This Privacy Policy details how REFILL COLLECTIVE LIMITED (“we”, “us”, or “our”) collects, uses, and protects your personal data when you visit www.zestysavor.com and purchase our seasoning jar combination sets. This document is governed by the provisions of the New Zealand Privacy Act 2020 and the European General Data Protection Regulation (GDPR).

By interacting with our website, you acknowledge the data practices described in this document.

1. The Data Controller

For the purposes of applicable data protection laws, the Data Controller is:

• Company Name: REFILL COLLECTIVE LIMITED
• Registration Number: 9301626 9429052531354
• Registered Address: 49 Pukutahi Drive, Te Anau 9600, New Zealand
• Email: seasoning@zestysavor.com
• Telephone: +64 224536654

2. Information We Collect

To facilitate the provision of our goods, we gather the following categories of information:

• Identity and Contact Data: Your full name, billing address, delivery address, email address, and telephone number.
• Financial and Transaction Data: Details regarding the items you purchase and the payment methods utilised. Please note: We do not collect or store your complete payment card details on our servers.
• Technical Data: Your Internet Protocol (IP) address, browser type and version, time zone setting, and operating system used to access our website.
• Usage Data: Information regarding how you navigate and interact with our website.

3. Payment Processing and Stripe

All financial transactions initiated on our website are handled directly by our designated payment processor, Stripe.

When you place an order, your payment details are transmitted directly to Stripe via encrypted connections. The processing and retention of your financial data by Stripe are governed exclusively by Stripe’s own privacy framework and legal terms. We rely on Stripe’s infrastructure to authorise charges and manage the financial completion of your order. We are provided only with limited transaction identifiers and the status of the payment to facilitate order fulfilment.

4. How We Use Your Information

We process your personal data under the following lawful bases:

• Contractual Necessity: To process your order, manage billing, and arrange the delivery of your seasoning jar combinations.
• Legal Obligation: To maintain accurate financial records as mandated by New Zealand taxation and corporate governance laws.
• Legitimate Interests: To respond to your customer service inquiries, provide status updates regarding your order, and improve the functionality of our website.
• Consent: Where you have explicitly opted in to receive marketing communications (which you may withdraw at any time).

5. Data Retention Periods

We maintain your personal data only for the duration necessary to fulfil the purposes for which it was collected, whilst strictly adhering to statutory requirements in New Zealand and the European Union:

• Transactional and Financial Records: Retained for a period of seven (7) years to comply with New Zealand Inland Revenue (IRD) obligations and corporate accounting statutes.
• Customer Accounts and General Inquiries: Retained for three (3) years following your last interaction with us. Following this period, your personal information will be permanently deleted or anonymised so that it can no longer be associated with you.

6. Data Protection and Confidentiality

We implement commercially reasonable administrative and structural measures to maintain the confidentiality and integrity of your personal information. These measures aim to restrict unauthorised access, alteration, or disclosure of your data. While we strive to protect your personal data through standard encryption protocols during transmission, no method of electronic storage or transmission is completely immune to risks, and we cannot make absolute statements regarding the invulnerability of data.

7. International Data Transfers

As our operations are based in New Zealand and we serve customers within the European Union, your data will be transferred outside the European Economic Area (EEA). New Zealand has been granted an “Adequacy Decision” by the European Commission, meaning that New Zealand’s privacy legislation provides a level of data protection comparable to that of the GDPR. Therefore, your data is transferred lawfully without the need for supplementary frameworks.

8. Your Statutory Rights (GDPR and NZ Privacy Act)

Depending on your jurisdiction, you possess specific rights regarding your personal data:

• Right of Access: You may request a copy of the personal data we hold about you.
• Right to Rectification: You may ask us to correct any inaccurate or incomplete data.
• Right to Erasure (‘Right to be Forgotten’): You may request the deletion of your personal data, subject to our overriding legal obligations to retain specific records (such as tax data).
• Right to Restrict Processing: You may request that we suspend the processing of your data under certain conditions.
• Right to Data Portability: You may request the transfer of your data to another organisation in a structured, commonly used format.
• Right to Object: You may object to the processing of your data for direct marketing purposes.

To exercise any of these rights, please submit your request in writing to seasoning@zestysavor.com. We aim to respond to all legitimate requests within one (1) month.

9. Cookies and Tracking

Our website utilises cookies to differentiate you from other users, allowing us to provide a better browsing experience and to refine our website’s structure. You may adjust your browser settings to refuse cookies; however, doing so may render certain areas of our website inaccessible or non-functional.

10. Updates to This Policy

We may update this Privacy Policy periodically to reflect changes in our operational practices or to comply with updated legislative requirements. Any modifications will be published directly on this page, and the “Effective Date” at the top of the document will be updated accordingly.

Contact Information
For any questions regarding this Privacy Policy or our data handling practices, please direct your correspondence to the Data Controller:
REFILL COLLECTIVE LIMITED
49 Pukutahi Drive, Te Anau 9600, New Zealand
Email: seasoning@zestysavor.com
Telephone: +64 224536654