Manuka Innovations Limited (NZBN 9429049321746) and BONNO NZ Limited (NZBN 9429052200045) and their subsidiaries and related entities (we) are committed to protecting the privacy and security of personal information you supply to us. BONNO NZ Limited is the data controller in respect of the personal information we collect and process.
This Privacy Policy (Policy) describes how we collect, use, disclose and protect your personal information. We have also set out how we comply with the Privacy Act 2020 (Privacy Act) when collecting, handling and using your personal information. If you do not agree with our use of your personal information as set out in this Policy, you should not submit your personal information to us.
When you use, visit or participate in our Website, any social media platforms (such as Facebook, Instagram, TikTok, Twitter, Snapchat or YouTube) owned by, affiliated with or administered by us (Social Media Platforms), or where you buy goods from us (Goods) or sign up for our marketing materials, you agree that you have read, understood and accept this Privacy Policy.
We reserve the right to make changes to this Policy from time to time by uploading a revised Policy on the Website. The changes will apply from the date we upload the revised Policy to the Website. Accordingly, you should review this Policy each time you visit our Website or before you provide your personal information to us.
This Policy was last reviewed on 5 September 2024.
What type of information do we collect?
Generally, the type of personal information we may collect from you includes your name, contact information such as residential or business address, phone number(s), email addresses, information about your dog(s), the items you purchase and your purchase history, a record of any correspondence you have with us, date of birth, gender and billing and payment information.
We may also collect government identifiers, such as your drivers licence, passport, as well as your credit history related information for the purpose of running credit checks or facilitating payment for our Goods.
When you create an online account with us, or update your account details, we collect your name, email address, delivery address and phone number, as well as the account password you set.
Other types of information we may collect could relate to your marketing and communication preferences, your location, other contact details, your computer or network and your forms of identification used to verify your identity for registration purposes.
When is information collected?
We collect personal information directly from you when:
(a) you purchase our Goods (whether online or in-person at one of our in-person marketplaces);
(b) if you use the Website to report an issue with the Goods, we collect the information that you provide in that report;
(c) you subscribe to emails from us and interact with surveys embedded in our emails or on our Website;
(d) you make enquiries with us, communicate directly with us or interact with us through our Social Media Platforms;
(e) you use our Website;
We may also collect personal information that you provide to us voluntarily, including:
(a) where you sign up to receive our marketing materials or newsletters;
(b) where you participate in competitions, surveys or special promotions carried out by us; and
(c) otherwise where permitted under the Privacy Act 2020.
Your credit card or payment details for any subscriptions or purchases you make are not collected by us, processed or transmitted by us through the Website. All payments are processed via Stripe (Payment Provider). The use of any personal information you provide to a third-party Payment Provider(s) is governed by the privacy policy and/or terms and conditions of that Payment Provider and is only used by us in order to facilitate your payment to us for the Goods.
We provide these third-party payment providers with information on the subscription or purchase so that they can process the payment for us. These third-party payment providers provide us with confirmation of your payment so that we can deliver the Services and Goods to which you subscribe or purchase. We recommend that you review these entities’ privacy policies before using the Services or purchasing the Goods.
We may also collect your personal information from:
(a) publicly available information; and
(b) third parties: we use third parties to market and deliver our Goods to you. These third parties may collect personal information about you or your purchasing history with us on behalf of us and may also store that information for us. The information collected includes your name and physical address. It may also include e-mail address and phone number(s).
The Website may also automatically collect and store information about your visit, including:
(a) the type of device you use;
(b) your IP address;
(c) the date and time you accessed the Website;
(d) the number of links you have clicked on;
(e) the internet address of the Website from which you linked directly to the Website; and
(f) the pages you accessed while visiting the Website.
We collect, hold, use and disclose your personal information for the following purposes:
(a) to provide Goods to you;
(b) to verify your identity and authenticate your login to purchase Goods (if purchasing through your account) or to make changes to your subscription;
(c) help support our sale of the Goods, and manage, monitor, maintain, develop or improve the content and functionality of the, Goods and the Website;
(d) analyse usage of the Website and the Goods, including to understand purchasing preferences, popular features and other user engagement and behaviour;
(e) to respond to communications from you, including if you make a complaint;
(f) resolve disputes and investigate complaints or any other matter concerned with the use of the Goods;
(g) enforce our Terms of Use or our Terms of Trade;
(h) to facilitate payment for the Goods;
(i)anonymise or aggregate data for our research or business purposes;
(j) to provide you with information and otherwise market the Goods to you where you have previously purchased Goods or have signed up to receive our marketing communications;
(k) inform you of our Goods, promotions, new products or services and other marketing activities;
(l) where it is necessary for our legitimate interests of conducting our business which include:
(i) seeking feedback in relation to the Goods;
(ii) promoting the Goods;
(iii) managing, reviewing, analysing and improving the Goods and processes (including any employment processes if you are an employee or are applying for employment with us);
(iv) education, training and development requirements;
(v) complying with our legal obligations, including health and safety obligations and for detecting fraud or suspected fraudulent behaviour; and
(m) any other purpose made known to you when collecting your personal information or any lawful purposes authorised by the Privacy Act and any other applicable privacy laws.
