Privacy Policy

Table of Contents

Privacy Policy — Vuly Play (New Zealand)

Last updated: Monday, 10 August 2026

1. INTRODUCTION

1.1 Vuly Play is committed to providing you with superior customer service, including the highest standards of privacy protection.

1.2 This Privacy Policy applies to customers and website visitors in New Zealand. We comply with the Privacy Act 2020 (NZ) and the Information Privacy Principles (IPPs) contained in that Act.

1.3 This Privacy Policy explains how we collect, use, disclose, store, and protect personal information collected through our websites, including vulyplay.com and regional or localised versions of that site.

1.4 The entity responsible for your personal information in New Zealand is:

Vuly NZ Limited (Company Number 6340414) Suite 1091 Unit A Level G 26 Hobson Street Auckland City 1010 New Zealand

Email: sales@vulyplay.co.nz

Phone: 0800 661 238

1.5 References to "Vuly Play", "we", "us", or "our" in this policy refer to Vuly Play (NZ) as the agency responsible for processing your personal information in New Zealand.

2. WHAT PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT

2.1 We collect personal information primarily to supply you with the products and services you order from us. The kinds of personal information we collect include:

(a) name, address, email address, and telephone number;

(b) payment and billing information;

(c) order history and transaction records;

(d) device, browser, and technical information when you visit our website; and

(e) any other information you choose to provide to us.

2.2 We collect personal information in the following ways:

(a) directly from you when you place an order, create an account, contact us, or interact with our website;

(b) automatically through cookies, analytics tools, and similar technologies when you visit our website; and

(c) from third parties, including social media platforms, payment processors, and analytics providers (see clause 3 below regarding indirect collection).

2.3 We use cookies on our website. Cookies are small files that a website uses to identify you when you return to the site and to store details about your use of the site. Most web browsers automatically accept cookies, but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website. We use Cookiebot by Usercentrics as our Consent Management Platform to manage cookie consent.

2.4 Our website contains links to third-party websites not owned or controlled by us. These links are provided for your convenience only and do not constitute sponsorship, endorsement, or approval of those websites. We are not responsible for the privacy practices of third-party websites and encourage you to read their privacy statements.

3. INDIRECT COLLECTION — NOTIFICATION (IPP 3A)

3.1 Where we collect personal information about you from a source other than you directly (for example, from social media platforms, analytics providers, payment processors, or other third parties), we will take reasonable steps as soon as practicable after collection to ensure you are aware of:

(a) the fact that we have collected your information and the circumstances of that collection;

(b) the purposes for which the information is collected;

(c) the types of third parties to whom we may disclose the information;

(d) our identity and contact details; and

(e) your rights to access and correct the information.

3.2 Where it is not reasonably practicable to notify you at the time of indirect collection (for example, where information is collected through automated analytics or social media tracking), we ensure this policy is readily accessible and clearly describes our indirect collection practices. This policy serves as the primary means of notification in those circumstances.

3.3 This clause satisfies the requirements of IPP 3A of the Privacy Act 2020 (NZ).

4. WHY WE COLLECT AND USE YOUR PERSONAL INFORMATION

4.1 We may collect, hold, use, and disclose personal information for the following purposes:

(a) supplying you with the products and services you order from us;

(b) verifying your identity;

(c) administering and managing products and services, including billing and payments;

(d) responding to enquiries or feedback;

(e) preventing fraud, misuse, or unlawful activity involving our website or services;

(f) researching and developing our products and services;

(g) contacting you about goods and services that may be of interest to you, where permitted by law; and

(h) complying with our legal obligations.

4.2 If you provide your contact details by phone or via our website checkout, a sales representative may contact you to assist with or follow up on your order.

5. ABANDONED CART FOLLOW-UP

5.1 When you begin the checkout process and provide contact details but do not complete your purchase, we may use this information to remind you about your basket.

5.2 If you have not opted in to marketing communications, we may send one or two follow-up emails relating only to the items left in your basket. These emails will include a clear unsubscribe option.

5.3 We will only contact you by telephone for abandoned cart purposes where you have expressly consented to receive marketing calls. Without such consent, your phone number will not be used for this purpose.

5.4 Information collected during checkout that is not associated with a completed order is retained for no longer than 30 days, after which it is securely deleted or anonymised.

5.5 Where processing is based on legitimate interests, we balance those interests against your rights. Where consent is required under applicable law, we rely on consent.

6. SECURE INFORMATION

6.1 We use up-to-date security measures to protect personal information from misuse, loss, unauthorised access, modification, or disclosure. All security measures employed by Vuly Play meet current industry standards.

6.2 Our website uses Secure Sockets Layer (SSL) technology to encrypt data transmitted between you and Vuly Play, ensuring that information you supply when using our website is kept private and its integrity is maintained.

6.3 Payments by New Zealand customers are processed through a PCI-DSS compliant third-party payment gateway paymentexpress.com.

7. AI-POWERED SERVICES AND CHATBOT USE

7.1 Overview

Vuly Play uses AI-powered technology to assist with customer support and website navigation through our chatbot. The chatbot does not make automated decisions that produce legal or similarly significant effects on individuals.

7.2 What data we collect

When you interact with our chatbot, we may collect:

(a) conversation content and messages you submit;

(b) timestamps and session information;

(c) device, browser, and technical information; and

(d) any personal information you choose to provide.

You are not required to provide personal information to use the chatbot.

