Privacy Policy

EARLY SETTLER PRIVACY POLICY (NEW ZEALAND)

Last updated: June 2025

At Early Settler, we are committed to protecting your personal information and maintaining your trust. This Privacy Policy explains how we collect, use, disclose, store, and safeguard your personal information when you engage with us, whether online through our website or digital platforms, in our retail stores, or via our customer service team. We comply with the Privacy Act 2020 (NZ) and the Information Privacy Principles (IPPs), which set out how personal information must be handled in New Zealand.

This Privacy Policy applies to all personal information collected by Early Settler and its related entities in the course of our business operations in New Zealand.

COLLECTION OF PERSONAL INFORMATION

At Early Settler, we collect personal information to deliver quality products, provide exceptional service, and operate our business efficiently. The information we collect depends on how you interact with us.

How we collect personal information
We may collect your personal information in a variety of ways, including when you:

make a purchase in-store or online;
create an account on our website;
join any promotional program we may offer (including Home Club);
sign up to receive marketing or promotional communications;
contact our customer service team;
enter a promotion, giveaway, or survey;
engage with us through social media platforms;
apply for a job with us; or
visit one of our stores, showrooms, or warehouses, where CCTV surveillance may be in operation.

We also collect personal information automatically when you use our website, apps, or digital services through cookies, web beacons, pixels, and similar tracking tools. Occasionally, we may obtain personal information from trusted third-party sources such as payment processors, social media platforms, marketing partners, or advertising networks - where legally permitted or where you have provided consent.

Types of personal information we collect
The types of personal information we may collect include:

your full name, gender, date of birth or age range;
residential, billing, and delivery addresses;
email address and telephone number;
purchase history, loyalty program participation, and service records;
payment method (excluding stored credit card details);
product preferences, responses to promotions or surveys, and customer service interactions;
IP address, browser type, and information about how you use our website or mobile applications.

Why we collect personal information
We collect and use your personal information for reasons you would reasonably expect, including to:

process and fulfil orders;
manage your online account;
provide customer support and respond to enquiries or complaints;
issue refunds or exchanges;
communicate with you about your transactions and purchases;
send marketing communications (with your consent or where permitted by law);
deliver personalised content, product recommendations, or special offers;
improve our website functionality and customer experience;
protect against fraud and ensure the security of our systems, premises, and staff;
meet our legal and compliance obligations;
conduct internal audits, training, analytics, and reporting.

You can opt out of receiving promotional emails or SMS at any time by following the unsubscribe instructions or replying ‘STOP’. However, we may still contact you about service-related matters such as order updates or warranty claims.

In-Store Wi-Fi and Technology Use
If you access complimentary Wi-Fi in our stores or showrooms (where available), we may collect limited technical information for security, analytics, and performance monitoring. This may include your device’s MAC address, IP address, and websites visited while connected to our network. We do not monitor the content of private communications or collect sensitive data through Wi-Fi.

Use of AI and Automated Tools
Early Settler may use artificial intelligence and automated technologies to enhance your customer experience. This includes:

chatbots for answering questions;
product recommendation engines;
fraud prevention software;
automated marketing and website tools.

These technologies are subject to human oversight. If a decision affecting your rights is made solely by automation, you may request a human review by contacting us. We recommend not entering sensitive personal information into automated tools such as chatbots. We do not make decisions with significant legal or similar effect solely using automated processes.

Interest-Based Advertising and Social Media Tracking
We may work with third-party providers (such as Meta/Facebook, Google, and other advertising platforms) to display personalised ads based on your browsing activity. These platforms may collect information such as:

pages viewed on our website;
products you browsed or placed in your cart;
whether you completed a purchase.

This data helps display relevant ads to you across other websites and apps. You can manage your preferences through your browser settings, cookie preferences, or directly on the ad platform (e.g. Google Ads or Facebook Ad Preferences).

Home Club Communications

When you subscribe to our Home Club, we will collect your personal information (such as your name and email address) in order to send you promotional materials, news updates, product announcements, and exclusive offers. After subscribing, you will receive a confirmation email containing an activation link to verify your subscription and commence receiving communications from us.

You can withdraw your consent and unsubscribe from Home Club communications at any time by clicking the ‘Unsubscribe’ link in the footer of our emails, or by contacting us at homeclub@earlysettler.co.nz.

By providing your phone number, you consent to receive marketing SMS from [Brand Name], including promotions and cart reminders. Consent is not a condition of purchase. Message frequency may vary. Standard message and data rates may apply. You can unsubscribe at any time by clicking the opt-out link in the message, replying STOP or by contacting us at [contact number or email].

