Brindle Limited Privacy Policy

Last updated as of 27/07/2025

This is the Privacy Policy Notice of Brindle Limited. In this document, "we", "our", or "us" refer to Brindle Limited.

Brindle Limited has the following registration details:

Brindle Limited, Company No.: 9345600; Registered Office: Brindle Limited, 43a Clarence Street, Devonport, Auckland, 0624, New Zealand.

Introduction

This privacy notice aims to inform you about how we collect, store and process any information that we collect from you, or that you provide to us. It covers information that could identify you ("personal information") and information that could not. In the context of the law and this notice, "process" means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.

We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information.

We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.

The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at https://www.privacy.org.nz/privacy-principles/

Except as set out below, we do not share, sell, or disclose to a third party any information collected through our website.

1. Data Protection Officer

We have appointed a data protection officer (DPO) who is responsible for ensuring that our policy is followed.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO, Pete Rose, at info@brindleai.com.

2. Data we process

We may collect, use, store and transfer different kinds of personal data about you. We have collated these into groups as follows:

• Your identity includes information such as first name, last name, title, date of birth, and other identifiers that you may have provided.
• Your contact information includes billing address, delivery address, email address, telephone numbers and any other information you have given to us for communication.
• Technical data includes your IP address, browser type and version, time zone, location, browser plug‐ins, operating system and platform.
• Marketing data includes your preferences in receiving marketing from us, communication preferences, responses and actions in relation to your use of our services.
• We may aggregate anonymous data such as statistical or demographic data for any purpose. Aggregated data is not personal information unless combined with personal data.

3. Special personal information

Special personal information is data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, genetic and biometric data.

We do not collect any special personal information about you.

4. If you do not provide personal information we need

Where we need to collect personal data by law, contract or your request for services, and you fail to provide it, we may be unable to perform that contract. We will notify you at the time if this occurs.

5. Bases on which we process your information

The law requires us to determine under which of six defined bases we process your personal information and, where required, to notify you of each basis. If a basis ceases to apply, we will stop processing or, if it changes, notify you.

6. Information we process because we have a contractual obligation with you

When you or your employer create an account, purchase a service, or agree to our terms, we process personal data to:

• verify your identity;
• sell products or provide services;
• suggest products, services and how to use our website.

We process this information under contract until the contract ends or is terminated.

7. Information we process with your consent

When you browse our website or request information without a contract, you consent to processing personal data (e.g. via cookies). We may share your name and contact details with third parties for products or services you request. You may withdraw consent anytime via our "Unsubscribe" function.

8. Information we process for legitimate interests

We may process personal data on the basis of legitimate interests, after assessing:

• whether objectives can be met by other means;
• whether processing might cause harm;
• whether you would reasonably expect such processing.

Examples include record‐keeping, responding to communications, protecting legal rights, insurance, and safeguarding interests.

9. Information we process because we have a legal obligation

We may process personal data to comply with statutory obligations, such as responding to lawful requests by authorities.

10. Communicating with us

When you contact us by phone, web form or email, we collect your data to respond. We record your request and our reply to improve efficiency and keep identifiable information to track communications.

11. Complaining

When you file a complaint, we record all information you provide to resolve it. We may share necessary details with third parties to investigate, but only as needed. We may compile anonymised statistics on complaints.

12. Affiliate and business partner obligations

Information provided by you as an affiliate or partner is used to track referrals and commissions. We keep it confidential and expect affiliates/partners to reciprocate.

13. Cookies

We use cookies—small data files stored by your browser—to personalise your experience and gather usage statistics. When you first visit, we ask your permission. If you refuse, only essential cookies are used. Blocking cookies may limit functionality.

Examples of our use of cookies:

• track website usage;
• record seen messages;
• keep you signed in;
• save survey answers;
• support live chat sessions.

Click here to see which cookies we use and their purposes.

14. Personal identifiers from your browsing activity

We log requests to our servers, including your IP address, ISP, location, device, browser type and screen resolution, to assess site performance. Combined with other data, this could identify you, so we treat it as personal data when linked.

15. Information we obtain from third parties

We may receive anonymised or aggregated data from third‐party services. Such data is not personally identifiable unless combined with personal data, in which case it is treated as personal data under this policy.

16. Data may be processed outside New Zealand

Our websites are hosted in New Zealand. We may use outsourced services abroad. We safeguard data with:

• NZ Privacy Act 2020–compliant standards;
• standard contractual clauses;
• binding corporate rules.

17. Your duty to inform us of changes

Please notify us if your personal data changes so we can keep records accurate.

18. Access to your personal information

You may review or update your personal information at any time. To request a copy, contact us; we will advise timing and any fees.

19. Removal of your information

You may request removal of personal information, though this may limit our ability to provide services.

20. Verification of your information

Before granting access or making changes, we will verify your identity to protect your data.

21. Encryption of data sent between us

We use advanced encryption to secure personal information you transmit to us.

22. How you can complain

If dissatisfied with our privacy policy, please contact us. If unresolved, we propose mediation to settle disputes in good faith.

23. Retention period for personal data

Except where noted, we retain personal data only as long as necessary to:

• provide requested services;
• comply with legal requirements;
• support or defend legal claims.

24. Compliance with the law

Our privacy policy is designed to comply with laws in all jurisdictions we serve. If you believe it falls short in your jurisdiction, please let us know. Ultimately, the choice to use our website is yours.