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Effective Date: 6 October 2021
Introduction
We know that you care about your personal data and how it is used, and we want you to trust that Fab Group NZ uses your personal data carefully. This Privacy Notice will help you understand what personal data we collect, why we collect it and what we do with it.
As you read our Notice, please keep in mind that it applies to Fab NZ Ltd as defined below.
Please take a moment to familiarise yourself with our privacy practices and let us know if you have any questions by sending us an email to enquiry@caci.co.nz
We have tried to keep this Notice as simple as possible, but if you’re not familiar with terms, such as cookies, IP addresses, and browsers, then please read about these key terms first.
Who is collecting my information?
Any personal information provided to or collected by Caci in New Zealand is collected and held by Fab NZ Limited (as the authorised distributor of Caci in New Zealand), and any company directly or indirectly owned and/or controlled by Fab NZ Limited and its related companies (whether incorporated in New Zealand or elsewhere) that you are interacting with or have a business relationship with (hereinafter referred to as “Fab Group NZ”, “we”, “us” or “our”).
This Privacy Notice also applies to Fab Group NZ’s marketing content, including offers and advertisements for Fab Group NZ products and services, which we (or a service provider acting on our behalf) send to you on third-party websites, platforms and applications based on your site usage information. These third-party websites generally have their own Privacy Notice and Terms and Conditions. We encourage you to read them before using those websites.
What information is being collected?
We are collecting Personal information. Personal information under the Privacy Act 2020 means information about an identifiable individual.
We may collect personal information from a variety of sources. This includes:
- Personal information you give us directly;
- Personal information we collect automatically; and
- Personal information we collect from other sources.
You may be asked to provide your personal information when you are in contact with us. Fab Group NZ entities may share this personal information with each other and use it in a manner and for any purpose consistent with this Privacy Notice.
How are you collecting my personal information?
We may collect personal information from a variety of sources. This includes:
Information collected directly.
We collect information about how you use our services and products, such as when you:
- Register for an account;
- Purchase products or services through our website and any related service, including our social media pages (“Platform”);
- Sign up to a membership through our Platform and agree to the membership agreement;
- Sign up to receive promotional communications from us;
- Join a loyalty, rewards or similar program or club;
- Participate in one of our promotional sweepstakes, contests, surveys, or focus groups;
- Use the Ratings & Reviews or related services and features;
- Submit a request to our Consumer Service team;
- Interact with the Platform and any of our social media pages;
- Apply for a job (including through our Platform) or to be a franchisee.
Information collected automatically.
We also receive and store certain types of personal information whenever you interact with us online such as:
- Visit and navigate our Platform on any device;
- Enable location-based features on our Platform;
- Click on sponsored links or third-party advertisements.
To collect this information, we may use cookies, web beacons, and similar technologies. A cookie is a text file that websites send to a visitor‘s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A web beacon, also known as a pixel tag, is used to transmit information back to a web server. We may also collect information about your online activities over time and across third-party websites. The information we collect automatically may include but is not restricted to:
- Purchases or uses of our services on our Platform or relevant third-party platforms;
- URLs that refer visitors to our Platform;
- Search terms used to reach our Platform;
- Details about the emails we send, such as opens, clicks, and unsubscribes;
- Details about the devices that are used to access our Platform (such as IP address, browser i information, device information, and operating system information);
- Details about your interaction with our Platform (such as the date, time, length of stay, and specific pages accessed during your visits to our Platform, referral activity, and which emails you may have opened);
- Usage information (such as the number and frequency of visitors to our Platform).
- We may associate this information with your account if you have one, the device you use to connect to our Platform, services, or email or social media accounts that you use to engage with Fab Group NZ.
For more information about how we use cookies and how to manage or block them, please refer to the “Cookies” section below.
Information collected from other sources.
We collect personal information from other sources including from our franchisee clinics, our trusted partnerships with third-parties and where we operate Fab Group NZ accounts on third-party platforms. This includes but is not limited to:
- Our franchisees, who you may deal with and who are independent of Fab Group NZ.
- Our business partners, including online advertising networks, analytics vendors, and companies that co-sponsor our promotions.
- Social media sites, including Facebook, Twitter, YouTube, Pinterest, Snapchat and Instagram. The information we receive from these social media sites is dependent upon the social media site’s policies and your settings on that site.
- Third party sites, including those that allow you to integrate your third-party account with your Fab Group NZ account.
- Companies that provide personal information to supplement what we already know about you, including data aggregators. Certain third parties might link your name or email address to other information they have collected. That might include past purchases made offline or online. It might also include online usage information.
