Privacy Policy

BROOK SERENE & CO LTD only collect and use personal information by fair, lawful, transparent and non-intrusive means.

BROOK SERENE & CO LTD will only collect personal information for specific, explicit and legitimate purposes.

Only personal data relevant to the specific purpose will be saved and processed by BROOK SERENE & CO LTD.

Any inaccurate personal information will be corrected or deleted. Where necessary, data must be kept up to date.

BROOK SERENE & CO LTD will only keep personal information in an identifiable format and no longer than necessary.

BROOK SERENE & CO LTD will keep personal information in a secure manner.

BROOK SERENE & CO LTD only use or disclose information for the purpose for which it was collected unless the person has provided permission to send direct marketing material.

BROOK SERENE & CO LTD takes reasonable steps, with reference to accepted work practices, to ensure that the personal information it collects and uses is accurate.

BROOK SERENE & CO LTD implement systems that protect any personal information held from misuse, unauthorised access, modification or disclosure.

BROOK SERENE & CO LTD will provide access (digital or in hard-copy) to any individual to their personal information which it holds about that individual, on request.

BROOK SERENE & CO LTD does not adopt or use an identifier that has been assigned by a Commonwealth government agency.

BROOK SERENE & CO LTD provides methods for customers to interact anonymously whenever it is lawful and practicable to do.

BROOK SERENE & CO LTD only transfers personal information to a recipient in a foreign country in circumstances where the information will have an appropriate level of protection.

BROOK SERENE & CO LTD does not collect sensitive information unless the individual has consented, it is required by law – or in other special specified circumstances, for example relating to emergency services, health service provision and health or safety.

This Privacy Statement describes the privacy practices of BROOK SERENE & CO LTD for data that we collect:

through websites operated by us from which you are accessing this Privacy Statement, including Brookserene.com and other websites owned or controlled by the BROOK SERENE & CO LTD (collectively, the “Websites”)

through the software applications, such as cookies, made available by us for use on or through computers and mobile devices (the “Apps”)

through our social media pages by way of pixels, that we control from which you are accessing this Privacy Statement (collectively, our “Social Media Pages”)

through HTML-formatted email messages that we send you that link to this Privacy Statement and through your communications with us

when you visit or stay as a guest at one of our properties, or through other offline interactions

Collectively, we refer to the Websites, the Apps and our Social Media Pages, as the “Online Services” and, together with offline channels, the “Services.” By using the Services, you agree to the terms and conditions of this Privacy Statement.

It applies to BROOK SERENE & CO LTD, its subsidiaries, all of the hotels and/or brands within it, including The George, Regent of Rotorua, and Hulbert House brands (collectively, BROOK SERENE & CO LTD, we, or us).

BROOK SERENE & CO LTD is committed to ensuring your personal information is protected. We also appreciate that you are concerned about your privacy, including the confidentiality and security of any information we may collect about you.

In addition to our overarching commitment to privacy, there may also be specific and additional privacy provisions, which apply to our collection and use of your personal information (e.g. information provided when entering a competition, subscribing to a newsletter, or participating in a survey). Any inconsistency between this privacy policy statement and any additional specific provisions will result in the additional provisions prevailing.

This content has been prepared in accordance with the laws of New Zealand.  Any matters or disputes connected with this content will be governed by New Zealand laws and courts.

Despite the above, for individuals whose personal information is collected and for whom the requirements of the EU General Data Protection Regulations apply, BROOK SERENE & CO LTD will conform to the General Data Protection Regulations, which are pursuant to Regulation (EU) 2016/679 of the European Parliament on the protection of natural persons with regard to the processing of personal information and the free movement of such information.

We collect information about you when you interact with our website or social network channels, make bookings, provide feedback, purchase goods or services, or otherwise when you engage with us directly or indirectly. We also collect information through Google Analytics.

The types of personal information we collect about you will depend on what services and products you obtain. This data can include collecting your name, address, email address, credit card details and, whatever other information is supplied to us.

