Effective Date: 04/05/2026
Website: theharlotpages.co.nz

The Harlot Pages (“Platform”, “we”, “us”, “our”) is committed to protecting personal information and handling it in accordance with the Privacy Act 2020 (New Zealand) and other applicable laws.

This Privacy Policy explains how we collect, use, store, disclose, retain, and protect personal information when you access or use the Platform, create an account, publish listings, purchase services, communicate with us, or otherwise interact with the Platform.

By using the Platform, you acknowledge this Privacy Policy.

  1. Who We Are

The Harlot Pages is an online advertising, directory, and promotional platform.

Unless otherwise stated, we are the controller of personal information we collect directly through the Platform.

For privacy enquiries:

Email: [Insert Privacy Contact Email]

  1. Information We May Collect

We may collect, receive, generate, infer, or store the following categories of information.

  1. Account Information
  • name, trading name, or alias;
  • username;
  • email address;
  • phone number;
  • login credentials (encrypted or hashed where applicable);
  • subscription status;
  • account preferences.
  1. Listing Information
  • profile descriptions;
  • categories;
  • pricing or rates voluntarily submitted;
  • service regions or location data voluntarily submitted;
  • photographs, media, and uploaded content;
  • links to websites or social media;
  • promotional settings.
  1. Verification Information

Where required, we may request:

  • proof of age;
  • identity verification;
  • business registration details;
  • authority to act for a business or agency;
  • proof of entitlement to work where legally relevant.
  1. Transaction Information
  • invoices;
  • billing history;
  • subscription records;
  • payment confirmations;
  • partial payment metadata supplied by processors.

We do not typically store full card numbers unless expressly stated.

  1. Communications
  • support emails;
  • complaints;
  • moderation reports;
  • dispute correspondence;
  • communications through platform tools where enabled.
  1. Technical & Usage Information
  • IP address;
  • browser type;
  • device identifiers;
  • operating system;
  • session data;
  • referral URLs;
  • timestamps;
  • approximate geolocation from IP;
  • pages visited;
  • clicks, impressions, favourites, analytics interactions;
  • cookies and similar technologies.
  1. Safety & Fraud Signals

We may generate internal risk indicators relating to suspicious activity, spam, fraud, misuse, duplicate accounts, or policy breaches.

  1. How We Collect Information

We collect information when you:

  • create or manage an account;
  • submit a listing;
  • upload content;
  • purchase services;
  • contact support;
  • submit verification information;
  • browse or interact with the Platform;
  • use messaging, reviews, or other features;
  • respond to surveys or promotions.

We may also receive information from:

  • payment processors;
  • analytics providers;
  • fraud prevention vendors;
  • hosting providers;
  • publicly available sources;
  • lawful complaints or reports from third parties.
  1. Purposes of Collection & Use

We may collect and use information to:

  • create, administer, and secure accounts;
  • display listings and public profiles;
  • process subscriptions and payments;
  • provide customer support;
  • verify eligibility, identity, age, authority, or compliance;
  • moderate content and enforce policies;
  • detect fraud, spam, scams, or unlawful activity;
  • investigate disputes or complaints;
  • improve functionality, UX, safety, and performance;
  • generate internal analytics and business intelligence;
  • communicate service notices, billing alerts, or operational updates;
  • send marketing where permitted by law;
  • protect our legal rights;
  • comply with legal obligations.
  1. Public Listings & User Responsibility

Information you choose to publish in a listing may become publicly visible and may be indexed, copied, cached, archived, or referenced by third parties, including search engines.

This may include:

  • username or trading name;
  • profile text;
  • location or service region;
  • contact methods voluntarily published;
  • images or media;
  • ratings or reviews where enabled.

You are solely responsible for what you choose to publish publicly.

We cannot control third-party copying, screenshots, scraping, republication, or caching outside our systems.

  1. Lawful Basis / Authorisation

Where required, our lawful basis may include:

  • performance of services requested by you;
  • legitimate business interests;
  • compliance with legal obligations;
  • consent where expressly obtained;
  • protection of rights, safety, and fraud prevention.
  1. Cookies, Pixels & Analytics

We may use cookies, scripts, pixels, tags, and analytics technologies to:

  • maintain sessions;
  • remember settings;
  • understand traffic and engagement;
  • measure campaign effectiveness;
  • personalise certain content;
  • detect misuse or suspicious activity;
  • improve services.