How do we use your information?
We collect, use and disclose your personal information only for specific and limited purposes. For example:
- To process your payments, if you purchase Fab Group NZ products, to provide you with your order status, deal with your enquiries and requests, and assess and handle any complaints;
- To provide you with the goods, services and/or information you have requested;
- To process your purchases of a Caci membership or similar treatment purchase;
- To process and answer your inquiries or to contact you to answer your questions and/or requests;
- To develop and improve Fab Group NZ products, services, communication methods and the functionality of our websites (including the Platform);
- For the purposes of competitions or promotions that you have entered;
- To communicate information to you and to manage your registration and/or subscription to our newsletter or other communications;
- To manage our everyday business needs, including regarding your participation in our contests, sweepstakes or promotional activities or request;
- To authenticate the identity of individuals contacting us by telephone, electronic means or otherwise, or when using the Platform;
- For internal training and quality assurance purposes;
- For the business operations and activities of our franchisees, and for the management and support of our franchisees in our role as a franchisor;
- For processing any employee or franchisee application;
- To understand and assess the interests, wants, and changing needs of consumers, to improve our website, our current products and services, and/or developing new products and services; and
- To provide personalised products, communications and targeted advertising as well as product recommendations to you from Fab Group NZ brands on Fab Group NZ sites (including the Platform), and via third-party websites.
We also create profiles by analysing the information about your online surfing, searching and buying behaviour and your interactions with our brand communications by building segments (creating groups that have certain common characteristics) and by placing your personal information in one or more segments.
Additionally, Fab Group NZ processes your personal information also using automated means. An automated decision is a decision which is made solely by automatic means, where no humans are involved in the decision-making process related to your personal information.
Online Advertising & Third-Party Data
Advertising and Analytics Services Provided by Others
We may allow others to provide analytics services and serve advertisements on our behalf across the internet and in mobile applications. They may use cookies, web beacons, and other technologies to collect information about your use of our services and other websites and applications, including your IP address, device ID, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Fab Group NZ and others to, among other things, analyse and track data, determine the popularity of content, deliver advertising and content targeted to your interests on our services and other websites, and better understand your online activity. For details about these types of cookies, and how to manage or block them, see the “Cookies” section below.
We may also work with third parties to serve ads to you as part of a customized campaign on third-party platforms (such as Facebook or Google). As part of these ad campaigns, we or third-party platforms may convert information about you, such as your email address, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and to serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.
Cookies
We use cookies and similar technologies for the following key purposes:
- To recognise your computer or device and greet you each time you visit our websites (including the Platform), without bothering you with a request to register or log-in;
- To keep track of products or services you view, so that we can send you, directly or through third parties, news about those products or services or other similar or related products or services from across Fab Group NZ that we think you may be interested in;
- To measure traffic patterns, to determine which areas of our websites have been visited, and to measure transaction patterns in the aggregate;
- To research our users’ habits so that we can improve our products and services;
- To operate our websites efficiently with a high level of functionality;
- To measure the effectiveness of our marketing initiatives;
- To learn about your preferences so that we can present you with web content and advertising that is relevant to you;
- To measure the number of advertising referrals we have received to our websites from other websites;
- To produce data on web traffic and customer web activity through our website or apps.
While we use cookies to improve our customers’ on-line experience, if you do not wish to allow cookies then you can choose to disable cookies (for all sites) from within your browser settings, however, your experience may be affected.
Who will my information be shared with?
- As a business, Fab Group NZ shares your personal information internally and with selected third-parties in the following circumstances:
- Our franchisees. For example, in order to provide you with goods or services.
- Third-party service providers. In order to carry out our services we share your personal information with third-party service providers that perform functions on our behalf, such as companies that:
- host or operate Fab Group NZ’s websites (including the Platform);
- process payments;
- analyse data;
- provide customer service, postal or delivery services;
- and sponsors or other third-parties that participate in or administer our promotions.
Third-party service providers have access to personal information needed to perform their functions but may not use it for other purposes. They must process this personal information in accordance with this Privacy Notice and as permitted by applicable privacy laws and regulations.
Other third-parties. Your personal information will also be used by us or shared with our sponsors, advertisers, advertising networks, advertising servers, social media networks, and analytics companies or other third-parties in connection with marketing, promotional, data enrichment and other offers, as well as product information.
Business transfers. Your personal information will be used by us or shared between entities in Fab Group NZ for internal reasons, primarily for business and operational purposes. As we continue to develop our business, we may sell or purchase assets, subsidiaries or business units. In such transactions, your personal information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, you consent otherwise). If another entity acquires us, our businesses or substantially all or part of our assets, or assets related to Fab Group NZ’s websites (including the Platform), your personal information will be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets.