We may disclose your personal information:
(a) to enforce this Privacy Policy or our General Terms and Additional Terms and Policies;
(b) where required by law such as to comply with a subpoena or similar legal process;
(c) when we believe on reasonable grounds that disclosure is necessary to protect our property, legal rights, your safety, or the safety of others;
(d) in order for us or other authorised agencies to detect, investigate, prevent or address fraud, security or technical issues;
(e) to respond to a government request to which we are obliged by law to respond, or where the Privacy Act 2020 permits us to respond;
(f) to any third party with your prior consent; and
(g) one of our third-party service providers who provide services to us including accounting software agencies, research, mailing houses, promotion and advertising agencies and data [management] agencies.
We may be required to disclose your personal information where requested to do so by a government authority. Where an authority requests your personal information from us, we will:
(a) review and consider the legality of the request; and
(b) where we disclose your personal information, we will disclose this only to the extent required to meet our legal obligations.
Under no circumstances do we sell, rent or otherwise make your personal information available to any third party.
We use various third parties to enable us to provide the Goods.
We seek to ensure that all of our agreements with third party service providers contain appropriate safeguards in respect of your personal information however we may authorise a third party to use such data for their own purposes, however this will only be in relation to aggregated or anonymised data so that it will not be personally identifiable to you.
Where you are outside of New Zealand, your personal information is transferred to New Zealand (which has an adequacy decision of the United Kingdom and the European Commission) and the other places referred to in this Policy.
We also transfer personal information to other companies (being technology providers, providers of business and marketing services and providers of software tools used by us in our business) to provide services on our behalf. These third parties may be based in countries that do not have an adequacy decision by the United Kingdom or the European Commission. For example, your personal information is stored on AWS servers in various countries including the United States.
Our agreements with our third party providers contain appropriate safeguards in respect of your personal information, such as standard data protection clauses. The third-party providers are also required to maintain the confidentiality of the information and are not authorised to use that information for their own purposes. For more information on the transfer of personal information to other jurisdictions please read the section entitled “Cross-border data transfers”.
We take all reasonable steps to store personal information and safeguard it against loss, misuse, or unauthorised disclosure. Despite taking all reasonable steps to safeguard the security of personal information, we cannot guarantee that your personal information cannot be accessed by an unauthorised person (e.g. a hacker) or that unauthorised disclosures will not occur.
We may use, disclose and otherwise process your personal information for any of these purposes, where the information is in a form in which the individual concerned is not identified, or for any other purpose authorised by you or by the Privacy Act and any other applicable privacy laws.
We are a New Zealand-based company and many of our external third party service providers are based outside the UK and the European Union (EU). Accordingly, to the extent you are based within the UK or the EU, the processing of your personal information may involve a transfer of information outside of these jurisdictions. Where your information is transferred to any country outside the UK or EEA, we ensure that this is done using specific legally-approved safeguards.
In the case of data transfers to the United States such safeguards are provided by either the EU-US Data Privacy Framework or the UK Extension to the EU-US Data Privacy Framework (see here [insert link]) as the case may be, standard contractual clauses approved by the European Commission or a supervisory authority, or the UK’s international data transfer agreement (IDTA) and the international data transfer addendum to the European Commission’s standard contractual clauses for international data transfers (Addendum), Binding Corporate Rules or approved certifications or codes of conduct to protect the data so transferred.
You can request further details and a copy of these safeguards by contacting us using the contact details set out at the end of this Policy.
We will retain personal information about you for as long as is necessary for the purpose for which it was obtained, including for the purposes of satisfying any legal, accounting, or reporting requirements, to manage backups of your personal information in accordance with our security practices, and to address any claim that might be made during or after your membership with us (or your employment with us (if you are an employee)).
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
When any personal information is uploaded to our Website or platform, it sends it over the internet using the https protocol. We also encrypt your personal information to help prevent others from reading it while it is in transit from your device to our Website.
We treat data as an asset that must be protected against loss and unauthorised access. To safeguard the confidentiality and security of your personal information, we use industry standard practices and technologies including but not limited to "firewalls", encrypted transmission via SSL (Secure Socket Layer) and strong data encryption when it is stored to disk. However, because the Internet is an open network, we cannot warrant or guarantee that your personal information is 100% safe from unauthorised access or use. Your personal information may be kept on computer systems operated by third parties. We will take reasonable precautions against unauthorised access and disclosure by those third parties.
