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Privacy Policy

Touch of Spice Limited (“us”, “we” or “our”), takes its obligations in relation to the privacy of your Personal Information seriously.  In this Privacy Policy, “you” and “your” means the individual providing Personal Information to us.

This Privacy Policy provides information in relation to the basis upon which we collect, hold, use and disclose your Personal Information.  Personal Information has the same meaning as in the Privacy Act 1993 (Act).  In essence, it is information relating to an individual which can be used to identify that individual or which is linked to an identified individual. 

By accessing our website and using our services you agree to the terms of this Privacy Policy.

1.             Updates to This Privacy Policy

2.             This Privacy Policy will be reviewed from time to time to take into account new laws and technology, changes to our operations and practices and the changing business environment.  The most current version of this Privacy Policy is located on this website.

3.             Use and disclosure of Personal Information collected from you is subject to the Privacy Policy in effect at the time such Personal Information is collected.

4.             How We Collect Personal Information

4.1          In general, the Personal Information we collect and hold includes (but is not limited to):  your name, phone number, email address and physical address, dietary requirements, payment information, information relevant to activities you book (eg height and weight), the content of all communications and any other information which assists us to provide you our services.  We also collect other Personal Information from you as set out in the Marketing Communications section below.

4.2          We collect your Personal Information when you provide it to us, when you contact us, or when you make a booking (whether online or over the phone, including through third party service providers such as Airbnb and Booking.com). We also collect your Personal Information through your use of our services, through your use of our website and when you interact with marketing communications we send you.  Your Personal Information may also be collected from third parties you authorise us to contact, or by agents who are authorised by you to provide such information, or as otherwise permitted by the New Zealand Privacy Act 1993 (Privacy Act).

4.3          This website may also state other ways in which we collect information from you. 

4.4          If you access this website from outside of New Zealand, you agree that any Personal Information you provide us is subject to this Privacy Policy and the Privacy Act.  This Privacy Policy will also apply where we tell you it applies when collecting Personal Information (for example in a face to face situation).

4.5          We may also use cookies on this website.  A cookie is a small data file stored on a device with a web browser (eg computer or ipad).  It can contain information about your device, your IP address, your session, and the online activity on this website of anyone using your device.  Most browsers allow you to disable or reject the use of cookies.  If you disable or reject the use of cookies some functionality on this website may not be available or it may take longer to use that functionality.

4.6          We also use social media services like Instagram, Twitter, LinkedIn, Google + and Facebook.  These services may be linked to this website through the use of social media buttons.  Your use of these third party services is entirely optional. We may make use of any information that you make public when you use any such third party services for the purposes of our business.

4.7          We may also use third party booking and payment services provided by third parties necessary to provide you with our services.

4.8          All third party services are governed by the privacy policies and/or practices of the third party service providers, for which we are not responsible.  If you do not want to provide Personal Information to any of those third parties, or make information publicly available, you should not use their particular service.

5.             Where Personal Information is not Provided

5.1          If you do not provide the Personal Information that this website asks you to provide, or the information is incorrect, we may not be able to provide the requested services to you.  For instance, if you do not provide your contact details we will be unable to secure your booking. Where you use the contact or enquiry function, if the requested information is not provided we may not be able to address your message or answer your enquiry.

6.             Purposes For Which We Collect, Use And Disclose Personal Information

6.1          We collect Personal Information for the following purposes:

6.1.1      to conduct our business, which may include reviewing, analysing and improving our own processes;

6.1.2      to provide you with the services you have requested, including to book and provide accommodation, concierge and other travel and event services, to facilitate payment of such services, to confirm relevant details in relation to your booking (such as arrival details and location of the property) and to identify you when we provide those services;

6.1.3      to optimise your experience as either a customer of our services or a user of this website;

6.1.4      to send you our newsletters, and to keep you updated with our services and to provide our marketing material to you, including letting you know about our special offers and promotions (where you have signed up to receive these marketing communications);

6.1.5      to assess a request to list a property with us (where you are contacting us to list your property);

6.1.6      to communicate with you, which includes responding to any message or enquiry you send us and identifying you when you want to communicate with us;

6.1.7      to take any action in any case of dispute, or legal proceeding of any kind between you and us, or between you and any other person with respect to our business;

6.1.8      to comply with our legal obligations; and

6.1.9      any other purpose made known to you when collecting the Personal Information.

6.2          We may use and disclose your Personal Information for any of these purposes, in any circumstances authorised by the Privacy Act, or in any other manner with your consent.

6.3          Where you provide your email address to us, you agree that we may contact you using that email address for any of the above purposes.

To whom we disclose your Personal Information

7.1          We may disclose your Personal Information to any third party where that is the purpose for collection or you have consented.  In particular, we may disclose your Personal Information to the third party provider of any services you book through us in order for them to provide the service to you.  They will handle your Personal Information in accordance with their privacy policy. We may also collect your Personal Information from these third parties as part of managing the provision of those services.

