Effective from 4 August 2026 

Foodstuffs Supermarkets Privacy Policy 

1. What is this Privacy Policy for? 

To access services provided by New World, PAK’nSAVE or Four Square (“Foodstuffs Supermarkets”) and our Club+ loyalty programme, you will be asked to provide some personal information about yourself. “Personal information” is any information about you that identifies you, or by which your identity can reasonably be discovered. Personal information includes the facial images and related biometric templates (“biometric information”) that are collected using facial recognition technology (“FRT”) in FR Stores (as defined below). This policy sets out how we will collect, use, disclose and protect your personal information and biometric information while complying with our obligations under the Privacy Act 2020 (“Privacy Act”) and the Biometric Processing Privacy Code 2025 (“Code”). 

The Services (as defined in section 3 below) are intended for use by people located in New Zealand and are not intended for use by anyone located outside of New Zealand. 

In addition, selected New World and PAK’nSAVE franchised stores that use FRT (“FR Stores”) may collect and use your personal information and biometric information using FRT (“FR System”). Section 12 of this Privacy Policy sets out how the FR Stores will use and protect personal information and biometric information collected using the FR System. For clarity, sections 2 to 11 of this Privacy Policy do not apply to any personal information and biometric information collected by FR Stores using a FR System. 

For more information about the use of FRT in FR Stores, including a list of FR Stores, see:  

• here for Foodstuffs North Island FR Stores - foodstuffs.co.nz/news-room/Facial-Recognition; and 
• here for Foodstuffs South Island FR Stores - foodstuffs-si.co.nz/news-room/Facial-recognition.

2. Who holds my personal information? 

Your personal information (other than personal information collected by a FR Store using its FR System) is held by Foodstuffs (N.Z.) Limited, Foodstuffs North Island Limited or Foodstuffs South Island Limited (together, “Foodstuffs”) to provide the Services set out below to you through the Foodstuffs Supermarkets (“we” or “us” in this Privacy Policy). 

We are committed to protecting your privacy because we understand your personal information is important to you and worth protecting. 

3. When will Foodstuffs Supermarkets be collecting my personal information? 

We may collect personal information from you when you interact with us. We may also collect your personal information from third parties – see section 6 below for more information on this. 

The circumstances where we will collect personal information from you include when you: 

• visit a Foodstuffs Supermarket store;
• use any of the Foodstuffs Supermarkets’ online stores where you can search for and purchase grocery items through the website or mobile application (Online Shopping);
• use the Club+ loyalty programme (including the Club+ website and mobile application);
• use Shop & Go (only some New World and PAK’nSAVE stores);
• register to receive regular marketing communications;

• use your Club+ card at our partner retailers; and/or
• use any other services we provide now or in the future, (together, the “Services”).

If there is a material change in the way we collect personal information or the purposes for which we will use it (for example, to provide a new type of service), we will tell you before or at the time we are collecting your information for that new purpose. 

4. What type of personal information will Foodstuffs Supermarkets’ collect? 

The type of personal information we may collect when you access and use the Services includes your name, postal and delivery address, email address and phone number (“Contact Information”). 

If you visit any Foodstuffs Supermarkets’ stores, those stores may collect your personal information through their CCTV camera system, including your image and the number plate of your vehicle (“CCTV Information”). 

In addition, in the course of using some of the Services we may collect other information from you, including demographic information like age and gender (“Demographic Information”), as well as mobile location data (Online Shopping), and information about the products you purchase (e.g. your preferences, products purchased and returns history) (“Purchases and Preferences Information”). 

You may register with any Foodstuffs Supermarkets (and Club+) to receive regular marketing communications from us, for example via email or text message. If you choose to register to receive regular marketing communications or to use any of the Services, you will need to provide us with certain personal information to create a Club+ account, which may include your name, age, email address, phone number and other requested information (“Club+ Information”). 

You may not be able to access some of the Services unless you agree to provide the personal information relevant to that service. 

