Freedom Privacy Policy

As At October 2023

Freedom recognises the importance of protecting the privacy and rights of individuals in relation to their Personal Information. This is our privacy policy and it tells you how we collect and manage your Personal Information.

We respect your rights to privacy under the Privacy Act 2020 (“Act”) and we comply with all of the Act’s requirements in relation to the collection, management and disclosure of your Personal Information. For more information, visit www.privacy.org.nz.

What is your Personal Information?
“Personal Information” has the meaning given to it in the Act. Generally, it includes any information that can be used to personally identify you.  This may include your name, address, telephone number, email address and occupation, and information about your dealings with us.

What Personal Information do we collect and hold?
Depending on the nature of our relationship with you, we may collect the following types of Personal Information:

• Initial identification details: name, residential address and date of birth;
• Contact details: telephone, residential, mailing and email addresses;
• Delivery information: GPS location, time zone, photos (for our logistics services);
• Demographics: date of birth, gender, age, purchase history, income, occupation, hobbies and interests;
• Confirmation of identity details: including driver’s license number and passport details;
• Product and service information: details of the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
• Business partner details: where you are engaged by us as a business partner, the name of the business that you work for, your role within the business, and your contact details;
• Work details: where you are engaged by us as a service provider, contractor or agent, information about your performance;
• Job applicant details: where you apply for a job with us, information about you that will help us decide whether to offer you the job, including your job application or resume, and references; 
• Employment details: where you work for us as an employee, information about you that is generated or shared in the course of your employment relationship with us;
• Financial information: including methods of payment you use, credit reports we receive, and any information you provide in relation to application for finance or in-store credit;
• Feedback: information relating to you that you provide to us directly through our website or service centre, customer surveys or visits by our representatives from time to time;
• Health information: information we collect about you that we consider reasonably necessary to protect the health and safety of our premises, staff and customers; and
• Analytics: information relating to you that you provide to us indirectly through use of our websites or online presence, including your IP addresses.

Depending on the nature of our relationship with you, we may collect the following types of Personal Information:

• Initial identification details: name, residential address and date of birth;
• Contact details: telephone, residential, mailing and email addresses;
• Delivery information: GPS location, time zone, photos (for our logistics services);
• Demographics: date of birth, gender, age, purchase history, income, occupation, hobbies and interests;
• Confirmation of identity details: including driver’s license number and passport details;
• Product and service information: details of the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
• Business partner details: where you are engaged by us as a business partner, the name of the business that you work for, your role within the business, and your contact details;
• Work details: where you are engaged by us as a service provider, contractor or agent, information about your performance;
• Job applicant details: where you apply for a job with us, information about you that will help us decide whether to offer you the job, including your job application or resume, and references;
• Employment details: where you work for us as an employee, information about you that is generated or shared in the course of your employment relationship with us;
• Financial information: including methods of payment you use, credit reports we receive, and any information you provide in relation to application for finance or in-store credit;
• Feedback: information relating to you that you provide to us directly through our website or service centre, customer surveys or visits by our representatives from time to time;
• Health information: information we collect about you that we consider reasonably necessary to protect the health and safety of our premises, staff and customers; and
• Analytics: information relating to you that you provide to us indirectly through use of our websites or online presence, including your IP addresses.

The information we will require will depend on the specific service(s) that we provide to you and/or the specific interactions or relationships we have with you. We will only seek to collect information about you that we think we need for these services, interactions and relationships.

How do we collect your Personal Information?

Direct collection: We collect your Personal Information directly from you unless it is unreasonable or impracticable to do so. When collecting Personal Information from you, we may collect in ways including:

• through your access and use of our website;
• during conversations and communications between you and our representatives;
• when you complete an application or purchase order or ask for a quote to be prepared;
• when you make an in-store or on-line purchase;
• when you access our premises;
• when you apply for finance;
• when you contact us for further information or register your details on our website;
• your participation in surveys and other types of research;
• when you enter a promotion, sweepstake, or contest hosted by Freedom;
• when you subscribe to our mailing list or member program;
• when you provide information via social media pages such as the Freedom Facebook page, Instagram or our Twitter account;
• when you apply for a franchise;
• when you supply goods or services to us;
• when you express interest in a particular Freedom service or product (as applicable); 
• when you submit a job application or résumé, including from your referees, and publicly available information about you; or
• when you work for us as an employee.

