IMAGR Limited – Privacy Policy
Your privacy

IMAGR Limited (we or us) is committed to ensuring the privacy of your information, and to meeting the requirements of the New Zealand Privacy Act 1993. We want to make sure that you understand how we collect and treat personal information in the course of your use of the SMARTCART App and Service, so please read this Privacy Policy carefully.

Application of this Privacy Policy

This Policy applies to all personal information that you submit on or through the App and the Service, and any information that may be automatically retrieved through your use of the App or the Service, including through the Bluetooth pairing of your mobile device with an in-store Smartcart. This Policy should be read in conjunction with our Terms of Use and terms which are defined in those Terms shall have the same meaning when used in this Policy.

Your consent

By accessing or using the Service or our websites, you consent to the collection, use, disclosure, storage and processing of your personal information in accordance with this Policy.

What personal information we collect

We collect personal information about you when you register an Account and use the Service.  The personal information we collect includes:

  • the information you enter into the App, such as your Account Information;
  • information about how you use the Service, including:
    • information about the goods you purchase; and
    • location data relating to the position of the Smartcart you pair with while you are in a Store;
  • other information about how the Service is used (for example, traffic volumes, time spent on pages);
  • your IP address and/or other device identifying data (to help detect unauthorised account use); and
  • other information that you may disclose to us during the course of our relationship with you.

You are under no obligation to provide us with any such information.  However, if you choose to withhold requested information, we may not be able to provide you with the Service.  For example, we need to hold certain minimum information about authorised users in order to maintain access controls to the Service and for security and user verification purposes.

When you create an Account on the App, you will be directed to the website of a third-party payment processing provider’s website and asked to enter payment details (for example, your credit card details).  Any personal information you enter via this third party’s website is subject to the third party’s privacy policy and may be used only for the purposes of processing payments transacted by you in using the Service.

What we do with the personal information we collect

We will use the personal information we collect to:

  • provide the Service to you and other authorised users;
  • identify you when you sign-in to your Account and verify that your Account is not being used by others;
  • communicate with you in relation to the Service and related issues (eg, quotes for other services, support requests and billing matters);
  • communicate information about your use of the Service to the Store at which you used the Service;
  • carry out research and marketing analysis so we can better understand and serve you;
  • direct marketing and other information to you based on your purchases;
  • monitor and enforce compliance with the law and applicable terms and conditions;
  • verify and carry out financial transactions in relation to services we provide; and
  • co-operate with any government, industry or regulatory authorities.
Disclosures of personal information

Unless you have authorised us to do so, we will not rent or sell any personal information and will not disclose it to any third party except:

  • where disclosure is connected to the purposes for which the information was collected as listed in clause 5;
  • to our third party service providers (such as hosting providers and payment processing providers) in connection with the purposes described in clause 5;
  • to relevant authorities, parties and/or applicable intellectual property rights holders (or their representatives) if we consider that you are in breach of the law or our rights; or
  • where required, or permitted, by law.

We may rent or sell anonymised data to third parties.  Such data will not be capable of identifying you individually.

We may choose to sell our business.  In these types of transactions, personal information is typically one of the business assets transferred to the third party purchaser. You acknowledge and agree that such transfers may occur, and that any acquirer of us or our assets may continue to use your personal information as set out in this Policy.


We use session-based cookies to collect information relating to usage of the Service and analyse traffic. Cookies are small pieces of information that are stored in a browser-related file on your computer or device when you use the Service.  The cookies we use do not collect any personally identifiable information.


You can unsubscribe from any marketing communications from us by following the instructions on any communications sent to you. You can also exercise this right at any time by contacting us using the details at the end of this Privacy Policy.

Access and correction

You have the right under the Privacy Act 1993 to access and/or correct your personal information held by us at any time. You can do this by contacting us using the details at the end of this Privacy Policy.

Storage and security of information

You should be aware that information transmitted over the internet is not always secure. We will take all reasonable steps to securely store any personal information we collect.  This information may (for the avoidance of doubt) be transferred and stored on servers outside of New Zealand.

Retention of your information

We will only retain your personal information for as long as is required for any of the purposes described in clause 5 or 6.

Changes to our Privacy Policy

We may amend or update this Privacy Policy from time to time, with or without notice to you. Revised versions will be effective immediately once posted here. You agree to be bound by the Privacy Policy that is in effect at the time you use the Service.

Contact us

If you have any questions about this Privacy Policy or if you would like to request access to, or correction of, your personal information, you can get in touch by writing to us at & Level 1, 111 Wellesley Street West, Auckland, 1010, New Zealand

More information about privacy

This Privacy Policy is governed by New Zealand law.  For more information about privacy issues in New Zealand and protecting your privacy, visit the New Zealand Privacy Commissioner’s website: