Privacy Policy

PROTECTING YOUR PRIVACY

SWAZI 

CONTENTS OF PRIVACY NOTICE

  1. Introduction
  2. What is Swazi?
  3. The legal bases we rely on
  4. When do we collect your personal data?
  5. What sort of personal data do we collect?
  6. How and why do we use your personal data?
  7. Combining your data for personalised direct marketing
  8. How we protect your personal data
  9. How long will we keep your personal data?
  10. Who do we share your personal data with?
  11. Where your personal data may be processed
  12. What are your rights over your personal data?
  13. How can you stop the use of your personal data for direct marketing?
  14. Contacting the Regulator
  15. If you live outside New Zealand
  16. Any questions? 
  1. Introduction

This Privacy Notice outlines the personal data we may gather from you when you engage with us, as well as how we will store, manage, and protect that data.

We understand this is a lot of information, however we aim to ensure you are aware of your rights and how Swazi uses your data. 

We intend the upcoming sections to address your questions, but feel free to reach out if you need further assistance.

Our products and services are aimed at those aged 16 and over.

We may need to periodically update this Privacy Notice. If there are any major changes, we'll let you know through email, but feel free to check back at any time.

When you are using the Swazi websites, Swazi New Zealand Limited is the data controller.

Swazi is based in New Zealand, so any personal data we collect via cookies or online forms when you visit our website will be transferred from your local jurisdiction to our New Zealand held database. 

  1. What is Swazi?

Swazi is a New Zealand-owned business dedicated to providing premium hunting apparel, workwear and outdoor gear. We aim to ensure our products serve you well while respecting your right to privacy. For any questions regarding your data or this policy, please contact us at:

Swazi Customer Service
Email: service@swazi.co.nz

For simplicity throughout this notice, ‘we’ and ‘us’ means Swazi New Zealand Limited and it's brands. 

  1. Explaining the legal bases we rely on

The data protection law outlines several reasons why a company can collect and process your personal data, these include:

Consent

With your consent, we can gather and use your data with your permission in certain situations.

For example, when you tick a box to receive our emails.

We will inform you about the personal data required for a particular service.

Contractual Obligations

In some situations, we require your personal data to fulfill our contractual commitments.

For example, when you place a home delivery order with us, we will gather your address information to ensure your purchase is delivered, and share it with our courier.

If required by law, we may have to collect and process your data.

For example, we can provide information about individuals involved in fraud or other criminal activities impacting Swazi to law enforcement.

Specific Situations

In certain situations, we may need your data to support our legitimate business interests in a manner that is reasonably expected and does not significantly affect your rights, freedoms, or interests.

For example, we may utilize your purchase history to provide you with personalised offers.

If you shop with us and don't choose to opt out, we'll send you marketing emails, which is known as a 'soft opt-in'.

We also analyse the shopping history of numerous customers to recognize trends and meet demand, as well as to create new products or services.

We may also use your address to send you marketing information by mail about products and services that may interest you.

We may contact you for market research purposes.

We will also send you direct marketing emails when you shop with us and do not choose to opt out - this is often called a 'soft opt in'

If you agree, or if you shop with us and don’t opt out of receiving emails (referred to as 'soft opt-in'), we may use your personal information, preferences, and transaction details to send you updates via email, web, text, phone, and our contact centers about products and services that may interest you, including personalised offers, discounts, promotions, events, competitions, etc. This applies only in the UK. 

