We Listen
We Research
We Design
We Build
We Deliver
New Digital Partners

Privacy Policy

Privacy Policy



it does not include any personally identifiable information. We may not be  

1.1. ‘Supplier,’ ‘we’, or ‘us’ means The Web Guys Limited trading as The Web  Guys (our successors and assigns) or any person acting with the  authority of The Web Guys Limited. 

1.2. ‘Client,’ ‘you’, or ‘your’ means the Client purchasing Services from us or  any person acting on your behalf. 

1.3. ‘Services’ means all Incidental Items (including any printed or virtual  material, samples, designs, drawings, images, graphics, advertising,  search engine optimisation, publication, data, files, information or other  associated documentation and goods), software, applications or mobile  application development (whether supplied from a third party software  development company or where custom developed or programmed for  you) or any advice or recommendations, personal development, Website  development, graphic design, consultancy, marketing assessment, brand  development, integration of strategies, analysis, project management,  videography, photography, drone photography or media sourcing)  provided by us at your request from time to time (and where the context  permits, the terms Incidental Items or Services shall be interchangeable  for the other). 

1.4. ‘Agreement’ means our terms & conditions of trade, as may be amended  from time to time (including our privacy policy and any SLA, orders,  purchases or schedules as applicable). 

1.5. ‘Cookies’ means small files stored on a user’s computer. They are  designed to hold a modest amount of data (including Personal  Information) specific to a particular Client and Website. They can be  accessed either by the web server or your computer. If you do not wish to  allow, Cookies to operate in the background when ordering from the  Website, you have the right to enable or disable the Cookies first by  selecting the option provided on the Website before ordering Services. 

1.6. ‘Personal Information’ is defined in Part 1, section 7 of the Privacy Act  2020. 

1.7. ‘Website’ means a location accessible on the internet through the world  wide web and provides multimedia content via a graphical user interface. 1.8. In this Agreement, unless the context otherwise requires: (a)headings are for convenience only and do not affect interpretation;  and 

(b)a reference to legislation includes all regulations, orders, instruments,  codes, guidelines, or determinations issued under that legislation or  any modification, consolidation, amendment, re-enactment,  replacement, or codification.


2.1. Personal Information is information about an identifiable individual and  includes the individual’s name, address, email address, and telephone  numbers. We collect information about you whenever you interact with  us, for example, when you visit our Website or engage in any Services.


3.1. We may collect Personal Information when you purchase our Services,  register for events, complete surveys, subscribe to our newsletters or  mailing list, enter promotions or otherwise communicate with us. The  Personal Information may include your name, contact details, email  address, credit card details, place of work, position and other information  necessary for us to provide the Services you have requested.  

3.2. We collect unique identifiers, browser type and settings, device type,  operating system, and mobile network information (including the carrier  name, phone number, and application data). We also collect information  about the interaction of your apps, browsers, and devices with our  Services, including IP address, crash reports, system activity, and the  date, time, and referrer URL of your request. 

3.3. We gather information about our Website user's Personal Information  provided when you complete an online form or request our  Services. When visitors leave comments on the Website, we collect the  data shown in the comments form and the visitor’s IP address and  browser user agent string to help spam detection. Google Analytics or  our web servers collected information can include the following types: 

(a)the date and time of visits to the Website 

(b)pages viewed; 

(c)the referring Website; 

(d)your IP address; and 

(e)technical information on browser connections 

3.4. This information is anonymous, and no attempt is made to identify users  or their search activities. When you visit our Website, we collect general  user information such as users’ internet protocol addresses, browser  type, internet service provider details, and other technical information.  We use this information to administer the Website and better understand  our users and how they use it. However, this information is not personal,  

able to provide you with the Services properly you require if you do not  provide us with the necessary Personal Information when requested. 3.5. We retain Personal Information regarding you for as long as your  account is active to provide you with our Services. We also retain  Personal Information for as long as necessary to achieve the purposes  described in this privacy policy, for example, to comply with our legal  obligations, protect ourselves in the event of disputes, and enforce our  Agreements. 

3.6. The precise periods for keeping your Personal Information vary  depending on the nature of the information and why we need it. Factors  we consider in determining these periods include the minimum required  retention period prescribed by law or recommended as best practice, the  period during which a claim can be made concerning an Agreement or  other matter, and whether the Personal Information has been aggregated  or anonymised (or other relevant criteria).


4.1. When you enquire about or purchase Services from us, we may ask for  your consent to collect information about you from others (including  undertaking credit checks, obtaining references, or co-operating with  your other service providers or suppliers).  