Cookies and web tracking: Freedom uses tracking technologies such as cookies to recognise your browser each time it visits our site, and to track which pages you visit whilst on our site. We use this information to optimise our site and create a better online experience for you. Cookies are pieces of information that a website transfers to a computer’s hard disk for record keeping purposes. Most web browsers are set to accept tracking technologies such as cookies. If you do not wish to receive any cookies, you may set your browser to refuse them.

Remarketing: Our website uses various software platforms and analytics programs, such as Google AdWords, Google Analytics, and the Google Display Network, to serve ads to you on other websites after you have visited our website. This practice is known as remarketing and is a tool that Google and other digital providers offer to businesses. If you would like to opt-out of receiving advertising like this from Google you can manage these settings by visiting the Google Ads Preferences Manager.

Payment protection: Freedom uses the payment protection provider, Forter, which allows for the approval of more legitimate transactions by accurately determining the trustworthiness of every transaction. Information collected by Forter is governed by Forter’s privacy policy (www.forter.com/privacy-policy). All application traffic, including payment information, traverses the internet through an encrypted channel.

Franchisees: Freedom may collect Personal Information from its franchisees as part of operating the Freedom franchise network.

Third parties: We may also collect information from third parties such as credit reporting bodies, law enforcement agencies, and other government agencies.

What happens if we can’t collect your Personal Information?

If you do not provide us with the Personal Information described above, we may not be able to provide the requested products or services to you, either to the same standard or at all, or we may not be able to provide you with information about our products and services.

For what purposes do we collect, hold, use and disclose your Personal Information?

Your Personal Information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy. 

We retain Personal Information for as long as is necessary for the purpose for which it was collected or in some circumstances for longer periods where extended retention is required by law or regulation, and as necessary in order to defend our legal rights. 

Freedom may use, collect and hold your information to provide our products and services to you, to better understand your needs and provide you with better services, including for:

Customer service, including to:

• complete transactions in store or online;
• deliver products and services;
• provide our membership program; and
• deal with queries, comments or customer service issues promptly whether by email, social media, telephone or mail. (We may also keep information on your communications with our customer service representatives).

Marketing, including to: 

• keep you up-to-date with products, services, events or promotions we think would be of particular interest through a variety of channels. (You are able to “opt-out” from this activity at any time);
• evaluate the effectiveness of our online advertising; and
• evaluate our website’s performance and to improve the content we display to you.

Business operations, including to:

• analyse our business, including for planning, marketing, research, recruiting and training purposes;
• enhance your customer experience in store and online and help us complete your transactions faster; 
• administer our business, analyse trends, administer our website, track users’ movements, and gather broad demographic information; and
• ensure the health and safety of our premises, staff and customers, which may involve us collecting your health related information.

Freedom may also use, collect and hold your information: 

• when seeking to prevent fraud and other criminal activities;
• when recruiting staff and engaging with contractors; 
• for activities and practices related to our employment relationships; and for other purposes:
• we have explained and where you have provided the required consent or been given the required notification; or
• which are required or authorised by or permitted under law.

Disclosure of Personal Information

We may disclose your Personal Information to:

• Related Bodies Corporate: in particular to our parent company.
• Franchisees: where relevant to your dealings with that franchisee. 
• Service providers: including, without limitation, technology service providers for services such as application and systems, cloud computing facilities, development and technical support, processing, storing, hosting, research and data analysis, payment protection providers, mailing houses, couriers, payment processors, delivery contractors,  data entry service providers, network administrators, debt collectors, third party product repairers, and professional advisors such as accountants, solicitors, business advisors and consultants.
• Partners: including, without limitation, our third party marketing agencies, membership program partners, Facebook, Twitter, Google, organisations we partner with for promotions or for distribution, and other organisations we think you would like to receive further information from.
• Law enforcement: to any person, regulatory body or government agency in order to comply with any law.
• Purchasers of our business: if we sell some or all of our business to a third party, we will disclose all of your information to the new owner(s) in the process of undertaking that transaction or transactions.

We will comply with the Act when we send Personal Information overseas. This includes satisfying ourselves that the overseas recipient will provide safeguards comparable to the Act. Entities located outside of New Zealand to whom we may disclose your Personal Information include, without limitation, the following: our Related Bodies Corporate, located in Australia, United Kingdom, Europe, Asia and South Africa; and our data hosting and other IT and CRM service providers, located in the United States, Brazil, Canada, Europe, Australia, United Kingdom and Asia.

