Last updated: 27 June 2025

1.  COMVITA PRIVACY POLICY
Comvita Limited and its subsidiaries (“Comvita”, “we”, “us” or “our”) are committed to protecting your privacy. This Privacy Policy sets out important information as to how and why Comvita collects, stores, uses and shares personal information from you. It also contains important information regarding your rights in relation to your personal information, and on how to contact us if you have any questions or complaints.

Please read this Privacy Policy carefully by accessing:
(a)  The Comvita websites at www.comvita.co.nz and www.comvita.co.uk (“Websites”);
(b)  Any other Comvita website, page or application used to gather your information or send you email notifications relating to Comvita and its products; or
(c)  Any other social media website or page, containing pages or content established by or associated with Comvita, including but not limited to:
(i)  Facebook and
(ii)  Twitter (“collectively, Social Media”)
(each of (a), (b) and (c) are collectively referred to as the “Internet Sites”), 
you are deemed to have read and agree to be bound by this Privacy Policy. If you do not agree with this Privacy Policy, you must not access the Internet Sites.
 
2.  TERMS AND CONDITIONS
In addition to this Privacy Policy, the Terms and Conditions of Use (“Terms and Conditions”) for the Websites also govern your access to and use of the Websites. By accessing the Websites, you are deemed to have read and agree to be bound by the Terms and Conditions as well as this Privacy Policy. In addition, if you are purchasing goods from the Websites (“Goods”) you should ensure you read the Terms of Purchase as these will govern the purchase of any Goods you make.
 
3.  AMENDMENTS
Comvita reserves the right to amend this Privacy Policy from time to time. When we do, we will  post the changes on our Websites. If we make any material changes to this Privacy Policy, we will notify you either via email or a prominently posted notice on the Websites of such changes. Amendments will be effective immediately upon being placed on the Website. Your continued use of the Internet Sites following such amendments being placed on the Websites will represent an agreement by you to be bound by the Privacy Policy as amended.

4.  INFORMATION WE MAY COLLECT AND HOW WE USE IT
4.1. Comvita collects the following information about you when you use the Internet Sites:
4.1.1. Information that you provide to us directly, including your name, birthdate, mobile number, email address and postal address when you enter these into our Website to buy Goods, register for our newsletter, set up an account, or make an inquiry;
4.1.2. Limited financial information that you provide when you place  an order through the Website (including payment card type, last 4 digits of the card number and expiry date);
4.1.3 Information that you provide to us within your account, including any profile information you choose to share, other addresses used for orders, and details of your communication preferences; 
4.1.4. Information that you provide to us in any communications you have with our customer service team via live chat or email;
4.1.5. Information you provide to us when you participate in surveys, competitions or experiences that we offer through the Internet Sites. Participation in these surveys, competitions or experiences is completely voluntary. Information may include contact information (such as your name and email address), and demographic information (such as your postcode and age). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of the Website.
 4.1.6. Information you provide when you leave a comment, post a review or send a post via Social Media or  the Internet Sites or otherwise provide information on Social Media (for example, your name, email address, Social Media identifier and the contents of your comment, review or post).
4.1.7 Information transmitted by your computer when you use the Internet Sites. This may include your IP address browser data and information we receive from cookies (please see section 9 below).
4.2 We may collect personal information about you from our group entities and other third parties who are entitled to disclose that information to us, or from whom you authorise us to collect your personal information. 
4.3. We may use this information in the following ways:
4.3.1. to provide our service(s) to you as a user of the Internet Sites, including enhancing your user experience;
4.3.2. to process and fulfil your orders for our products;
4.3.3. to provide you with newsletters, information about our or third-party products and services, and other information about special offers or features of the Internet Sites which we think may be of interest to you and for related marketing purposes, if you have submitted your contact details to us for these purposes or otherwise provided your consent for us to do so;
4.3.4. to ensure that content from the Internet Sites is presented in the most effective manner for you and your computer;
4.3.5. to notify you about changes to our products and/or the Internet Sites;
 4.3.6. to notify you about product recalls; 
 4.3.7. when managing and maintaining the Internet Sites;
4.3.8.  to deal with any support requests or questions you raise; 
4.3.9. for the purposes of fraud protection and credit risk reduction; 
4.3.10. to comply with our obligations at law and to exercise and enforce our legal rights; and 
4.3.11. to combine the personal information we collect from you with personal information collected by our related companies, in order for us to better understand your preferences and improve our services.
4.4. We do not collect any ‘details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, criminal convictions and offences, or health or genetic and biometric data unless you voluntarily provide this to us (e.g. through a Social Media post). 
4.5. You are not required to provide us with the personal information we have requested. However, if you do not provide to us all the personal information we request from you, you may not be able to access and use, and we may be unable to provide to you, all of our products and services.