At touchpoints throughout your guest journey, we collect Personal Data in accordance with the law, such as:

• Name
• Gender
• Postal address
• Telephone number
• Email address
• Credit and debit card number or other payment data
• Financial information in limited circumstances
• Language preference
• Date and place of birth
• Nationality, passport, visa or other government-issued identification data
• Important dates, such as birthdays, anniversaries and special occasions
• Membership or loyalty program data (including co-branded payment cards, travel partner program affiliations)
• Employer details
• Travel itinerary, tour group or activity data
• Prior guest stays or interactions, goods and services purchased, special service and amenity requests
• Geolocation information
• Social media account ID, profile photo and other data publicly available, or data made available by linking your social media and loyalty accounts

In more limited circumstances, we also may collect:

• Data about family members and companions, such as names and ages of children
• Biometric data, such as digital images
• Images and video and audio data via security cameras located in public areas, such as hallways and lobbies, in our properties.
• Guest preferences, enquiries and comments and any other personalised data (Personal Preferences), such as your interests, activities, hobbies, food and beverage choices, services and amenities of which you advise us or which we learn about during your visit

If you submit any Personal Data about other people to us or our Service Providers (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Statement.

“Other Data” are data that generally do not reveal your specific identity or do not directly relate to an individual. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Data. Other Data include:

• Browser and device data
• App usage data
• Data collected through cookies, pixel tags and other technologies
• Demographic data and other data provided by you
• Aggregated data

Online Services. We collect Personal Data when you make a reservation, purchase goods and services from our Websites or Apps, communicate with us, or otherwise connect with us or post to social media pages, or sign up for a newsletter or participate in a survey, contest or promotional offer.

Property Visits and Offline Interactions. We collect Personal Data when you visit our properties or use on-property services and outlets, such as restaurants, concierge services, and spas. We also collect Personal Data when you attend promotional events that we host or in which we participate, or when you provide your Personal Data to facilitate an event.

Reservation Centre. We collect Personal Data when you make a reservation over the phone, communicate with us by email, fax or via online chat services or contact customer service. These communications may be recorded for purposes of quality assurance and training.

Your browser or device. We collect certain data through your browser or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Online Services (such as the Apps) you are using. We use this data to ensure that the Online Services function properly.

Your use of the Apps. We collect certain data when you download and use an App, such as App usage data, the date and time the App on your device accesses our servers and what data and files have been downloaded to the App based on your device number.

Cookies. We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect data such as browser type, time spent on the Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data. We use the data for security purposes, to facilitate navigation, to display data more effectively, to collect statistical data, to personalise your experience while using the Online Services and to recognise your computer to assist your use of the Online Services. We also gather statistical data about the use of the Online Services to continually improve design and functionality, understand how they are used and assist us with resolving questions.

Cookies further allow us to select which advertisements or offers are most likely to appeal to you and display them while you are using the Online Services or to send marketing emails. We also use cookies to track responses to online advertisements and marketing emails.

If you do not want data collected with cookies, you can learn more about controlling cookies at http://www.allaboutcookies.org/manage-cookies/index.html.

You can choose whether to accept cookies by changing the settings on your browser or by managing your tracking preferences by clicking on “Tracking Preferences” located at the bottom of our home page. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Online Services. For example, we will not be able to recognise your computer, and you will need to log in every time you visit. You also will not receive advertising or other offers from us that are relevant to your interests and needs. At this time, we do not respond to browser “Do-Not-Track” signals.

Pixel Tags and other similar technologies. We collect data from pixel tags which are used with some Online Services to, among other things, track the actions of users of the Online Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Online Services.

Analytics. We collect data through Google Analytics and Adobe Analytics, which use cookies and technologies to collect and analyze data about the use of the Services. These services collect data regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/ and opt-out by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. You can learn more about Adobe and opt-out by visiting https://www.adobe.com/privacy/opt-out.html.

Your IP Address. We collect your IP address, a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address is identified and logged automatically in our server log files when a user accesses the Online Services, along with the time of the visit and the pages that were visited. We use IP addresses to calculate usage levels, diagnose server problems and administer the Online Services. We also may derive your approximate location from your IP address.

Other Sources. We collect Personal Data from other sources, such as public databases, joint marketing partners and other third parties.

Aggregated Data. We may aggregate data that we collected, and this aggregated data will not personally identify you or any other user.

The information that we collect about you is used to help you access the services or acquire the goods that BROOK SERENE & CO LTD provides more easily. That may include the use of information which assists BROOK SERENE & CO LTD to communicate with you and which assists us to develop our services and business.