7.2          We may also disclosure your Personal Information to third party providers we use to assist us with marketing communications as set out in the section below on Marketing Communications.

7.3          We do not otherwise share your Personal Information without your consent, except where permitted by the Privacy Act, unless we believe it is necessary:

7.3.1      to enforce the terms and conditions of this website, or where it is legally required to do so;

7.3.2      for us or other authorised agencies (including credit card and EFTPOS facility providers) to detect, investigate, prevent or address, fraud, security or technical issues;

7.3.3      to otherwise protect our property, legal rights, or that of others; or

7.3.4      for the purposes of carrying out the matters noted in the section below on the Management of Personal Information.

8.             Marketing Communications

8.1          We collect, use and disclose your Personal Information only where we have a legal basis to do so, including where you have provided your consent in accordance with the relevant law, and where it is necessary for the purposes of our legitimate interests of conducting our business. Our legitimate business interests include managing and analysing our customer data, understanding your interaction with our marketing communications, and reviewing our own processes with the aim of improving our services, website and marketing efforts, including our online marketing efforts.

8.2          We use third parties to assist us to send you our marketing communications.  We provide those third parties with your name and relevant contact information, such as email and physical address and telephone number.  Such third parties may be offshore, including in the United States. Some countries where such third party service providers are based may not have privacy laws as comprehensive as in your country of residence, and for EU residents, may not have an adequacy decision by the European Commission. 

8.3          Where marketing communications are sent by electronic means that third party will collect information about your interaction with the communication and may collect information about your activity on our website. This information includes whether you opened the email, the links you clicked on, the webpages viewed and the dates and times of such access and activity.  Information about the device used to access the marketing communication may also be collected.  The third party provides this information to us for the various purposes outlined in this Privacy Policy. We will retain such information for the duration of your relationship with us, as needed to provide you with our services (including marketing our services in line with our legitimate business interests), or to meet any legal obligations. We will not hold your Personal Information for longer than is reasonably required for the lawful purpose for which the information was collected.

8.4          Some of these third parties also use the information that we provide them and which is collected from your interaction with our marketing communications for their legitimate business interests, such as to provide, support and improve the services they provide and to undertake data analytics projects.  We do not permit them to use your Personal Information to market their or any other person’s services to you.

8.5          We currently use MailChimp to assist us in sending marketing communications.  MailChimp is located in the United States.  Please read their privacy policy to understand the ways in which they collect, hold, use and disclose such Personal Information.  For EU residents, please also read the sections of their privacy policy addressing the collection of data from EU residents.  If you do not agree with how they will handle your Personal Information then you will need to unsubscribe from receiving marketing communications from us. 

8.6          You may unsubscribe from receiving marketing communications from us in accordance with the unsubscribe facility in any email sending you marketing communications or by contacting us in accordance with the Contact Us section below.

8.7          We will not be able to provide marketing communications to you if you unsubscribe or do not agree to our use of third parties to assist us with our marketing communications.

8.8          Where you sign up to receive marketing communications from us, you agree that we may disclose your Personal Information to those third parties as set out above.

Management Of Personal Information

9.1          Except as otherwise stated in this Privacy Policy, your Personal Information is collected and held by us. Our address is set out in the Contact Us section below. 

9.2          We also use other third-party service providers to facilitate your payment and manage your booking. In general, these third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.

9.3          We may transfer Personal Information to other third parties to perform services on our behalf, to process the information for us or hold it on our behalf.  These third parties may be offshore, but we will not authorise them to use such information for their own purposes.

9.4          As required by the Privacy Act, we take reasonable steps to protect Personal Information held from misuse and loss and from unauthorised access, modification or disclosure.  We do this by, for example, use of passwords and restricted access to electronic records.  Our personnel are required to respect the privacy of your Personal Information.

9.5          Where we no longer require your Personal Information for a permitted purpose under the Privacy Act, or you have withdrawn your consent to use your Personal Information, we will take reasonable steps to delete it.  

Contact Us

10.1        You have the ability to seek access to your Personal Information and to ask for it to be corrected if you think it is wrong.  Subject to the exceptions set out in the Privacy Act, you may seek access to, or seek the correction of, the Personal Information which we hold about you by contacting us as follows:

Email: [email protected]

Address: Remarkables House, Level 2, 26 Hawthorne Drive, Queenstown 9300  

Telephone: +64 3 450 0855

10.2        If you contact us, we will require you to verify your identity and specify what Personal Information you require access to. 

10.3        If a dispute were to arise between us and we cannot resolve this with you, then you may contact the Office of the Privacy Commissioner whose Website is here.

10.4        For EU residents where the General Data Protection Regulation (GDPR) applies, you have the right to restrict processing, or to object to processing and data portability as set out in the GDPR. You may also lodge a complaint with a supervisory authority.

11.          Governing Law

11.1        This Privacy Policy is governed by the laws of New Zealand.