Privacy Policy

Last updated: 18th August 2026

1. Who we are

This policy describes the personal information that the Bellwether Group of companies, being Marcomms Limited, MC Lease Limited, Bellwether AI Limited, Bellwether AI Pty Limited (together, "Bellwether," "we," "us," or "our"), collects from and about you, how we use and disclose it, and your choices and legal rights. We are committed to providing powerful retail insights while maintaining the highest standards of data privacy.

Bellwether is based in New Zealand and operates globally, including in Australia, the United States, United Kingdom, Europe and Canada. When you engage with our services, hardware, software, or consultancy, you agree to our collection, use, and disclosure of your personal information as described in this policy. If you do not agree, please do not use our software or engage with our services.

2. What this policy covers

This policy applies to visitors to our website, customers who use our platform, dashboards, and services, and end users whose information is processed through our footfall sensors and analytics tools.

It does not cover information our customers collect and control themselves through their own internal systems. We act only as a service provider for that data, under contract with the customer.

3. Information we collect

A. Analytics and consulting services

There are several sources of personal information we collect to provide our retail and data intelligence services:

• Retail and footfall data. Our IOT sensors collect footfall data, specifically entry and exit counts.
• Spatial processing. Our sensors process spatial data rather than personal biometric data and do not use facial recognition.
• Anonymised tracking. We distinguish between adults and children and track movement patterns, but we do not identify individual shoppers.
• Third party data providers. We collect aggregated personal information from third party providers based on their engagement with third party apps or advertisements where you have consented.
• Aggregate data. We use information from publicly available sources, social media companies, census data providers, public directories, or other data brokers to build our products and services, and we link this aggregate information to information we have collected as part of the services we offer our customers.

B. Website and marketing communications

We collect information when you visit our websites, read marketing communications, or engage with our brand:

• Direct interaction. We collect personal information directly from you when you choose to share it with us, such as your name, email address, phone number, business details, and billing information when you set up an account, contact support, or subscribe to our services.
• Automatic collection. We automatically collect technical and usage information when you visit and browse our website, such as IP address, browser type, device information, login activity, and pages visited.
• Third party analytics. We use third party analytics and tracking tools, including Google Analytics, to better understand who is using our website and how to improve the effectiveness of our content.
• Tracking technologies. We and our third party analytics, tracking partners, and service providers, including Google Analytics, may use cookies, tags, SDKs, or scripts to collect information about your activity and use of our website, such as the time, place, and frequency of your visits.
• Session replay. We may use session replay software to capture and record information about your interaction with our website, including keystrokes, mouse movements, and form field entries.

4. How we use your information

We use the information collected for the following purposes:

• Platform maintenance. To provide and maintain our analytics platforms and data intelligence services.
• Retail optimisation. To sync with point of sale systems (for example Shopify or Vend) to calculate conversion rates and dollars per visitor.
• Targeted advertising. To help customers understand visitors to their locations and develop demographic profiles for targeting advertising campaigns.
• Analytics. To generate anonymised, aggregated statistical reports identifying industry benchmarks, insights, and trends.
• Improvement. To improve the way we work and provide additional insights.
• Support. To provide customer support and technical troubleshooting.
• Compliance. To meet our legal, tax, and regulatory obligations and to detect, prevent, and investigate fraud or misuse of our services.

5. Lawful basis for processing

We rely on the following legal grounds to process your data:

• Consent. For marketing, certain cookies, and third party data collection.
• Contract. To provide services you have requested, such as dashboard access, hardware support, or consultancy services.
• Legitimate interests. To study how people engage with our products, to grow our business, and to protect our operations.

6. Cookies and tracking technology

Our website uses cookies and similar technologies, including Google Analytics and session replay tools, to understand site traffic, improve user experience, and, where you have consented, support advertising. You can manage or disable cookies at any time through your browser settings. Disabling cookies may affect some website functionality.

7. How we share your information

We do not sell your personal data to anyone. We may disclose categories of information to:

• Our service providers. Companies that provide cloud hosting (such as AWS), payment processing, or hardware shipping, under contracts that require them to protect your data.
• Our customers. In the form of aggregated, anonymised data that powers our market benchmarking insights, never as identifiable personal data about individual visitors.
• Legal authorities. To comply with laws, investigations, or court orders.
• Successor entities. In connection with a merger, acquisition, sale of assets, or other corporate change.

8. How long we keep your information

We retain personal information for as long as necessary for the purposes for which it was collected, or as required by law, typically for the length of your contract with us plus a period afterwards for legal, tax, or accounting obligations. Aggregated, anonymised footfall data may be retained for longer term trend reporting, as it does not identify individuals. After this, information is securely deleted or anonymised.

9. Security

The security of your information is important to us. We implement industry standard technical measures, including encrypted data transmission (SSL/TLS) and secure login protocols, and we limit who on our team can access personal data. No system is completely secure and we cannot guarantee absolute security, but we continually review and improve our safeguards. If we become aware of a data breach affecting your personal information, we will notify you and the relevant regulator as required by law.

10. International data transfers

Because we operate across New Zealand, Australia, the United States, United Kingdom, Europe, and Canada, your information may be transferred to and stored in countries other than the one you live in. Where this happens, we take steps to ensure your data is protected to a standard consistent with this policy, including standard contractual protections where required by law, for example under the GDPR for customers in the EU and UK.

11. Your privacy rights and choices

In accordance with applicable law, including the New Zealand Privacy Act 2020 and, for individuals in the EU and UK, the GDPR, you have the right to:

• Access: request copies of the personal information we hold about you
• Rectify: correct inaccurate personal information
• Erase: request the deletion of your personal information
• Object to or restrict certain processing, and request a copy of your data in a portable format
• Withdraw consent, where processing is based on consent, at any time

To exercise any of these rights, contact us using the details below. We will respond within the timeframe required by applicable law.

12. Changes to this policy

This policy is subject to change from time to time to reflect changes in our services, technology, or legal requirements. We will notify active subscribers of material changes by email or dashboard notification. The "last updated" date at the top of this page shows when it was last revised.

14. Contact us

For questions about this policy or to exercise your privacy rights, contact us:

• Email: support@askbellwether.com
• Website: www.askbellwether.com