We use Personal Data and Other Data to provide you with Services, to develop new offerings and to protect the BROOK SERENE & CO LTD group and our guests as detailed below. In some instances, we will request that you provide Personal Data or Other Data to us directly. If you do not provide the data that we request, or prohibit us from collecting such data, we may not be able to provide the requested Services.

We use Personal Data and Other Data for our legitimate business interests, including the following:

Provide the Services you request. We use Personal Data and Other Data to provide Services you request, including:

To facilitate reservations, payment, send administrative information, confirmations or pre-arrival messages, to assist you with meetings and events and to provide you with other information about the area and the property at which you are scheduled to visit.

To complete your reservation and stay, for example, to process your payment, ensure that your room is available and provide you with related customer service

To support our electronic receipt program. When you provide an email address in making a reservation, we use that email address to send you a copy of your bill. If you make a reservation for another person using your email address, that person’s bill will be emailed to you, as well. You can opt-out of receiving your bill via email and instead receive a paper copy by contacting the front desk

We will use Personal Data and Other Data to manage our contractual relationship with you because we have a legitimate interest to do so and/or to comply with a legal obligation.

Personalise the Services according to your Personal Preferences. We use Personal Data and Other Data to personalise the Services and improve your experiences, including when you contact our call centre, visit one of our properties or use the Online Services, to:

Customise your experience according to your Personal Preferences

Present offers tailored to your Personal Preferences

We will use Personal Data and Other Data to provide personalised Services according to your Personal Preferences either with your consent or because we have a legitimate interest to do so.

Communicate with you about goods and services according to your Personal Preferences. We use Personal Data and Other Data to:

Send you marketing communications and promotional offers, as well as periodic customer satisfaction, market research or quality assurance surveys

We will use Personal Data and Other Data to communicate with you with your consent, to manage our contractual relationship with you and/or because we have a legitimate interest to do so.

Loyalty Programs. We use Personal Data and Other Data to:

Develop, offer and manage your participation in our loyalty programs, as well as others that are specific to certain properties or tailored to your interests

Send you offers, promotions and information about your account status and activities

Assess your benefits

We will use Personal Data and Other Data in this way with your consent, to manage our contractual relationship with you and/or because we have a legitimate interest to do so.

Competitions, activities, events and promotions. We use Personal Data and Other Data to allow you to participate in sweepstakes, contests and other promotions and to administer these activities. Some of these activities have additional rules and may contain additional information about how we use and disclose your Personal Data. We suggest that you read any such rules carefully.

We use Personal Data and Other Data in this way with your consent, to manage our contractual relationship with you and/or because we have a legitimate interest to do so.

Business Purposes. We use Personal Data and Other Data for data analysis, audits, security and fraud monitoring and prevention (including with the use of closed-circuit television, card keys, and other security systems), developing new goods and services, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

We use Personal Data and Other Data in this way to manage our contractual relationship with you, comply with a legal obligation and/or because we have a legitimate interest to do so.

We will use and disclose Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including authorities outside your country of residence and to meet national security or law enforcement requirements; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect the rights, privacy, safety or property of the BROOK SERENE & CO LTD group, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

We may use and disclose Other Data for any purpose, except where we are not allowed to under applicable law. In some instances, we may combine Other Data with Personal Data (such as combining your name with your location). If we do, we will treat the combined data as Personal Data as long as it is combined.

Once we receive personal information from you, we take all reasonable steps to ensure that all information we collect or use is accurate and stored in a secure way, with access only by authorised persons.  We ensure that any companies who help process the information we have collected from you also meet the same criteria that we apply to keep your information secure.

We seek to use reasonable organisational, technical and administrative measures to protect Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section, below

Any personal information that we collect about customers, including email addresses, will be kept in a BROOK SERENE & CO LTD database.

The information we collect from you is confidential. BROOK SERENE & CO LTD will not sell, rent, loan, trade or lease the names, addresses, or email addresses stored in our database to any third parties. However, we may disclose personal information to third parties, including entities outside of New Zealand, and other information or data we collect from you if:

a) You give us your consent.

b) You would reasonably expect us to disclose it for another purpose.

c) That disclosure for the purpose of processing your personal information for BROOK SERENE & CO LTD.

