Privacy Policy

Napier Port Holdings Limited and Port of Napier Limited (together, we, us, our, Napier Port) recognise the importance of protecting your privacy.



This Privacy Policy applies to our employees, contractors, Napier Port users and visitors. The Policy explains how Napier Port may collect, hold, use and disclose information that identifies you (your Personal Information).

If you would like to contact us in relation to this Privacy Policy or our use of your Personal
Information, please contact us at the details set out in the Contact Us section below.

Application of this Privacy Policy

Please read this Privacy Policy carefully. It applies to any Personal Information that you provide to Napier Port or authorise us to collect. By providing Napier Port with your Personal Information, or using our Website or other services, you authorise us to collect, use and disclose your Personal

Information in accordance with this Privacy Policy. This includes our website available at: (our Website).

Updates to this Privacy Policy

Napier Port may update this Privacy Policy at any time by posting an updated version of this Privacy Policy on our Website. The updated version of this Privacy Policy will take effect immediately upon such notice. We may also take additional steps to bring the changes to your attention, including by notifying you directly. You are responsible for reviewing this Privacy Policy regularly to ensure that

you are aware of any updates.

Additional rights and obligations

This Privacy Policy applies in addition to, and does not limit, our rights and obligations under the Privacy Act 2020 (as amended or replaced from time to time) (the Privacy Act) or any specific
authorisation that you provide to us when you interact with us or use our services.

You are not required to provide us with any Personal Information that we request. However, if you do not do so, we may not be able to provide certain services to you.

Collection of Personal Information

Types of Personal Information we collect

The Personal Information about you we may collect includes:

 Name, Date of Birth, and Contact information (address, telephone number, e-mail address);

 Information on how you use our services;

 Any billing, or payment details or other financial information;

 Photographs of individuals (for example, through Port Pass);

 Photographs of individuals that we take, with permission, on Napier Port sites;
 Your location data and device information, and

 Other information relating to your relationship with Napier Port.

How we collect Personal Information

The Personal Information we collect will vary depending on your interactions with us:
 You enter or upload to our Website;

 You provide to us over the phone or by email;

 Through other channels (for example, through social media);

 You enter our physical sites and offices, through port pass access, and

 You enter our physical sites and offices, through our use of CCTV cameras.

Generally, we collect Personal Information directly from you or the organisation you are associated with (for example as a customer, contractor, or supplier). We do this through application forms,
stakeholder and customer surveys, Website enquiry forms, or other direct engagement.

We may also collect footage of you through CCTV cameras operating at the Napier Port sites. Where CCTV cameras are operating we seek to make you aware of this by physical signage.

We may also collect your Personal Information from third parties if you have authorised them to provide, or authorised us to collect, that information, or as otherwise permitted by law.


Napier Port also collects information through our Website through cookies. Cookies are small pieces of information that are stored on a user’s computer. We use cookies to personalise your experience on the Website, make it easier for you to navigate our Website, and improve your experience by

storing your search, posting and application history, and your login details. Cookies also assist us to analyse the profile of our visitors. These can be session cookies which are deleted when you close
your browser and/or persistent cookies which remain on your computer or mobile device for a
longer period of time. Cookies can be disabled via your web browser; however doing so may limit
your access to some of the Website’s content and features. We may use cookies to track non-
personally identifiable information such as usage and volume statistics, for research purposes in
order to further develop our Website. For further information visit

Information about other people

If you provide us with, or authorise us to collect, personal information about another person, you
confirm that they have authorised you to provide us, or authorised us to collect, their personal
information in accordance with this Privacy Policy and that you have informed them of their rights to obtain confirmation of whether we hold personal information about them, and to access and

request correction of their personal information, as set out below.