While we use reasonable and appropriate technical and organisational measures to protect your personal information, we are also reliant upon you to do the same.
We only want to communicate with you if you want to hear from us. With your permission, we may send you information such as newsletters and promotional materials about us and our Goods.
To keep you informed of the latest improvements, we may send you a newsletter and other marketing communications, where you have signed up to receive such communications. Where we obtained your consent to receiving the newsletter or other marking communications, you may withdraw your consent at any time by contacting us via info@bonno.nz.
We may use third parties to assist us to send you our newsletters and other marketing communications. We provide those third parties with your name and relevant contact information. Such third parties may be in countries that do not have an adequacy decision by the United Kingdom or the European Commission.
The relevant third-party (where applicable) will collect information about your interaction with the communication. The information collected 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 or makes available this information to us for the various purposes outlined in this Policy. They may also hold this information on our behalf.
While these third parties are primarily collecting this information on our behalf, 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. However, we do not permit them to use your personal information to market their or any other person’s services to you.
We may use a third party service like Klaviyo for the purpose of sending our marketing communications. Klaviyo is located in the United States, which does not have an adequacy decision by the EC. If we use Klaviyo, we will ensure that our agreement with Klaviyo contains safeguards in respect of your personal information, such as standard data protection clauses.
To understand the ways in which the third party service provider as named above collects, holds, uses and discloses personal information, please read their privacy policy available here.
If you do not agree with how the third party service provider will handle your personal information then you will need to unsubscribe from receiving marketing communications from us. We will not be able to provide newsletters or marketing communications to you if you unsubscribe.
We may promote third-party advertisers on the Website or in connection with the Goods. Clicking advertisements may redirect you to websites where the third party’s collection, use or disclosure of personal information you provide to them is beyond our control.
We will never share or sell personal information collected by us to advertisers - even when you are logged in and click an advertisement. Different sites have very different privacy practices and policies. We recommend you locate and read the privacy policy of any site you are redirected to.
We, along with our affiliated partners and service providers, use cookies and other technologies to provide the functionality of our platform and Website. Cookies are small data files stored on a device with a web browser such as a personal computer, tablet and smartphone. A cookie can contain information about your IP address, your device, or the online activity of a person who uses that device. The information in each cookie is sent to the party that controls that cookie.
We use cookies where it is necessary for our legitimate interests of conducting our business, which may include managing, analysing and improving our Website or optimising your experience as a user of our Website. If you do not agree with our use of cookies you can manage and control them through your browser, including removing cookies by deleting them from your browser history (cache) when you leave the site.
We also use third party cookies for marketing and to gather Website analytics. When we collect cookies from third parties, that information is collected in aggregated form. Where a third party is collecting the information, you will need to opt out in accordance with the process set out in the third party’s privacy policy or ad preferences material.
If you follow a link on our Website to another Website, the owner of that sit will have its own privacy policy relating to your personal information. We suggest you review that site’s privacy policy before you provide personal information.
While we take reasonable steps to maintain secure connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.
We may occasionally update this Privacy Policy. We encourage you to review it periodically to stay informed about how we are helping to protect the personal information we collect.
Your continued use of our Website and membership services constitutes your agreement to this Privacy Policy and any updates. The change will apply from the date that we upload the revised statement.
Subject to certain grounds for refusal set out in the Privacy Act, you are entitled to access your personal information held by us and request correction of it, in accordance with the Privacy Act. If you live in certain other jurisdictions, you may have other rights.
Before we supply any information to you, we will need evidence that you are the individual to whom the personal information relates.
If your personal information is wrong you can ask for it to be corrected. If we consider the correction is reasonable (and we are reasonably able to make it) we will make the correction. If we do not make the correction, you may request that we note on the personal information a statement of the correction sought but not made.
If you want to exercise either of the above rights, email us at the address provided below.
We will respond to your request within one month of receipt of your request. In some cases we may not be able to fulfil your request to exercise the right before this date and may need to request more time. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request.
We may charge you our reasonable costs of providing to you copies of your personal information or correcting that information.
We are committed to dealing with privacy matters quickly and appropriately.
To exercise any of your above rights, or if you have any questions about this Privacy Policy, please contact our Privacy Officer:
Name: Privacy Officer
Email: Privacy@Bonno.nz
Address: 494a Kerikeri Road, Rd 3, Kerikeri, 0293, New Zealand
We will work with you to resolve any query, problem or complaint that you have in accordance with applicable privacy laws.
If you have a complaint about the way we have handled your personal information, you may contact our Privacy Officer using our contact details above.
If a dispute arises between us and we cannot adequately resolve it, you may lodge a complaint with the Privacy Commissioner.
For more information on privacy, see the Privacy Commissioner’s Website at https://www.privacy.org.nz/.
