This policy describes how we collect, process and use personal information or data (personal data) about you. It is our intention to comply with the New Zealand Privacy Act 1993 (NZ Act), the European General Data Protection Regulation (GDPR) and other data protection and privacy laws and regulations applicable to us or to our processing of your personal data (Data Protection Legislation).
2. Who we are
Wilderness Motorhomes Limited is a New Zealand registered company with its principal places of business at 11 Pavilion Drive, Airport Oaks, Auckland, New Zealand and 3 Export Avenue, Harewood, Christchurch, New Zealand.
For the purposes of the GDPR, Wilderness is the data controller.
3. The information we collect about you
Information we collect automatically
When you visit our website, our server or the server of our technical providers automatically collects certain browser or device generated information, including but not limited to:
- your IP address;
- domain names;
- referring website address;
- your date, time and duration of your visit;
- your browser type;
- your operating system;
- your page visits;
- other information about your computer or device
Information you provide
In order to access or use certain portions of the website or enjoy the full functionality of the website, or otherwise in conducting business with us or seeking to conduct business with us, you may be prompted to provide certain personal data to us in the following ways:
- by making a booking with us for the hire of a motorhome;
- by filling in forms (for example, a 'Contact us' form) on our website or at a trade show or anywhere else we conduct business;
- by downloading documentation such as an e-book from our website;
- by subscribing to newsletters, offers and tips, blog posts or other communications;
- by corresponding with us by phone, e-mail or otherwise using our contact details;
- or by submitting questions or comments to us or requesting any other information from us.
We do not collect any sensitive data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We do not collect any information about criminal convictions and offences, although we may be required to briefly hold and pass on any driving infringements that you incur while renting our vehicles.
5. Lawful basis for processing of personal data
The table below describes the various forms of personal data we collect and the lawful basis for processing this data. We have processes in place to make sure that only those people in our organisation who need to access your data can do so. A number of data elements are collected for multiple purposes, as the table below shows. Some data may be shared with third parties and, where this happens, this is also identified below. In the table below, the following terms have the stated meaning:
- Consent means only when you have consented to the processing for one or more specific purposes.
- Contractual Performance means the processing is necessary to perform a contract with you or in order to take steps at your request prior to entering into a contract, such as to fulfil a booking, or to provide product information you have requested;
- Legal Obligation means the processing is necessary for us to comply with a relevant legal obligation, such as keeping accounting records;
- Legitimate Interest means the processing is in our or a third party’s legitimate interests, which are not overridden by your interests or fundamental rights and freedoms which require protection of personal data.
When we process on the lawful basis of legitimate interest, we apply the following test to determine whether it is appropriate:
- The purpose test – is there a legitimate interest behind the processing?
- Necessity test – is the processing necessary for that purpose?
- Balancing test – is the legitimate interest overridden, or not, by the individual’s interests, rights or freedoms?
|Data collection point||Personal Data collected||Purpose for collection||Lawful basis for processing||Personal Data shared with?|
|e-Book or Guide download||
||Consent / Legitimate Interest||Internally only|
||Consent / Legitimate Interest||Internally only|
|Motorhome Selector Tool||
||Consent / Legitimate Interest||Internally only|
|Contact Us Page||
||To respond to your questions or required information||Contractual Performance||Internally only|
|To subscribe to our latest news, offers and tips||Consent||Internally only|
|To subscribe to our latest blog posts||Consent||Internally only|
|Website visitor analysis-general||
||To help us to provide you with a good experience when you browse our website and also allows us to improve our site||Legitimate Interest||Internally only|
|Website visitor analysis-security||Technical Information as above plus any personal data that may be required for this purpose||To protect our websites and infrastructure from cyber attack or other threats and to report and deal with any fraud or other illegal acts.||Legitimate interest||Internally, forensic and other organisations with whom we might contract for this purpose.|
||To process hire transactions for motorhomes and services with customers, and to ensure any transaction issues can be dealt with.||Contractual performance||Internally only|
|For accounting and taxation purposes||Legal Obligation||Internally and professional advisers|
|Documentation should any contractual legal claim arise||Legitimate Interest||Internally and professional advisers|
|To deal with parking and driving local and other regulatory authorities||Legitimate Interest||Internally, relevant local and other regulatory authorities, and professional advisors|
|To send you our latest news, offers and tips and/or latest blogs||Consent||Internally only|
|To send you information to help you with your travel journey||Contractual performance||Internally only|
Payment card details including,
|To pay deposits, hire fees and other authorised charges||Contractual performance||Payment card companies, all in line with PCI DSS.
