Privacy Policy
Creative Fuel Limited trading as CORO DIGITAL ("CORO DIGITAL", "we", "us" or "our") respects your privacy and is committed to protecting the personal information we hold about you.
This Privacy Policy explains how we collect, use, store, disclose and protect personal information when you visit our website, contact us, request or use our services, or otherwise interact with us.
CORO DIGITAL is based in Whitianga, Coromandel Peninsula, New Zealand.
This Privacy Policy is intended to comply with the Privacy Act 2020 and applicable New Zealand privacy requirements.
1. What is personal information?
For the purposes of this Privacy Policy, personal information means information about an identifiable individual.
This may include information that identifies you directly, or information that could reasonably be used together with other information to identify you.
2. Information we collect
The amount and type of personal information we collect depends on how you interact with CORO DIGITAL.
We may collect personal information when you:
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contact us through our website;
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submit an online enquiry or contact form;
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request a proposal or quotation;
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purchase or use our services;
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enter into an agreement with us;
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communicate with us by email, telephone or other means;
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subscribe to a mailing list;
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communicate with us through social media;
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provide feedback or make a complaint;
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provide information in connection with a website, graphic design, branding or other project; or
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otherwise interact with us.
The personal information we collect may include:
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your name;
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business or organisation name;
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job title or position;
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postal or physical address;
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email address;
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telephone or mobile number;
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information about your business or organisation;
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website and domain information;
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information required for billing and invoicing;
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payment-related information;
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correspondence and communications with us;
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information you provide in connection with a project;
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information about your use of our website; and
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other information reasonably necessary for us to provide our services and operate our business.
We generally do not seek to collect sensitive personal information. You should not provide sensitive personal information to us unless it is necessary for a particular purpose and we have requested it.
3. How we collect personal information
We generally collect personal information directly from you.
For example, you may provide information when you:
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complete an online form;
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send us an email;
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telephone us;
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request a quotation or proposal;
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enter into a contract;
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provide information for a website or graphic design project; or
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communicate with us through social media.
In some circumstances, we may collect personal information from another person or organisation where this is permitted by law and reasonably necessary for our business activities.
For example, information may be provided by:
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your authorised representative;
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your employer or organisation;
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a business or professional adviser;
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a service provider;
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a client for whom you are an employee, customer or contact;
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a business contact; or
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another person or organisation where permitted by law.
Where we collect personal information indirectly, we will comply with the applicable notification requirements of the Privacy Act 2020, including Information Privacy Principle 3A, unless an applicable exception applies.
4. Why we collect and use personal information
We collect and use personal information for purposes that are reasonably necessary for our business activities, including to:
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respond to enquiries;
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prepare proposals, quotations and estimates;
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provide website design, development and related services;
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provide graphic design, branding and other creative services;
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communicate with clients and prospective clients;
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manage projects and client relationships;
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provide customer and technical support;
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issue invoices and process payments;
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maintain business and financial records;
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improve our services;
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administer and improve our website;
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analyse website usage;
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send information about our services where permitted by law;
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manage mailing lists;
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protect our systems and business from fraud, misuse and security threats;
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comply with our legal and regulatory obligations; and
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otherwise operate and manage our business.
We will not use personal information for a purpose that is inconsistent with the purpose for which it was collected, except where permitted or required by law.
5. If you do not provide personal information
You can generally visit the CORO DIGITAL website without identifying yourself or providing personal information.
However, some personal information may be necessary for us to respond to an enquiry, prepare a quotation, enter into an agreement or provide our services.
If you do not provide information that is reasonably necessary for these purposes, we may not be able to provide the relevant service or respond fully to your request.
6. Website forms and databases
When you submit information through a CORO DIGITAL website form, the information you provide may be stored in the website's database and may also be transmitted to us for the purpose of responding to your enquiry or providing the requested service.
We use appropriate access controls and security measures to protect information stored in our website databases.
For client websites that we design, develop or host, personal information submitted by users of those websites may similarly be stored within the relevant website database.
Where CORO DIGITAL handles personal information on behalf of a client, the relevant client generally remains responsible for determining the purposes for which that information is collected and used.
