Location, location, location Russell TOP 10 Holiday Park Gateway to the Bay of Islands Russell TOP 10 Holiday Park Ocean views that go for miles

Privacy Policy


Because we consider you an important customer, our first priority is to offer you exceptional times and stays at our park.

Your complete satisfaction and confidence in Russell TOP 10 Holiday Park are absolutely essential to us.

That’s why, as part of our commitment to meeting your expectations, we have set up a customer privacy protection policy. This policy formalizes our commitments to you and describes how Russell TOP 10 Holiday Park uses your personal data.

The main rules applicable within Russell TOP 10 Holiday Park are founded on seven principles.


“Personal data” means any information collected and logged in a format that allows you to be identified personally, either directly (e.g. name) or indirectly (e.g. telephone number) as a natural person. Before providing us with this information, we recommend that you read this document describing our customer privacy protection policy.

This customer privacy protection policy forms part of the terms and conditions that govern our holiday park services. By accepting these terms and conditions, you expressly accept the provisions of this policy.


The seven principles below are applicable at the Russell TOP 10 Holiday Park in New Zealand.

  1. Transparency: When collecting and processing your personal data, we will communicate all information to you and inform you of the purpose and recipients of the data.
  2. Legitimacy: We will collect and process your personal data only for the purposes described in this policy.
  3. Relevance and accuracy: We will only collect personal data that is necessary for data processing. We will take all reasonable steps to ensure that the personal data we hold is accurate and up to date.
  4. Storage: We will hold your personal data for the period necessary for processing the same in compliance with the provisions of the law.
  5. Access, rectification, opposition: You may access, modify, correct or delete your personal data. You may also oppose the use of your personal data, particularly to avoid receiving sales and marketing information. The details of the department to contact in this respect are shown below in clause 13.
  6. Confidentiality and security: We will ensure reasonable technical and organizational measures are in place to protect your personal data against alteration or accidental or unlawful loss, or unauthorized use, disclosure or access.
  7. Sharing and international transfer: We may share your personal data with third parties (such as commercial partners and/or service providers) for the purposes set out in this policy. We will take appropriate measures to guarantee security when sharing or transferring such data.

For any questions concerning the seven principles of Russell TOP 10 Holiday Park Data Protection, please contact us using the contact methods outlined in clause 13.


This policy applies:

  1. To all data processing implemented in our holiday park. 

At various times, we will be obliged to ask you, as a Russell TOP 10 Holiday Park customer, for information about you and/or members of your family, such as:

  • Contact details (for example, last name, first name, telephone number, email)
  • Personal information (for example, date of birth, nationality)
  • Information relating to your children (for example, first name, date of birth, age)
  • Your credit card number (for transaction and reservation purposes, 2% surcharge applies to all credit cards)
  • Your membership number for a park loyalty program (e.g. TOP 10 Holiday Parks)
  • Your arrival and departure dates
  • Your vehicle registration
  • Your questions/comments, during or following a stay in one of our holiday parks.

The information collected in relation to persons under 18 years of age is limited to their name, nationality and date of birth, which can only be supplied to us by an adult. We would be grateful if you could ensure that your children do not send us any personal data without your consent (particularly via the Internet). If such data is sent, you can contact us to arrange for this information to be deleted.

We do not deliberately collect sensitive information, such as information concerning race, ethnicity, political opinions, religious and philosophical beliefs, union membership, or details of health or sexual orientation.

Moreover, depending on applicable local laws, other information could be considered sensitive, such as your credit card number, your leisure activities, personal activities and hobbies, and whether or not you are a smoker. We may be obliged to collect such information in order to meet your requirements or provide you with an appropriate service.

In this case, depending on the laws in force in certain countries, your prior consent may be required with regard to the collection of sensitive information.