NB: Only retained while authorisation is pending.
|Reviews and Surveys||
||To request a review or to take a survey||Contractual performance /Legitimate Interest||Internally and approved third party service providers and professional advisers|
To enable you to participate in prize draws, competitions and giveaways
|Contractual performance /Legitimate Interest||Internally and approved third party service providers|
6. Disclosure of personal data
We use various marketing tools that help us create a better user experience for people visiting our site. These tools allow us to look at aggregated data such as scrolling patterns, clicks, and allow us to run tests to determine which pages result in the best actions. However, your personal data is not used by any of these tools. We use the following third-party service providers for tracking:
We also use remarketing tracking cookies and conversion pixels from vendors such as Google and Facebook to present special offers to you for our products or services over the Google Content Network and via social networks. This means you may see an ad for one of our products or services as a result of visiting our website. However, your personal data is not used by any remarketing service other than to present you special offers and messages from us. When you first visit our website you will be prompted to accept or decline the use of these cookies that aren't strictly necessary for the functioning of the website. Cookie consent can be withdrawn at any time by clicking here.
The website is not for use by children under the age of 16 years and Wilderness does not knowingly collect, store, share or use the personal data of children under 16 years. If you are under the age of 16 years, please do not provide any personal data, even if prompted by the website to do so. If you are under the age of 16 years and you have provided personal data, please ask your parent(s) or guardian(s) to notify Wilderness and Wilderness will delete all such personal data.
8. Marketing emails
We will only send you marketing communications for the lawful purposes set out in the table above. If you wish to opt-out of receiving marketing communications, please use the 'unsubscribe' link provided in our emails, or otherwise contact us directly and we will stop sending you communications.
Wilderness aims to safeguard and protect your personal data from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss, and Wilderness utilizes and maintains certain reasonable processes, systems, and technologies to do so. However, you acknowledge that no transmission over the Internet is completely secure or error-free, and that these processes, systems, and technologies utilized and maintained by Wilderness are subject to compromise. Accordingly, we cannot be held responsible for unauthorized or unintended access that is beyond our control.
10. International transfers
For the most part, your personal data is collected, stored and processed outside the European Economic Area (EEA).
If we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we have entered into EU-approved standard contractual clauses with the recipient to give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
11. Retention of your personal data
We apply a general rule of keeping personal data only for as long as required to fulfill the purposes for which it was collected. In general, we retain your personal data for a period of time corresponding to a statute of limitation, for example to maintain an accurate record of your dealings with us. However, in some circumstances we may retain personal data for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.
12. External links
The website may contain links to third party sites. Since Wilderness does not control nor is responsible for the privacy practices of those websites, we encourage you to review the privacy policies of these third-party sites. This notice applies solely to personal data collected by our websites or in the course of our business activities.
13. Your Rights
As a data subject whose personal information we hold, you have certain rights depending upon the applicable Data Protection Legislation. If you wish to exercise any of these rights, please email firstname.lastname@example.org or use the information supplied in the Contact Us section below. In order to process your request, we will ask you to provide two valid forms of identification for verification purposes. Subject to the applicable Data Protection Legislation, your rights may include the following:
The right to be informed
The right of access
You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:
- The purposes of the processing.
- The categories of personal data concerned.
- The recipients to whom the personal data has been disclosed.
- The retention period or envisioned retention period for that personal data.
- When personal data has been collected from a third party, the source of the personal data.
If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.
The right to rectification
When you believe we hold inaccurate or incomplete personal data about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete data is not processed until it is corrected.
The right to erasure (the ‘right to be forgotten’)
Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
The right to restrict processing
You may ask us to stop processing your personal data. We will still hold the data, but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:
- The accuracy of the personal data is contested.
- Processing of the personal data is unlawful.
- We no longer need the personal data for processing but the personal data
- is required for part of a legal process.
- The right to object has been exercised and processing is restricted pending a decision on the status of the processing.
The right to data portability
You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.
The right to object
You have the right to object to our processing of your data where:
- Processing is necessary for the purposes of a task carried out in the public interest or in the exercise of official authority;
- Processing is based on legitimate interest;
- Processing is for the purpose of direct marketing;
- Processing is for the purposes of scientific or historic research or statistical purposes;
- Processing involves automated decision-making and profiling.
14. Contact us
Alternatively, you may contact us at our head office using the following postal address or telephone numbers:
Physical Address: Privacy Officer, Wilderness Motorhomes, 11 Pavilion Drive, Airport Oaks, Auckland, New Zealand
Phone: +64 9-255 5300
Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.
You may also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal data infringes applicable Data Protection Legislation
16. Changes to this notice
Any changes or updates we may make to this notice will be posted on this page. If we have your contact details on file we will endeavour to notify you in advance of any changes to this notice that are material or may impact you. For other changes, please check back frequently to see any updates or changes to this notice.