Sanderson Group and its relatedentities, officers, employees, agents and contractors (“Sanderson Group”,“our”, “us” or “we”) are committed to protecting your personal information andprivacy in accordance with the New Zealand Privacy Act 2020 (the “Act”).

Personal information isinformation about an identifiable individual (a natural person). This policysets out how we collect, use, disclose, store and protect your personalinformation. It does not limit or exclude any of your rights under the Act.

This policy applies to anywebsite, service, sales suite, display suite or office operated by SandersonGroup and its related entities. It applies to any person whose personalinformation we currently hold, or may collect in the future. If you would likemore information about the Act, visit privacy.org.nz.

What personal information we collect

The personal information wecollect and hold is information relevant to providing our services to you. Itmay include:

•    your name, postal and email addresses, and contactnumbers

•    proof-of-identity documents, such as a driver’s licenceor passport

•    details about your requirements and preferences inrelation to our villages, residences, products or services

•    financial information needed to process a transaction,such as payment or deposit details

•    information about other people connected to yourenquiry, such as a partner, family member or representative (please onlyprovide this where you are authorised to do so)

•    any information you provide to us directly, through ourwebsites, or via our representatives

•    technical and usage information collected automaticallywhen you visit our websites (see “Cookies, analytics and tracking” below)

This is not an exhaustive list,as we may need to collect further information to provide our services to you.Where additional information is needed for a specific purpose, we will identifythat purpose at the time of collection.

How we collect your personal information

We collect personal informationabout you from:

•    you, when you provide it to us, for example via ourwebsites, through any registration, enquiry or subscription process, throughany contact with us (such as a phone call, email or visit to a display suite),or when you buy or use our services and products

•    third parties, where you have authorised this or theinformation is publicly available.

Wherever possible, we collectpersonal information directly from you. We also collect some informationautomatically when you use our websites, such as your IP address, the pages andlinks you view, and the date and time of your visit.

How we use your personal information

We use your personal informationto further our relationship with you and to operate our business. Inparticular, we may use it:

•    to verify your identity

•    to respond to your enquiries and provide services andproducts to you

•    to manage the sale, licensing or occupation of aresidence, including preparing and administering agreements

•    to market our services and products to you, includingcontacting you electronically (for example by phone, email or text)

•    to promote other property developments across ouraffiliated group of companies where they are relevant to you

•    to improve the services, products and websites that weprovide

•    to analyse your enquiries, interactions andcommunications with us (including email correspondence), including by usingautomated tools, to understand your preferences and level of interest and totailor and improve the products, services and communications we offer you(where we generate insights or a profile about you, you may ask to access orcorrect it)

•    to undertake credit checks (where necessary)

•    to respond to communications from you, including anycomplaint

•    to conduct research and statistical analysis (on ananonymised basis)

•    to protect and enforce our legal rights and interests,including defending any claim

•    to comply with applicable legal requirements andindustry standards

•    for any other purpose authorised by you or by the Act.

We may also use your personalinformation for other purposes that we identify to you at the time ofcollection. We reserve the right to transfer personal information we hold aboutyou if we sell or transfer all or part of our business assets.

Cookies, analytics and tracking

When you visit our websites, weautomatically collect certain information from your browser or device. This mayinclude your IP address, the URL visited, the search terms you used, the pagesand links you viewed, the referring website, the date and time of your visit,your operating system, browser type, screen resolution and language setting.This information is generally aggregated and does not identify you personally.

We use cookies, pixel tags andsimilar technologies to understand how our websites are performing and toimprove and personalise content. The analytics and tracking tools we currentlyuse include:

Google Analytics, privacy policyat policies.google.com/privacy

Meta (Facebook) Pixel andanalytics, privacy policy at facebook.com/policy.php

other analytics, performance andadvertising platforms that help us understand and improve how our websites areused. These providers maintain their own privacy policies, which govern howthey handle information collected through our websites.

