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KiwiGiftCard Privacy Policy

Last updated: 14 September 2026

1. About KiwiGiftCard

KiwiGiftCard is operated jointly by:

AGC Promotions Pty Ltd ABN 96 617 236 898

and

EMBR Group Pty Ltd ABN 27 417 837 587

Together referred to in this Privacy Policy as “KiwiGiftCard”, “we”, “us” or “our”.

KiwiGiftCard operates consumer promotions, competitions, surveys, marketing campaigns, co-registration programs, lead-generation activities and consumer-information services through KiwiGiftCard.co.nz and associated websites, landing pages and campaigns.

A core commercial purpose of KiwiGiftCard is the collection of consumer information and, where permitted by law and the permissions provided by the consumer, the disclosure, referral or licensing of that information to selected third-party businesses so those businesses may contact consumers about relevant products and services.

AGC Promotions Pty Ltd and EMBR Group Pty Ltd jointly operate the KiwiGiftCard business, website, database, intellectual property and associated commercial activities.

Although the operating companies are incorporated in Australia, KiwiGiftCard is directed to New Zealand consumers. We therefore intend to handle personal information relating to the KiwiGiftCard business in accordance with the Privacy Act 2020 (NZ), including the Information Privacy Principles, together with other applicable New Zealand laws.

2. What is personal information?

“Personal information” has the meaning given under the Privacy Act 2020.

Generally, it means information about an identifiable individual.

3. Information we may collect

Depending on how you interact with KiwiGiftCard, we may collect information including:

Technical information may include:

4. Data provenance and consent records

We may retain information showing how and when your information was collected and what information, notices and permissions applied at that time.

This may include:

These records help us establish and demonstrate the provenance and lawful permitted uses of information held within the KiwiGiftCard database.

5. Sensitive information

We do not ordinarily seek to collect sensitive information.

Where we collect sensitive information, we will only do so where permitted under applicable law and where any required permission has been obtained.

Standard participation in a KiwiGiftCard Promotion does not ordinarily require sensitive information.

6. How we collect personal information

We may collect personal information directly from you when you:

We may also obtain personal information from:

Where KiwiGiftCard obtains personal information indirectly, we will take reasonable steps to provide any notice required under the Privacy Act 2020, including Information Privacy Principle 3A, unless an applicable exception applies.

7. Our co-registration and lead-generation business

A core purpose of KiwiGiftCard is co-registration, consumer marketing and lead generation.

KiwiGiftCard is therefore not merely a prize-draw website.

When you:

we may collect information for the disclosed purpose of matching you with relevant products, services, businesses, advertisers and marketing partners.

Where permitted by the notice and permission applying to your information, we may:

8. Intended recipients of personal information

Personal information collected through KiwiGiftCard may, subject to applicable law and the notices or permissions associated with the information, be provided to selected businesses including:

These organisations may operate in sectors including:

The particular organisations with which KiwiGiftCard works may change over time.

Where appropriate or required, particular businesses or more specific categories of businesses may be identified:

9. Third-party marketing

Where the relevant collection notice or permission allows it, selected third-party businesses may contact you regarding products or services that may be relevant to you.

Depending on the permission provided, contact may occur by:

A recipient must use personal information consistently with:

Where required by law, a third-party recipient that obtains your personal information indirectly is responsible for complying with its own notification obligations under the Privacy Act 2020.

10. Commercial benefit

KiwiGiftCard is operated for commercial purposes.

We may receive money, commissions, lead fees, referral fees, data-licensing fees, marketing fees or other commercial benefits when information, an enquiry, a lead or a marketing opportunity is provided or licensed to another business.

This does not require you to purchase any third-party product or service.

11. Why we use personal information

We may use personal information for purposes including:

Promotion administration

Co-registration and lead generation

Marketing

Consumer-data services

Subject to applicable law:

Administration and compliance

12. Marketing by KiwiGiftCard

Where permitted by applicable law and your permissions, KiwiGiftCard may contact you about:

Marketing may occur through:

13. Electronic marketing

Commercial electronic messages sent by KiwiGiftCard or on its behalf will be handled in accordance with applicable New Zealand law, including the Unsolicited Electronic Messages Act 2007.

Where required, commercial electronic messages will:

We may retain records evidencing how permission to send commercial electronic messages was obtained.

14. Withdrawal and opting out

You may ask us to:

You may make a request by:

We may retain limited information on a suppression or do-not-contact list so that we can continue to honour your request.

Withdrawal does not invalidate lawful uses or disclosures that occurred before the withdrawal took effect.

Where your information has already been lawfully disclosed to another organisation, that organisation may separately hold your information and you may need to contact it regarding its subsequent use.

15. Data matching, validation and enhancement

Where lawful and consistent with the purposes for which information is held, we may undertake:

Information may also be supplemented using lawful third-party or public sources where permitted.