Where information is collected through a client's website, the client's own privacy policy will generally apply to the collection and use of that information by the client.
7. Website analytics and cookies
We use Google Analytics on the CORO DIGITAL website to help us understand how visitors use our website and to improve its performance, content and usability.
Google Analytics may collect information such as:
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IP address;
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approximate geographic location;
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browser type;
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operating system;
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device type;
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screen resolution;
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pages visited;
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links clicked;
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referring website;
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date and time of visits;
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approximate duration of visits; and
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other information about how the website is used.
Google Analytics may use cookies and similar technologies to collect and analyse information about website usage.
Information collected through Google Analytics may be processed by Google in accordance with Google's applicable terms and privacy policies.
CORO DIGITAL uses Google Analytics for website usage analysis, performance measurement and improvement of our website. We do not use Google Analytics for the purpose of selling personal information.
You can control or disable cookies through your browser settings. You may also be able to control certain Google Analytics-related activity through tools provided by Google or your browser.
Disabling cookies or analytics technologies may affect the functionality of some websites.
8. Third-party websites and services
Our website may contain links to websites, applications or services operated by third parties.
These may include social media platforms, Google services, payment services and other online services.
We are not responsible for the privacy practices, content or security of third-party websites or services.
We recommend reviewing the privacy policy of any third-party website or service before providing personal information to it.
9. Disclosure of personal information
We do not sell your personal information.
We may disclose personal information where reasonably necessary for the purposes described in this Privacy Policy, where you have authorised the disclosure, or where disclosure is permitted or required by law.
This may include disclosure to:
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employees and contractors who need the information to perform their functions;
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authorised representatives;
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professional advisers;
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accountants and auditors;
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lawyers;
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insurers;
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payment and banking service providers;
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website and technology providers;
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hosting and server providers;
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email and domain service providers;
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analytics providers;
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IT and security providers;
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debt collection or credit-related service providers where applicable;
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government agencies and regulatory bodies where required or permitted by law; and
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other service providers engaged to assist us in operating our business.
We take reasonable steps to ensure that service providers who receive personal information from us handle that information appropriately and in accordance with applicable privacy obligations.
10. Our website, hosting and email providers
Our own website, business email services and websites we host for clients use server infrastructure managed by Voyager Internet Ltd.
Where applicable, hosting infrastructure is located in New Zealand data centres.
Information submitted through websites hosted by CORO DIGITAL may therefore be stored on those hosting systems, subject to the applicable hosting arrangements.
We may also use other third-party technology and business service providers from time to time where reasonably necessary to operate our business or provide our services.
11. Personal information handled on behalf of our clients
As a website design, development and hosting business, CORO DIGITAL may sometimes handle personal information contained within a client's website, database, customer-management system or other platform while providing services to that client.
In these circumstances, the information may belong to the client or may have been collected by the client from its customers, users, employees or other individuals.
Where we handle personal information solely on behalf of a client, we will generally handle that information in accordance with our agreement with the client and applicable New Zealand privacy law.
The client remains responsible for determining why and how that information is collected and used, including providing appropriate privacy notices to its customers and website users.
Where information is collected through a client's website, the client's privacy policy should explain how the client collects, uses, stores and discloses that information.
Where appropriate and within the scope of our services, CORO DIGITAL will provide reasonable assistance to the client with the technical handling of personal information.
12. Overseas disclosure and processing
Some third-party services we use may involve information being processed or stored outside New Zealand.
This may include services such as analytics, software, cloud services, email, security, backup or other technology services.
Where we disclose personal information to an overseas organisation, we will comply with the requirements of Information Privacy Principle 12 of the Privacy Act 2020.
Depending on the circumstances, this may include ensuring that the overseas recipient is subject to the Privacy Act 2020, is subject to privacy laws providing comparable safeguards, is contractually required to provide appropriate safeguards, or that another lawful basis for the disclosure applies.
Where an overseas provider merely stores or processes personal information on our behalf as an agent, the Privacy Act treats the information differently from a disclosure for the provider's own purposes.
13. Direct marketing
We may use your contact information to send you information about CORO DIGITAL services, news, updates, special offers or other information that may be relevant to you.
