. Whitcoulls Rewards and Business Account Members
4.1 Additional collection of personal information and uses
In addition, if you are a Whitcoulls Rewards or Business Account Member, we collect the information you supply to us when you apply to be a member, such as name, address, email, phone number, month of birth to administer your membership and enhance your experience with us. As a member we may also collect information:
- About your purchases of products and services, reward redemption history, special shopping preferences.
- You supply to us via your My Account page.
- About your browsing history when you are logged in and browse our website. If you have signed into your account, we can identify you on that visit to our website and on subsequent visits to our site, even where you do not sign in.
- When you email a ‘wishlist’ from our website.
In addition to the purposes set out above, as a Whitcoulls Rewards or Business Account Member we use your personal information to:
4.2 Whitcoulls Rewards and Business Account Members and Direct Marketing
If you are a Whitcoulls Rewards or Business Account Member we may send direct marketing communications and information about products and services offered by us or our retail brands, suppliers, or selected business partners. This may include but is not limited to, by post and if you consent via email, SMS, social media and other electronic channels.
Where we have received an indication to a preference for a method of communication, we will endeavour to use that method wherever practical to do so. By consenting to receive email marketing communications from Whitcoulls, customers may also receive access to a range of exclusive offers and rewards not available to the general public. Click on the link to join Whitcoulls Rewards https://www.whitcoulls.co.nz/register or apply for a business account https://www.whitcoullsbusiness.co.nz/register
We do not provide personal information to other organisations for the purposes of direct marketing unless expressly authorised by you.
5. How we hold and protect your personal information
5.1 How we hold personal information
Whitcoulls holds your personal information in either electronic or hard copy form. When we receive information electronically, we retain this information in our computer systems and databases. This includes computer software programs, internet servers, and hosted internet solutions. Information received in hard copy (commonly paper) is normally retained in our files and a copy may be made to our electronic files.
We may use third party service providers to store your personal information and provide us with services. This means that we may transfer personal information, or access it from, countries other than New Zealand.
We recognise that we are accountable for your personal information wherever it is in the world, and we will take reasonable steps to ensure that any third-party service providers we use can meet our privacy and security expectations.
We retain your information for as long as we need to carry out the purposes of collection, or longer if we are required to by law.
5.2 Security
We use industry standard security measures to safeguard and protect all personal information. This includes taking reasonable steps to protect personal information from misuse, loss, unauthorised access, modification, or unauthorised disclosure.
Wherever your personal information is stored, we take reasonable steps to ensure that it is protected against loss or unauthorised access, modification, use or disclosure. For example:
- Whitcoulls systems are protected by firewalls and modern encryption standards.
- Whitcoulls systems are password protected, and access is monitored and audited.
- All employees are required to adhere to the Whitcoulls IT and Security related suite of policies.
- Access to the personal information we store is limited to those staff members who have a legitimate business requirement to use it.
- We make privacy and information security training available to employees.
- We have a data breach management procedure in place.
- Information is backed up regularly, and backups are encrypted ad held in secure storage facilities.
6. Cookies, identifiers, and remarketing
6.1 Cookies and identifiers
We use cookies and identifiers on our websites. Cookies are small pieces of information captured when a device is used to access online content. We use cookies to ensure a more streamlined online shopping experience, to identify and store personal preferences. We may use temporary (session) cookies or permanent cookies when devices access our websites, which allows us to recognise individual browsers and track the web pages visited and web pages the device has navigated from. We use cookies to help improve the customer experience with us. See section below on opting out of cookies. Outlined below are some other reasons we use cookies:
- To keep track of products or services viewed, so that we can send directly or through third party service providers, information and advertising about those products or services, or other similar related products or services we think may be of interest.
- To measure traffic patterns, to determine which areas of our websites have been visited, and to measure transaction patterns, produce data of web traffic and customer web activity through our websites or apps.
- To research and analyse habits so that we can improve our products, services and online content and customise this to individuals.
- To operate our websites efficiently with a high level of functionality.
- To measure the effectiveness of our marketing initiatives, measure the number of advertising referrals we have received to our websites from other websites.
6.2 Remarketing
Remarketing is where your browsing history on a website is then used to show you advertising related to your history once you have left that website. For example, a product you have viewed on our website may be remarketed to you while you are accessing another website or social media platform. We supply cookie information (from your browser) about your browsing history on our websites to the following remarketing providers (current as at the date of this Privacy Notice and may change from time) Facebook and Google. If you wish to opt-out of remarketing, see Opt-Out Information below.
6.3 Opting out from cookies, analytics and remarketing
You may modify your browser settings to accept or decline cookies. You may also go to www.allaboutcookies.org or to www.aboutads.info/choices for instructions on how to disable cookies. If you choose to configure your computer so that it disables cookies or does not accept them, you may not be able to make full use of our websites.
Here are the links to opt-out of cookies (current as at the date of this Privacy Notice and may change from time to time):
Facebook - https://www.facebook.com/policies/cookies/
Google - https://adssettings.google.com/authenticated
Google Analytics - https://support.google.com/analytics/answer/181881?hl=en
Flashtalking - https://www.flashtalking.com/optout
Quantcast - https://www.quantcast.com/opt-out/
You can opt out of remarketing, here opt out of the DoubleClick cookie and double-check your Facebook Adverts settings
6.4 Links to other websites and services
The Whitcoulls websites may contain links to other sites which are not administered or governed by Whitcoulls. These are provided solely for the convenience of our visitors. We are not responsible for the content of these websites or how your personal information will be handled. We are not liable in respect of any use of these linked websites.
7. Accessing and correcting your personal information
Please contact us (as set out below) if you would like access to the personal information we may hold about you or if you would like us to update or correct it. We may require further information to assist the retrieval of information and or verify your identity and reserve the right to charge a reasonable fee for gaining access.
We will handle any request in accordance with the relevant privacy regulations. Generally, if requested we will amend any personal information which is inaccurate, incomplete, or out of date. If we are not able or unwilling to provide access to any personal information or to correct any personal information held by us, we will provide the reason for declining to provide.
Enquiries on how to access personal information can be emailed to:
privacyofficer@whitcoulls.co.nz
Or by contacting Whitcoulls on 0800 904 584 or by mail to:
The Privacy Officer
Whitcoulls 2011 Limited
Legal Services
Private Bag 92098
Auckland Mail Centre
Victoria St West
Auckland 1142
Privacy Complaints
Any concerns that we may have breached our privacy obligations or to make a complaint please contact us. If you make a complaint, we will endeavour to respond and resolve any complaints promptly. For more information about privacy generally, or if your complaint is not resolved to your satisfaction, you may contact the Office of the Privacy Commissioner at www.privacy.org.nz and on (04) 474 7590.