Personal data may be collected on a variety of occasions, including:

  1. Holiday park activities:
    • Booking a room
    • Checking-in and paying
    • Booking tours/attractions
    • Requests, complaints and/or disputes.
  2. Participation in marketing programs or events:
    • Signing up for loyalty programs
    • Participation in customer surveys (for example, the Guest Satisfaction Survey)
    • Online games or competitions
    • Subscription to newsletters, in order to receive offers and promotions via email.
  3. Transmission of information from third parties:
    • Tour operators, travel agencies, GDS reservation systems, and others
  4. Internet activities:
    • Connection to our websites (IP address, cookies)
    • Online forms (online reservation, questionnaires, Russell TOP 10 Holiday Park pages on social networks, network login devices such as Facebook login etc.).

We collect your personal data for the purposes of:

  1. Meeting our obligations to our customers.
  2. Managing the reservation of rooms/sites and accommodation requests:
    • Creation and storage of legal documents in compliance with accounting standards.
  3. Managing your stay at the holiday park:
    • Managing access to rooms
    • Internal management of lists of customers having behaved inappropriately during their stay at the hotel (aggressive and anti-social behaviour, non-compliance with the park rules, non-compliance with safety regulations, theft, damage and vandalism, or payment incidents).
  4. Improving our holiday park service, especially:
    • Processing your personal data in our customer marketing program in order to carry out marketing operations, promote brands and gain a better understanding of your requirements and wishes
    • Adapting our products and services to better meet your requirements
    • Customizing commercial offers and the promotional messages we send to you
    • Informing you of special offers and any new services created by Russell TOP 10 Holiday Park. 
  5. Managing our relationship with customers before, during and after your stay:
    • Managing loyalty programs
    • Providing details for the customer database
    • Segmentation operations based on reservation history and customer travel preferences with a view to sending targeted communications
    • Predicting and anticipating future behaviours
    • Developing statistics and commercial scores, and carrying out reporting
    • Knowing and managing the preferences of new or repeat customers
    • Sending you newsletters, promotions and tourist, holiday park or service offers, or offers from Russell TOP 10 Holiday Park partners, or contacting you by telephone
    • Managing requests to unsubscribe from newsletters, promotions, offers and satisfaction surveys
    • Taking into account the right to object
  6. Improving Russell TOP 10 Holiday Park services, especially:
    • Carrying out surveys and analyses of questionnaires and customer comments
    • Managing claims/complaints
    • Offering you the benefits of our loyalty program.
  7. Securing and enhancing your use of Russell TOP 10 Holiday Park websites, especially:
    • Improving navigation
    • Implementing security and fraud prevention.
  8. Conforming to local legislation (for example, storing of accounting documents).

We endeavour to provide you with the same services throughout the world. Thus, to guarantee you the right of access and amendment (clause 13), we have to share your personal data with internal and external recipients subject to the following conditions:

  1. Within the Russell TOP 10 Holiday Park group, in order to offer you the best service, we can share your personal data and give access to authorized personnel from the organisation, including:
  • Holiday park staff
  • IT departments
  • Medical services if applicable
  • Legal services if applicable
  • Generally, any appropriate person within Russell TOP 10 Holiday Park entities for certain specific categories of personal data.
  1. With service providers and partners: your personal data may be sent to a third party for the purposes of supplying you with services and improving your stay, for example:
  1. External service providers: IT sub-contractors, banks, credit card issuers, external lawyers, dispatchers, printers.
  2. Franchise/loyalty partners: Due to our franchise/affiliate memberships with TOP 10 Holiday Parks your data may be shared for the purposes of verifying you against the loyalty database and providing program benefits and discounts to you.
  3. Social networking sites: In order to allow you to be identified on the website without the need to fill out a registration form, Russell TOP 10 Holiday Park has put the Facebook login system in place. If you log in using the Facebook login system, you explicitly authorize Russell TOP 10 Holiday Park to access and store the public data on your Facebook account, as well as the other data mentioned during use of the Facebook login system. Russell TOP 10 Holiday Park may also communicate your email address to Facebook in order to identify whether you are already a Facebook user, in order to post personalized and relevant ads on your Facebook account if appropriate
  4. Local authorities: We may also be obliged to send your information to local authorities if this is required by law or as part of an inquiry and in accordance with local regulations.

