Effective Date: 26 October 2025 Last Updated: 22 July 2026

This Privacy Policy explains how DEEJNZ Limited (“Company”, “we”, “our”, “us”), a company registered in New Zealand, collects, uses, discloses and protects your personal information when you visit janinecartwright.com (the “Site”), purchase or use the 21-Day Digital Detox for Kids Transformation System or any associated digital products (the “Products”), or otherwise interact with us. The Products may be marketed under variant or abbreviated names from time to time, including without limitation “The 21-Day Digital Detox Transformation System”, “The Digital Detox for Kids”, “The Digital Detox Formula”, or “Digital Detox for Kids Transformation System”; all such variants refer to the same Products, and this Privacy Policy applies equally to each of them.

A note about the “Janine Cartwright” brand: “Janine Cartwright” is a pen name and fictitious brand persona operated by DEEJNZ Limited. DEEJNZ Limited is the legal entity responsible for your personal information and is the “agency” for the purposes of the New Zealand Privacy Act 2020 and the data controller for the purposes of the EU and UK General Data Protection Regulation (GDPR).

By using our Site or purchasing our Products, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with it, please do not use our Site or Products.

1. Who We Are and How to Contact Us

Data controller / agency: DEEJNZ Limited (New Zealand) Privacy contact email: [email protected]

Please include “Privacy Request” in the subject line of any privacy-related email so we can respond promptly.

2. Information We Collect

2.1 Information you provide to us directly. When you purchase a Product, subscribe to our email list, complete a form, request a refund, leave a review or testimonial, or contact us for support, we may collect your name, email address, billing address or country, phone number (if provided), the content of your messages to us, and any testimonial or feedback you choose to share.

2.2 Payment information. Payments are processed securely by third-party payment processors (such as Stripe or PayPal). We do not collect or store your full credit card or bank account numbers. We receive limited transaction information from the processor, such as your name, email address, the amount paid, the last four digits of your card, and transaction status, which we use for order fulfilment, receipts, refunds and fraud prevention.

2.3 Information collected automatically. When you visit the Site, we and our service providers may automatically collect your IP address, approximate location (country or region derived from IP), browser type and version, device type and operating system, referring pages and URLs, pages visited, time spent on pages, clicks, and similar usage data. This is collected through cookies and similar technologies described in Section 8.

2.4 Information from third parties. We may receive information about you from our payment processors, email marketing platform, and analytics or advertising providers, limited to what is described in this Policy.

2.5 Children’s information. Our Products are educational materials sold to adults (parents, guardians and caregivers). We do not knowingly collect personal information from children under 16, and our Site and Products are not directed at children. Although the subject matter of our Products relates to children’s screen time, we do not ask you to submit, and you should not submit, personal information about your children to us. If we become aware that we have collected personal information from a child without verified parental consent, we will delete it promptly. If you believe a child has provided us with personal information, contact us at [email protected].

3. How We Use Your Information and Our Legal Bases

We use your personal information for the following purposes. Where the GDPR or UK GDPR applies to you, the legal basis for each purpose is indicated.

PurposeExamplesLegal basis (GDPR/UK GDPR)Order processing and deliveryProcessing your payment, delivering digital products, sending access details and receiptsPerformance of a contractCustomer supportResponding to your questions, delivery issues and refund requestsPerformance of a contract; legitimate interestsTransactional communicationsPurchase confirmations, important service or security notices, changes to termsPerformance of a contract; legal obligationMarketing communicationsSending newsletters, offers and product updates by email, where permittedConsent (which you may withdraw at any time); legitimate interests for existing customers where permitted by local lawSite analytics and improvementUnderstanding how visitors use the Site, improving content, fixing errorsLegitimate interests; consent where required for cookiesFraud prevention and securityDetecting fraudulent transactions, abuse of the refund policy, and unauthorised sharing of ProductsLegitimate interests; legal obligationLegal complianceTax and accounting records, responding to lawful requests from authoritiesLegal obligationTestimonialsDisplaying testimonials you have given us permission to publishConsent

We do not use your personal information for automated decision-making that produces legal or similarly significant effects about you.

4. Marketing Communications

If you subscribe to our email list or purchase a Product, we may send you marketing emails where permitted by law, including the New Zealand Unsolicited Electronic Messages Act 2007, the Australian Spam Act 2003, the US CAN-SPAM Act, and the GDPR/ePrivacy rules for EU/UK residents. Every marketing email we send contains a functional unsubscribe link. You may opt out of marketing emails at any time by clicking that link or by emailing [email protected]. Opting out of marketing does not affect transactional emails necessary to deliver your purchase (such as receipts and access details).

5. How We Share Your Information

We do not sell your personal information, and we do not share it with third parties for their own direct marketing purposes. We share personal information only as follows:

5.1 Service providers (processors). We use trusted third-party providers to operate our business, and share with them only the information they need to perform their services for us. These categories include payment processors (e.g., Stripe, PayPal), email delivery and marketing platforms, website hosting and content delivery providers, analytics providers, and customer support tools. These providers are contractually or legally required to protect your information and use it only to provide services to us.

5.2 Legal and safety disclosures. We may disclose information where required or permitted by law, including to comply with a legal obligation, court order or lawful request from a government authority; to enforce our Terms and Conditions; to detect or prevent fraud or security issues; or to protect the rights, property or safety of DEEJNZ Limited, our customers or others.

5.3 Business transfers. If DEEJNZ Limited or the Janine Cartwright brand is involved in a merger, acquisition, restructuring or sale of assets, your personal information may be transferred to the successor entity, which will be required to respect this Privacy Policy or notify you of any material changes.

We are not responsible for the privacy practices of third-party platforms that you use independently of us (see Section 9).