We handle your personal information in accordance with this Privacy Policy and take reasonable steps to protect it from misuse, interference, loss, and unauthorised access, modification, or disclosure.

Use of Social Media Content
If you tag Early Settler or interact with us publicly on social media (e.g. using branded hashtags), we may use your content - including images or reviews - in our marketing materials, unless you ask us not to. We will never use private messages or closed content without permission. If you would like to opt out, contact our Customer Service Manager or message us directly through the platform.

Customer Feedback, Reviews, and Surveys
We may invite you to provide feedback or submit reviews about your shopping experience. Responses may be published on our website or used internally to improve service. If you raise concerns, we may contact you to follow up.

Call Recording
If you contact our customer service team by phone, your call may be recorded to help us monitor service quality, support staff training, and maintain accurate records. You will be notified at the beginning of the call if a recording is in progress. Call recordings are managed in accordance with the Privacy Act 2020 (NZ). If you do not wish to be recorded, please let us know or choose an alternative contact method such as email or web chat.

Use of Aggregated and De-Identified Data
We may use aggregated or de-identified information (that does not identify you personally) for business improvement, trend analysis, product development, and performance measurement.

Collection and Delivery Services
When using our collection or home delivery service, we may collect or sight additional information such as:

photographic ID;
delivery instructions;
recipient name and contact information (if delivering to a third party).

This information may be shared with third-party logistics partners to fulfil and track your order. You are responsible for ensuring any third party you nominate consents to the disclosure of their personal details.

Warranties, Repairs, and After-Sales Service
When handling a product warranty, service request, or repair, we may collect:

your purchase history and contact details;
correspondence, photos, or documentation;
information provided by third-party repairers.

This information is used solely to assess, coordinate, and resolve the request and meet our obligations under law or warranty.

Job Applicants and Employment
If you apply for a role at Early Settler, we may collect:

your resume, qualifications, and references;
contact details and work rights information;
emergency contact, tax file, and superannuation details (if employed).

This data is used for recruitment and ongoing employment management and is accessed only by authorised personnel and securely stored.

Cookies and Tracking Technologies

Early Settler uses cookies, local storage, and similar tracking technologies on our website and digital platforms to enhance site functionality, remember your preferences, analyse user interactions, and deliver more relevant advertising content.

Cookies are small text files stored on your device that help us recognise repeat visits, personalise content, and monitor website performance. Some cookies are essential for key site features such as shopping cart functionality. Others assist in understanding how visitors browse our site, enabling us to improve the quality and relevance of our content and offers.

We also use cookies from trusted third-party service providers—such as advertising and analytics platforms - that may collect non-personal information including your IP address and browser details. These cookies are anonymised and do not collect your name, address, email, or other directly identifiable information. For logged-in visitors, we only collect a single encrypted identifier that cannot be used to identify you. These cookies may also gather statistical information about how the site is used, and typically expire after one year.

Early Settler uses Google technologies to better understand user behaviour. When you take certain actions on our website (such as making purchases or adding products to your cart), this information may be recorded using Google tools. This enables us to display targeted advertisements when you visit other websites as part of remarketing campaigns.

You can opt out of Google’s and Early Settler’s use of these cookies by visiting Google’s Ads Preferences Manager. You may also view Google’s advertising privacy policies here.

You can manage or disable cookies through your browser settings. However, please note that blocking some cookies may affect your ability to use certain features on our website. By continuing to use our site, you consent to our use of cookies as outlined in this policy.

Third-party services and social media integrations

Our website and digital platforms may include links to third-party websites or integrations with services such as Facebook, Google, Instagram, or other platforms. These services may collect information about you when you interact with our content, login using social media credentials, or use embedded tools (such as reviews, maps, or share buttons). If you choose to connect or communicate with Early Settler through a third-party platform, we may receive certain personal information from that provider, subject to their privacy policy. We encourage you to review the privacy settings and policies of these platforms to understand how your personal information is handled.

Re-marketing and personalised advertising

Early Settler may use re-marketing tools and personalised advertising platforms to display ads to you based on your previous interactions with our website, such as viewing products or abandoning a shopping cart. These tools may use cookies or tracking pixels to show you targeted ads across other websites, social media platforms, and search engines. These services help us share relevant promotions with you and improve our marketing effectiveness. You can manage your preferences for interest-based advertising by adjusting your browser or platform settings, or by disabling cookies.

Children’s Privacy
Early Settler’s website, digital services, and in-store offerings are designed for individuals aged 18 and over. We do not knowingly collect information from children under 18. If we discover this has occurred without parental or guardian consent, we will promptly delete the data. Please contact our Customer Service Manager if you suspect this has happened.

