Our privacy commitment
We are committed to being open and transparent about how we manage your personal information.
At Winton Group we have a few fundamental principles:
- We will only use your personal information when it is necessary for us to deliver you our services or perform other necessary business functions and activities.
- We will not use or disclose your personal information for purposes unrelated to our business activities and the services we provide, unless we first obtain your consent.
We are bound by the requirements of those laws, which regulate how we may collect, store, use and disclose your personal information. Those laws also specify other requirements, such as how individuals may access, correct and delete personal information held about them.
- "health information" have the meaning given to that term in the Health Information Privacy Code 2020.
- “Website” means any Winton Group website.
- "you" and "your" refer to individuals who use our Services or provide their personal information to any member of Winton Group, and, in the case of our Northbrook retirement villages, includes the authorised personal representative of a resident or applicant.
Section One – Your consent
Winton is a publicly listed developer with many large-scale projects currently in progress in New Zealand and Australia, specialising in developing integrated and fully master-planned communities and hospitality precincts that are best by design, with superior building standards. Winton Group provides residential, commercial and retirement properties and related services (including on-site medical support from GPs, visiting specialists in our aged care facilities, rest home/hospital level care and secure dementia care), and various products and services in the hospitality industry including restaurants, bars, our group vineyard, online wine sales and transport ("Services").
Section Three – The personal information we collect from you
Information you provide to us directly: Our usual practice is to collect personal information directly from you, when you create an account or online profile, complete any form, including online forms, register to use our Services, make a booking, make a purchase, participate in our contests or surveys, email, call or otherwise communicate with us, or otherwise provide any information in connection with your use of our Services. A few examples include:
- Personal details: name(s); contact details; profile pictures.
- Demographic information: gender; date of birth; age.
- Contact details: telephone number; email address; physical address.
- Credit card details for payment of Services (which are stored encrypted or tokenised).
- Authorised representatives: copies of any enduring powers of attorney; contact details.
- Health information, such as: information about your health (including medical history, prescription details, clinical notes), and health services or disability services currently or previously provided to you.
- Personal care and welfare such as: copies of any enduring powers of attorney in relation to personal care and welfare and/or property that you have executed and not revoked at the time of your admission, together with relevant contact details of the appointed attorneys.
The nature of the personal information will of course depend on your relationship with us and which Services you are obtaining from Winton Group companies. You can always choose not to provide your personal information to Winton Group, but it may mean that we are unable to provide you with the Services.
Information we get from third parties: We may collect or obtain personal information and health information (where applicable) from authorised third parties and as permitted by applicable privacy laws.
Information we collect automatically: We may collect personal information about you automatically when you visit and use the interactive areas and features on our Websites or use our Services, like your IP address, device type access times, language settings and websites you visited before navigating to our Websites. Some of this information may be collected using cookies and similar tracking technologies. We collect your location-based information. We may use this information to show you where you can find us and will only share this information with our mapping provider for the sole purpose of providing you this service. You may opt-out of location-based services at any time by disabling location-based services in your browser settings or emailing our Privacy Officer at the email address set out in Section Thirteen below.
Information we create in the performance of the Services: We may also create or obtain personal information about your interactions with us, and any interactions we have with others on your behalf.
Information you make public: We may collect or obtain your personal information that you manifestly choose to make public, including via online channels such as social media (e.g., LinkedIn, Facebook etc.)
We may combine these types of personal information that we collect about you from these sources. We do this to improve services we offer you, to improve marketing, analytics, or site functionality.
Section Four – How we use the personal information we collect
Where we collect personal information, we will only process it:
- to perform a contract with you; or
- where we have legitimate interests to process the personal information and these interests are not overridden by your rights; or
- in accordance with a legal obligation; or
- where we have your consent.
Winton Group collects your personal information so that we can provide you with the Services and any related services you may request. In doing so, we may use the personal information we have collected from you for purposes related to the Services. Examples of how we process and use the personal information you have provided to us include:
- creating a customer profile for you;
- providing you with the information you have requested;
- sending news and information about events, activities, offers, promotions, products and services offered by Winton Group that we think will be of interest to you;
- responding to comments and questions and providing customer service;
- fulfilling product orders; and
- delivering prizes and completing necessary promotional activities for competition purposes.