    For the purposes set out in Clause 7 of this policy, we may transfer your personal data to internal or external recipients who may be in countries offering different levels of personal data protection.

    Consequently, in addition to implementation of this policy, Russell TOP 10 Holiday Park employs appropriate measures to ensure secure transfer of your personal data to a Russell TOP 10 Holiday Park entity or to an external recipient located in a country offering a different level of privacy from that proposed in the country where the personal data is collected.

    As part of these activities, your data may be sent, in particular as part of the reservation process, to Russell TOP 10 Holiday Park located outside of the European Union, in particular in the following countries: Australia and New Zealand.

    Other than those that are required to carry out your reservation, dataflows to countries having different levels of personal data protection are regulated by standard contractual manager-to-subcontractor clauses defined by the European Commission.


    Russell TOP 10 Holiday Park takes appropriate technical and organizational measures, in accordance with applicable legal provisions, to protect your personal data against illicit or accidental destruction, accidental alteration or loss, and unauthorized access or disclosure. To this end, we have taken technical measures (such as firewalls) and organizational measures (such as a user ID/password system, means of physical protection etc.).

    When you submit credit card data when making a reservation, SSL (Secure Socket Layer) encryption technology is used to guarantee a secure transaction.

    1. COOKIES

    Use of cookies by Russell TOP 10 Holiday Park

    You are advised that the company Russell TOP 10 Holiday Park uses cookies or other tracers on its online booking sites www.russelltop10.co.nz

    These tracers may be installed on your device depending on the preferences that you expressed or may express at any time in accordance with this policy.

    1. Why have a cookies policy?

    With a view to provide information and ensure transparency, Russell TOP 10 Holiday Park established this policy so that you can learn more about:

    • The origin and purpose of the information processed when you browse Russell TOP 10 Holiday Park Website
    • Your rights with regard to cookies and other tracers used by Russell TOP 10 Holiday Park
    1. What is a cookie?

    Cookies and other similar tracers are packets of data used by servers to send status information to a user’s browser and return status information to the original server through this same browser.

    The status information can be a session identifier, a language, an expiration date, a response field or other types of information.

    During their validity period, cookies are used to store status information when a browser accesses various pages of a website or when the browser returns to this website at a later point.

    There are different types of cookies:

    • Session cookies, which are deleted as soon as you exit the browser or leave the website
    • Persistent cookies, which remain on your device until their expiration or until you delete them using the features of your browser
    1. Why use cookies?

    We use cookies and other tracers primarily for the following purposes:

    Cookies strictly necessary for browsing the Russell TOP 10 Holiday Park Website and the ability to use all of their features, and intended in particular to:

    • Manage authentication of website visitors and the associated security measures, and ensure proper functioning of the authentication module
    • Optimize the user experience and facilitate browsing, in particular determining “technical routes” for browsing
    • Store information regarding the “cookies” information banner seen by website visitors who then continue to browse the website after agreeing to accept cookies on their device
    • Implement security measures (for example, when you are asked to log in again for content or a service after a certain period of time, or to ensure basic operation of Russell TOP 10 Holiday Park Websites and use of their major technical features, such as monitoring of performance and browsing errors, management of user sessions, etc.)

    Cookies for features intended in particular to:

    • Adapt Russell TOP 10 Holiday Park Websites to the display preferences of your device (language, currency, display resolution, operating system used, configuration and settings of the display of web pages based on the device you are using and its location, etc.)
    • Store specific information that you enter on Russell TOP 10 Holiday Park Websites in order to facilitate and customize your subsequent visits (including displaying the visitor’s first and last names if the visitor has a user account)
    • Allow you to access your personal pages more quickly by storing the login details or information that you previously entered

    Cookies for visitor tracking are aimed at improving the comfort of users by helping us understand your interactions with Russell TOP 10 Holiday Park Websites (most visited pages, applications used, etc.); these cookies may collect statistics or test different ways of displaying information in order to improve the relevance and usability of our services.