  1. When do we collect your personal data?
  • When you use your account to purchase products and services or redeem vouchers from Swazi, whether online, in a shop, or via phone, you are visiting any of our websites.
  • If you make a purchase online and check out as a guest, we only gather data related to the transaction.
  • When you create an account with us.
  • When you shop online, we collect information using cookies and similar technologies, which you can manage when you visit our site.
  • When you buy a product or service in-person or over the phone without having or using an account.
  • When you interact with us on social media.
  • When you download or install one of our apps.
  • When you join a Swazi loyalty programme (such as the Swazi Clan).
  • When you contact us through any method if you have questions, complaints, or other concerns.
  • When you enter prize draws or competitions.
  • When you  complete one of our surveys.
  • When you complete a review of one of our products and services, or comment on a product or post.
  • When you complete any forms, such as in the case of an accident occurring in a store, that store might gather your personal information.
  • When you allow another business to share the information they have about you with us.
  • We gather data from sources that are publicly accessible when you have agreed to share your information or when it is legally required to be made public.
  • Contains HM Land Registry data © Crown copyright and database right 2021. This data is licensed under the Open Government Licence v3.0.
  • Our car parks and shops have CCTV systems for the safety of our customers and staff, which may capture your image while you are there.
  • When you agree to participate in our product tests and trials. 
  1. What sort of personal data do we collect?
  • If you have an online account with us, we will store your name, gender, date of birth, billing and delivery address, order history, email, and phone number. To ensure your security, we will also maintain an encrypted version of your login password.
  • Information about your interactions with us via contact centers, in-store visits, online, or using our apps.

For example, we gather information from our conversations, such as any complaints or comments you provide, your purchase details, items viewed or added to your basket, voucher redemptions, brands you're interested in, web pages you visit, and the ways and times you reach out to us.

  • When you add items to your Wish List.
  • When you need to provide copies of documents to verify your age or identity as required by law, such as your passport or driver's license. These documents should contain your full name, address, date of birth, and facial image. The passport will also show your place of birth, gender, and nationality.
  • Information about your shopping preferences, including your favorite shops and where you use your vouchers.
  • Information about your visits to our websites or apps, as well as the site you originated from, is collected.
  • Cookies are used to collect information in your web browser. Find out more about our use of cookies and related technologies in our cookies policy.
  • We use Pixels to monitor email marketing open rates, click through rates and financial data regarding purchases.
  • Account browsing details which enable us to recommend items you might like.

For example, you could provide your clothing size, and we will use that information to recommend items for you.

We will request and use your personal information solely to suggest items you might like and to customize your shopping experience with us. It's entirely up to you if you choose to share this information.

  • Payment card information.
  • Comments and reviews of products.
  • When you visit a shop or car park, your image might be captured on CCTV. We may also record audio while using body-worn video.
  • We gather technical details about your internet connection and browser, as well as your location, the pages you visit, the ads you interact with, and any search terms you use, to provide an optimal web experience. You can read more about this in our cookies policy.
  • When you provide your social media username if you engage with us on those platforms, so we can respond to your comments, questions, or feedback.
  • During a user trial, we may request important information about your demographics and household to ensure you receive suitable products. 
  1. How and why do we use your personal data?

Our goal is to provide you with a great customer experience. To do that, we aim to gather as much information as possible about you by combining the data we have.

We use this information to provide you with promotions, products, and services that may interest you. For loyalty scheme members, we will also offer relevant rewards.

The data privacy law permits this to help us better understand our customers and deliver appropriate, high-quality service.

If you want to modify how we utilize your data, you can find information in the 'What are my rights?' section below.

If you decide not to share your personal data or decline certain permissions, we may not be able to offer some of the services you've requested.

For example, if you’ve asked us to notify you when an item is back in stock, we won’t be able to do that if you’ve revoked your general consent to receive communications from us.

Here’s how we’ll use your personal data and why:

  • We need to collect your personal data during checkout to process any orders made through our websites, apps, or in-store. Without this information, we cannot complete your order or meet our legal requirements.

For example, your information might be shared with another company to provide or deliver the product or service you requested, and we could retain your information for some time afterward to meet any contractual requirements, like processing refunds or guarantees.