Employee Records

Early Settler collects and handles personal information about employees and job applicants in accordance with the Privacy Act 2020 (NZ). This may include contact details, CVs, work eligibility, payroll and tax information, performance records, leave and attendance data, and health and safety information. We use this information to assess candidates, manage employment relationships, administer payroll and entitlements, monitor safety and performance, and meet our legal obligations. Employee information is only accessed by authorised staff and may be shared with payroll providers, government agencies, or legal advisers where required. Employees may request access to or correction of their personal information at any time by contacting our HR team or Customer Service Manager.

Sensitive information

Early Settler does not collect sensitive information unless it is required or authorised by law, or where you have provided explicit consent. Sensitive information may include details about your health, race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, sexual orientation, criminal history, or biometric data. If we ever need to collect sensitive information, we will explain the purpose of collection and seek your express consent in advance.

HOW WE USE PERSONAL INFORMATION

Early Settler collects, holds, and uses your personal information to deliver the products and services you expect from us and to support the smooth and lawful operation of our business. We only use personal information for the purposes for which it was collected, for related purposes you would reasonably expect, where you have provided consent, or where required or permitted by law.

Processing Orders and Transactions
We use your personal information to process and fulfil orders, arrange delivery or click-and-collect services, verify your identity, manage payments and refunds, issue tax invoices, confirm transactions, and keep accurate records for financial and legal purposes.

Customer Service and Support
Your personal information is used to respond to your enquiries and requests, manage complaints, provide product advice, process warranty claims or repairs, and offer customer service by phone, email, online chat, or in-store. We may retain records of these interactions to ensure consistent service and improve future support.

Marketing and Promotions
We may use your personal information to send marketing communications via email, SMS, post or digital advertising. This may include updates about new products, promotions, exclusive offers, and events - provided we have your consent or are otherwise permitted by law. You can opt out at any time by following the unsubscribe link or contacting us directly. We will only send electronic marketing communications with your consent or where otherwise permitted by the Unsolicited Electronic Messages Act 2007.

Personalisation and Recommendations
We analyse your preferences, purchase history, and browsing behaviour to personalise your experience, provide tailored offers and product suggestions, and enhance your interactions with Early Settler.

Loyalty Program and Membership Management
If you participate in any Early Settler loyalty or rewards program we may use your personal information to manage your membership, track points and redemptions, send exclusive member offers, and deliver special occasion promotions such as birthday discounts.

Website Performance and Analytics
We use cookies and analytics tools to monitor website and app performance, track usage patterns, diagnose issues, and optimise user experience. This includes understanding what content is viewed, how long users stay on each page, and how our digital platforms perform across different browsers and devices.

Fraud Prevention and Security
Your personal information may be used to protect our systems, staff, and customers from fraud, theft, and unauthorised behaviour. We may verify identities, flag unusual activity, and use CCTV in-store to deter theft, monitor safety, and support investigations.

Internal Business Operations
We use personal information to support our day-to-day operations, including staff training, quality assurance, risk assessment, business planning, system testing, and internal reporting. In the event of a business restructure or sale, your personal information may be used to ensure service continuity and compliance with regulatory obligations.

Legal and Regulatory Compliance
We use and retain your personal information to comply with our legal obligations under New Zealand law. This includes taxation compliance, responding to lawful requests from regulators or law enforcement, managing product safety incidents, and handling disputes or legal claims. We may also use your information to enforce or defend our legal rights.

Use of De-Identified and Aggregated Data
We may use de-identified or aggregated information - data that does not identify you - for market research, performance analysis, business insights, or product development purposes.

DISCLOSURE OF PERSONAL INFORMATION

Early Settler may disclose your personal information to trusted third parties where reasonably necessary to carry out our business operations and provide you with goods or services. This may include disclosure to:

· employees and authorised staff who require access to your information to perform their duties;

· service providers such as couriers, logistics and delivery partners, IT support technicians, website hosting providers, cloud storage platforms, customer service tools, marketing and advertising agencies, payment processors, and warranty or repair agents;

· professional advisers such as lawyers, auditors, and accountants;
regulatory or government authorities where required by law or in response to valid legal requests; and

· our related companies or business partners, including those engaged in joint promotions, provided that such use complies with privacy requirements.

These third parties are required to protect your information and only use it for the purposes for which it was disclosed. We do not sell your personal information to any third party.

Overseas Disclosure and Cloud Services

Early Settler may use third-party service providers, including cloud-based platforms, to host, process, and store personal information. As a result, your data may be stored or processed on servers located outside New Zealand, depending on where these providers operate and maintain their infrastructure. This may include services used for website hosting, data analytics, marketing tools, or customer support systems.