4.2. We may record information about how you use and interact with our  Website, including how, when, where and how often you use our Website  (such as login information and the internet protocol address of the device  you use to access our Website). We may also maintain records of your  communications with our staff, including phone calls, e-mails and other  electronic messages. 

4.3. We use our collected information to interact with you directly, like your  email address. We may notify you if we detect suspicious activity, like an  attempt to sign in to your account from an unusual location. Or we may  let you know about upcoming changes or improvements to our Services.  If you contact us, we will keep a record of your request to help solve any  future issues you might be facing. 

4.4. We also use third-party service providers (such as Google) to help us  track the effectiveness of our Website to generate visitor traffic and  display targeted advertising. These advertisements may collect  anonymous information about your visits to the Website on which such  ad is placed, your interaction with these ads and the Services offered by  us and others through a cookie (including Google Analytics) or other web  technologies. We and other selected marketing organisations may use  this anonymous information to inform, optimise and provide targeted  advertisements. 

4.5. If you consent to our Cookies on our Website and later wish to withdraw  your consent, you may manage and control your privacy settings via your  web browser (including removing Cookies or deleting them from your  browser history when exiting the Website). 

4.6. We may use collected information to: 

(a)provide you with the Services that you have requested; 

(b)verify that existing information that we hold about you is accurate and  complete; 

(c)undertake credit checks; 

(d)process credit card transactions; 

(e)maintain or improve our Services or Website; 

(f) communicate with you to inform you about new Services or other  promotional activities; 

(g)help with any issues or problems you may have with our Services or  Website;  

(h)assist us in performing our obligations or enforcing our rights under  any Agreement with you; and 

(i) understate research and analysis. 

4.7. We will share Personal Information outside of our business if we have a  good-faith belief that access, use, preservation, or disclosure of the data  is reasonably necessary to: 

(a)meet any applicable law, regulation, legal process, or enforceable  governmental request; 

(b)enforce applicable terms of our service, including investigation of  potential violations; 

(c)detect, prevent, or otherwise address fraud, security, or technical  issues; and 

(d)protect against harm to our rights, property, safety, users, or the public  as required or permitted by law. 

4.8. If a third party acquires us or substantially all of our assets, our Client  information will be one of the transferred assets. We will continue to  ensure the confidentiality of any Personal Information and will give  affected users notice before personal data is transferred or becomes  subject to a different privacy policy. 

© Debt Free Limited 2021-2022 1


4.9. We may share aggregated, non-personally identifiable information  publicly and with our contractors, service providers and other third parties  (including marketing organisations such as Google). 

4.10.We will ask for your consent before using Personal Information for  purposes other than those set out in this privacy policy. 

4.11.You are solely responsible for complying with any laws and regulations  that apply to your collection and use of your end users’ information,  including Personal Information you collect about them from us or using  Website technology (including Cookies or similar technologies). 

4.12.We acknowledge our obligation regarding the handling, use, disclosure  or processing of Personal Information under the Privacy Act 2020 (and  part two of the Organisation for Economic Co-operation and  Development (OECD) guidelines on the protection of privacy and trans 

border flows of personal data) including any statutory requirements  where relevant under the General Data Protection Regulation (GDPR). 4.13.If we become aware of any data breaches or disclosure of your Personal  Information held by us that may result in serious harm to you, we will  notify you in accordance with the Privacy Act 2020 or the requirements  set out in the GDPR. 


5.1. A cookie is a small text file placed on your device by a Website to  capture information about your visit. 

5.2. We use Cookies (including Cookies developed by our third-party service  providers such as Google Analytics) for several purposes, including  improving our Services and enhancing your online experience with us  and maintaining the secure connection between your browser and our  servers while using our Website. 

5.3. We receive information when you interact with and use our Website. We  use server logs and different web analytic tools to help us record this  information (including Cookies and other anonymous identifiers). These  tools may gather information such as what browser and operating system  you use, the Website address from which you came, and the Website  you are going to when you leave our Website. We may also identify  search terms, your location and what content or Services are viewed  when visiting our Website. 

5.4. You agree that: 

(a)in most circumstances, you can adjust the settings on your browser to  notify you when you are offered a cookie so you can decide whether or  not to accept it. However, if you disable or block Cookies, our secure  Services (such as online payments) won’t work, and other parts of our  Website may not work correctly; and 

(b)we use Cookies and other tracking software throughout our Website.  These collect information covering multiple sessions across multiple  devices which may identify you personally, such as where you provide  us with information on an online form (regardless of whether that form  is submitted or not) or when you are using, or have used, one of our  secure online Services. 