From time to time we may also collect from you in the course of providing you, or by you using, the Services, information that is not personal information at the time of collection (“Non-identifiable Information”), for example payment card information. However, by choosing to register to use any of the Services, you agree that we may combine the Non-identifiable Information with your personal information that we collect, or that is otherwise held by Foodstuffs, its partners or service providers, in a manner that will change the nature of the Non-identifiable Information such that it becomes personal information. You agree that we may use this Non-identifiable Information in accordance with this Privacy Policy. 

We also collect anonymous information such as the number of visitors per day to our websites and the average amount of time spent on the Foodstuffs Supermarkets (and Club+) websites. 

5. Why do we collect personal information? 

We collect personal information to provide you with the Services. 

By accessing and using the Services, or by registering to receive marketing communications, you agree that we may collect, store and use any of your personal information including to do any of the following: 

• to allow you to access and view your account created to receive the Services, or marketing communications (where, in the case of electronic marketing communications, you have consented to receiving them);
• to contact you about your use of the Services;
• to process and deliver any orders placed through the Services. For example, if you are a Club+ member, we may contact you in relation to store transactions where you have scanned your Club+ card (for example in relation to any product recalls) or if you made a purchase through Online Shopping, we may contact you about your order;
• to enable you to participate in competitions and promotions which may be available to Foodstuffs’ Supermarket customers from time to time;
• to take appropriate actions to keep your information secure;
• to provide or send you targeted marketing (or allow a third party to provide you) via email, online (including social media) or physical mail, with details of special offers, discounts, prize draws, loyalty programmes (including Club+), information about products or services offered by Foodstuffs’ Supermarkets, or other third party providers, or other information that may be of interest to you, your family or household;

• to enhance your overall experience of the Services;
• to identify and determine the benefits, offers or promotions that may be of interest to you, your family or household based on your use of the Services;
• matching your shopping preferences with those of other Foodstuffs Supermarket customers on an anonymous basis by using your demographics, to help us improve our customer offerings instore and online and develop new products;
• providing tailored specials and discounts for you;
• to undertake data analytics, insights or data mining (including the anonymisation or aggregation of your personal information with other data to identify patterns and trends and use the full benefit of that analysis);
• collating all personal information that Foodstuffs Supermarkets, Foodstuffs, and our partners and service providers, hold about you, including collected via any Foodstuffs’ managed platforms or services, in a single profile, so that we can analyse and improve your experience and the services provided to you by Foodstuffs Supermarkets;
• to conduct research related to your use of the Services;
• to help you complete any application by you to join Foodstuffs’ loyalty programme (Club+) and obtain the benefits of the programme;
• if you visit Foodstuffs Supermarkets’ stores, to detect and prevent criminal or disorderly behaviour and to monitor and ensure the safety and security of people in or around those stores, including our staff and customers; and
• such other purpose we make known to you at the time of collection.

In doing so, your personal information may be combined with other personal information held by Foodstuffs, our partners and service providers. 

6. When do we collect your personal information from other parties? 

Where possible, Foodstuffs Supermarkets will collect your personal information directly from you. However, we may also collect your personal information from third parties in the circumstances described below. 

We may also indirectly collect personal information from third parties not listed in the table above. This will be where authorised by you or from sources that make that information publicly available. 

* See section 4 above for details of what these categories of personal information (eg Contact Information) include. 

7. Do we disclose personal information to anyone else? 

We may sometimes need to disclose your personal information to others. By using one or all of the Services, you agree that we may disclose your personal information for any of the purposes listed in the above section, but only to the extent necessary to achieve those purposes. 