16. Accuracy

We will take reasonable steps to ensure personal information is accurate, up to date, complete, relevant and not misleading before using or disclosing it where required by law.

You may contact us to request correction of your information.

17. Cookies and digital technologies

KiwiGiftCard.co.nz may use:

These may be used for:

Where information collected through these technologies constitutes personal information, it will be handled under this Privacy Policy.

18. Service providers

We may provide personal information to providers assisting with:

Where a provider merely stores or processes information on our behalf and does not use it for its own purposes, it may act as our agent or service provider rather than as an independent recipient.

19. Australia and overseas handling

AGC Promotions Pty Ltd and EMBR Group Pty Ltd are Australian companies and elements of the KiwiGiftCard business, systems, staff or infrastructure may therefore be located in Australia.

Personal information may accordingly be stored, accessed or processed in Australia.

Some other technology providers or partners may also operate outside New Zealand.

Where personal information is disclosed to an organisation outside New Zealand, we will take reasonable steps required by the Privacy Act 2020, including Information Privacy Principle 12.

Depending on the circumstances, this may include ensuring that the overseas recipient:

Where appropriate, contractual privacy protections may be imposed on overseas recipients.

20. Disclosure to overseas lead or marketing partners

If a third-party lead purchaser, advertiser, data partner or marketing partner is located outside New Zealand and receives information for its own purposes, KiwiGiftCard will consider the cross-border disclosure requirements of Information Privacy Principle 12.

We may require overseas partners to contractually agree to safeguards comparable with the New Zealand Privacy Act.

Where those requirements cannot otherwise be met, we will obtain any informed authorisation required before making the disclosure.

21. Security

We take reasonable safeguards to protect personal information against:

Safeguards may include:

22. Privacy breaches

Where a privacy breach occurs, we will assess the incident in accordance with the Privacy Act 2020.

Where a breach is a notifiable privacy breach, we will notify the Office of the Privacy Commissioner and affected individuals as required by law.

23. Retention

We retain personal information only for so long as it may lawfully and reasonably be required for the purposes for which it is held.

Relevant purposes may include:

We may retain evidence of consent, opt-outs, provenance and suppression for longer periods where reasonably necessary for compliance or evidentiary purposes.

Where personal information is no longer required, we will take appropriate steps regarding deletion, destruction or de-identification where required by law.

24. Access and correction

You may request access to personal information about you held by KiwiGiftCard.

You may also request correction of your information.

We may require appropriate verification of your identity before actioning a request.

Requests will be handled in accordance with the Privacy Act 2020.

25. Privacy Officer

The KiwiGiftCard business will maintain at least one Privacy Officer responsible for assisting with compliance with the Privacy Act 2020.

Privacy enquiries, access requests, correction requests and complaints may be directed to the KiwiGiftCard Privacy Officer using the details below.

26. Sale or transfer of KiwiGiftCard

The ownership or structure of the KiwiGiftCard business may change.

Subject to applicable law, information and systems associated with KiwiGiftCard may form part of an actual or proposed:

Due diligence

In connection with a proposed transaction, appropriately limited information may be disclosed to:

where lawful and reasonably necessary.

Where reasonably practicable, information used during preliminary due diligence will be:

Appropriate confidentiality and security controls may be imposed.

Completed transaction

If KiwiGiftCard or relevant Business Assets are lawfully transferred to a purchaser or successor, personal information associated with the Business may also be transferred where permitted by law.

A purchaser or successor receives information subject to:

A change in ownership does not automatically permit materially unrelated new uses of personal information.

27. KiwiGiftCard business and database assets

AGC Promotions Pty Ltd and EMBR Group Pty Ltd jointly operate KiwiGiftCard and may own or control commercial rights associated with:

Nothing in this Privacy Policy means that personal information itself is treated as unrestricted property.

Rights of identifiable individuals remain subject to applicable privacy law.

28. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

The current version will be published on KiwiGiftCard.co.nz and identify its most recent update date.

An update to this Privacy Policy does not retrospectively create permission for a materially different use or disclosure where additional permission or notification is legally required.

29. Complaints

If you believe KiwiGiftCard has not handled your personal information appropriately, please contact our Privacy Officer.

We will investigate the matter and respond within a reasonable period.

You may also be entitled to contact the:

Office of the Privacy Commissioner – New Zealand privacy.org.nz

30. Contact details

KiwiGiftCard Privacy Officer

KiwiGiftCard is operated jointly by:

AGC Promotions Pty Ltd ABN 96 617 236 898

and

EMBR Group Pty Ltd ABN 27 417 837 587

Website: www.kiwigiftcard.co.nz

Email: hello@embr.com.au

Postal address: PO Box 5016, Mermaid Waters QLD 4218, Australia