Privacy is important, especially when you consider the number of ways we communicate and interact these days. That’s why we’ve put together this statement. It explains how we collect, hold, use and disclose your personal information and who we share it with.
When we say ‘we’ or ‘us’ or ‘El Gusto’ we mean UBT Holdings Limited as Trustee of UBT Holdings Trust, trading as El Gusto and any other authorised businesses that sell goods and services under the El Gusto brand.
What is “Personal Information”?
Personal information is information or an opinion about an identified individual or an individual who is reasonably identifiable.
When do we collect Personal Information?
El Gusto collects Personal Information about individuals directly from those individuals or their authorised representatives.
When you interact with us, we may collect Personal Information, such as names, contact details and other relevant information. Some instances of this are when you:
• visit our website
• use or purchase our products or services
• contact us by telephone
• provide information voluntarily
We do not collect Sensitive Information without your consent and then only if it is reasonably necessary. El Gusto may also collect Personal Information about you from a third party or from a publicly available source, but only if:
• You have consented to such collection or would reasonably expect us to collect information in this way, and
• It was not reasonable or practical to collect this information directly from you.
Do we collect Personal Information via websites?
El Gusto does not collect any Personal Information about visitors to websites except when they knowingly provide it or as otherwise described below.
Click Stream Data – when you visit and browse El Gusto’s website will collect Personal Information for statistical reporting and maintenance purposes via Google Analytics.
Google Analytics uses first-party cookies to track visitor interactions. These cookies are used to store information, such as:
• the date, time and duration of a visit;
• whether the visitor has been to the site before;
• what site referred the visitor to the web page; and
• the number of users visiting the websites and the number of pages viewed
Cookies are small text files that are transferred to a user’s computer hard drive by a website for the purpose of storing information about a user’s identity, browser type, or website visiting patterns; if you access El Gusto’s website a cookie is downloaded onto your computer’s hard drive when you first log onto the website and it is automatically deleted from your hard drive after a period of thirty days.
Web beacons are images that originate from a third party site to track visitor activities; El Gusto currently uses web beacons to track the visiting patterns of individuals accessing the website
Login audit logs are used to record a user’s usage history and selections
How do we use the Personal Information we collect about you?
El Gusto uses the information it collects about you to:
• Identify you and conduct appropriate checks
• Communicate with you
• Provide you with goods or services you have requested
• Provide you with information about goods and services we reasonably believe you may be interested in
• Provide you with general information we reasonably believe you may be interested in
• Personalise and customise your experiences with websites
• Manage complaints and disputes, and report to dispute resolution bodies
• Comply with Occupational Health and Safety regulations
• Comply with industry codes or a lawful request
How do we check the quality of Personal Information?
El Gusto takes reasonable steps to ensure the personal information we collect is accurate, up to date and complete. We may do this by providing you access to edit some of your personal information, periodic update requests, when interacting with you and where practical electronic synchronization of the El Gusto database. We provide you the right to access and correct Personal Information. You may request that your personal information be erased from our records.
Who sees your Personal Information?
El Gusto discloses the information about you if or when:
• El Gusto has your consent to share the information; or
• Someone acting on El Gusto’s behalf provides the product or service you have requested; or
• El Gusto reasonably believes that your actions on the website violate El Gusto’s Terms
• El Gusto may disclose Personal Information to third parties but only to the extent necessary to fulfil the purposes for which the Personal Information was collected.
El Gusto may also disclose your Personal Information to the website host in certain limited circumstances for example ensuring that if the website experiences a technical problem it is able to operate in an effective and secure manner.
El Gusto may collect government related identifiers from you, which will be used or disclosed only where such use or disclosure is reasonably necessary to verify your identity for the purpose of an activity we are undertaking on your behalf such as provision of tax related services requested for a government agency.
Do we use your Personal Information for marketing?
El Gusto may use your Personal Information to provide you with promotional material about El Gusto or the services and products offered by El Gusto and preferred suppliers. If you do not wish to receive promotional information you can contact our Data Manager by emailing email@example.com at any time requesting that your name be removed from El Gusto’s marketing lists.
Otherwise El Gusto will not disclose any of your Personal Information to any other organisation unless the disclosure is required by law or is otherwise permitted by the Privacy Principles in your country.
How do we keep your Personal Information safe?
El Gusto takes reasonable steps to protect and keep your Personal Information from misuse, interference, loss, unauthorised access, modification or disclosure. The ways we do this include:
• Using Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive information
• Limiting physical access to our premises and files
• Limiting electronic access to our networks, applications and files
• Using security related hardware and software
• Implementing personnel safe practice policies and training
• Monitoring and reviewing our practices periodically
• Using third parties who meet obligations under the Privacy Principles in your country.
We periodically consider whether we need to retain your Personal Information in order to continue providing our goods and services to you, and may destroy or de-identify your Personal Information, except where we are required by law to retain it.
How can you see the Personal Information that we hold about you?
You are entitled to access Personal Information that El Gusto holds about you.
Access to your Personal Information is subject to El Gusto being satisfied you are the individual we hold Personal Information on or the person requesting is authorised to make a request on your behalf.
If El Gusto delays or refuses your request to access some or all of your Personal Information it will provide you written notice of the reasons for the refusal, such as access would unreasonably impact upon the privacy of others or would not otherwise be permitted under the Privacy Principles in your country. A request for access can be done in any of the following ways:
Telephone: +64 800 828 123
Post to: PO Box 5206, Terrace End, Palmerston North 4441, New Zealand
Your rights, if you are located in the European Economic Area
If you are located in the European Economic Area, under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
• fair processing of information and transparency over how we use your use personal information;
• access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address;
• require us to correct any mistakes in your information which we hold;
• require the erasure of personal information concerning you in certain situations;
• receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
• object at any time to processing of personal information concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
• object in certain other situations to our continued processing of your personal information;
• otherwise restrict our processing of your personal information in certain circumstances;
• claim compensation for damages caused by our breach of any data protection law.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
• email, call or write to our Data Manager whose contact details are at the end of this notice;
• let us have enough information to identify you;
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
• let us know the information to which your request relates.
How can you correct your Personal Information?
You can update your Personal Information at any time by contacting El Gusto.
Otherwise our Data Manager will correct your Personal Information. If we find that we have no further need for your Personal Information we will permanently de-identify it or remove it from our system and destroy all record of it. El Gusto welcomes any changes to your details so as to keep our records up to date.
What can you do if you have a question, problem or complaint about our use of your Personal Information?
Telephone: +64 800 828 123
Post to: PO Box 5206, Terrace End, Palmerston North 4441, New Zealand
Lodge a complaint to firstname.lastname@example.org