1. Data Controller Information
The data controller responsible for your personal information is Strongfresh, located at 50 Broadway, Newmarket, Auckland 1023, New Zealand. You may contact our privacy team at admin@strongfresh.world or by telephone at +64 800 44 44 88 regarding any matters related to this Privacy Policy or your personal data.
As the data controller, we determine the purposes and means of processing personal data collected through strongfresh.world and associated communication channels. We are committed to processing your data lawfully, fairly, and transparently in accordance with the General Data Protection Regulation (GDPR), the New Zealand Privacy Act 2020, and other applicable international privacy legislation.
2. Scope of This Policy
This Privacy Policy applies to all personal data collected when you visit our website, submit inquiries through our contact form, enroll in walking programmes, purchase educational products, or otherwise interact with Strongfresh services. It covers data collected through our website, email communications, telephone conversations, and in-person interactions at our Newmarket office.
This policy does not apply to third-party websites linked from our platform. We encourage you to review the privacy policies of any external sites you visit through links on our website, as their data practices are governed by their own policies and not by ours.
3. Types of Personal Data We Collect
3.1 Information You Provide Directly
When you contact us through our inquiry form, we collect your name, email address, and message content. If you enroll in a walking programme, we may additionally collect your phone number, Auckland suburb, emergency contact details, and any accessibility requirements you choose to share. When purchasing educational products, we collect billing information necessary to process your transaction.
3.2 Information Collected Automatically
When you visit our website, we automatically collect certain technical information including your IP address, browser type and version, operating system, referring URL, pages viewed, time spent on pages, and the date and time of your visit. This information is collected through cookies and similar technologies as described in our Cookie Policy.
3.3 Information from Third Parties
We may receive limited information from payment processors when you purchase educational products or paid services. We do not purchase personal data from data brokers or marketing lists. Any third-party data we receive is limited to what is necessary to fulfil the specific transaction or service you requested.
4. Purposes of Data Processing
We process your personal data for the following specific purposes:
- Responding to your inquiries about community walking programmes, route planning, and educational resources
- Processing programme registrations and managing your participation in walking initiatives
- Delivering personalised route plans and consulting services you have requested
- Processing payments for paid services and educational products
- Sending programme updates, schedule changes, and relevant informational communications
- Improving our website functionality and user experience through aggregated analytics
- Complying with legal obligations under New Zealand and international law
- Protecting the security and integrity of our website and services
We will not use your personal data for purposes incompatible with those described above without obtaining your prior consent. Marketing communications are sent only to individuals who have explicitly opted in to receive them.
5. Legal Basis for Processing
Under the GDPR, we process personal data based on the following legal grounds:
- Consent: When you submit our contact form, enroll in programmes, or accept cookies, you provide consent for the specific processing activities described at the point of collection.
- Contractual necessity: Processing necessary to fulfil our obligations when you purchase services or enroll in programmes constitutes a contractual basis for data processing.
- Legitimate interests: We process certain data based on our legitimate interest in operating and improving our informational services, provided these interests do not override your fundamental rights and freedoms.
- Legal obligation: We may process data where required to comply with applicable laws, regulations, court orders, or regulatory requests.
6. Data Retention Periods
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected. Specific retention periods include:
- Contact form submissions: retained for 24 months from the date of submission, then securely deleted
- Programme registration records: retained for the duration of programme participation plus 36 months for historical reference
- Payment and transaction records: retained for 7 years as required by New Zealand tax and financial regulations
- Website analytics data: aggregated and anonymised after 26 months
- Cookie consent preferences: retained for 12 months, after which consent is re-requested
- Email correspondence: retained for 36 months from the date of the last communication in the thread
When retention periods expire, personal data is securely deleted or anonymised so that it can no longer be associated with you. Anonymised data may be retained indefinitely for statistical and research purposes.
7. Data Sharing and Third Parties
We do not sell, rent, or trade your personal data to third parties. We may share data with the following categories of recipients only when necessary:
- Payment processors for transaction processing (data shared is limited to billing information)
- Email service providers for delivering programme communications and inquiry responses
- Website hosting providers who store data on secure servers within or outside New Zealand
- Analytics providers when you have consented to analytics cookies
- Legal authorities when required by law, court order, or regulatory requirement
All third-party processors are bound by data processing agreements that require them to protect your data in accordance with applicable privacy laws and to process data only according to our instructions.
8. International Data Transfers
Some of our service providers may process data in countries outside New Zealand and the European Economic Area. Where such transfers occur, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission, adequacy decisions, or other legally recognised transfer mechanisms. You may request details of the specific safeguards applied to your data by contacting our privacy team.
9. Security Measures
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:
- HTTPS encryption for all data transmitted between your browser and our servers
- Secure server infrastructure with regular security updates and monitoring
- Access controls limiting personal data access to authorised personnel with legitimate business needs
- Regular review and updating of security practices and incident response procedures
- Staff training on data protection obligations and secure handling practices
- Secure deletion procedures for data that has reached the end of its retention period
While we take reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security but commit to notifying affected individuals and relevant authorities of any data breach as required by applicable law.
10. Your Rights Under GDPR and New Zealand Law
Depending on your location and applicable law, you have the following rights regarding your personal data:
- Right of access: Request a copy of the personal data we hold about you
- Right to rectification: Request correction of inaccurate or incomplete personal data
- Right to erasure: Request deletion of your personal data where no compelling reason exists for continued processing
- Right to restrict processing: Request limitation of processing under certain circumstances
- Right to data portability: Receive your data in a structured, commonly used, machine-readable format
- Right to object: Object to processing based on legitimate interests or for direct marketing purposes
- Right to withdraw consent: Withdraw consent at any time where processing is based on consent, without affecting the lawfulness of prior processing
- Right to lodge a complaint: File a complaint with the Office of the Privacy Commissioner in New Zealand or your local supervisory authority
To exercise any of these rights, contact us at admin@strongfresh.world with sufficient information to verify your identity. We will respond to valid requests within 30 days, or inform you if an extension is necessary.
11. Children's Privacy
Our website and services are not directed at individuals under the age of 16. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us immediately and we will take steps to delete such information promptly.
12. Automated Decision-Making
We do not use automated decision-making or profiling that produces legal effects or similarly significant effects on individuals. Any route recommendations or programme suggestions are prepared by human team members based on information you provide, not by automated algorithms making binding decisions about you.
13. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. Material changes will be communicated through a notice on our website. The date at the top of this page indicates when the policy was last revised. We encourage you to review this page regularly to stay informed about how we protect your data.
14. Contact Information
For questions, concerns, or requests related to this Privacy Policy or your personal data, please contact:
Strongfresh
50 Broadway, Newmarket, Auckland 1023, New Zealand
Email: admin@strongfresh.world
Phone: +64 800 44 44 88