Velvet Privacy Policy

Last updated: [DATE]

Velvet respects your privacy and is committed to protecting personal information in accordance with the New Zealand Privacy Act 2020.

This Privacy Policy explains how we collect, use, store and disclose personal information when you visit our website, submit an application, purchase a membership or ticket, attend an event or otherwise interact with Velvet.

1. Who We Are

In this Privacy Policy, “Velvet”, “we”, “us” and “our” refer to:

Legal business name: [FULL LEGAL ENTITY NAME]
Trading name: Velvet
NZBN: [NZBN]
Registered address: [REGISTERED ADDRESS]

Our Privacy Officer can be contacted at:

Privacy Officer: [NAME OR POSITION]
Email: [PRIVACY EMAIL]
Postal address: [POSTAL ADDRESS]

2. Personal Information We Collect

Depending on how you interact with Velvet, we may collect:

• Your full name.

• Date of birth or confirmation of age.

• Postal and residential addresses.

• Email address and telephone number.

• Identification information where reasonably necessary.

• Membership and application information.

• Billing and transaction information.

• Event bookings and attendance history.

• Guest information supplied by you.

• Preferences, interests and concierge requests.

• Dietary, accessibility or health information you choose to provide for an event or service.

• Communications with Velvet.

• Feedback, complaints and customer-service records.

• Photographs or recordings from Velvet events.

• Website usage information, device information and IP address.

• Marketing preferences.

• Information reasonably required to assess eligibility for an application, membership or opportunity.

Payment-card information may be processed directly by an independent payment provider. Velvet may receive transaction confirmations and limited payment details rather than complete card information.

3. How We Collect Information

We may collect personal information:

• Directly from you.

• Through our website and application forms.

• When you purchase a membership, product or ticket.

• When you register for or attend an event.

• When you contact our team or concierge service.

• Through cookies and similar technologies.

• From a person authorised to act for you.

• From event, hospitality, payment or service providers.

• From publicly available sources where collection is lawful and reasonably necessary.

• From other sources with your authorisation or where permitted by law.

Where practical, we will collect personal information directly from you.

4. Why We Collect and Use Personal Information

We may use personal information to:

• Assess membership applications and eligibility.

• Verify identity and age.

• Create and administer memberships.

• Process payments and transactions.

• Manage tickets, reservations and event access.

• Deliver concierge and membership services.

• Arrange approved guest privileges.

• Coordinate travel, accommodation, transportation or partner services.

• Personalise member experiences.

• Communicate service information.

• Respond to questions, complaints and requests.

• Maintain safety and security at events.

• Prevent or investigate suspected fraud, misuse or unlawful conduct.

• Improve our website, events and services.

• Maintain business and accounting records.

• Comply with legal and regulatory obligations.

• Send marketing communications where we have consent or another lawful basis.

• Exercise or defend legal rights.

If you do not provide information identified as required, we may be unable to process an application, complete a purchase or provide the requested service.

5. Membership Applications

Information submitted in a membership application may be used to assess your suitability and eligibility for the relevant Velvet membership.

Submitting an application does not guarantee approval.

We will only collect and use information that is reasonably necessary for the application process or another purpose permitted by law.

If application information is collected from another source, we will comply with applicable transparency requirements under the Privacy Act 2020.

6. Disclosure of Personal Information

We may disclose personal information to:

• Velvet employees, contractors and authorised representatives.

• Payment processors and financial service providers.

• Website, database and cloud-service providers.

• Event venues, security providers and event contractors.

• Travel, transportation, accommodation and hospitality providers.

• Concierge and membership-service providers.

• Professional advisers, including lawyers, accountants and insurers.

• Marketing or communication providers.

• Government, regulatory or law-enforcement authorities where required or permitted by law.

• A purchaser, investor or adviser involved in a proposed business transaction, subject to appropriate confidentiality protections.

• Other parties authorised by you.

We do not sell personal information.

Service providers may use personal information only for authorised purposes and subject to applicable contractual and legal obligations.

7. Overseas Disclosure

Some service providers or partners may store or process personal information outside New Zealand.

