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Freedom Privacy Policy

Freedom recognises the importance of protecting the privacy and rights of individuals
in relation to their Personal Information. This is our privacy policy and it tells you how we
collect and manage your Personal Information.

We respect your rights to privacy under the Privacy Act 2020 (“Act”) and we comply
with all of the Act’s requirements in relation to the collection, management and
disclosure of your Personal Information. For more information, visit www.privacy.org.nz.

What is your Personal Information?

“Personal Information” has the meaning given to it in the Act. Generally, it includes
any information that can be used to personally identify you. This may include your
name, address, telephone number, email address and occupation, and information
about your dealings with us.

What Personal Information do we collect and hold?

Depending on the nature of our relationship with you, we may collect the following
types of Personal Information:

1. Initial identification details: name, residential address and date of birth;
2. Contact details: telephone, residential, mailing and email addresses;
3. Location information: precise geolocation data (if you have enabled location
services), or general location information derived from your IP address;
4. Browsing information: information about your interactions with our website and
digital services;
5. Data collected via cookies, pixels and tags;
6. Delivery information: GPS location, time zone, photos (for our logistics services);
7. Demographics: date of birth, gender, age, purchase history, income,
occupation, hobbies and interests;
8. Confirmation of identity details: including driver’s licence number and passport
details;
9. Product and service information: details of the products and services you
have purchased from us or which you have enquired about, together with any
additional information necessary to deliver those products and services and to
respond to your enquiries;
10. Business partner details: where you are engaged by us as a business partner, the
name of the business that you work for, your role within the business, and your
contact details;
11. Work details: where you are engaged by us as a service provider, contractor or
agent, information about your performance;
12. Job applicant details: where you apply for a job with us, information about
you that will help us decide whether to offer you the job, including your job
application or resume, and references;
13. Employment details: where you work for us as an employee, information about
you that is generated or shared in the course of your employment relationship
with us;
14. Financial information: including methods of payment you use, credit reports we
receive, and any information you provide in relation to application for finance or
in-store credit;
15. Feedback: information relating to you that you provide to us directly through our
website or service centre, customer surveys or visits by our representatives from
time to time; and
16. Health information: information we collect about you that we consider
reasonably necessary to protect the health and safety of our premises, staff and
customers.

The information we will seek will depend on the specific service(s) that we provide to
you and/or the specific interactions or relationships we have with you. We will only seek
to collect information about you that we think we need for these services, interactions
and relationships.

How do we collect your Personal Information?

Direct collection: We collect your Personal Information directly from you unless it is
unreasonable or impracticable to do so. When collecting Personal Information from
you, we may collect in ways including:

• through your access and use of our website and apps;
• through third party analytics and advertising tools;
• during conversations and communications between you and our representatives;
• when you complete an application or purchase order or ask for a quote to be
prepared;
• when you access our premises;
• when you make an in-store or on-line purchase;
• when you apply for finance;
• when you contact us for further information or register your details on our website;
• your participation in surveys and other types of research;
• when you enter a promotion, sweepstake, or contest hosted by Freedom;
• when you subscribe to our mailing list or member program;
• when you provide information via social media pages such as the Freedom
Facebook page, Instagram, X, Pinterest, TikTok or our LinkedIn account;
• when you apply for a franchise;
• when you supply goods or services to us;
• when you express interest in a particular Freedom service or product (as
applicable); or
• when you submit a job application or résumé, including from your referees, and
publicly available information about you; or
• when you work for us as an employee.

Web tracking: Freedom uses tracking technologies such as cookies, pixels and tags
to recognise your browser each time it visits our site, and to track which pages you visit
whilst on our site. We use this information to optimise our site and create a better online
experience for you. If you do not wish to receive any cookies, you may set your browser
to refuse them.

Browsing information: Freedom may automatically collect information about your
interactions with our website, IP address, device identifiers, and interaction data
(such as pages viewed, time on site, clicks, scrolls). We use this information to help us
understand user behaviour and improve our services.

Remarketing: Our website uses various sofware platforms and analytics programs to
serve ads to you on other websites afer you have visited our website. This practice is
known as remarketing and is a tool that Google and other digital providers offer to
businesses. If you would like to opt-out of receiving advertising like this you can opt out
of personalised ads in the ad platform preferences.

Payment protection: Freedom uses the payment protection provider, Adyen, which
allows for the approval of more legitimate transactions by accurately determining
the trustworthiness of every transaction. Information collected by Adyen is governed
by Adyen’s privacy policy (www.adyen.com/privacy-policy). All application traffic,
including payment information, traverses the internet through an encrypted channel.