  • To respond to your queries, refund requests, and complaints. The information you provide allows us to address these issues. We may keep a record of your information to guide future communications with you. This practice also helps us demonstrate how we have communicated in the past. We do this to meet our contractual obligations, legal obligations, and to ensure we provide the best service possible. We aim to understand how to improve our service based on your experience.
  • To send email notifications when you add products to your basket but leave the site without completing your purchase. We do this based on our legitimate interest. We also provide tracking information. This allows you to follow your order. We aim to enhance your customer experience by keeping you informed about your delivery and the arrival of your order.
  • To protect our business and your account from fraud and illegal activities. This involves using your personal data to maintain, update, and secure your account. We also monitor your browsing activity with us. This helps us quickly identify and resolve problems. Additionally, it protects the integrity of our websites. We do all of this as part of our legitimate interest.

For example, by enhancing security by verifying your password during login and utilising automated monitoring of IP addresses to detect potential fraudulent log-ins from unfamiliar locations.

  • To handle payments and take steps to prevent fraud to support our business interests. This also aids in safeguarding our customers from fraudulent activities.
  • If we find any criminal or alleged criminal activity through our use of CCTV, fraud monitoring, and suspicious transaction monitoring, we will use this data to prevent or detect unlawful acts. Our goal is to protect the individuals we engage with from criminal activities.
  • If you agree, or if you make purchases with us without opting out of receiving updates, we will use your personal data, preferences, and transaction details to inform you via email, web, text, phone, and our contact centers about relevant products and services, including special offers, discounts, promotions, events, and competitions. This applies only within the UK.

Of course, you are free to opt out of hearing from us by any of these channels at any time.

  • To send you personalised updates, offers, services, and product information by post, based on our legitimate business interest.

You are free to opt out of hearing from us by post at any time.

  • To send you communications that are required by law. These messages may inform you about changes to the services we provide. For example, we may update you on this Privacy Notice or provide product recall notices. These messages will not include promotional content. They do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we cannot comply with our legal obligations.
  • We will share your email address and other information about your website use with Meta and Google. This is for analyzing the effectiveness of our advertising with them. It is based on your consent to advertising cookies. You can opt out of Meta's use of your data through their platforms. For more information on changing your cookie consent, please see our cookie notice.
  • We will show you the content you find most interesting on our websites or apps by using data about your preferred brands and products. This is based on your consent to receive app notifications and/or allowing our website to use cookies or similar technologies on your device. If cookies or similar technologies aren't used, we rely on our legitimate interest instead.

For example, we may show you a list of items you've viewed recently or provide recommendations based on your purchase history and other information you've shared with us.

  • To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
  • To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.

For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having

  • To comply with our contractual or legal obligations to share data with law enforcement.

For example, when a court order is submitted to share data with law enforcement agencies or a court of law.

  • We may send you surveys and feedback requests to improve our services. These messages are not promotional and do not require your prior approval when sent through email or text. This is necessary as it helps us customize our products and services to better meet your needs.
  • To build a picture of you by gathering information about you and your preferences by combining our data, third parties data, and publicly available lists, as outlined under 'What Sort of Personal Data do we collect?' This will be done for legitimate business reasons.

For example, by combining this data, this will help us personalise your experience and decide which inspiration or content to share with you. We also use anonymised data from customer purchase histories to identify trends in different areas of the country. This may then guide which products we display in particular stores.

  • For Swazi Clan loyalty members, to decide which information to show you, with the help of computer algorithms. We do so on the basis of your consent when you become a my Swazi or joint loyalty member. If you don’t want to continue receiving Swazi offers, you’ll be unable to continue your Swazi Clan membership.

For example, if you consent through our apps, we may use your shopping preferences to offer you tailored rewards.

  • To ensure your purchases are correctly assigned to you we track the payment card token ID assigned to your debit or credit card, regardless of whether you log into your account or check out as a guest, to ensure your purchases are correctly assigned to you. This is done for several reasons based on our legitimate interest.

For example, to ensure your purchases show on your account or your points are recorded correctly

  • Help inform business decisions for example which 3rd Party websites we partner with to ensure our advertising reaches our customers
  • To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.