We may disclose your personal information to: 

• a Foodstuffs entity and its staff;
• a franchisee of Foodstuffs i.e. a Foodstuffs Supermarket;
• for Club+ members who choose to collect Airpoints, to Air New Zealand Limited (which operates as Koru);
• our strategic partners that offer goods or services that we think may be of interest to you (for example, fuel providers);
• a third party outside of the Foodstuffs Supermarkets who are contracted to us to provide a particular service to you on our behalf;
• a third party outside of the Foodstuffs Supermarkets who are contracted to us to provide a particular service to us (or Foodstuffs);
• our appointed payment provider to process your payments for purchases;
• a third party helping us to manage loss prevention, retail crime, damage to property and public safety, including other retailers and law enforcement agencies; and
• third parties when we believe, in good faith, that we are required to do so by law.

Additionally, Foodstuffs South Island collects and discloses contact information and CCTV information to help manage loss prevention, retail crime, and damage to property with: 

• The Warehouse Group Limited: [email protected]
• Mitre 10 (New Zealand) Limited: [email protected]
• The Hub Hornby: [email protected]

You consent to the disclosure of your personal information in accordance with this Privacy Policy to the parties listed above. 

8. Do the Foodstuffs Supermarkets use cookies? 

When you access Foodstuffs Supermarkets and Club+ websites, social media pages and/or mobile apps, we may use cookies to track your use of the Services so that we can provide you with the best possible shopping experience. A cookie is a small piece of data that a website sends to your browser that may be stored on your system. Some information/services may be unavailable if you chose to disable your browser from accepting cookies. 

We may use the information generated by cookies to: 

• track traffic patterns to and from our website;
• ensure any content (which may include any advertising) is being shown to the most appropriate person; and
• enable us to serve targeted advertising to you (on our website and elsewhere).

By using the Services you consent to the storing and accessing of cookies or other information on your device in connection with your use of our website. 

We use various app, web and/or email analytics tools to collect information about your activity when you use the Services through one of our websites or mobile applications (e.g. clubplus.co.nz, Online Shopping or Club+). The information we collect through the use of such analytics tools may be information about you (e.g. products, services, or specials that you engage with on the relevant website) or anonymous information (e.g. the number of visitors per day or the average amount of time spent on the relevant website). By accessing and using one of our websites, you consent to our use of such analytics tools to collect information about your access and use of the Services through that website. 

9. How do I receive and opt out of direct marketing? 

When you register to receive marketing communications from us, your name and contact details will be added to the relevant Foodstuffs Supermarkets’ database (and/or a database of Foodstuffs) along with your preferences for receiving communications from us, e.g. email, and text message. 

All commercial electronic messages from us will contain an unsubscribe function if you no longer want to receive them from us. You can unsubscribe at any time by using this function or by changing your account communication preferences which you can access under your Club+ profile. To opt-out of receiving text messages from us, either reply ‘STOP’ to a text or update your account preference details. We will endeavour to update your account preferences as soon as possible. 

If you unsubscribe or cancel your registration we may not be able to provide you with all or some of the Services. 

10. Do you keep my personal information secure? 

Security of personal information is very important to us and we will take all reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification or disclosure. However, you acknowledge that security of the transmission of data over the internet can never be guaranteed, and it is your sole responsibility to protect access to any emails you receive from us that provide access to your account. To the maximum extent permitted by law, Foodstuffs will not be liable for any direct or indirect damage or loss if any third party gains unauthorised access to your information. 

We will only retain personal information for as long as is required for the purposes for which that information may lawfully be used. Where Foodstuffs Supermarkets’ collects personal information through the use of video surveillance systems, we may retain the personal information for as long as is necessary to investigate a crime or incident in accordance with New Zealand law. 

Where FR Stores collect your personal information and biometric information, that information is retained as set out in section 12 below. 

11. How do I access and update my personal information? 

Your personal information (other than personal information collected by a FR Store using its FR System) will be held by Foodstuffs (N.Z.) Limited or Foodstuffs North Island Limited at 35 Landing Drive, Mangere, Auckland 2022, or by Foodstuffs South Island Limited at 167 Main North Road in Christchurch and/or by one or more of Foodstuffs’ trusted data service providers. 