Franchisees: Freedom may collect Personal Information from its franchisees as part of
operating the Freedom franchise network.

Third parties: We may also collect information from third parties such as credit reporting
bodies, law enforcement agencies, and other government agencies.

What happens if we can’t collect your Personal Information?

If you do not provide us with the Personal Information described above, we may not be
able to provide the requested products or services to you, either to the same standard
or at all, or we may not be able to provide you with information about our products and
services.

For what purposes do we collect, hold, use and disclose your Personal
Information?

Your Personal Information will not be shared, sold, rented or disclosed other than as
described in this Privacy Policy.

Freedom may use, collect and hold your information to provide our products and
services to you, to better understand your needs and provide you with better services,
including for:

Customer service, including to:

• complete transactions in store or online;
• deliver products and services;
• provide our membership program; and
• deal with queries, comments or customer service issues promptly whether by
email, social media, telephone or mail. (We may also keep information on your
communications with our customer service representatives).

Marketing, including to:

• keep you up-to-date with products, services, events or promotions we think
would be of particular interest through a variety of channels. (You are able to
“opt-out” from this activity at any time);
• evaluate the effectiveness of our online advertising; and
• evaluate our website’s performance and to improve the content we display to you.

Business operations, including to:

• analyse our business, including for planning, marketing, research, recruiting and
training purposes;
• enhance your customer experience in store and online and help us complete
your transactions faster;
• administer our business, analyse trends, administer our website, track users’
movements, and gather broad demographic information; and
• ensure the health and safety of our premises, staff and customers, which may
involve us collecting your health related information.

Freedom may also use, collect and hold your information:

• when seeking to prevent fraud and other criminal activities;
• when recruiting staff and engaging with contractors;
• for activities and practices related to our employment relationships; and
• for other purposes:
    • we have explained and where you have provided the required consent or
    been given the required notification; or
    • which are required or authorised by or permitted under law.

Disclosure of Personal Information

We may disclose your Personal Information to:

• Related Bodies Corporate: in particular to our parent company.
• Franchisees: in their capacity as a member of the Freedom franchise network.
• Service providers: including, without limitation, technology service providers
for services such as application and systems, cloud computing facilities,
development and technical support, processing, storing, hosting, research and
data analysis, payment protection providers, mailing houses, couriers, payment
processors, delivery contractors, mobile application providers, data entry service
providers, network administrators, debt collectors, third party product repairers,
and professional advisors such as accountants, solicitors, business advisors and
consultants.
• Partners: including, without limitation, our third party marketing agencies,
membership program partners, organisations we partner with for promotions or
for distribution, and other organisations we think you would like to receive further
information from.
• Social media and analytics platforms: including Facebook, Instagram, X, Pinterest,
TikTok, LinkedIn and Google.
• Law enforcement: to any person, regulatory body or government agency in order
to comply with any law.
• Purchasers of our business: if we sell some or all of our business to a third party,
we will disclose all of your information to the new owner(s) in the process of
undertaking that transaction or transactions.

We will comply with the Act when we send Personal Information overseas. This includes
satisfying ourselves that the overseas recipient will provide safeguards comparable to
the Act. Entities located outside of New Zealand to whom we may disclose your Personal
Information include, without limitation, the following: our Related Bodies Corporate,
located in Australia, United Kingdom, Europe, Asia and South Africa; our international
suppliers, located in Australia and Asia; and our international service providers, located in
the United States, Canada, Europe, Australia, United Kingdom, Europe and Asia.

Direct marketing materials

We may send you direct marketing communications and information about our products
and services that we consider may be of interest to you if you would reasonably
expect us to do so in light of how we collected your Personal Information. These
communications may be sent in various forms, including mail, messaging platforms and
email, in accordance with applicable marketing laws, such as the Unsolicited Electronic
Messages Act 2007. If you indicate a preference for a method of communication, we will
endeavour to use that method whenever practical to do so.

For those customers who have only signed up to our Family & Friends promotion, we
may only send you direct marketing communications and information about our Family
& Friends promotions. These communications may be sent by messaging platforms and
email.

With your consent, we may provide your Personal Information to organisations that we
partner with from whom we think you would like to receive further information. We may
also provide you with direct marketing communications from organisations that we
partner with from whom we think you would like to receive further information.

At Freedom we only want to communicate with you if you want to hear from us. If you
would like to be removed from the Family & Friends marketing communications you can
do so at www.freedomfurniture.co.nz/FamilyandFriends/Unsubscribe/. If you would like to be
removed from all marketing communications you can do so at www.freedomfurniture.
co.nz/my-account/preferencesfreedomfurniture.co.nz/opt-out
.