We will send commercial electronic messages only where permitted by the Unsolicited Electronic Messages Act 2007 and other applicable laws.
Where consent is required, we will obtain appropriate consent before sending commercial electronic messages.
Commercial electronic messages we send will include a functioning unsubscribe facility where required by law.
You may unsubscribe from marketing communications at any time by using the unsubscribe facility included in the communication or by contacting us.
Unsubscribing from marketing communications will not prevent us from sending service-related or transactional communications that are necessary for an existing business relationship.
14. Security of personal information
We take reasonable steps to protect personal information against:
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loss;
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misuse;
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interference;
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unauthorised access;
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unauthorised disclosure;
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unauthorised alteration; and
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destruction.
Depending on the nature of the information and how it is stored, our security measures may include:
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access controls;
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password protection;
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multi-factor authentication where available;
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secure hosting;
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secure backups;
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software and security updates;
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restricted access to personal information; and
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other reasonable technical and organisational safeguards.
Our server infrastructure uses managed backups, although the security measures applicable to a particular CORO DIGITAL website will depend on the hosting service and configuration used.
No website, internet transmission or electronic storage system can be guaranteed to be completely secure.
15. Privacy breaches
If we become aware of a privacy breach involving personal information we hold, we will assess the breach and take reasonable steps to contain, investigate and remedy it.
Where a breach is a notifiable privacy breach under the Privacy Act 2020, we will notify the Office of the Privacy Commissioner and affected individuals as required by law.
If a privacy breach involves personal information that CORO DIGITAL handles solely on behalf of a client, we may notify the relevant client and work with that client to respond to the breach in accordance with our contractual obligations and applicable law.
16. Retention of personal information
We will retain personal information only for as long as reasonably necessary for the purposes for which it was collected, or for another purpose permitted or required by law.
The appropriate retention period will depend on the nature of the information and the reason we hold it.
We may retain certain information for longer periods where reasonably necessary to:
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comply with legal or accounting obligations;
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maintain business records;
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resolve disputes;
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enforce agreements;
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protect our legal rights; or
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meet other legitimate business requirements.
When personal information is no longer required, we will take reasonable steps to securely delete, destroy or de-identify it, unless retention is required or permitted by law.
17. Access to your personal information
Under the Privacy Act 2020, you generally have the right to request access to personal information we hold about you, subject to certain exceptions.
To request access, please contact our Privacy Officer using the details below.
We may need to verify your identity before providing access to personal information.
We will respond to your request within the timeframe required by law.
18. Correction of your personal information
You may ask us to correct personal information we hold about you if you believe it is inaccurate, incomplete, misleading or out of date.
Please contact our Privacy Officer with details of the information you believe should be corrected.
If we do not agree to make a requested correction, we will provide an explanation where required by law and, where appropriate, provide an opportunity for a statement of correction to be associated with the relevant information.
19. Privacy Officer
Our Privacy Officer is responsible for overseeing privacy matters and acting as a point of contact for privacy enquiries, access requests, correction requests and privacy complaints.
Privacy Officer
Dean Klouwens
Creative Fuel Limited trading as CORO DIGITAL
5 Eyre Street
Whitianga 3510
New Zealand
Phone: 027 822 2900
Email:
20. Privacy complaints
If you have a concern about how we have collected, used, stored or disclosed your personal information, please contact our Privacy Officer in the first instance.
We will consider your complaint and work with you to resolve the issue where reasonably possible.
If you are not satisfied with our response, or believe that we have interfered with your privacy rights, you may contact the Office of the Privacy Commissioner.
Office of the Privacy Commissioner
Phone: 0800 803 909
Website: www.privacy.org.nz
21. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to our business, services, technology or applicable privacy requirements.
The latest version will be published on the CORO DIGITAL website and will show the date on which it was last updated.
We encourage you to review this Privacy Policy periodically.
22. Contact us
If you have any questions about this Privacy Policy or the way CORO DIGITAL handles personal information, please contact us:
Creative Fuel Limited trading as CORO DIGITAL
5 Eyre Street
Whitianga 3510
New Zealand
Phone: 027 822 2900
Email:
Website: www.corodigital.nz