Under the Privacy Act you have the right to request access to your personal information that we hold, and to have that information corrected and/or updated. You can update some of your personal information online via your account or contact our Customer Support Centre on 0800 80 70 70. We will rely on the information that you have provided us so please ensure that information is accurate and kept up-to-date. 

If you find that information we hold about you is incorrect, please contact us immediately and we will correct it. Our contact details are above. 

Where FR Stores collect your personal information and biometric information, see section 12 below for how you can access and update that information.  

12. Use of FRT by FR Stores 

FR Stores use FRT for the sole purpose of preventing and reducing repeat harmful behaviours by previous offenders. When we use the term “harmful behaviour”, we mean assault (physical and verbal) and other forms of aggressive, violent and threatening behaviour, theft, burglary and robbery.  FR Stores do not use personal information and biometric information collected for or via the use of FRT for any other purpose, including marketing or advertising. 

This section sets out how a FR Store will collect, use, disclose and protect personal information and biometric information collected using that store’s FRT System. 

All personal information and biometric information collected through an FR Store’s FRT System is collected and held by that FR Store.  

For a list of FR Stores in the North Island (and the store’s address) and further information about a FR Store’s use of FRT, including the assessment of proportionality, see: foodstuffs.co.nz/news-room/Facial-Recognition. 

For a list of FR Stores in the South Island (and the store’s address) and further information about a FR Store’s use of FRT, including the assessment of proportionality, see: foodstuffs-si.co.nz/news-room/Facial-recognition. How will I know it’s a FR Store? 

You can use the links above to see a list of FR Stores. Each FR Store will also have signage at entry points to notify you that it uses FRT in its store. If you do not want your personal information or biometric information to be collected by the FR System, please do not enter a FR Store. 

What type of personal information and biometric information will a FR Store collect using its FR System? 

A FR Store will collect facial images of everyone entering that store using the FR System.  

The store’s FR System will convert these facial images into a digital code called a ‘biometric template’ and will compare that biometric template against a watchlist of individuals who have previously been identified as a person of interest (as defined below).  

If your facial image does not match with the image of a person of interest in a FR Store’s watchlist, then your facial image and associated biometric template will be automatically and permanently deleted from the FR System immediately. 

If the FR System in a FR Stores identifies a potential match with an image on the FR Store watchlist, then trained and authorised FR Store team members are immediately alerted. Any potential match must be verified by two trained and authorised FR Store team members before any action is taken. If a match is not verified by two team members, then no action is taken.  

The FR Store may also collect and save your image from its CCTV system into its FR System if the store reasonably believes that you are a person of interest. 

For FR Stores in the North Island, a person of interest is someone who: 

• is an “offender” because they have engaged in harmful behaviour by: (i) assaulting (physically or verbally), or behaving in a violent, aggressive, threatening or abusive manner towards, staff and/or other customers in the FR Store; damaging FR Store product(s) and/or property; (iii) stealing or attempting to steal high-value items from the FR Store; or (iv) re-entering the FR Store in breach of their trespass notice where that trespass notice was issued because the individual engaged in harmful behaviour; or
• is an “accomplice” because they actively assisted an offender in the commission of harmful behaviour.

For FR Stores in the North Island, the watchlist of a FR Store is specific to that FR Store and is not shared with any other FR Store. 

For FR Stores in the South Island, a person of interest is defined as someone who has displayed serious threatening behaviour, including assaults, the use of weapons, incidents of verbal abuse and incidents of disorderly conduct in Foodstuffs South Island Supermarkets. 

If a FR Store in the South Island reasonably believes you are a person of interest it may save your image from its CCTV system and this may be shared with an FR Store in the South Island. In the South Island, in the unlikely event that your facial image creates a false positive alert in the FR System, your image and associated biometric template will be automatically deleted from the FR System after 72 hours. 

If you are a person of interest, a FR Store may also collect the following personal information and biometric information: 

• your name;
• your image;
• your biometric template;
• a description of the harmful behaviour;
• a trespass notice reference ID; and
• any security system reference ID,

and add this information to the FR Store watchlist.  This information may be collected directly from you or, where this is not reasonably practicable, from third parties including law enforcement agencies. 