5.  FURTHER COLLECTION
You acknowledge that by accessing the Internet Sites information may be collected from you as a result of the workings of the Internet Sites and the attached systems and software. 
In addition, where we consider it necessary to do so, we may collect personal information about you to assist us in assessing your creditworthiness and to collect payments that are overdue in relation to credit provided by us. This information may include financial data (including information as to your assets and income) and credit ratings. We may collect this information from you directly or from a third party who is authorised to disclose the information to us. We may share your personal information with credit reporting agencies for these purposes, and those credit reporting agencies may use and disclose the information for their own business purposes (which may include use for, or disclosure to, the credit reporting agencies’ other customers).

6.  SOCIAL MEDIA
6.1. We work with trusted third parties, including social network sites like Facebook, Twitter, YouTube, Google+, and with application developers who specialise in social media so we can connect to your social networks. All these companies operate third party sites. We provide access to our Social Media to third parties and business partners so we can generate interest in our products and services among members of your social networks and to allow you to share product and service interests with friends in your network.
6.2. We cannot control how your data is collected, stored, used or shared by third party sites or to whom it is disclosed. Please be sure to review the privacy policies and privacy settings on your social networking sites to make sure you understand the information they are sharing. If you do not want a third-party site to share information about you, you must contact that site and determine whether it gives you the opportunity to opt-out of sharing such information. Comvita is not responsible for how these third parties may use information collected from or about you.
 
7.  INFORMATION DISCLOSURE TO THIRD PARTIES
7.1. We may disclose your personal information as follows:
7.1.1. to third parties for marketing purposes, provided your consent has been given;
7.1.2. to Social Media partners, provided your consent has been given (for further details, please see the section 6 “SOCIAL MEDIA” above).
7.1.3. to service providers who manage aspects of our operations (for example third parties who provide support services to the Internet Sites, payment providers and delivery agents);
7.1.4. to our insurers, brokers and external auditors;
7.1.5. to our related companies within the Comvita group;
7.1.6. to debt collection and credit reporting agencies; .
7.1.7. to organisations involved in a transfer or sale of all or part of our assets or business. If Comvita or substantially all its assets or business are acquired by a third party, in which your personal information may be transferred to the new owners. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Privacy Policy;
7.1.8. to regulatory and enforcement authorities or government agencies; or
7.1.9. to anyone else to whom you have authorised us to disclose it.
7.2. Where we disclose your personal information to third parties, we take reasonable steps to ensure that the third party takes appropriate measures to protect your personal information. One way we achieve this is by placing contractual obligations on third parties governing the collection, use and disclosure of personal information that we provide them with.
 
8.  YOUR RIGHTS – MARKETING
8.1. You will only receive marketing communications from us and/or third parties if you have consented to this (such as when you provided your contact details to us for this purpose).
8.2. You have the right to ask us not to use your personal information for marketing purposes. You can request that you stop receiving marketing materials from us at any time by contacting us at the address set out below (please see section 14 “QUERIES & COMPLAINTS”)

9.  IP ADDRESSES AND COOKIES
9.1. We may collect information about your computer including your IP address, operating system and browser type for system administration and to report aggregated information. This is statistical data about your browsing actions and patterns and does not identify you individually.
9.2. 'Cookies' are small pieces of information that are stored by your browser on your computer's hard drive. Most web browsers automatically accept cookies, but you can usually change your browser to prevent that. We only use cookies to keep track of the pages you and other visitors have been to on our Website and to tell us whether you have visited the Website previously to deliver a better service.
9.3. You may refuse to accept cookies by activating the setting on your browser which disables the setting of cookies. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you login to our Website.
 
10.  STATISTICS
Comvita may use and publish non-personal aggregate statistics and group data about those people who access the Internet Sites and their usage of the Internet Sites. Such aggregate information may also be provided to our advertisers and sponsors. However, subject to the further terms of this Privacy Policy, Comvita will not share or make public identifiable information about you without your prior permission.

11.  ACCESSING & AMENDING INFORMATION
If you wish to obtain confirmation that Comvita holds personal information about you and to access that information, or you wish to request a correction to your personal information that Comvita holds, please contact us at the details provided in section 14 below. 
If you request access to, or a copy of, your personal information, Comvita will provide you with a copy of the personal information Comvita keeps about you, subject to any lawful grounds that may be available to Comvita for withholding the information.  Comvita reserves the right to charge you a reasonable amount for providing copies of any personal information you request, to take into account reasonable time, cost and effort involved in Comvita complying with your request. 
If you request a correction to your personal information and Comvita agree that your personal information needs correcting, an amended record of your personal information will be provided back to you. If we do not agree to your request for a correction, you have the right to provide Comvita with a statement of correction sought, and request that Comvita attach to your information a statement of correction sought but not made.