In this way, we may use your information to send you out promotional material, which we consider may be relevant to you.

If you do not wish to receive any of this material you may simply choose to “unsubscribe” from our mailing lists and the unsubscribed material will cease to be sent.

If you have given us consent in relation to particular processing or activities, you can withdraw your consent at any time by contacting us as indicated below.

BROOK SERENE & CO LTD cannot control and is not responsible for the collection of information by third-parties, their websites and platforms, or other websites or platforms not controlled or authorised by BROOK SERENE & CO LTD.

Customers may be able to access third-party websites through links on the BROOK SERENE & CO LTD websites. Such third-party websites have their own separate privacy practices. BROOK SERENE & CO LTD has no control or liability for the practices or policies implemented by such parties, whether or not such third parties use trademarks or other brand elements owned by BROOK SERENE & CO LTD.

Customers should communicate directly with third parties to get information about their privacy practices and policies.

This policy does not cover customers who enter the BROOK SERENE & CO LTD websites through links from non-BROOK SERENE & CO LTD sites, e.g. advertisers or other content providers.

BROOK SERENE & CO LTD are not responsible for any privacy implications arising from the use of sites or applications involving third parties. If you provide information on and use third-party sites, the privacy policy and terms of service on those sites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting personal information.

This Privacy Statement does not address, and we are not responsible for the privacy, data or other practices of any entities outside of BROOK SERENE & CO LTD, including Owners, Strategic Business Partners or any third party operating any site or service to which the Services link, payment service, loyalty program, or website that is the landing page of the high-speed internet providers at our properties. The inclusion of a link on the Online Services does not imply endorsement of the linked site or service by us. We have no control over and are not responsible for, any third party’s collection, use and disclosure of your Personal Data.

In addition, we are not responsible for the data collection, use, disclosure or security policies or practices of other organisations, such as Meta (Facebook and Instagram), Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Data you disclose to other organisations through or the Apps or our Social Media Pages.

You have choices when it comes to how we use your data, and we want to ensure you have the information to make the choices that are right for you.

We will retain your Personal Data for the period necessary to fulfil the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services)
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
• Whether retention is advisable considering our legal position (such as, for litigation or regulatory investigations)

If you no longer want to receive marketing-related emails, you may opt-out by following the instructions in any such email you receive from us.

We will try to comply with your request as soon as reasonably practicable. If you opt-out of receiving marketing emails from us, we may still send you important administrative messages, from which you cannot opt-out.

Unless specifically requested, we ask that you not send us, and you not disclose, on or through the Services or otherwise to us, any Sensitive Personal Data (e.g., social security number, taxpayer identification number, passport number, driver’s license number or other government-issued identification number; credit or debit card details or financial account number, with or without any code or password that would permit access to the account, credit history; or information on race, religion, ethnicity, sex life or practices or sexual orientation, medical or health information, genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records or information on other judicial or administrative proceedings).

BROOK SERENE & CO LTD reviews its policies and notices from time to time. Any updated materials will have an immediate effect, without notice having been provided, and will continue to be available on this page.

By continuing to use BROOK SERENE & CO LTD’s websites, platforms, apps or services after any such amendment, you are deemed to have agreed to the amended terms of use.

If you have any questions or comments in relation to this Privacy Policy Statement or if you wish to access your personal information, update it, or arrange for its deletion, please contact us at [email protected] or by mail addressed to:

Privacy, Brook Serene & Co Ltd

50 Park Terrace, Christchurch 8143

P O BOX 1001, Christchurch, 8140

You should provide us with as much detail as possible about the particular information sought, in order to help us retrieve it. An access fee may be charged. If BROOK SERENE & CO LTD does not allow you to access your personal information, we will provide you with the reasons for our decision.

In the event that you wish to opt-out of any collection of personal information, BROOK SERENE & CO LTD will take reasonable steps to assist you with this process.

For your protection, we may need to verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law.

Please note that we often need to retain certain data for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or reservation or enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such purchase, reservation, or promotion).

There may also be residual data that will remain within our databases and other records, which will not be removed. In addition, there may be certain data that we may not allow you to review for legal, security, or other reasons.