Access and correction

You may request access to any Personal Information we hold about you at any time by
contacting us (see details below). Where we hold information that you are entitled to
access, we will try to provide you with suitable means of accessing it (for example, by
mailing or emailing it to you). We may ask you to pay our reasonable costs to give you
access to your Personal Information.

There may be instances where we cannot grant you access to the Personal Information
we hold. For example, we may need to refuse access if granting access would interfere
with the privacy of others or if it would result in a breach of confidentiality. If that happens,
we will give you written reasons for any refusal.

If you believe that Personal Information we hold about you is incorrect, incomplete or
inaccurate, then you may request us to amend it. We will consider if the information
requires amendment. If we do not agree that there are grounds for amendment, then we
will add a note to the Personal Information stating you disagree with it.

Third-party web sites

Links to third party web sites on www.freedomfurniture.co.nz are provided solely as a
convenience to you. If you use these links, you will leave Freedom’s site. Freedom is not
responsible for any of these sites, their content or their usage of your Personal Information.

Security

Freedom is committed to ensuring the security of your Personal Information and uses
industry standard security measures to safeguard and protect your information. This
includes taking reasonable steps to ensure your Personal Information is protected from
loss, misuse, unauthorised modification or disclosure. Some of the steps we take to protect
your information include:

• utilising security restrictions on access to our systems such as passwords,
firewalls and anti-virus sofware;
• external and internal premises security.

Freedom franchisees

If you purchase a Freedom product from a franchisee (the company identified by
company name and/or company number on the front of the customer invoice), then
the provisions of this Privacy Policy also apply to you and the franchisee (as though
the franchisee is “Freedom”), with the following amendments:

• Provisions relating to the web are not applicable to your relationship with a
franchisee.
• A franchisee may disclose your Personal Information to Freedom for the
purposes of its operation of the Freedom franchise network.

Freedom is not responsible for any failure by a franchisee to comply with this Privacy
Policy or applicable law when handling your Personal Information.

Data retention and destruction

Freedom retains Personal Information for as long as is reasonably necessary to fulfil
the purposes for which it was collected or in some circumstances for longer periods
where extended retention is required by law or regulation, and as necessary in order
to defend our legal rights.

We will securely dispose of or de-identify Personal Information when:

• the information is no longer required for the purpose it was collected;
• the individual requests its deletion (subject to legal obligations);
• we are no longer legally required to retain it.

Complaints or questions

If you have any questions about this Policy, a request for deletion of your Personal
Information, or any concerns or a complaint regarding the treatment of your privacy
or a possible breach of your privacy, please use the contact link on our website or
contact our Privacy Officer using the details set out below.

Privacy Officer contact details:

Privacy Officer

Freedom Furniture New Zealand Limited

Email: privacy@freedom.com.au

All complaints received will be dealt with fairly and in a timely manner considering
all the circumstances of the complaint. In most cases, we expect that complaints will
be investigated and a response generally provided within 30 days of receipt of the
complaint. If the matter is more complex and our investigation may take longer, we
will contact you and advise you of this.

For information about privacy generally, you may visit the New Zealand Office of the
Privacy Commissioner’s website at www.privacy.org.nz.

Employees

Freedom collects Personal Information from its employees, such as name, address,
telephone and email contacts, bank account details, emergency contact details,
employment records, such as your position description and all other work-related
information. Freedom is required to collect some of this Personal Information by
law, however, Freedom also collects Personal Information to enable the business
to operate (for example, to ensure our employees can be paid, to manage the
employee/employer relationship and to keep employees safe).

Where possible we endeavour to obtain Personal Information from our employees
directly. However, in some circumstances such information is gathered indirectly (for
example, from colleagues or other entities, such as where we carry out a criminal
reference check).

Some Personal Information is publicly available and necessary to carry out an
employee’s role, for example, an employee’s company email address and contact
work phone number. However, sensitive personal information is retained in one or
more secure locations. We retain employee records in accordance with our data
retention requirements under the Employment Relations Act 2000.

In accordance with the Act, employees are entitled to access their personal
information held by or on behalf of Freedom, and to request updates to any incorrect
details.

Definitions and Changes

In this policy “Freedom”, “we”, “us”, “our”, etc means Freedom Furniture New
Zealand Limited.

Freedom may make changes to this Privacy Policy from time to time for any reason.
Any changes we make will automatically apply to all personal information that we
hold about you. We will publish those changes on our website and, if the changes
are material to you, we may also update you directly by email. This policy was last
updated in October 2025.