Across Swazi, we record your interactions with us e.g. looking at how often you might shop with us or how much you spend. We do this to create a profile on how you interact with tus and, in turn, that can affect how we engage you. For example, if you shop with us regularly, then this can affect what offers and rewards you might receive from us. We rely on our legitimate interest to undertake this activity.

When you shop at one of our stores or online and log into your loyalty account and/or payment card, we may consolidate your purchases using the unique account details and/or tokenised payment card. A loyalty account is unique to you and has a number associated to you which allows us to match it to your profile and therefore any associated spend. Your payment card also has a unique tokenised reference number and we associate this with you when you have used this payment card, also with any spend.

We want to understand your preferences better. This helps us tailor direct marketing and browsing on our websites to suit you. If you have an online account, it also allows your receipts to be stored, even when shopping in our store. The information we collect about your spending helps inform our business decisions. We analyze anonymized spending data for trends or collaborate with third-party suppliers like Google. 

  1. Combining your data for personalised direct marketing

We aim to provide you with offers and promotions that align with your interests at specific times. To enhance our understanding of you as a customer, we integrate your personal data collected from our retail channels, including your shopping history at Swazi. Additionally, we may combine data collected directly from you with information obtained from third parties to whom you have consented to share that data with, such as the Land Registry mentioned earlier. 

  1. How we protect your personal data

We understand that data security is important to our customers, so we will handle your data carefully and take necessary measures to protect it.

We use 'https' technology to ensure secure access to all transactional areas of our websites and apps.

Your personal data is protected by a password, and sensitive information like payment card details is secured and encrypted for safety.

We monitor our system for potential vulnerabilities and threats, and we conduct penetration testing to find ways to enhance security. 

  1. How long will we keep your personal data?

We will retain your personal data only for as long as needed for the purpose it was collected.

Once the retention period is over, your data will either be completely deleted or anonymised, such as being combined with other data to ensure it can be used for statistical analysis and business planning without identifying individuals.

Some examples of customer data retention periods:

Orders

When you place an order, we’ll keep the personal data you give us for a minimum of five years so we can comply with our legal and contractual obligations. 

Warranties

If your order included a warranty, the associated personal data will be kept until the end of the warranty period. 

  1. Who do we share your personal data with?

Occasionally, we share your personal information with reliable third parties.

We use this information for various purposes, such as for delivery couriers, technicians visiting your home, managing fraud, addressing complaints, and personalizing our offers to you.

This is how we work with these organizations to ensure your data is secure and your privacy is protected.

  • We supply only the information necessary for them to carry out their specific services.
  • They are permitted to use your data solely for the specific purposes outlined in our contract with them.
  • We collaborate with them to make sure your privacy is always respected and protected.
  • If we discontinue their services, any data they have will either be deleted or anonymised.

Examples of the kind of third parties we work with are:

  • IT companies that provide support for our website and other business systems.
  • Delivery companies may reach out to you regarding your order delivery and occasionally for service review feedback.
  • Companies that provide direct marketing services to assist us in managing electronic communications with you.
  • When you browse the internet, Google and Facebook may display products that could interest you, depending on your marketing consent or cookie preferences on our websites. Please refer to our Cookies Notice for more information.
  • Data insight companies verify that your information is current and correct.

Sharing your data with third parties for their own purposes:


We will only do this in very specific circumstances, for example:

  • With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.

For instance, if you participate in a holiday competition and select a box allowing the travel company to send you promotional information directly. Or if we host an event together with a restaurant, and you consent to receive direct communications from them.

  • We might share information about fraudulent activities that occur on our premises or systems with law enforcement, including data about specific individuals.
  • We might need to share your personal data with law enforcement or other regulatory bodies in your home country or elsewhere if there's a valid request. Each request is evaluated individually, keeping our customers' privacy in mind.
  • We might occasionally change the size or ownership of Swazi, which could involve transferring parts or the entire business to new owners. If that occurs, your personal data will be passed on to the new owner or controlling party as outlined in this Privacy Notice.