Use of Personal Information

Napier Port may use your Personal Information for the following purposes:
 To provide you services, as well as improve and refine our services;
 To contact you regarding our services, answer your questions and otherwise manage our

relationship with you;

 Interacting and communicating with you on social media or through other channels, dealing

with your requests, enquiries or complaints, and other customer care related activities;

 To understand you better (for example through customer or stakeholder surveys);

 Billing, payment and financial purposes;

 Collecting any debt owed to us by you;

 To carry out credit checking and scoring;

 For historical record keeping;

 To assist the business development and sales function of Napier Port;

 To identify you on Napier Port sites via Port Pass;

 To use your photograph in our communications and promotional material (if you have given

us your permission);

 To market to you (for example via newsletters or other marketing materials) unless you have

opted-out of such marketing;

 To analyse your use of our Website, personalise and improve your experience on our

Website using cookies and similar technologies;

 To respond to your Website enquiries;

 COVID-19 related contact tracing purposes;

 To keep you updated on our activities and to otherwise engage with you;

 To detect, deter, and prevent criminal or offensive behaviour at Napier Port sites;

 Monitoring the safety and security of our staff and Napier Port community;

 To fulfil our health and safety responsibilities at Napier Port sites;

 Carrying out incident investigations;

 General administrative purposes and to facilitate our internal business operations;

 For employment record keeping

 To carry out any activity in connection with a legal, governmental or regulatory requirement

on us, or in connection with legal proceedings, crime or fraud prevention, detection or

 To exercise and enforce our rights, including under our Standard Conditions of Service (Use
of Port Contract);

 To comply with New Zealand laws and any applicable overseas laws, and
 For any other purpose authorised by you or permitted by law.

We may also use aggregated and anonymous information (where identifiable characteristics are
removed, so that you will remain anonymous) for statistical and research purposes.

Disclosure of Personal Information

Napier Port may share your Personal Information for the purposes set out in this section and in the above section with the following parties:

 Service providers (including our IT services providers, customer survey provider, marketing
service provider and share registrar) to assist us with the operation of Napier Port;

 Contractors and suppliers to assist us with the operation of our business;

 To whatever party as may be necessary to lessen a serious threat to a person’s health or

safety (for example Worksafe);

 To people through social media and other direct marketing platforms, and

 Any other party authorised by you or to whom we are required or authorised to disclose
Personal Information in accordance with applicable law.

Unless we have your consent, or an exception under the Privacy Act applies, we will only disclose your Personal Information to overseas recipients (other than service providers to us holding your Personal Information on our behalf) where we believe on reasonable grounds that the overseas

recipient is subject to privacy laws or contractual obligations that, overall, provide comparable
safeguards to those in the Privacy Act.

We require any third parties to adhere to our confidentiality requirements and to the requirements of the Privacy Act. We will only share your Personal Information where we believe this is appropriate to help us with any of the purposes outlined above. We will take reasonable steps to ensure that
those recipients do not use that Personal Information for any other purpose.

Storage of Personal Information


We will store your Personal Information we collect from you in accordance with our obligations under the Privacy Act.

Your Personal Information may be stored on servers owned by our computing infrastructure

provider under an account we control. Some information we hold will be stored in “the cloud” in
secure databases on our behalf by third parties based overseas. The use of these services, and the
transfer of information overseas (if applicable) will not relieve us of our obligations under the Privacy Act and this Privacy Policy.

We retain CCTV for as long as we consider appropriate to help us with any of the purposes outlined above.


Security of your Personal Information is very important to us. We will take reasonable technical and organisational precautions to protect Personal Information that we hold. However, due to the
inherent nature of the internet, we are not able to guarantee the security of any Personal
Information that we hold or that you transmit to us.


We rely on you to update us if your Personal Information changes (please refer to the Contact Us
section below).

Access and correction of Personal Information

Under the Privacy Act, you have the right to obtain confirmation that we hold Personal Information about you, and to access and request correction of any Personal Information that we hold about
you. Please refer to the Contact Us section below.

Other websites

Our Website may provide links to other websites for your convenience and information. These
websites are outside our control and are not covered by this Privacy Policy. If you access other
websites using the links provided, the operators of these sites may collect information from you

which will be used by them in accordance with their privacy policy. We are not responsible for the privacy policies or the content of any third party website.

Contact us

If you have any questions or requests relating to this Privacy Policy or Personal Information that we may hold about you, please contact us at:

Napier Port Holdings Limited and Port of Napier Limited

Port of Napier,
Breakwater Road, PO Box 947

Napier, 4140,

New Zealand

Phone: +64 6 833 4387