Last updated on 14 February 2022.

1. INTRODUCTION  

This privacy notice provides you with details of how we collect and process your personal information through your use of the website www.empoweredandexpressed.com. 

Alicia Sutton International Limited ("we", "us", "our") complies with the New Zealand Privacy Act 2020 (the "Act") when dealing with personal information.  "Personal information" is information about an identifiable individual (a natural person).

This policy does not limit or exclude any of your rights under the Act.  If you wish to seek further information on the Act, see www.privacy.org.nz.

By providing us with your personal information, you warrant to us that you are over 18 years of age.

2. CHANGES TO THIS POLICY

We may change this policy by uploading a revised policy onto the website.  The change will apply from the date that we upload the revised policy.

3. HOW WE USE YOUR PERSONAL INFORMATION

We may process the following categories of personal information about you:

• Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, app messaging, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

• Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

• User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

• Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

• Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

• We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

Sensitive Data 

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

4. HOW WE COLLECT YOUR PERSONAL INFORMATION

We may collect personal information about you by you providing the personal information directly to us (for example by filling in forms on our site, or by sending us emails). We may automatically collect certain personal information from you as you use our website by using cookies and similar technologies.

We may receive personal information from third parties such as search and/or analytics providers such as Google, advertising networks such as Facebook, providers of technical, payment and delivery services, such as data brokers or aggregators.

5. MARKETING COMMUNICATIONS 

Our lawful ground of processing your personal information to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

We may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. If you are a limited company, we may send you marketing emails without your consent. You can opt out of receiving marketing emails from us at any time.

Before we share your personal information with any third party for their own marketing purposes we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or OR by emailing us at support@aliciajanesutton.com at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal information provided as a result of other transactions, such as purchases. 

6.  DISCLOSURES OF YOUR PERSONAL INFORMATION

We may have to share your personal information with the parties set out below:

• Other companies who provide services to us.
• Service providers who provide IT and administration services.
• Professional advisers including lawyers, bankers, auditors and insurers
• Government or bodies that require us to report processing activities.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.
• Any other person authorised by you.

Many of our third party service providers are based outside of New Zealand. This means your personal information may be held and processed outside New Zealand.

We will only transfer your personal information if we reasonably believe that comparable protections are in place (e.g. the recipient is subject to comparable privacy laws or to an agreement with us that imposes comparable protections).

If none of the above safeguards are available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. 

7.  PERSONAL INFORMATION SECURITY  

We will take reasonable steps to keep your personal information safe from loss, unauthorised activity, or other misuse. We only allow access to your personal information to those employees and partners who have a business need to know such personal information. We will notify you and any applicable regulator of a breach if we are legally required to.

8.  PERSONAL INFORMATION RETENTION  

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the personal information for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including contact, identity, financial and transaction data) for seven years after they stop being customers.

In some circumstances we may anonymise your personal information for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.  ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION  

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at support@aliciajanesutton.com.  

Subject to certain grounds for refusal set out in the Act, you have the right to access your readily retrievable personal information that we hold and to request a correction to your personal information.  Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.

In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the personal information, we will make the correction.  If we do not make the correction, we will take reasonable steps to note on the personal information that you requested the correction.

If you want to exercise either of the above rights, email us at support@aliciajanesutton.com.  Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information, or the correction, that you are requesting).

Where entitled to do so by law, we may charge you our reasonable costs of providing to you copies of your personal information or correcting that information.

If you are not happy with any aspect of how we collect and use your personal information, we should be grateful if you would contact us so that we can try to resolve it for you. 

10. INTERNET USE / THIRD PARTY LINKS  

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.

If you post your personal information on the website’s message board/ chat room, or on a social media site (such as a Facebook group), you acknowledge and agree that the information you post is publicly available.

11. COOKIES  

We use cookies (an alphanumeric identifier that we transfer to your computer’s hard drive so that we can recognise your browser) to monitor your use of the website.  You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

12. CONTACTING US

If you have any questions about this privacy policy, our privacy practices, or if you would like to request access to, or correction of, your personal information, you can contact us at support@aliciajanesutton.com.