To help personalise your journey through our websites we currently use the following companies, who will process your personal data as part of their contracts with us:

  • Shopify
  • Google
  • Twitter
  • Instagram
  • YouTube
  • Pinterest
  • Facebook
  • Meta
  • Klaviyo
  • MYOB
  • LinkedIn
  • Various payment providers 
  1. Where your personal data may be processed

Swazi is a New Zealand based company and so we will transfer your data to New Zealand, which is outside of the EU. We may also need to share your personal data with third parties and suppliers outside the European Economic Area (EEA).

Protecting your data outside your home jurisdiction

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.

We may transfer personal data that we collect from you to third-party data processors in countries that are outside of your home jurisdiction.

This may be necessary to complete your order, handle your payment information, or offer support services.

By following these steps, we ensure that your data is protected similarly to how it would be in your home jurisdiction. For example, our contracts with third parties specify the standards they must consistently follow.

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice. 

  1. What are your rights over your personal data?

An overview of your different rights

You have the right to request:

  • You can usually get free access to the personal data we have about you.
  • For your data to be updated if it is incorrect, outdated, or incomplete.
  • The deletion of your data under certain conditions, like if you withdraw your consent or object and we don't have a valid reason to keep it, or once we've fulfilled the purpose for which we collected it, such as after a warranty ends.
  • You can obtain a computer file in a widely used format (like CSV) that includes the personal data you've given us, and you have the right to transfer your information to another organization if it's technically feasible.
  • Your personal data may be restricted in certain situations, usually while we review an objection you have raised.
  • We will halt the processing of your personal data in certain situations, such as when you withdraw your consent or object due to personal circumstances.
  • If you request that we refrain from using your personal data for direct marketing purposes, whether through specific channels or all channels.
  • That we cease any consent-based processing of your personal data once you revoke that consent.
  • Review by a Partner of any decision made based solely on automatic processing of your data (so where no human has yet reviewed the outcome and criteria for the decision).
  • You can contact us to request to exercise these rights at any time by contacting our customer service team.
  • If we choose not to action your request, we will explain the reasons for our refusal.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

If we're handling your personal data based on our legitimate interest, you can request that we stop for reasons related to your specific situation. We will comply unless we have a valid reason to keep processing your data, like managing an extended warranty.

Direct marketing

You can choose to stop your personal data from being used for direct marketing in all or certain channels, and we will always honour your request.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.

If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act. 

  1. How can you stop the use of your personal data for direct marketing?

There are several ways you can stop direct marketing communications from us:

  • To stop receiving emails from that division, please click the ‘unsubscribe’ link in any of our email communications.
  • If you have an account, please log into your swazi.com, swazi.co.nz or swaziworkwear.com account, go to the ‘My Account’ section, and update your preferences.
  • In our apps, you can adjust your preferences and choose to receive or not receive any of the push notifications by selecting or unselecting the relevant options in the 'Settings' section.
  • Write to our customer services team using the information in the "Contact Us" section of our websites.

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated. 

  1. How our providers use your personal data

When you then apply for a product or service from one of our chosen providers, your data will be collected and used by them under the terms of their own separate privacy policies. 

  1. Contacting the Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the relevant privacy or data protection office in your country of residence.

Swazi Apparel Ltd complies with the New Zealand Privacy Act 2020 (the Act) when dealing with your personal information. This policy does not limit or exclude any of your rights under the Act. For further information on the Act, see www.privacy.org.nz.

For all non-New Zealand customers

By ordering from Swazi, navigating our websites for analytics and usage research, or consenting to receive marketing emails as outlined in this Privacy Notice and our Cookies Notice, your personal data will be processed by us or through a third party. You can also request that we do not process your data in these manners, and we will honor your request.

