Privacy Policy
Last updated:
1. Information We Collect
Spinefreshia collects information to provide and improve our educational services and website. Information may be collected through:
- Contact Forms: Name, email, and message content when you contact us
- Cookies and Tracking: Technical data via cookies, Google Analytics, and Google Ads conversion tracking
- Automatically: IP address, browser type, pages visited, and referral source
2. How We Use Your Information
We use collected information to:
- Respond to your enquiries and provide customer support
- Deliver educational content and programme information
- Understand site usage and improve user experience via analytics
- Measure advertising effectiveness through conversion tracking
- Send service updates or promotional communications (only with consent)
3. Legal Basis for Processing
Under GDPR and Privacy Act 2020 (New Zealand), we process personal data based on:
- Article 6(1)(a) GDPR / Consent: Where you have explicitly consented
- Article 6(1)(b) GDPR / Contract: To fulfil our programme and service agreements
- Article 6(1)(f) GDPR / Legitimate Interests: To operate our site and provide services safely
4. Third-Party Services
We use the following third-party services, which collect data subject to their own privacy policies:
- Google Analytics: Tracks site traffic and user behaviour (_ga, _gid, _gat cookies)
- Google Ads Conversion Tracking: Measures advertising effectiveness (_gcl_au, _gcl_aw, ad_storage)
- Google Maps API: Displays our location on the contact page
These services may transfer data internationally. Google's data processing agreements are available on their website.
5. Data Security
We implement reasonable technical and organisational measures to protect your personal data against unauthorised access, alteration, or destruction. However, no method of transmission over the internet is entirely secure.
6. Your Rights
You have the right to:
- Access: Request a copy of your personal data
- Correction: Request we correct inaccurate data
- Deletion: Request deletion of your data (right to be forgotten)
- Portability: Request your data in a structured, portable format
- Object: Object to processing or withdraw consent at any time
- Lodge a Complaint: Contact the Privacy Commissioner (New Zealand) or relevant data protection authority
To exercise these rights, contact us at info@spinefreshia.world
7. Data Retention
We retain contact form data for up to 2 years to respond to follow-up enquiries. Analytics data is retained according to Google's default policies. You can request deletion at any time.
8. International Data Transfers
Some of our third-party services process data outside New Zealand, including in the United States (Google). These transfers are conducted under Standard Contractual Clauses or adequacy decisions.
9. Children
Our services are not directed to anyone under 18. We do not knowingly collect data from minors. If we become aware of such collection, we will delete it promptly.
10. Cookies
See our Cookie Policy for detailed information about cookies we use, including consent management and browser settings.
11. Policy Updates
We may update this policy at any time. Continued use of our site constitutes acceptance of changes. We will notify you of material changes.
12. Contact
Data Controller: Spinefreshia
Level 2, 48 Greys Avenue, Auckland 1010, New Zealand
Email: info@spinefreshia.world
Phone: +64 9 374 8521
Registration No. 5493891
Privacy Commissioner (New Zealand): www.privacy.org.nz