We may use the aggregate data generated when you visit any of our Websites or use our Services to conduct analysis of how you interact with our Websites or Services and to improve and develop our Websites and Services.
Section Five – When we may disclose your personal information and who we share your personal information with
Your personal information will not be sold, traded, rented or otherwise provided to others without your consent.
We will not otherwise disclose your personal information unless we believe on reasonable grounds that you have provided your authorisation. However, you should be aware that we may be required to disclose your personal information without your consent in order to comply with any court orders, subpoenas or other legal process or investigation including by tax authorities, if such disclosure is permitted or required by law. Where possible and appropriate, we will notify you if we are required by law to disclose your personal information.
We may also share information with other representatives, agents, third party vendors, consultants and service providers of the Winton Group. We will only provide your information to these other entities on the basis that they will use it for the purposes for which it was originally collected from you. These entities adhere to their own privacy policies and any concerns you may have about the collection, use or misuse of your personal information by those entities should be directed to them.
From time to time, we may also share aggregated or anonymous information that does not directly identify you.
Section Six – International Data Transfers
In connection with providing the Services, you accept that your personal information may be collected or held in New Zealand and be disclosed to recipients in, or transferred to, or processed in, countries other than New Zealand. We may provide your personal information to third parties in countries other than New Zealand if we have reasonable grounds to believe the recipient is required to protect your personal information in a way that, overall, provides comparable safeguards to those required by New Zealand’s privacy laws.
However, there may be differences between New Zealand's privacy laws and those of the overseas locations in which we may store and process your personal information. If we cannot ensure that recipients in those locations are required to protect your personal information using comparable safeguards to those under New Zealand’s privacy laws then we will only provide your personal information to recipients in those locations if you authorise us to do so.
For further information, please contact us using the details set out in Section Thirteen below.
Section Seven – Storage and security
We are committed to protecting the security of your personal information and we take all reasonable precautions to protect it from unauthorised access, modification or disclosure.
Winton Group implements and maintains organisational and technical security measures that are designed to provide reasonable protection against the loss, interference or misuse of your personal information and to prevent unauthorised access, modification or disclosure of that information.
Section Eight - How you can access or correct your personal information
It is your responsibility to ensure that the personal information you provide is accurate, complete and up to date.
You may request access to the information we hold about you, or request that we update or correct any personal information we hold about you, or ask us to restrict or cease processing your personal information or even delete your personal information, by setting out your request in writing and sending it to us at firstname.lastname@example.org.
We will review your request as soon as reasonably practicable to comply with our legal obligations. If we are unable to give you access to the information you have requested, we will give you reasons for this decision when we respond to your request.
Section Nine – Retention
The length of time we keep your personal information depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with a service you've requested or to comply with applicable legal requirements such as money laundering and financial reporting legislation).
We will retain your personal information for as long as your account is active or as needed to provide you with our Services and as necessary to comply with our legal obligations, resolve disputes and enforce our agreements, in accordance with our internal retention policies and practices. Following that, we will make sure your personal information is deleted or anonymised.
Section Ten - Email, text and telephone communications
We are committed to full compliance with the Unsolicited Electronic Messages Act 2007.
By subscribing to emails and/or text communications, or otherwise providing your email address and/or mobile number, you consent to receiving emails and/or texts (as the case may be) which promote and market our products and Services, or the products and services of others, from time to time.
You always have the option to opt in to receive information or services from us, and/or to opt out or unsubscribe at any time. If you wish to stop receiving our newsletter or marketing emails just follow the unsubscribe instructions in those emails or email us at email@example.com. If you opt-out of receiving such communications, you will be removed from the corresponding marketing list as soon as is reasonably practicable however we may still send you non-promotional emails, such as emails about your account, purchases or our on-going business relations.
Section Eleven – Cookies and tracking
Section Twelve – Links to other websites
Section Thirteen - Privacy Officer
We take your concerns seriously. If you have any concerns about privacy or the use or collection of your personal information by Winton Group, please contact our Privacy Officer at firstname.lastname@example.org and include the words 'ATT: THE PRIVACY OFFICER'.
We will respond as quickly as possible (our target response is 20 days) and handle all complaints in a way that is fair and consistent. However, if you remain dissatisfied, you can make a formal complaint with Office of the Privacy Commissioner.