While we may not always be able to identify the specific country in which your data is stored at a given time, we take reasonable steps to ensure that any overseas disclosure of personal information is carried out in accordance with the requirements of the Privacy Act 2020 (NZ). This includes requiring contractual assurances that your personal information will be safeguarded against misuse, interference, loss, and unauthorised access or disclosure. While the exact locations may vary, a list of countries where our key third-party providers operate can be made available upon request.

These arrangements help improve our service delivery, security, and website performance. If you have any concerns about how your information is handled or shared, you are encouraged to contact our Privacy Officer using the details provided in this policy.

SECURITY AND RETENTION OF PERSONAL INFORMATION

Early Settler takes the security of your personal information seriously. We implement a combination of physical, electronic, and managerial safeguards to protect your information from misuse, interference, loss, unauthorised access, modification, or disclosure.

Our security measures include secure password protocols, role-based access controls, encrypted transaction technology (such as SSL), firewall protection, intrusion detection systems, and secure file transfer tools. We also conduct staff training, restrict access to personal information on a need-to-know basis, and carry out regular reviews and audits of our data handling practices.

Personal information is stored in both physical and electronic formats. Physical records are stored securely at controlled locations. Electronic records are hosted on secure servers located in New Zealand, Australia or managed by reputable cloud service providers that meet high standards of data protection and service reliability.

When personal information is no longer required for the purpose for which it was collected - and there is no legal obligation to retain it - we take reasonable steps to destroy or de-identify the information in a secure manner. We follow established data retention and disposal procedures to prevent unauthorised access or recovery.

Retention of Personal Information
Early Settler retains personal information only for as long as reasonably necessary, or as required to comply with legal, accounting, or regulatory obligations. Examples include:

· Transaction and tax-related records, which are generally retained for at least seven years in accordance with New Zealand law;

· CCTV footage captured in-store or at our warehouse, which is typically retained for up to 60 days unless it relates to an incident requiring longer retention;

· Customer service records, complaints, or warranty-related correspondence, which may be held for the duration of the product warranty or applicable statutory period; and

· Marketing data, such as subscription and contact preferences, which may be retained until you opt out or request deletion.

You may request the deletion of your personal information at any time, subject to any legal requirements we have to retain certain records. In such cases, we will take all reasonable steps to comply with your request and confirm when the deletion is complete.

Access to and Correction of Personal Information
You have the right to access and request correction of the personal information we hold about you. If you believe that any of your personal details are inaccurate, incomplete, or outdated, you may contact our Customer Service Manager using the details provided in this policy.

In most cases, access requests are free of charge. However, we may charge a reasonable fee to cover administrative costs if your request requires substantial effort to locate or compile the information. In some circumstances, we may decline access or correction if permitted or required by law. In these cases, we will provide you with written reasons for our decision. We aim to respond to access and correction requests within 30 days.

Business Transfer Clause
If Early Settler undergoes a merger, acquisition, restructure, sale of business assets, or any other corporate transaction, your personal information may be transferred to a new owner or controlling entity as part of that process.

Where this occurs, we will take reasonable steps to ensure that the new entity handles your personal information in a manner consistent with this Privacy Policy and the requirements of the Privacy Act 2020 (NZ) We will also ensure your information remains protected throughout the transition.

By continuing to engage with Early Settler or providing your personal information after such a transaction, you acknowledge and consent to these potential transfers, unless you notify us otherwise.

Data Breach Notification

Early Settler takes all reasonable steps to protect personal information from loss, misuse, or unauthorised access. In the event of a privacy breach that is likely to cause serious harm, we will comply with our obligations under the Privacy Act 2020 (NZ). This includes assessing the breach, notifying the Office of the Privacy Commissioner, and informing affected individuals as soon as practicable.

Anonymity and pseudonymity

Where reasonable and lawful, Early Settler will allow you to interact with us anonymously or by using a pseudonym - for example, when making a general enquiry or browsing our website. However, for certain activities - such as processing payments, fulfilling orders, or handling warranty claims - we will need to collect personal information to verify your identity and complete the requested service.

CONTACTING US

Customer Service Manager
Early Settler (NZ)
0800 523 828

For privacy concerns, access requests, or complaints, contact us via the details above.

If you are not satisfied with our response or how we have handled your personal information, you have the right to lodge a complaint with the Office of the Privacy Commissioner (New Zealand):
Website: www.privacy.org.nz
Phone: 0800 803 909

CHANGES TO THIS POLICY

This Privacy Policy may be updated periodically. The most recent version will be available at www.earlysettler.com.nz. Continued use of our services after an update constitutes acceptance of the revised policy.