6. International Data Transfers

We are based in New Zealand, and our service providers may store or process your information in other countries, including New Zealand, Australia, the United States and the European Union. Data protection laws in these countries may differ from those in your country. Where we transfer personal information of EU or UK residents outside the EEA or UK, we rely on appropriate safeguards, such as transfers to countries with an adequacy decision (New Zealand holds an EU adequacy decision) or standard contractual clauses entered into by our service providers. Where the New Zealand Privacy Act 2020 applies, we only disclose personal information overseas in accordance with Information Privacy Principle 12.

7. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, including to deliver your purchase and provide ongoing access, to comply with legal obligations (for example, New Zealand tax law generally requires business records to be kept for 7 years), to resolve disputes and prevent fraud, and to enforce our agreements. Email marketing data is retained until you unsubscribe or ask us to delete it, after which you are removed from marketing lists (a suppression record may be kept to ensure you are not emailed again). When personal information is no longer required, we delete it or anonymise it securely.

8. Cookies and Similar Technologies

We use cookies and similar technologies (such as pixels and local storage) on the Site for purposes including keeping the Site secure and functioning correctly (strictly necessary cookies), remembering your preferences, measuring Site traffic and performance through analytics, and, where used, measuring the effectiveness of our advertising. Where required by law (including for visitors from the EU/UK), non-essential cookies are used only with your consent, which you can withdraw at any time. You can also control or delete cookies through your browser settings; disabling cookies may affect some Site functionality. If we use third-party analytics or advertising tools, those providers may set their own cookies subject to their own privacy policies.

9. Third-Party Links

The Site and our Products may contain links to third-party websites, resources or services. This Privacy Policy does not apply to those third parties, and we are not responsible for their content or privacy practices. We encourage you to review the privacy policy of every site you visit.

10. Data Security

We take reasonable technical and organisational measures to protect your personal information, including encryption of data in transit (HTTPS/TLS), reputable hosting and payment providers, access controls limiting who can view personal information, and secure disposal of information no longer required. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a privacy breach occurs that is likely to cause you serious harm, we will notify you and the relevant regulator as required by applicable law, including the New Zealand Privacy Act 2020 and, where applicable, the GDPR/UK GDPR.

11. Your Privacy Rights

Your rights depend on where you live, but we extend the following core rights to all customers: you may request access to the personal information we hold about you, request correction of inaccurate information, request deletion of your information (subject to legal retention requirements), object to or restrict certain processing, and withdraw consent to marketing at any time. To exercise any of these rights, email [email protected] with the subject line “Privacy Request”. We may need to verify your identity before acting on your request. We will respond within the timeframe required by applicable law (generally within 20 working days under the New Zealand Privacy Act 2020, and within one month under the GDPR/UK GDPR). We will not discriminate against you for exercising any privacy right.

11.1 New Zealand residents. You have rights of access to and correction of your personal information under the Privacy Act 2020. If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner (privacy.org.nz).

11.2 Australian residents. We handle personal information of Australian customers consistently with the Australian Privacy Principles under the Privacy Act 1988 (Cth). You may request access to and correction of your personal information, and you may complain to the Office of the Australian Information Commissioner (oaic.gov.au) if you are dissatisfied with our response.

11.3 EU and UK residents (GDPR / UK GDPR). In addition to the rights above, you have the right to data portability, the right to object to processing based on legitimate interests, the right to withdraw consent at any time without affecting the lawfulness of prior processing, and the right to lodge a complaint with your local supervisory authority (or the UK Information Commissioner’s Office, ico.org.uk). Our legal bases for processing are set out in Section 3.

11.4 United States residents (including California). Depending on your state, you may have the right to know what personal information we collect and how we use and disclose it, the right to access and delete your personal information, the right to correct inaccurate information, and the right to opt out of the “sale” or “sharing” of personal information. We do not sell your personal information, and we do not share it for cross-context behavioural advertising as those terms are defined in the California Consumer Privacy Act (CCPA/CPRA). We do not use or disclose sensitive personal information for purposes requiring a right to limit. California residents may exercise their rights by emailing [email protected]; authorised agents may submit requests on your behalf with proof of authorisation. We do not knowingly sell or share the personal information of consumers under 16 years of age.

12. Do Not Track and Opt-Out Preference Signals

Some browsers transmit “Do Not Track” or Global Privacy Control (GPC) signals. Because we do not sell or share personal information for behavioural advertising, honouring these signals does not change our practices; where legally required, we treat a GPC signal as a valid opt-out request.

13. Children’s Privacy

As stated in Section 2.5, our Site and Products are directed at adults only. We do not knowingly collect personal information from children under 16 (or under 13 for the purposes of the US Children’s Online Privacy Protection Act, COPPA). If you believe we have inadvertently collected information from a child, contact us and we will delete it promptly.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies or legal requirements. The current version, with its effective date, will always be published on this page. If we make material changes, we will take reasonable steps to notify you, for example by email or a prominent notice on the Site, before the changes take effect. Your continued use of the Site or Products after changes are published constitutes acknowledgement of the updated Policy.

15. Contact Us

If you have any questions, concerns or complaints about this Privacy Policy or how we handle your personal information, contact:

DEEJNZ Limited (operator of the Janine Cartwright brand) Email: [email protected] Subject line: “Privacy Request”

We take privacy complaints seriously and will investigate and respond to you as required by applicable law. If you are not satisfied with our response, you may contact the privacy regulator in your jurisdiction, including the New Zealand Office of the Privacy Commissioner (privacy.org.nz), the Office of the Australian Information Commissioner (oaic.gov.au), the UK Information Commissioner’s Office (ico.org.uk), or your local EU supervisory authority.