You may disable cookies in browser settings, though parts of the Platform may not function correctly.

  1. Payments & Third-Party Providers

Payments may be processed through third-party providers.

Those providers may independently collect and process payment data under their own terms and privacy policies.

We are not responsible for third-party systems beyond our reasonable control.

  1. Disclosure of Information

We may disclose information where reasonably necessary to:

  1. Service Providers

Hosting, cloud storage, analytics, payment processors, communications tools, customer support tools, fraud prevention providers, developers, or professional advisers.

  1. Legal & Safety Reasons
  • comply with law;
  • respond to lawful requests;
  • enforce Terms & Conditions;
  • investigate suspected unlawful conduct;
  • protect users or the public;
  • prevent fraud or abuse;
  • defend legal claims.
  1. Business Transactions

In connection with sale, merger, restructuring, financing, or transfer of assets, subject to applicable law.

We do not sell personal information to third-party advertisers as a standalone commodity.

  1. International Processing

Some providers may store or process information outside New Zealand.

Where practicable, we seek commercially reasonable safeguards, but overseas protections may differ from New Zealand law.

By using the Platform, you acknowledge such transfers may occur.

  1. Security

We take commercially reasonable steps to protect information, including administrative, technical, and organisational safeguards.

However:

  • no website is completely secure;
  • no transmission is risk-free;
  • no system can guarantee prevention of all breaches, hacking, misuse, or interception.

You use online services at your own risk.

  1. Data Retention

We may retain information for as long as reasonably necessary for:

  • account administration;
  • subscriptions and accounting;
  • dispute resolution;
  • moderation history;
  • fraud prevention;
  • backups;
  • legal compliance;
  • enforcing rights;
  • internal recordkeeping.

Residual copies may remain in backups, logs, archives, or disaster recovery systems for reasonable periods.

  1. Access, Correction & Requests

Subject to law, you may request:

  • access to personal information we hold;
  • correction of inaccuracies;
  • closure of your account;
  • deletion of certain information where appropriate;
  • cessation of marketing communications.

We may:

  • require identity verification;
  • refuse requests where legally permitted;
  • redact third-party information;
  • charge reasonable administrative costs where allowed;
  • retain information where necessary.
  1. Marketing Communications

Where permitted by law, we may send promotional or service communications.

You may unsubscribe from marketing messages, but we may still send:

  • billing notices;
  • legal notices;
  • security alerts;
  • essential operational communications.
  1. Minors / Age Restrictions

This Platform is strictly for adults.

We do not knowingly allow persons under 18 to hold accounts or be listed.

We may remove suspected underage material or accounts immediately.

  1. User-Generated Content & Third Parties

We are not responsible for privacy practices or conduct of:

  • users;
  • advertisers;
  • agencies;
  • external websites;
  • third-party apps;
  • search engines;
  • scrapers;
  • people who copy or share public content.

Use caution when communicating with third parties.

  1. Automated Monitoring & Moderation

We may use automated tools or internal review processes to identify spam, fraud, duplicate accounts, prohibited content, security threats, or policy breaches.

Decisions may be reviewed manually at our discretion.

  1. Breach Response

Where we consider there has been unauthorised access, misuse, or a privacy incident, we may investigate, restrict access, notify relevant persons or authorities where required, and take remedial action at our discretion.

  1. Limitation of Liability

To the maximum extent permitted by law:

  • we are not liable for indirect, incidental, consequential, punitive, or special loss arising from privacy, security, or data incidents;
  • we do not guarantee uninterrupted or error-free security;
  • we are not liable for third-party misuse of publicly posted information;
  • where liability cannot be excluded, it is limited to the minimum extent permitted by law.

Nothing in this Policy limits rights that cannot lawfully be excluded.

  1. Changes to this Policy

We may amend this Privacy Policy at any time.

Updated versions take effect when published on the Platform.

Continued use of the Platform constitutes acceptance of the updated Policy.

  1. Contact & Complaints

Privacy requests, complaints, or enquiries:

Email: support@theharlotpage.co.nz

If unresolved, you may contact the Office of the Privacy Commissioner (New Zealand), subject to applicable procedures.