At times, we may need to move your personal data across borders to provide the products or services you asked for. Typically, we will send your personal data to the New Zealand and might also share it with third parties in New Zealand or your home country.

We shall endeavour to ensure that reasonable steps are taken to procure that all such third parties outside of your country of residence shall not use your personal data other than for the services they provide and for which they need the personal data, and to adequately protect the confidentiality and privacy of your personal data.

We will ensure that any third parties manage your personal data in line with their legitimate interests. These third parties may be subject to different laws than those in your country. We do not actively confirm that any foreign recipient of your personal data complies with the laws relevant to your country.

If you have questions, reach out to our Customer Support team at service@swazi.co.nz, and we'll get back to you based on your local response times. To report a potential issue with this Privacy Notice or our legal privacy commitments, please give us as much detail as you can about your concern. We take privacy complaints seriously and will evaluate each one to resolve issues promptly and effectively.

Australia

For the purposes of this Privacy Notice, “personal data” means any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information or opinion is true, or opinion is recorded in a material form.

We are committed to keeping your personal information secure and will use all reasonable precautions to protect it from loss, misuse or unauthorised access or alteration. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information. Nothing in this Privacy Notice restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth).

We store personal information on computer databases and will take reasonable commercial physical and electronic security measures to protect any records that we hold which contain your personal information.

If you are in Australia, you may submit a complaint to our Data Protection Officer who will come back to you within 30 days. If we have not come back to you or you are not happy with the response that you receive you may submit a complaint to the Office of the Australian Information Commissioner.

USA

For information about our cookies and website ‘track’ or ‘do not track’ practices please refer to our cookies notice.

Canada

If you submit a request to stop direct marketing communications from us, it will
take no longer than 10 days.

As your data may be transferred to third parties outside the country where you are located, local police or other enforcement, regulatory or Government bodies may have access to that data with or without Swazi's knowledge. The personal data we process may be accessed by persons within Swazi, or our third party service providers, who require such access to carry out the purposes indicated in this Privacy Notice, or such other purposes as may be permitted or required by the applicable law. Personal data we collect is maintained primarily in New Zealand.

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal information, you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada, or in some Canadian provinces, your local Privacy Commissioner.

Hong Kong

Terms used in this Privacy Notice shall have the same meanings ascribed to them in the Personal Data (Privacy) Ordinance (the “PDPO”)

Under the Personal Data (Privacy) Ordinance (the “PDPO”), individuals must be notified at the point of collection of the purposes for which the data was collected and thereafter the data can only be used for those purposes unless consent is obtained for a new purpose.

If you are in Hong Kong you may submit a complaint to our Customer Services team who will come back to you within 30 days. If we have not come back to you or you are not happy with the response that you receive you may submit a complaint to the Office of the Privacy Commissioner for Personal Data.

Malaysia

Terms used in this Privacy Notice shall have the same meanings ascribed to them in the Personal Data Protection Act 2010 (“PDPA”).

If you are in Malaysia you may submit any questions, comments or complaints to our Data Protection Officer who will come back to you within 21 days.

South Korea

The transfer of data to enable the company to supply the goods or services a customer has requested can be deemed as a Delegation.

Singapore, Qatar

Terms used in this Privacy Notice shall have the meanings assigned to them by the Personal Data Protection Act 2010 (also known as the PDPA).

By placing an order with us, opening an account, browsing our website and/or agreeing to receive digital direct marketing communications, you agree that we may process your personal data as described in this Privacy Notice and our Cookies Notice, including for analytics and research into website use.

EU AND EEA Countries

If you are sending us your personal data directly you do so within the sphere of your household or personal activity. If you want to purchase a Swazi product for your business please contact our B2B service. This Privacy Notice will apply to how any personal data you provide to us is processed. 

  1. Any questions?

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:

  • Email us at service@swazi.co.nz 

This notice was last updated on the 30/10/24

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