These tools may set persistentcookies (cookies with an expiry date) to monitor site usage. You can manage ordisable cookies through your browser settings, and you can opt out of manyanalytics and advertising cookies directly with the providers above. Disablingcookies may mean some features of our websites do not work as intended. Bycontinuing to use our websites you consent to our use of cookies and analyticsas described in this policy.

Disclosing your personal information

It is sometimes necessary for usto share your personal information with others in order to provide ourservices. We do not sell your personal information. We may disclose it to:

•    another company within our group of related entities

•    agents, contractors, consultants and subcontractorsengaged in our business activities

•    businesses that support our services and products,including providers that host or maintain the IT systems, data centres andplatforms we use to operate our websites and services

•    a credit reference agency, for the purpose of creditchecking you

•    banks, funders and other financial institutions, wherenecessary in connection with our business and your dealings with us

•    professional advisers, such as our lawyers andaccountants

•    third parties, in anonymised or aggregated form, forstatistical purposes

•    a person who can lawfully require us to supply yourpersonal information, such as a regulatory or law-enforcement authority

•    any other person authorised by the Act or another law

•    any other person authorised by you.

Storing and sending information overseas

Some of the service providers weuse store and process information on servers located outside New Zealand. Thismeans your personal information may be held and processed overseas. Where wetransfer personal information overseas, we take reasonable steps to ensure itis subject to protections comparable to those under the Act.

Keeping your personal information secure

We take reasonable steps to keepyour personal information safe from loss, unauthorised access, use,modification, disclosure or other misuse. However, no method of transmissionover the internet is completely secure, so if you provide us with personal informationover the internet you do so at your own risk.

If you post personal informationon any of our social media channels (for example Facebook or Instagram), youacknowledge that the information you post is publicly available.

How long we keep your personal information

We keep personal informationonly for as long as we need it for the purposes set out in this policy, or foras long as we are required to keep it by law (for example, financial andcontractual records). When we no longer need it, we take reasonable steps tosecurely destroy or de-identify it.

Accessing and correcting your information

Under the Act, you have theright to ask for access to the personal information we hold about you, and torequest that we correct it if it is wrong. We may need to verify your identitybefore providing access. To make a request, contact us using the details below.There is generally no charge, although in some cases a reasonable charge mayapply.

Marketing and your choices

When you provide us withyour email address, whether through ourwebsite enquiry form, registration, or any other contact, youmay be subscribed to receive our newsletter and marketing communications,including updates on new homes, developments and promotions. You can opt out atany time by clicking the “unsubscribe” link in any marketing email, or bycontacting us at info@sandersongroup.co.nz. We will action all unsubscriberequests promptly and within five working days, in accordance with theUnsolicited Electronic Messages Act 2007.

If you no longer wish to receivemarketing communications from us, you can opt out at any time by using theunsubscribe link in our emails or by contacting us directly. We will continueto send you communications that are necessary to manage our existingrelationship with you (for example, in relation to an agreement you have withus).

Privacy breaches

If a privacy breach occurs thatwe believe has caused, or is likely to cause, serious harm, we will notify theaffected individuals and the Office of the Privacy Commissioner as required bythe Act.

Links to other websites

Our websites may contain linksto other websites. We are not responsible for the content or privacy practicesof those websites. If you follow a link to another site, that site will haveits own privacy policy, and we suggest you review it before providing anypersonal information.

Changes to this policy

We may update this PrivacyPolicy from time to time. If we do, we will publish the updated version on ourwebsites, and the change will apply from the date the revised policy isuploaded. We encourage you to review this policy periodically.

Complaints and how to contact us

If you have any questions aboutthis policy or our privacy practices, or you would like to access or correctyour personal information, please contact our Privacy Officer:

Sanderson Management Limited

44 Brown Street, Tauranga 3110

PO Box 15083, Tauranga 3144, NewZealand

Phone: 0800 887 779

Email: info@sandersongroup.co.nz

If you are not satisfied withour response to a privacy concern, you can contact the Office of the PrivacyCommissioner:

Phone: 0800 803 909 · Website: privacy.org.nz

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