Privacy Policy

Your privacy is important to us. Vitality Works complies with the Privacy Act 2020 (New Zealand), and this Privacy Policy outlines how we do that.

In short, we only collect data that is relevant to the services we provide, we keep it secure, and do not share it with anyone unless required to under law or where you agree to share it.

Full details are provided below.

If you have any questions about our Privacy Policy, please contact the Vitality Works Privacy Officer at



1. Who we are

1.1        Your privacy is important to us. New Zealand Wholistic Health and Wellbeing Company Limited, trading as Vitality Works (Vitality Works) complies with the Privacy Act 2020 (“Privacy Act”) and any applicable codes of practice issued under the Privacy Act (together the “Privacy Laws”), and this Privacy Policy outlines how we do that.  It also sets out your rights and obligations in relation to the personal information that you provide to us, including when you use the Vitality Works websites,,, and the Vitality Hub online health and wellbeing portal and its Wellbeing 360 online health assessment platform (together the “Website”) or any applications, products or services we provide (together with the Website, the “Services”).

1.2       In short, we only collect your personal information if it is relevant to the Services, we keep it secure, and do not share it with anyone unless permitted to under law or where you agree to share it.

1.3       Full details are provided below. Please read this Privacy Policy carefully before you use our Services or otherwise provide your personal information to us.

1.4       If you have any questions about our Privacy Policy, please contact the Vitality Works Privacy Officer at


2. Information we collect

2.1       The type of personal information we collect depends on the nature of our engagement with you.

2.2       Where Vitality Works provides certain health, safety and wellbeing Services, we may collect information:

  • from service recipients that you provide for the purpose of registering with programs and Services provided by or on behalf of Vitality Works (including your first and last names, email address, telephone number, date of birth, gender, employee identifying number and content that you upload or post to our Website);
  • about your use of the Services, including when and where you visit the Website and which pages you look at;
  • from service recipients relating to personal health and / or medical data that we collect when providing health, safety and wellbeing services on behalf of your employer such as conducting health checks;
  • relating to personal health and / or medical data that we collect when conducting certain health, safety and wellbeing programs such as pre-employment health checks on behalf of a potential employer;
  • captured via wearable devices, including activity levels, step counts, calories burned, etc, where these are available and where you choose to associate these with your Vitality Works account;
  • from service recipients that you provide during participation in team challenges;
  • from service recipients that you share through your profile in the Vitality Hub, or with others during team challenges;
  • about the device you are using to access Vitality Works’ Services (such as your hardware model, operating system version);
  • from cookies stored on your device by your browser;
  • that you send to us directly via phone, text, post, email or through any of Vitality Works’ platforms.


2.3       When you apply for a position with us as an employee, contractor or volunteer, in which case we may also collect your occupation, employment details and resume.

2.4      From time to time we may also collect our customer's personal information such as name, NZBNs, payment and bank details in order to provide Services.  

2.5       If you fail to provide necessary personal information when requested, this may result in certain Services or functionality not being available to you.


3. Information we don’t collect

3.1        Vitality Works does not collect:

  • information about your use of websites and services other than those provided by Vitality Works;
  • personal details beyond those required to register and use the Services (for example we do not collect details of your home address);
  • credit card or bank details – where Vitality Works offers Services which require payment via credit card or bank transfer, these are handled by accredited payment service providers, and at no time does Vitality Works have access to your credit card number or bank details;
  • geographic location information derived from IP addresses, GPS, cell towers or wireless access points.


4. How we use your personal information

4.1       You agree that Vitality Works may use your personal information to:

  • enable your access to and use the Services, including to withdraw or manage your access to any Services;
  • monitor your use of the Services;
  • analyse data you provide in health, safety and wellbeing programs such as the Wellbeing 360 assessment to provide you with a personal summary of your health and recommendations for ways to improve this;
  • provide recommendations from health, safety and wellbeing programs and assessments if you have undertaken one;
  • perform health checks and health monitoring for your own benefit, and / or in support of terms of employment and employment legislation;
  • reply to questions you raise with us;
  • send you information that you request.

4.2      We may collect and use your personal information for the purpose of telling you about products or services in which you might be interested. You may opt out of any such marketing communications by using the opt-out mechanism in the communication or by contacting us directly using the Contact Us details below.

4.3      You also agree that Vitality Works may, and may permit its service providers to: (a) de-identify and aggregate your personal information and use it in a de-identified and aggregated form (that does not identify any individual) with data from other sources to improve the Services and for reporting and analytical purposes (“Combined Data”); and (b) create and distribute derivative works that are based on Combined Data and/or your personal information where any personal information has been de-identified.


5. Keeping your personal information private

5.1       We keep the personal and health information that you provide to Vitality Works private.

5.2       We do not sell, rent, trade or in any other way share your personal information with any other individual, your employer, other companies, health authorities, or government agencies except with your specific consent or in circumstances permitted by or where we are required to by law.

5.3       For some services we may use third party service providers to help us operate our business or administer activities on our behalf, such as providing hosting services and IT security services, sending out newsletters or surveys, analysing data. We will not disclose personal information to third party service providers unless we believe on reasonable grounds that they will only use personal information as required to perform their functions (and not for other purposes), and will process personal information in accordance with the Privacy Laws.

5.4      For some services, we do provide your employer with anonymised, aggregate reports to allow them to determine where best to invest in future health and wellbeing programs, but no personally identifiable information is ever shared with them except where you have provided your specific consent or in circumstances permitted by or where we are required to by law.

5.5       For some services, where a condition of your employment is undergoing health monitoring (such as eyesight or hearing screening), key results from these tests are provided to your employer, but only those that we reasonably believe or understand are of direct relevance to your ability to perform your job and any associated legislative requirements.