5.5. Session Cookies: 

(a)we use session Cookies to identify a particular session on our  Website. A session is the time you visited and spent on our Website  using a specific device. The information collected from the session  (which may or may not identify you personally) is about your browsing  activities on our Website, such as what buttons you clicked, what  pages you visited, what content we displayed to you, and information  you entered on our Website. We don’t monitor your activity after you  have left our Website, and we do not watch what you are doing on  other Websites simultaneously as you are using ours; 

(b)every time you go back to our Website using the same device in the  same session, the Website will recognise what happened previously  with the browsing activities on that device; 

(c)we use persistent Cookies to give you the ability to set your  preferences for our Website (such as bookmarking the business home  page to your browser); and 

(d)we may also use these Cookies for fraud detection and investigation. 5.6. Information collected by our Cookies will: 

(a)identify you and your browser, and determine if your device has  previously visited our Website; 

(b)identify other pages or a third party’s Website you have accessed  through our Website or when we provide you with a link to click; (c)help us to understand, optimise and personalise your experience; (d)improve our advertising and deliver you content or offers we think are  most relevant; and 

(e)detect malicious activity from your device that may place your security  at risk. 

5.7. You may set your browser to block all Cookies, including Cookies  associated with our Website or Services, or indicate when we are using a  

cookie. If you set your browser to reject all Cookies, however, you may  not be able to use all of the features and functionalities of our Website. 


6.1. We always try to ensure that our information is accurate and up to date.  We will maintain security safeguards to protect your information and take  all reasonable steps to ensure that your information is not disclosed to  any unauthorised person or entity. 

6.2. We use encryption to protect your private information as you enter it on  our Website, such as the Secure Socket Layer (SSL) protocol. When  you pay online by credit card, we use a PCI-DSS compliant third-party  payment gateway to process the payment securely. 

6.3. We keep your Personal Information only as long as we need it for the  purposes for which it was initially collected (or to which you have  consented), for other legitimate purposes (such as regulatory  compliance) or as required by applicable laws. 

6.4. We may store the Personal Information we collect in any format we  choose at our offices or premises outside our offices, including data  storage facilities or online storage located within or outside New Zealand,  which independent service contractors may operate, where your  Personal Information is transferred outside New Zealand. 

6.5. We store and process information (both personal and non-personally  identifiable information) on servers in several different countries  worldwide. Information held in another country may be subject to that  country's privacy laws. It may permit the government and other  regulatory authorities to access such information in certain  circumstances. Regardless of where your information is processed, we  apply the same protections described in this privacy policy. We also  comply with specific legal frameworks relating to the transfer of data. 


7.1. Articles on this Website may include embedded content or articles.  Embedded content from other Websites behaves the same way as if the  visitor has visited the other Website. These Websites may collect data  about you, use Cookies, embed additional third-party tracking, and  monitor your interaction with that embedded content, including tracking  your interaction with the embedded content if You have an account and  are logged in to that Website. 

7.2. Our Website may also contain links and advertisements which link to  third party Websites. We have no control over the privacy policies of such  third parties, and we encourage you to review such policies before  providing any information. 


8.1. Under the Privacy Act 2020, individuals have the right to access and  request the correction of their Personal Information. You also have rights  under the GDPR. If you have any questions about this privacy policy or  requests relating to your Personal Information, please contact us. If you  would like to update your details, please request and complete a Client  Information Form with your amended details. 


9.1. Resolving complaints: When we receive formal written complaints, we  respond by contacting the person who made the complaint. We work with  the appropriate regulatory authorities, including local data protection  authorities, to resolve any complaints regarding the transfer of your data  that we cannot resolve with you directly. 

9.2. Updates to this Policy: We change this privacy policy from time to time.  We will not reduce your rights under this privacy policy without your  explicit consent. We always indicate the date the last changes were  published, and we offer access to archived versions for your review. If  changes are significant, we’ll provide a more prominent notice (including  for certain Services, email notification of privacy policy changes). 

9.3. Legal Basis For Collecting Information: We process your Personal  Information based on your written or oral consent. You may withdraw  your consent at any time. The withdrawal of consent will not affect the  lawfulness of processing Personal Information based on consent before  its withdrawal. 

9.4. This privacy policy is governed by and to be construed in accordance  with the laws of New Zealand, and each party submits to the exclusive  jurisdiction of the courts of New Zealand.