7.3 How we use this data

Chatbot data is used to:

(a) respond to customer enquiries;

(b) provide customer support;

(c) improve chatbot functionality and accuracy; and

(d) maintain security, prevent fraud, and ensure system integrity.

7.4 Third-party AI providers

Chatbot interactions are processed using a third-party AI service provider (currently OpenAI, Inc.):

(a) data is processed in real time to generate responses;

(b) limited retention may occur for safety and abuse monitoring; and

(c) customer data is not used to train general AI models under current contractual terms.

Data may be processed on servers outside New Zealand, including the United States, subject to the safeguards described in clause 9 below.

7.5 Data retention

Chatbot data is retained only for as long as necessary to fulfil the purposes described above and is periodically reviewed. Where data is used for service improvement, it is anonymised or pseudonymised where practicable.

7.6 Your rights and choices

You may at any time request access to, correction of, or deletion of chatbot data, object to processing, withdraw consent, or request human assistance instead of chatbot assistance by contacting us using the details in clause 13.

8. DISCLOSURE OF PERSONAL INFORMATION

8.1 We may disclose personal information about you for the purposes set out in clause 4 to the following categories of recipients:

(a) our distribution partners, contractors, and joint venture partners;

(b) our suppliers who need to access this information to provide us with specific services that enable us to supply you with the products and services you have ordered;

(c) payment systems operators, including merchants receiving credit card payments and rewards programme managers;

(d) our professional advisers, including our accountants, auditors, and lawyers; and

(e) government and regulatory authorities and other organisations, as required or authorised by law.

8.2 Our current third-party contacts include, but are not limited to:

ZipMoney: privacy policy

Google: privacy policy

AfterPay: privacy policy

Meta:  privacy policy

PayPal:  privacy policy

Direct Freight Express: privacy policy

Jim's Group: privacy policy

Auswide Assembly: privacy polic

9. OVERSEAS DISCLOSURE (IPP 12)

9.1 In the course of providing our products and services, we may transfer your personal information to recipients located outside New Zealand, including to Australia, the United States, the Netherlands, the United Kingdom, and Canada.

9.2 We will only disclose your personal information to overseas recipients where:

(a) we believe on reasonable grounds that the recipient is subject to privacy laws that provide comparable safeguards to the Privacy Act 2020 (NZ);

(b) the transfer is authorised or required by New Zealand law; or

(c) you have expressly authorised the disclosure after being expressly informed that the overseas recipient may not be required to protect the information in a way that provides comparable safeguards to the Privacy Act 2020 (NZ).

9.3 Important notice regarding consent under clause 9.2(c): If we rely on your consent to transfer personal information to an overseas recipient, that recipient may not be required to protect your personal information to the same standard as required under New Zealand law. You should be aware of this before providing consent.

9.4 Where we transfer personal information to our AI service provider (currently OpenAI, Inc.) in the United States, we rely on contractual protections that require the recipient to handle your information in a manner consistent with applicable privacy obligations. The United States does not have a general adequacy finding under New Zealand law.

9.5 If you wish for more information about the safeguards in place for any specific international transfer, please contact us using the details in clause 13.

10. YOUR RIGHTS

10.1 Under the Privacy Act 2020 (NZ), you have the right to:

(a) request access to the personal information we hold about you (IPP 6);

(b) request correction of personal information that is inaccurate, out of date, incomplete, or misleading (IPP 7);

(c) opt out of marketing communications at any time by using the unsubscribe link in our emails or by contacting us; and

(d) request deletion of personal information collected through a Facebook integration by contacting us at sales@vulyplay.co.nz or 0800 661 238.

10.2 If you do not provide all the personal information that we request, we may be unable to supply your desired products or services, or we may be restricted in the way that we supply those products or services to you.

11. CALL RECORDING

11.1 We may record telephone conversations between you and our representatives ("Recorded Calls") for legitimate business purposes including:

(a) staff training and development;

(b) quality assurance and service improvement;

(c) compliance with legal obligations;

(d) verification of verbal instructions or agreements; and

(e) dispute resolution.

11.2 Recorded Calls are:

(a) stored securely in accordance with the Privacy Act 2020 (NZ);

(b) accessible only to authorised personnel;

(c) retained only for as long as necessary for the purposes described above; and

(d) protected by appropriate technical and organisational security measures.

11.3 Recorded Calls will not be disclosed to third parties unless:

(a) required by law;

(b) necessary for legal proceedings;

(c) you have provided consent; or

(d) necessary to protect our rights or the rights of others.

11.4 You will be notified at the beginning of each call if recording is taking place. If you do not wish your call to be recorded, you may request alternative contact methods where available.

12. COMPLAINTS

12.1 If you have a complaint about the way we have handled your personal information, please contact us in the first instance using the details in clause 13. We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days.

12.2 If you are not satisfied with our response, you may refer your complaint to the Office of the Privacy Commissioner (OPC):

Website: privacy.org.nz

Phone: 0800 803 909

13. CONTACT US

For questions about this policy, to exercise your rights, or to make a complaint:

Email: sales@vulyplay.co.nz

Phone: 0800 661 238

14. UPDATES TO THIS POLICY

14.1 This Privacy Policy is reviewed annually and updated when regulatory requirements or our practices change.

14.2 The current version of this policy is always available on our website. We will notify you of material changes by posting a notice on our website or, where appropriate, by direct communication.

14.3 This policy was last updated on Monday, 10 August 2026.

ACKNOWLEDGEMENT

By using our website or providing your personal information to us, you acknowledge that you have read and understood this Privacy Policy.