PRIVACY POLICY
This Privacy Policy explains how your personal data is collected, used, and protected in accordance with the New Zealand Privacy Act 2020 when you use or purchase something from orthocomfort.co.nz (the “Website”).
1. Personal Data We Collect
Device Information. When you visit the Website, we automatically collect information about your device, including your browser type, IP address, time zone, and cookies installed. As you browse, we also collect information about the pages or products you view, referral source, and how you interact with the Site. We call this “Device Information.”
Log files: record IP address, browser type, ISP, referring/exit pages, and timestamp.
Web beacons, tags & pixels: electronic files used to collect details about how you navigate the Website.
Order Information. When you place (or attempt to place) an order, we collect your name, billing and shipping addresses, payment details (including credit card numbers), email address, and phone number. We call this “Order Information.”
Together, Device Information and Order Information are “Personal Data.”
2. Cookies & Consent (applicable privacy and electronic communications laws)
We use cookies and similar tracking technologies to operate the Website, improve your experience, and analyse usage. For details and how to withdraw consent, see our Cookie Policy.
3. How We Use Your Personal Data
We use your Personal Data to:
- Process and fulfil orders (including payment processing, shipping preparation, and sending invoices/confirmations).
- Communicate with you about your order and account.
- Screen for fraud and assess risk.
- Send you marketing (where you have consented).
- Improve and optimise the Website (e.g. analytics, marketing campaign measurement).
4. Disclosure of Your Personal Data
We share your Personal Data only when necessary to:
Operate our store via Shopify Inc.
Analyse Site usage via Google Analytics (opt-out)
Comply with legal obligations (e.g. subpoenas, court orders)
Provide targeted advertising (with your consent)
5. Behaviour-Based Advertising
With your consent, we use your data for targeted ads. You can opt out here:
Network Advertising Initiative
Facebook: https://www.facebook.com/settings/?tab=ads
Google: https://myadcenter.google.com/home
Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
DAA: https://optout.aboutads.info
6. Do Not Track
Our Website does not currently honour “Do Not Track” browser signals.
7. Your Rights
Under the New Zealand Privacy Act 2020, you have the right to access your Personal Data held by us, and to request correction of your Personal Data if it is inaccurate, incomplete, or misleading. We will respond to your request within 20 working days.
As Sanovex OÜ is established in Estonia (EU), the General Data Protection Regulation (GDPR) also applies to our processing of your data. Under the GDPR, you have the right to:
- Access your personal data (Art. 15)
- Rectify inaccurate data (Art. 16)
- Erasure of your data ("right to be forgotten") (Art. 17)
- Restriction of processing (Art. 18)
- Data portability (Art. 20)
- Object to processing based on legitimate interests (Art. 21)
- Withdraw consent at any time, without affecting the lawfulness of processing before withdrawal
To exercise any of these rights, contact us at info@orthocomfort.co.nz.
7a. Legal Basis for Processing (GDPR)
We process your personal data on the following legal bases:
- Performance of a contract (Art. 6(1)(b) GDPR): Processing your Order Information to fulfil your purchase, arrange shipping, send order confirmations, and manage returns.
- Legal obligation (Art. 6(1)(c) GDPR): Retaining transaction records to comply with accounting and tax obligations.
- Legitimate interests (Art. 6(1)(f) GDPR): Processing Device Information to prevent fraud, ensure website security, and analyse site performance.
- Consent (Art. 6(1)(a) GDPR): Sending marketing communications and placing non-essential cookies (where you have given consent).
7b. International Data Transfers
We use the following third-party services which may transfer your data outside the European Economic Area (EEA):
- Shopify Inc. (Canada/USA) — our e-commerce platform. Data transfers are covered by Standard Contractual Clauses (SCCs) and Shopify's Data Processing Agreement.
- Google LLC (USA) — analytics and advertising. Data transfers are covered by SCCs and Google's Data Processing Agreement.
You may request a copy of the applicable transfer safeguards by contacting info@orthocomfort.co.nz.
8. Right to Lodge a Complaint
If you believe your data rights have been infringed, you may complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon – AKI):
Andmekaitse Inspektsioon (AKI)
Tatari 39, 10134 Tallinn, Estonia
Website: https://www.aki.ee/
If you are based in New Zealand, you may also lodge a complaint with the Office of the Privacy Commissioner (OPC): https://www.privacy.org.nz/
9. Data Retention
We retain your Order Information (name, billing/shipping address, email, phone, payment details) for a maximum of 5 years from the date of your last order, in order to comply with our accounting and legal obligations under Estonian and New Zealand law. Device Information (IP address, browsing data) is retained for a maximum of 26 months. You may request deletion of your data at any time by contacting info@orthocomfort.co.nz, subject to our legal retention obligations.
10. Changes
We may update this Privacy Policy to reflect legal or operational changes.
11. Contact
Questions or complaints? Email info@orthocomfort.co.nz
or write to:
Sanovex OÜ
Sepapaja tn 6
15551 Tallinn
Estonia
Company Name: Sanovex OÜ
Registered Office: Sepapaja tn 6, 15551 Tallinn, Estonia
Phone: +6498844175
Email: info@orthocomfort.co.nz
Our customer service is available Monday to Friday from 9 AM to 5 PM. We respond within 24 hours.