Before disclosing personal information overseas, we will take reasonable steps to ensure that the recipient is subject to privacy safeguards comparable to those required under New Zealand law, is otherwise legally permitted to receive the information, or that you have provided informed authorisation where required.

Overseas countries may have different privacy laws from New Zealand.

8. Cookies and Website Analytics

Our website may use cookies and similar technologies to:

• Operate essential website functions.

• Remember preferences.

• Understand website traffic and usage.

• Improve performance.

• Support security and fraud prevention.

• Measure marketing effectiveness.

You can manage cookies through your browser settings. Disabling some cookies may affect website functionality.

Where required, we will request consent before using non-essential cookies.

9. Marketing Communications

With your consent or where otherwise permitted, we may send information about Velvet memberships, events, experiences and offers.

Commercial electronic messages will identify Velvet and include a functional unsubscribe facility.

You can unsubscribe by:

• Using the unsubscribe link in the message.

• Following the instructions provided in the message.

• Contacting us at [MARKETING OR PRIVACY EMAIL].

We will action valid unsubscribe requests in accordance with New Zealand law.

Unsubscribing from marketing does not prevent us from sending service communications necessary for an existing membership, application, purchase or booking.

10. Security

We use reasonable administrative, technical and physical safeguards designed to protect personal information against loss, unauthorised access, use, modification or disclosure.

These safeguards may include:

• Access restrictions.

• Authentication controls.

• Secure service providers.

• Staff confidentiality requirements.

• System monitoring and security updates.

• Secure disposal processes.

No internet transmission or storage system can be guaranteed to be completely secure.

11. Retention

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, including legal, accounting, fraud-prevention and dispute-resolution requirements.

When information is no longer required, we will securely delete it, anonymise it or otherwise dispose of it in accordance with our legal obligations.

12. Accessing and Correcting Your Information

You may ask us to:

• Confirm whether we hold personal information about you.

• Provide access to that information.

• Correct information that is inaccurate, incomplete or out of date.

Requests should be sent to our Privacy Officer at [PRIVACY EMAIL].

We may need to verify your identity before responding.

We will respond in accordance with the Privacy Act 2020. In some circumstances, the Act permits or requires us to withhold certain information. If we decline a request, we will explain the applicable reason where legally permitted.

If a requested correction is not made, you may ask us to attach a statement of correction to the information.

13. Privacy Breaches

If a privacy breach occurs, we will assess the likely harm and take appropriate steps to contain and address it.

Where a breach has caused or is likely to cause serious harm, we will notify the Office of the Privacy Commissioner and affected individuals as required by the Privacy Act 2020.

14. Children and Minors

Velvet memberships and age-restricted services are not intended for people under 18.

We do not knowingly collect personal information from minors for adult memberships or alcohol-related services.

Information relating to a minor guest may be collected only where reasonably necessary, with appropriate authority and subject to applicable law.

15. Photographs and Recordings

Photography or recording may occur at Velvet events.

Where required, we will provide notice or obtain appropriate consent before using identifiable images for promotional purposes.

You may contact event staff or our Privacy Officer if you have concerns about the use of your image.

16. Third-Party Websites

Our website may contain links to independent third-party websites.

Velvet is not responsible for the privacy practices of those websites. You should review their privacy policies before providing personal information.

17. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to our services, practices or legal obligations.

The current version will be published on our website with the updated effective date.

Where appropriate, we will notify affected individuals of material changes.

18. Privacy Complaints

If you believe we have not handled your personal information appropriately, please contact our Privacy Officer first:

Email: [PRIVACY EMAIL]
Postal address: [POSTAL ADDRESS]

We will investigate and respond within a reasonable period.

If you are not satisfied with our response, you may contact:

Office of the Privacy Commissioner
Website: www.privacy.org.nz
Telephone: 0800 803 909

19. Contact Us

For privacy questions, access or correction requests, complaints or withdrawal of marketing consent, contact:

Velvet Privacy Officer
[LEGAL ENTITY NAME]
[POSTAL ADDRESS]
[PRIVACY EMAIL]
[PHONE NUMBER]