Privacy Policy.

Growth Partners Limited (Growth Partners) is committed to ensuring that your privacy is protected. This Website Privacy Policy sets out how we use and protect any information that you provide us through this website (Website). By visiting the Website, you are accepting the terms of this Website Privacy Policy and we have the right to use your information as described here. We reserve the right to modify this Website Privacy Policy at any time. Growth Partners is bound by privacy regulations in New Zealand. This includes the Privacy Act 2020 (Act) and the Information Privacy Principles that the Act is based on. This Website Privacy Policy does not limit or exclude any of your rights under the Act.

What we collect

We may collect the following types of personal information:

• your name, email address and contact information
• demographic information such as postcode, preferences and interests
• technical and usage data, including your IP address, device type, browser session information, the webpage you visited before coming to our Website, the pages you visit on our Website and how long you spend on them, links you click on, and any identifiers associated with your device
• other information relevant to customer surveys and/or special offers

Collection of personal information

Directly

When you use some parts of our Website and/or services we might ask you to provide personal information to us. For example, we ask for your personal details and contact information when you: use our Website and/or services; complete a customer survey; or provide feedback to us through our Website or email.

You do not have to provide us with your personal information if you do not want to. However, if you choose not to, you may be unable to use some parts or all of our Website and/or services.

Automatically

We collect some information about you automatically when you visit our Website and/or use our services. This information includes your IP address, device type, the webpage you visited before coming to our Website, what pages you are visiting on our Website and for how long, any links you click on while using our Website and any identifiers associated with your device. This also includes the use of Google Signals, a standalone Google product that is integrated within Google Analytics 4. Google Signals enables cross-device tracking and remarketing. This information is used to gain a better understanding of how users interact with the Website across multiple devices and sessions in order to create a better user experience for our customers.

From third parties

In addition to the information we collect directly from you, we may collect personal information from third parties. This may be publicly available information or may be from analytics, marketing or research partners. This information is used to supplement the personal information we already hold about you, in order to personalise and improve our services and to validate the personal information you have already provided to us.

Where we collect personal information about you from a source other than you, we will take reasonable steps to ensure you are aware of: the fact that the information has been collected and the source it was collected from (or, where naming the source is not practicable, the fact that it was collected from a third party); the purpose of collection; the intended recipients; our name and contact details; whether supply of the information was voluntary or required by law and any consequences if it was not provided; and your rights of access to and correction of the information, as set out in the "Controlling your personal information" section below. We will do this unless an exception under the Privacy Act 2020 applies.

We do not collect any sensitive information about you (as that term is defined in the Act), including details about your race, ethnicity, religious beliefs, sexual orientation, political information or any other genetic or biometric data.

What we do with the information we gather

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

• providing you with our services
• internal record keeping and statistics
• to improve our products and services
• to periodically send promotional emails about new products, special offers or other information that we think you may find interesting, using the email address you have provided
• to contact you for market research purposes
• to customise the Website according to your interests
• to provide your information to our third party partners for marketing or promotional purposes (they may not use this information for any other purpose than what we have instructed them to do)
• to protect and/or enforce our legal rights and interests, including defending any claim

We will never sell your information.

Disclosure of your personal information

Unless expressly authorised by you or under this Website Privacy Policy, we will not disclose your personal information to any third party except in the course of providing our services to you. We may disclose your personal information in the following circumstances:

• to third party service providers who assist us with our use of your personal information, including providers who support our delivery of the Website and/or services to you, who assist us with marketing or promoting our services, or who provide cloud hosting, analytics, IT support, professional advisory, security or AI and automation services
• to government agencies, regulators, law enforcement, courts and tribunals where we are required by applicable laws or regulations to do so or to defend our legal rights (where possible, we will notify you of this type of disclosure)
• to an actual or potential buyer (and its agents and advisers) in connection with an actual or proposed purchase, merger or acquisition of any part of our business
• when we have your express consent to do so

While we store personal information in New Zealand, where we disclose your personal information to the third parties listed above, these third parties may store, transfer or access personal information outside of New Zealand. We will only disclose your personal information overseas in accordance with the Information Privacy Principles.

