Privacy Policy
This policy explains what Headlands Club Hospitality Ltd does with information about you. It is written under the Privacy Act 2020 and its thirteen information privacy principles, which is the law that applies to us in New Zealand.
Last updated 14 May 2026.
1. Who we are
Headlands Club Hospitality Ltd, NZBN 9429048631572, of 27 Coote Road, Bluff Hill, Napier 4110, Hawke's Bay, trading as Headlands Club. We are the agency responsible for the personal information described here.
Our privacy officer can be reached at [email protected], by phone on +64 6 835 2471, or by post at the address above marked "Privacy Officer".
2. What we collect
| When | What |
|---|---|
| You send the enquiry form | Name, email address, phone number if you give one, the type of enquiry, dates, number of people, and anything you type in the message box. |
| You book a room | The above, plus a postal address, payment card details (processed by our payment provider — we do not store card numbers), arrival and departure dates, and any accessibility or dietary requirements you tell us about. |
| You stay with us | Room charges, restaurant and bathhouse charges, vehicle registration if you use the car park, and any incident record if something goes wrong. |
| You enter The Breakwater Room | We sight photo identification to confirm you are 20 or over. We do not copy, scan or record it unless you are entering a self-exclusion agreement. |
| You self-exclude | Your name, one photograph, the term you have chosen and the date. See section 8. |
| You use this website | Cookies as described in the cookie policy, and standard server log entries: IP address, browser, pages requested, time. |
| You are on the premises | CCTV covers the lobby, corridors, car park and the gaming floor. Recordings are held 31 days and then overwritten, unless retained for an investigation. |
We do not collect information about your health, ethnicity, religion or political views, and we ask you not to put anything of that kind into the message box unless it is directly relevant — a dietary or accessibility requirement, for instance.
3. Why we collect it
- To answer you. If you send an enquiry, we use your details to reply to it. That is the whole purpose.
- To run your stay. Take the booking, give you the right room, bill you correctly, and get a message to you if your taxi is early.
- To meet legal obligations. Age verification and host responsibility records under the Gambling Act 2003; tax and company records; health and safety incident records.
- To keep the building safe. CCTV, and a record of who is in the hotel in case of a fire.
- To send you offers — but only if you ticked the box asking us to. We do not add people to that list any other way.
- To improve the site, if you accepted analytics cookies.
We do not sell personal information. We do not trade, rent or share it with data brokers or advertising networks, and we do not build profiles of guests for resale.
5. How long we keep it
| Record | Held for |
|---|---|
| Website enquiries that do not become bookings | 24 months |
| Booking and stay records | 7 years (Inland Revenue requirement) |
| Marketing list entries | Until you unsubscribe, then 30 days |
| CCTV | 31 days, then overwritten |
| Self-exclusion records | The term of the exclusion, then destroyed |
| Host responsibility incident logs | 3 years |
| Server logs | 90 days |
6. How we look after it
The website runs over HTTPS. Booking and guest records sit in a system that requires individual logins and two-factor authentication, and access is limited to staff who need it for their job. Paper records — self-exclusion forms in particular — are locked in the duty manager's office and seen only by staff who work the door of The Breakwater Room.
If we ever suffer a privacy breach that is likely to cause you serious harm, we will notify you and the Office of the Privacy Commissioner, as the Privacy Act 2020 requires.
7. Your rights
Under the Privacy Act 2020 you may:
- Ask what we hold about you and get a copy of it. We respond within 20 working days.
- Ask us to correct it if it is wrong. If we disagree, you can require us to attach a statement of the correction you sought.
- Unsubscribe from marketing at any time — one click in any email, or a sentence to [email protected].
- Ask us to delete information we no longer have a lawful reason to keep. Where a tax or gambling-law obligation applies, we will explain why we cannot.
There is no charge for any of this. Write to the privacy officer at [email protected].
8. Gaming-related information
Entry to The Breakwater Room requires us to sight photo identification confirming you are 20 or over. We look at it and hand it back. We do not photograph, scan, photocopy or record the document, and we do not keep a list of who entered the room.
There is one exception. If you enter a self-exclusion agreement, we keep your name, one photograph and the term of the exclusion, because we cannot honour the agreement otherwise. That record is held in the duty manager's office, is seen only by door staff, and is destroyed when the exclusion ends. It is never used for marketing and never shared with another venue without your written consent.
CCTV on the gaming floor is a condition of operating and is retained for 31 days like the rest of the system.
9. Complaints
Tell our privacy officer first — [email protected]. We acknowledge within two working days and answer within twenty.
If you are not satisfied, you can complain to the Office of the Privacy Commissioner: privacy.org.nz, 0800 803 909. You do not need our permission and you do not have to come to us first.