How long will personal information and biometric information be kept in a FR Store’s FR System? 

Where the FR System does not find a match between the collected facial image and a person of interest, then the collected facial image and associated biometric template is immediately and automatically deleted. 

For FR Stores in the North Island, where the FR System finds a potential match and an alert is created, then regardless of whether or not a match is verified by authorised, trained FR Store team members, the personal information and biometric Information collected and generated by the FR System (including the collected image and related biometric template) will be automatically deleted from the FR System at midnight on the day an alert is generated. Foodstuffs North Island separately retains information from alerts in FR Stores in the North Island (but not collected images or biometric templates) for record keeping, review and auditing purposes for three years from the date of an alert. 

Personal information and biometric information of:  

• offenders included in a FR Store’s FR watchlist is retained for up to 2 years (unless they re-offend); and 
• accomplices is retained for 3 months (for FR Stores in the North Island only).

On expiry of these time periods the personal information and biometric information included in the FR watchlist is automatically and permanently deleted from a FR Store’s FR System. 

Will personal information and biometric information collected by the FR System be disclosed to anyone else? 

Personal information and biometric information collected by the FR System will only be disclosed to: 

• specially trained and authorised FR Store personnel with a legitimate need-to-know;
• Foodstuffs’ and the FR Store’s  service providers solely for the purpose of assisting the FR Store with operating its FR System. Foodstuffs and FR Stores take steps to ensure that these parties only use the information to perform their contractual functions for us (and not for any other purposes) and handle the information on our behalf in accordance with applicable privacy laws and confidentiality undertakings;
• the FR System provider, but only for support and maintenance services. Personal information and biometric information is not used by the FR System provider or any other person to train the algorithms or models underlying the FR System (or any other system); and

• law enforcement agencies, but only where compelled to do so by law.

Please note that FR Stores cannot access or extract biometric templates from their FR Systems. 

Can I request removal of my image from the FR System? 

In certain circumstances, a FR Store can remove an individual that is a person of interest from the FR Store’s watchlist. All other images are automatically deleted from the FR System if there is no match. If you wish to query your enrolment in the FR System as a person of interest, or if you have any other questions, please email [email protected] [email protected]for FR Stores in the North Island, or [email protected] for FR Stores in the South Island. You can also contact the relevant FR Store directly. 

If you wish to request the removal of your information from the FR System, please set out in your email: (i) the FR Store the incident took place in, (ii) the date and time of the incident, (iii) what happened, and (iv) the reasons why your information/image should be removed from the FR system. The FR Store will then consider your request by reviewing the information you have provided, including assessing it against the information it has relating to the incident. 

How do I access and update my personal information and biometric information held in a FR Store’s FR System? 

You may submit a request to access and correct any personal information or biometric information held about you by a FR Store directly to that store or by emailing [email protected] for FR Stores in the North Island, or [email protected] for FR Stores in the South Island.  

To ensure information is disclosed only to you, we (or the FR Store) will need to verify your identify before providing access to or correction of this information. 

13. How can you ask questions or make a complaint? 

You can send any questions or complaints to [email protected] for FR Stores in the North Island, and [email protected] for FR Stores in the South Island. You can also contact the relevant FR Store directly. 

You have the right to make a complaint at any time to the Office of the Privacy Commissioner (by contacting them at www.privacy.org.nz or 0800 803 909). However, we would appreciate the chance to respond to your concerns before you approach them, 

14. Will this policy change? 

We may change this Privacy Policy from time to time and we will tell you about a change in the Privacy Policy by updating the “last updated” date on our website. 

Unless otherwise stated, any changes to the Privacy Policy will take effect immediately upon being placed on the website and your continued use of the Services will represent an agreement by you to be bound the Privacy Policy as amended. 

Last updated: 4 August 2026