Direct marketing materials

We may send you direct marketing communications and information about our products and services that we consider may be of interest to you if you would reasonably expect us to do so in light of how we collected your Personal Information. These communications may be sent in various forms, including mail, SMS, social media and email, in accordance with applicable marketing laws, such as the Unsolicited Electronic Messages Act 2007. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. 

For those customers who have only signed up to our Family & Friends promotion, we may only send you direct marketing communications and information about our Family & Friends promotions. These communications may be sent by SMS and email. 

With your consent, we may provide your Personal Information to organisations that we partner with from whom we think you would like to receive further information. We may also provide you with direct marketing communications from organisations that we partner with from whom we think you would like to receive further information.

At Freedom we only want to communicate with you if you want to hear from us. If you would like to be removed from the Family & Friends marketing communications you can do so at freedomfurniture.co.nz/FamilyandFriends/Unsubscribe/. If you would like to be removed from all marketing communications you can do so at  www.freedomfurniture.co.nz/my-account/preferencesfreedomfurniture.co.nz/opt-out.

Access and correction

You may request access to any Personal Information we hold about you at any time by contacting us (see details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may ask you to pay our reasonable costs to give you access to your Personal Information.

There may be instances where we cannot grant you access to the Personal Information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

If you believe that Personal Information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the Personal Information stating you disagree with it.

Third-party web sites

Links to third party web sites on www.freedomfurniture.co.nz are provided solely as a convenience to you. If you use these links, you will leave Freedom’s site. Freedom is not responsible for any of these sites, their content or their usage of your Personal Information.

Security

Freedom is committed to ensuring the security of your Personal Information and uses industry standard security measures to safeguard and protect your information. This includes taking reasonable steps to ensure your Personal Information is protected from loss, misuse, unauthorised modification or disclosure. Some of the steps we take to protect your information include:

• utilising security restrictions on access to our systems such as passwords, firewalls and anti-virus software;
• external and internal premises security.

Freedom franchisees

If you purchase a Freedom product from a franchisee (the company identified by company name and/or company number on the front of the customer invoice), then the provisions of this Privacy Policy also apply to you and the franchisee (as though the franchisee is “Freedom”), with the following amendments:

• Provisions relating to the web are not applicable to your relationship with a franchisee.
• A franchisee may disclose your Personal Information to Freedom for the purposes of its operation of the Freedom franchise network.

Freedom is not responsible for any failure by a franchisee to comply with this Privacy Policy or applicable law when handling your Personal Information.

Complaints or questions

If you have any questions about this Policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please use the contact link on our website or contact our Privacy Officer using the details set out below.

Privacy Officer contact details:

Privacy Officer
Freedom Furniture New Zealand Limited 
Email: privacy@freedom.com.au

All complaints received will be dealt with fairly and in a timely manner considering all the circumstances of the complaint. In most cases, we expect that complaints will be investigated and a response generally provided within 30 days of receipt of the complaint. If the matter is more complex and our investigation may take longer, we will contact you and advise you of this.

For information about privacy generally, you may visit the New Zealand Office of the Privacy Commissioner’s website at www.privacy.org.nz. 

Employees

Freedom collects Personal Information from its employees, such as name, address, telephone and email contacts, bank account details, emergency contact details, employment records, such as your position description and all other work-related information.  Freedom is required to collect some of this Personal Information by law, however, Freedom also collects Personal Information to enable the business to operate (for example, to ensure our employees can be paid, to manage the employee/employer relationship and to keep employees safe).   

Where possible we endeavour to obtain Personal Information from our employees directly.  However, in some circumstances such information is gathered indirectly (for example, from colleagues or other entities, such as where we carry out a criminal reference check).  

Some Personal Information is publicly available and necessary to carry out an employee’s role, for example, an employee’s company email address and contact work phone number.  However, sensitive personal information is retained in one or more secure locations. We retain employee records in accordance with our data retention requirements under the Employment Relations Act 2000.

In accordance with the Act, employees are entitled to access their personal information held by or on behalf of Freedom, and to request updates to any incorrect details.  

Definitions and changes

In this policy “Freedom”, “we”, “us”, “our”, etc means Freedom Furniture New Zealand Limited.

Freedom may make changes to this Privacy Policy from time to time for any reason. Any changes we make will automatically apply to all personal information that we hold about you.  We will publish those changes on our website and, if the changes are material to you, we may also update you directly by email. This policy was last updated in September 2023.