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PRIVACY POLICY 

Last updated: May 2026

1. Introduction

   1. Delightable Limited (Delightable) takes privacy seriously and is committed to protecting personal information. In this policy, “Personal Information” means any information about an identifiable individual, as defined in the New Zealand Privacy Act 2020 (Privacy Act), and Delightable is also referred to as “we” and “us”.

   2. This policy applies to Personal Information we and our people hold in connection with the Delightable service. This policy explains how we collect, use, share, and protect personal information.

   3. We comply with New Zealand privacy laws when handling personal information. If you use the service from outside New Zealand, you do so knowing your information will be handled in line with the Privacy Act. Nothing in this policy limits your rights under the Privacy Act.

2. Collection of Personal Information

   1. We may collect Personal Information about you in different ways:

1. When using the Service, you participate in conversations (Conversations). The content of those Conversations and the recommendations generated by the Service may constitute Personal Information. Conversation data is not Personal Information unless we hold information that enables us to identify the individual.

2. If you provide us information to create an account, then we will collect the information you provide. 

3. We may collect information from other third parties, in accordance with clause 3 below.

2. You are responsible for ensuring that any Personal Information you provide to us is accurate, complete, and up to date. You must not provide Personal Information about another individual unless you have their authority to do so and have made them aware of this Privacy Policy.

3. We will also collect information that does not identify you for the purposes of improving the Service.  This information may identify your computer or mobile device, including browser type and version, mobile device type and operating system.  We do this by using analytical tools to collect information about the Service and its performance, Service interactions, and Service use analysis.

3. Collection from third parties

   1. Where possible, we will collect Personal Information directly from the individual concerned.  However, in some situations we may collect Personal Information about you from a third party.

   2. Where you use the Service as part of your work, we may collect Personal Information about you from the organisation you work with. We will deal with that Personal Information in accordance with this Privacy Policy. 

   3. Where you use the Service on a retailer’s website, we may collect information about your interactions with that website from third‑party ecommerce providers (such as Shopify), such as products you view or purchase, cart activity, and related browsing behaviour. We may combine that information with information generated through your use of the Service (including Conversations and preference data). We will deal with that Personal Information in accordance with this Privacy Policy.

4. Cookies

   1. A cookie is a small text file that may be stored on your device. Cookies will not collect identifiable information about you.  Except for the purposes contemplated in this Privacy Policy, we will not disclose any such information except in aggregate (anonymised) form.

   2. You may disable cookies by changing the settings on your browser, although this may mean that you cannot use all of the features of the Service. 

5. Storage and security of Personal Information

   1. We take the security of your Personal Information seriously. We take reasonable steps to ensure the safety of Personal Information stored in electronic format, and to protect against loss, unauthorised access, use, modification, disclosure, or other misuse.  We will not divulge Personal Information except in accordance with normal legal requirements and practices, including the ways that we have covered in this Privacy Policy.  

   2. Personal Information may be stored or processed outside New Zealand, including in Australia. Where we disclose Personal Information overseas, we take reasonable steps to ensure that the overseas recipient protects the information in a way that, overall, provides comparable safeguards to those under the Privacy Act, or where disclosure is otherwise permitted by law.

   3. To provide the Service we use third party service providers to store and process data, such as Amazon Web Services (AWS), in Sydney, Australia. Amazon Web Services has its own privacy policy which you can read here.

6. How we may use Personal Information

   1. We may use Personal Information:

1. to provide the Service, including giving you recommendations; 

2. to maintain and improve the Service;

3. to generate insights for retailer clients (on an anonymised basis);

4. to respond to communications from you;

5. to conduct research and statistical analysis (on an anonymised basis);

6. to send marketing communications to you; 

7. if you are a retailer client or an employee of a retailer client, to contact you to talk about your experience with the Service and/or your feedback about the Service;

8. to protect and/or enforce our legal rights and interests, including defending any claim; and

9. for any other purpose authorised by you or Privacy Act.

2. Delightable may use aggregated information from the Service to improve the quality the Service and for statistical purposes. This aggregated information is not associated with any individual person.  We may use this data in aggregate form as a statistical measure, but not in a manner that would identify any individual personally. 

3. We will take steps reasonable in the circumstances to ensure that your Personal Information is accurate, up to date, complete, relevant, and not misleading before using or disclosing it in accordance with this Privacy Policy. 

7. Disclosing Personal Information

   1. We may disclose Personal Information for the purposes for which it was collected, and directly related purposes, and for other purposes specified in this Privacy Policy or permitted by the Privacy Act. 

   2. We may disclose Personal Information:

1. to provide insights to retailer clients;

2. to third party marketing platforms used by retailer clients; 

3. to our third party service providers and contractors, who help provide, support, and enhance the Service;

4. to communicate with you by (e.g. by phone or email);

5. for internal purposes relating to maintaining and improving the Service;

6. when you have authorised us to do so;

7. when we reasonably believe we are required or permitted to do so by law;

8. if we believe that the disclosure is reasonably necessary to enforce any legal rights or obligations we may have;

9. if we sell/transfer all or part of our business to a third party; and

10. where it is necessary to do so to resolve a complaint you make about us.

8. Accessing and correcting Personal Information

   1. You have the right to request access to your Personal Information that we hold, and to request a correction to your Personal Information. 

   2. In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the Personal Information, we will make the correction. If we do not make the correction, we will note that you requested the correction.

   3. If you want to exercise your access or correction rights in respect of your Personal Information, please contact our Privacy Officer using the email below.  Before you exercise these rights, we may need evidence to confirm that you are the individual to whom the Personal Information relates. 

   4. Conversations in the Service are not Personal Information unless we know who you are (e.g. because you are a logged-in user). Therefore, the access and correction rights do not apply to any anonymous Conversation information.

9. Retention and destruction of your Personal Information

   1. We will only retain Personal Information for as long as is required for the purposes for which it may lawfully be used.  

   2. Once Personal Information is no longer required, we will securely destroy it or otherwise delete all identifying details information so that only anonymised data is retained.  

10. Reporting of notifiable privacy breaches

    1. If your Personal Information is involved in a privacy breach which we reasonably believe must be reported in accordance with Privacy Act (Notifiable Privacy Breach), we will inform the affected individual(s) and report the Notifiable Privacy Breach to the relevant persons as required by Privacy Act.    

11. Changes to this Privacy Policy

    1. We may update this Privacy Policy from time to time. We will publish the updated Privacy Policy on the Service. The revised Privacy Policy will apply from the date that we update it. 

    2. We encourage you to review this Privacy Policy periodically to stay informed. If you do not agree with any aspects of this Privacy Policy as updated from time to time, you must immediately stop using the Service. 

12. Contacting our Privacy Officer

    1. If you have any questions, concerns, or a complaint in relation to this Privacy Policy or the protection of your Personal Information, please direct them to the Privacy Officer at hello@itsdelightable.com. To enable us to more easily address any questions or concerns you have, it is preferable if they are made in writing.

The Privacy Officer will investigate any complaints that are received and respond to you as soon as possible. If you are not satisfied with how we have handled your complaint, you can contact the Office of the Privacy Commissioner.