12.  DATA STORAGE, SECURITY AND TRANSMISSION 
12.1. All information you provide to us is stored on our secure servers and those of our group of companies, service providers and agents.
12.2. Where we have given you (or where you have chosen) a password or other data which enables you to access certain parts of our Website, you are responsible for keeping this password and any other identifier confidential and we strongly recommend that you do not share your password or other identifier with anyone. Furthermore, we strongly recommend that you do not use the same password for any other service or website.
12.3. The dynamics of the internet may mean that information is sent electronically to servers outside of the country where you originally entered the information. In addition, that information may be used, stored and processed outside the country where you entered that information and by using the Internet Sites you consent to such transfer, storage or processing. We will always take steps to ensure that your information is treated securely and adequately protected in accordance with this Privacy Policy.
12.4. Your data may be processed by staff that work for us or for one of our suppliers who may be situated outside the country where you entered that information. Such staff may be engaged in, among other things, the provision of our service(s) to you and the provision of support services. By submitting your personal information, you agree to such transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy.
12.5. We use strict procedures and security features to prevent unauthorised access. Agents or contractors who, while providing services to Comvita, have access to information which you give to us are required to keep that information secure and confidential and are not permitted to use it for any purpose other than to carry out the services which they are performing for Comvita. 
12.6. Unfortunately, no data transmission over the internet can be guaranteed as totally secure. Whilst Comvita strives to protect such information we do not warrant, and cannot ensure, complete security of any information which you transmit to us. Accordingly, any information which you transmit to us is transmitted at your own risk. Nevertheless, once we receive your transmission, we will take reasonable steps to preserve the security of such information.

13.  FOR HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION?
13.1 If you choose to create an account, we will keep your personal information for as long as your account is open. If you don’t have an account, or choose to close your account, we will keep some of your information until 8 years have passed since we last provided product to you. We consider 8 years to be an appropriate retention period because it is as long as is necessary for us to:
13.1.1. respond to any questions, complaints or claims made by you or on your behalf;
13.1.2. show that we treated you fairly;
13.1.3. keep records required by law; and
13.1.4. satisfy any accounting or reporting requirements.
13.2. We will not retain your personal information for longer than necessary for the purposes set out in this policy or for which the information may lawfully be used.
13.3. When it is no longer necessary to retain your personal information, we will delete or anonymise it.

14.  QUERIES & COMPLAINTS
If you have any queries in regard to our Privacy Policy please do not hesitate to contact Comvita by email: privacy@comvita.com or telephone 0800 504 959.
Please contact us at privacy@comvita.com with any request different to our standard policy.
Postal Address: 23 Wilson Road South, Private Bag 1, Paengaroa 3153, New Zealand
We will do our best to resolve any concerns you may have directly with you and encourage you to contact us with details of your concerns. If we are unable to resolve your concerns you have the right to make a complaint to the NZ Privacy Commissioner. For further information on making a complaint visit www.privacy.org.nz/your-rights/making-a-complaint.

15.  ADDITIONAL TERMS THAT APPLY TO RESIDENTS OF THE UNITED KINGDOM AND THE EUROPEAN ECONOMIC AREA 
If you are located in the United Kingdom (“UK”) or the European Economic Area (“EEA”), the following additional terms apply.
15.1. The data controller responsible for your personal information is Comvita.
15.2. Our legal basis or collecting and using the personal information described in this Privacy Policy will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you.
15.3. If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
15.4. If we collect and use your personal information in reliance on our legitimate interests, this interest will normally be to operate our Website and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, or improving our Website. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
15.5 In addition to the rights already recorded above, you may have the following additional rights in relation to the personal information we hold about you:
15.5.1. Right to be forgotten - The right to require us to delete your personal information where there is no good reason for us continuing to process it or where you have successfully exercised your right to object to processing (see below). Note however that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
15.5.2. Right to restrict processing - The right to require us to restrict processing of your personal information in the following scenarios:
•    If you want us to establish the data’s accuracy.
•    Where our use of the data is unlawful but you do not want us to erase it.
•    Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
•    You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
15.5.3. Right to data portability - The right to receive the personal information you provided to us in a structured, commonly used and machine-readable format and / or to transmit that data to a third party, in certain situations. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
15.5.4. Right to object – Right to object: 
•    At any time to your personal information being processed for direct marketing (including profiling).
•    In certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests.
15.5.5. Right not to be subject to automated individual decision-making - The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly affects you.
15.5.6. Right to withdraw consent at any time - This only arises where we are relying on your consent to process your personal information. However, this will not affect the lawfulness of any processing before you withdraw consent.
Please be aware that some of these rights may be limited or unavailable where we have an overriding interest or legal obligation to continue to process the data.
15.6 The applicable Comvita Cookies Policy can be accessed at https://comvita.co.uk/pages/cookie-policy