Legal disclosure. We may transfer and disclose your personal information to third-parties:
- To comply with a legal obligation;
- When we believe in good faith that an applicable law requires it;
- At the request of governmental authorities conducting an investigation;
- To verify or enforce our “Terms of Service” or other applicable policies;
- To detect and protect against fraud, or any technical or security vulnerabilities;
- To respond to an emergency; or otherwise
To protect the rights, property, safety, or security of third-parties, visitors to the Platform, other Fab -Group NZ websites, Fab Group NZ or the public.
Franchisees
Many of our clinics are individually owned and operated by franchisees who are independent of Fab Group NZ. We and our franchisees may share any personal information collected with each other, and each use such personal information, for the purpose for which the information was collected or for any purpose set out in this Privacy Notice, including to enable us and/or our franchisees to provide products and services to you, and to enable us and our franchisees to conduct our business generally.
Contests, sweepstakes or promotional activities
We will collect personal information provided by you if you participate in our contests, sweepstakes or promotional activities. We collect this information in order to conduct the contest, sweepstake or promotional activity. We may disclose such information to third parties, such as agents, contractors, service providers and prize suppliers to conduct the contest, sweepstake or promotional activity. We may also use and disclose this information as set out in this Privacy Notice. Entry is conditional on providing this information. If the information is not fully supplied the entry may be void.
If you provide us with the names and contact details of any other people that you would like to have participate in our contests, sweepstakes or promotional activities, we will also collect this information. You promise that you have their permission to provide us with this information and for us to use if for this purpose.
How do we protect your personal information?
Fab Group NZ takes the security of your personal information very seriously. We take reasonable technical and organisational precautions to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure.
Our measures include implementing appropriate access controls, investing in the latest Information Security Capabilities to protect the IT environments we leverage, and ensuring we encrypt, pseudonymise and anonymise) personal information wherever possible.
What are your rights?
Under the Privacy Act 2020, you have certain rights to access, and request the correction of, personal information that we hold about you. You can find out more information about your rights on the Privacy Commissioner’s website (https://www.privacy.org.nz/). You can exercise your rights by sending an email to enquiry@caci.co.nz.
Your request will be processed in accordance with the Privacy Act 2020.
If you make an access request, we will ask you to verify your identity. There may be instances where we refuse to grant you access to the personal information we hold (based on a ground contained within the Privacy Act 2020). If that happens, in most circumstances we will give you written reasons for any refusal.
We may charge a reasonable fee for making your personal information available to you or providing you with copies of it.
If you believe that personal information, we hold about you is incorrect, incomplete or inaccurate, then you may ask us to amend it. We will consider if the information requires amendment and will not charge for making any amendments. We may not agree that the information requires amendment. If we do not agree to amend the information, you may ask that we attach a statement of correction to our records, and if reasonable, we shall do so. Registered users of our website can access and update their user details online. We request that you keep your information as current as possible so that we may continue to improve our service to you.
Further information and advice about your rights can be obtained from the New Zealand Privacy Act 2020.
How do you contact Fab NZ Ltd?
The general point of contact for you for any privacy queries you may have is enquiry@caci.co.nz.
If you have any questions or concerns about Fab Group NZ’s Privacy Notice or any privacy related matter or if you would like to make a complaint about a possible breach of applicable privacy laws, please do so by sending an email to enquiry@caci.co.nz.
How do we keep this notice up to date?
We will update this Privacy Notice when necessary to reflect customer feedback and changes in our products and services. When we post changes to this statement, we will revise the “last updated” date at the top of this Notice. If the changes are significant, we may provide a more prominent notice (including, for certain services, email notification of Privacy Notice changes). We will also keep prior versions of this Privacy Notice in an archive for your review.
Additional Privacy Terms or Notices
In addition to this Privacy Notice, there may be specific campaigns or promotions which will be governed by additional privacy terms or notices. We encourage you to read these additional terms or notices before participating in any such campaigns or promotions as you will be required to comply with them if you participate. Any additional privacy terms or notices will be made prominently available to you.
Commercial electronic messages
If you provide us with electronic contact details, you agree that we may send you commercial electronic messages (e.g. texts and emails) for any of the purposes set out in this Privacy Notice.
Consequences for failure to provide
Failure to provide necessary personal information when requested may result in us not being able to provide you with products and/or services, and may result in you not being able to access certain features of the Platform.