5.6      We do also provide anonymised information to select academic institutions in support of health and wellbeing research. This anonymised data does not contain your name, email address, phone number or staff number, or any other personally identifiable information.

5.7       We never provide your contact details (or any other information) to other companies for purposes of marketing.


6. Where your personal information is stored


6.1       Some of your personal information (including sensitive information) may also be disclosed, transferred, stored, processed or used overseas by us, or by third party service providers that we engage to assist us in providing certain health and wellbeing services to our clients (for example Vitality Hub services) or in the operation of our business. This may happen if:

  • our offices or related entities are overseas
  • we outsource certain activities overseas
  • transactions, information, services or products have an overseas connection, or
  • our computer systems including IT servers are located overseas.

6.2      In particular, your personal information may be disclosed to third parties in the United States of America, Australia and such other countries in which those parties or their, or our, personnel and/or computer systems may be located from time to time, where it may be used for the purposes described in this Privacy Policy.

6.3      You consent to the collection, use, storage, and processing of your personal information outside of New Zealand as set out in this Privacy Policy.

6.4      In providing this consent, you understand and acknowledge that while such third parties will often be subject to privacy and confidentiality obligations, you accept that where lawful, such obligations may differ from and be less stringent than the requirements of the Privacy Laws in relation to personal information.


7. Keeping your personal information secure

7.1       Vitality Works keeps your personal information secure through:

  • encrypting services using an SSL secured communication channel, to prevent your personal information being intercepted between our servers and your PC / tablet / smart phone;
  • encrypting data held on our servers, which reside in secure data centres;
  • never sharing your personal information with anyone, including your line manager or HR manager except with your specific consent or in circumstances permitted by law;
  • regularly reviewing the security of our systems and operational processes;
  • regularly being audited by a specialist security consultancy to protect against unauthorized access to our systems;
  • restricting access to personal information to specific Vitality Works employees, contractors and agents who need to know that information in order to provide services to us, and who are subject to strict confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.


8. Notifiable Privacy Breach

8.1       If we become aware that there has been a notifiable privacy breach of your personal information (being a privacy breach that has caused or is likely to cause you serious harm), we will, in accordance with the Privacy Act, notify:

(a) the Privacy Commissioner

(b) you (individually or by public notice), unless we are not required to notify you because specific exceptions in the Privacy Act apply relating to your age, health or safety or the safety of another person, national security or law enforcement or a trade secret, or we are required to delay notifying you because notification or public notice may have risks for the security of the personal information we hold that outweigh the benefit of notifying you.


9. Accessing and updating your personal information

9.1       We will provide you with access to your personal information, and give you ways to update / correct your personal information as required under Privacy Laws.

9.2      In some cases you may need us to update your information on your behalf. In such instances, we will ask you to verify your identity before we can act on your request. If we are unable to verify your identity to our satisfaction, we will refuse to make changes that you request.


10. Deleting your personal information

10.1     If you request that your personal information is deleted, we will remove all personally identifiable attributes (name, email address, contact details) from your records, unless we need to retain that information for legitimate business or legal purposes.  If you request that your personal information is deleted, this may result in the Services or certain functionality not being available to you.


11. How you can make a privacy complaint

11.1       If you wish to make a complaint, please contact the Vitality Works Privacy Officer via We will acknowledge your complaint within 5 working days, and will contact you in an attempt to resolve your complaint.

11.2      For more information about the Privacy Laws and how these protect the personal information of individuals in New Zealand, please visit:


12. When this privacy policy applies

12.1      This Privacy Policy applies to personal information that we collect from clients, customers, service participants, Vitality Works employees (including prospective employees), contractors, suppliers and other individuals in the course of our business activities and operations and providing the Services offered by Vitality Works.

12.2     From time to time, Vitality Works may be related to other companies and entities (related entities). This Privacy Policy applies to the use of your personal information by us and by those related entities. Those related entities may also have their own privacy policies which set out additional detail or differences in their privacy practices. To the extent that those privacy policies are inconsistent with this Privacy Policy, those privacy policies will prevail over this Privacy Policy in relation to the actions of those related entities. A reference in this Privacy Policy to Vitality Works, we, us or our is also a reference to those related entities.

12.3     Our Privacy Policy does not apply to services offered by other companies or other sites linked from our services.


13. Changes

13.1      Our Privacy Policy may change from time to time.

13.2     We will display our most current privacy policy on this page with a date of change.

13.3     We encourage Users to frequently check this page to stay informed about how we are helping to protect the personal information we collect.

13.4     We will also keep prior versions of this Privacy Policy in an archive.

13.5     We will ask for your consent before using personal information for a purpose other than those that are set out in this Privacy Policy, unless otherwise permitted under the Privacy Laws.

13.6     If Vitality Works is involved in a proposed merger, acquisition or asset sale (“Proposed Business Restructure”), we will not disclose your personal information to a potential purchaser (“Purchaser”) or any other third party involved in the Proposed Business Restructure (together the “Third Parties”) unless we believe on reasonable grounds that the Third Parties will: (a) use your personal information solely for the purpose of them assessing Vitality Works and carrying out the Proposed Business Restructure but not for any other purposes (until after the Proposed Business Restructure is complete when the Purchaser may contact you to agree new terms on which they wish to hold, collect, use and disclose your personal information); and (b) comply with the Privacy Laws. 


14. Contact Us

14.1     For any queries about our use or handling of personal information, or if you wish to make a complaint, please direct any enquiries to our Privacy Officer via:



This Privacy Policy was last updated March 2023