Data retention

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required or permitted by law. Our retention periods are determined based on the nature and sensitivity of the personal information, the purposes for which we collected and use the information, legal, regulatory, tax, accounting and other requirements and our legitimate business needs. We regularly review our data holdings and securely delete or anonymise personal information that is no longer required.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. The security measures we have in place ensure that New Zealand information handling and storage standards are adhered to.

While we strive to protect your personal information, no data transmission over the internet or any wireless network can be guaranteed to be 100% secure. You transmit information to us at your own risk.

Privacy breaches

We are committed to protecting your personal information and have implemented security measures to prevent privacy breaches. However, if a privacy breach occurs that is likely to cause serious harm to affected individuals, we will respond in accordance with our obligations under the Privacy Act 2020. This includes notifying the Office of the Privacy Commissioner as soon as reasonably practicable after becoming aware of the breach, and notifying affected individuals without unreasonable delay where the breach is likely to cause serious harm, unless we are permitted to withhold notification under the Act.

If you believe there has been a privacy breach affecting your personal information, please contact us immediately using the details below. You may also contact the Office of the New Zealand Privacy Commissioner.

How we use cookies

A cookie is a small file that asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

Overall, cookies help us provide you with a better Website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Website.

Information collected may be used by third party vendors, including Google, to show you related ads on other sites on the internet. Third party vendors, including Google, use cookies to serve ads based on a user's prior visits to our Website. Users may opt out of Google's use of cookies by visiting the Google advertising opt-out page.

This Website uses the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. It could mean that we advertise to previous visitors who haven't completed a task on our site, for example using the contact form to make an enquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Any data collected will be used in accordance with our own Website Privacy Policy and Google's privacy policy.

Links from this Website

This Website's content may include links to third party websites that are controlled and maintained by others. We have no responsibility and we will have no liability for the content and activity of these linked sites. Any link to other websites is not an endorsement of those websites and you acknowledge and agree that Growth Partners is not responsible for any content or claims of any such websites.

Controlling your personal information

You have the following rights with respect to the personal information we hold about you:

• to request access to your personal information
• to request a correction to your personal information
• to request the deletion or removal of your personal information
• to object to or request a restriction on the processing of your personal information
• to request a transfer of your personal information to you or a third party
• to withdraw consent to the use of your personal information

Whenever you are asked to fill in a form on the Website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at our contact page.

To exercise any of the rights listed above, please contact us via our contact page. There are exemptions where access to your information may be denied under the Act, or where we may otherwise be permitted not to action a request. We will notify you if this is the case.

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.

Your choices and opting out

Growth Partners will contact you only if you elect to be contacted. If you choose to receive email messages, Growth Partners may periodically send you email messages describing updates, new features or promotional offers related to this Website. You can choose to stop receiving these emails at any time by following the instructions included in the email or sending a reply stating your request. If you do not explicitly choose to receive informational emails, the only email messages you will receive from Growth Partners will be in response to email enquiries that you send us.

Acceptance of policy

By visiting the Website, you are accepting the terms of this Website Privacy Policy and we have the right to use your information as described here. We reserve the right to modify this Website Privacy Policy at any time. Your continued use of the Website after we either personally notify you or generally post such changes on the Website will constitute your acceptance of those changes. Please also refer to Growth Partners' Website Terms of Use information.

Notification of changes

We may change or update this Website Privacy Policy at any time by uploading a revised Website Privacy Policy to our Website. By using our services and Website you agree to be bound by the Website Privacy Policy that is in effect at that time. We encourage you to check back periodically to review this Website Privacy Policy for any changes since your last visit.

Questions or comments

If you have any questions or comments about this Website Privacy Policy and/or the way it affects you, please contact us via our contact page.

If you feel as if we have not addressed your concern in a satisfactory manner, please get in touch with the Office of the Privacy Commissioner in New Zealand.

Last updated: 1 May 2026

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