Privacy Policy
1. Who We Are
Elbowscrmobility is the agency that collects and holds your personal information.
727 Bird Road, Tākaka 7142, New Zealand
Email: office@elbowscrmobility.world
Phone: +64 3 525 9887
2. Scope
This Privacy Policy explains how we collect, use, store, and protect personal information when you visit elbowscrmobility.world, use our contact form, enrol in courses, or interact with our services. We comply with the New Zealand Privacy Act 2020 and its Information Privacy Principles (IPPs). Where the EU General Data Protection Regulation (GDPR) applies to you, we also meet those requirements.
3. Data We Collect
We may collect the following categories of personal data:
- Identity data: name
- Contact data: email address, phone number, postal address
- Communication data: messages sent via our contact form
- Technical data: IP address, browser type, device information, pages visited
- Cookie data: preferences stored in your browser (see our Cookie Policy)
4. How We Use Your Information
We collect personal information only where it is necessary for a lawful purpose connected with our functions. We use it to:
- Respond to enquiries and communicate with you
- Process course enrolment, payment, and delivery
- Operate, secure, and maintain our website
- Improve our services through analytics, where you have consented
- Send marketing communications, where you have consented
- Meet legal, tax, and accounting obligations and resolve disputes
Under the Privacy Act 2020, we ensure information is collected for lawful purposes, is relevant to those purposes, and is not used in ways that are unfair or unreasonably intrusive.
5. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected:
- Contact form submissions: up to 24 months after resolution
- Course enrollment records: duration of enrollment plus 5 years
- Analytics data: up to 26 months
- Cookie consent records: up to 12 months
- Legal and accounting records: as required by applicable law
6. Data Sharing
We do not sell your personal data. We may share data with:
- Service providers who assist with hosting, email delivery, and analytics (bound by data processing agreements)
- Legal authorities when required by law
- Professional advisers bound by confidentiality obligations
Where data is transferred outside the European Economic Area or New Zealand, we ensure appropriate safeguards such as Standard Contractual Clauses.
7. Your Rights
Under the Privacy Act 2020, you have the right to:
- Ask whether we hold personal information about you
- Request access to your personal information (IPP 6)
- Request correction of inaccurate, incomplete, or misleading information (IPP 7)
- Withdraw consent for optional processing, such as marketing or non-essential cookies, without affecting prior lawful use
If you are in the European Economic Area, you may also have additional rights under the GDPR, including erasure, restriction of processing, data portability, and objection to certain processing.
To exercise your rights, contact us at office@elbowscrmobility.world. We aim to respond within 20 working days, as required by the Privacy Act 2020, or within 30 days where GDPR applies.
If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner (Te Mana Mātāpono Matatapu): www.privacy.org.nz.
8. Privacy Breaches
We take reasonable steps to protect personal information from loss, misuse, and unauthorised access. If a privacy breach is likely to cause serious harm, we will notify the Privacy Commissioner and affected individuals as soon as practicable, in line with the Privacy Act 2020.
9. Data Security
We implement appropriate technical and organisational measures to protect personal information, including HTTPS encryption, access controls, secure hosting infrastructure, and regular security assessments. We retain information only for as long as needed for the purposes for which it was collected, unless a longer period is required by law.
10. Overseas Disclosure
Some service providers we use may process data outside New Zealand (for example, hosting or email delivery). Before disclosing personal information overseas, we take reasonable steps to ensure the recipient protects it in a way that, overall, provides comparable safeguards to the Privacy Act 2020 (IPP 12).
11. Children
Our services are not directed at individuals under 16 years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately so we can delete it.
12. Changes
We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated date. Continued use of our website after changes constitutes acceptance of the revised policy.