    Affiliate cookies identify the third-party website that redirected a visitor to Russell TOP 10 Holiday Park Websites.

    Social network cookies, set by third parties, allow you to share your opinion about and content from Russell TOP 10 Holiday Park Websites on social networks (for example, the “Share” or “Like” application buttons for social networks).

    Review site cookies, set by third parties, display external review data about our parks.

    The social network applications on Russell TOP 10 Holiday Park Websites as mentioned above can in some cases allow the social networks concerned to identify you even if you did not click on the application button. This type of button can allow a social network to track your browsing on Russell TOP 10 Holiday Park Websites, simply because your account in the social network concerned is enabled on your device (open session) while you are browsing.

    We recommend that you read the policies of these social networks to familiarize yourself with how they use the browsing information they may collect, especially with regard to advertising. These policies must specifically allow you to make choices on these social networks, particularly by configuring your user accounts for each of them.

    1. Consent

    The installation of certain cookies is subject to your consent. Also, when you first visit the Russell TOP 10 Holiday Park Websites, you are asked whether you agree to the installation of this type of cookie, which is only activated after your acceptance.

    This process is supported by means of a chat popup on the home page of the Russell TOP 10 Holiday Park Websites, which informs you that by continuing to browse, you are agreeing to the installation of cookies that require consent on your device.

    You can change your mind at any time using the various methods described in section “Deleting and/or blocking cookies”.

    1. Deleting and/or blocking cookies

    You have several options for deleting cookies and other tracers.

    Browser settings

    Although most browsers are set by default to accept cookies, you can, if you desire, choose to accept all cookies, always block cookies, or choose which cookies to accept based on their senders.

    You can also set your browser to accept or block cookies on a case-by-case basis before they are installed. Your browser also allows you to regularly delete cookies from your device. Remember to configure all the browsers in your different devices (tablets, smartphones, computers, etc.).

    Regarding management of cookies and your preferences, configuration varies for each browser. This is described in the Help menu of your browser, as well as how to edit your preferences with regard to cookies. For example:

    Saving a cookie to your device depends on your wishes, which you can exercise and change at any time and free of charge using the settings offered by your browser software.

    If your browser is set to accept cookies on your device, the cookies embedded in the pages and content that you view may be temporarily stored in a dedicated space on your device. They can only be read by their issuer.

    However, you can set your browser to block cookies. Keep in mind that if you set your browser to block cookies, some features, pages and spaces on Russell TOP 10 Holiday Park Websites will not be accessible, and we cannot be held responsible in this case.
    Specialized advertising platforms

    Several professional advertising platforms also give you the option to accept or block cookies used by companies that are members. These centralized mechanisms do not block the display of ads; they simply prevent the installation of cookies that tailor ads to your interests.

    For example, you can visit the website http://www.youronlinechoices.com to prohibit the installation of these cookies on your device. This website is offered by digital advertising professionals brought together within the European Digital Advertising Alliance (EDAA) and managed in France by Interactive Advertising Bureau France.


    We retain your personal data only for the period necessary for the purposes set out in this policy or in accordance with the provisions of applicable law.


    You have the right to access your personal data collected by Russell TOP 10 Holiday Park and to modify it subject to applicable legal provisions.

    You may also exercise your right to object by writing to the address below.

    In the event of difficulty exercising your rights, please contact the Data Privacy department for Russell TOP 10 Holiday Park directly by sending an email to info@russelltop10.co.nz or by writing to the address below:

    Russell TOP 10 Holiday Park Privacy Department
    1 James Street, Russell NZ

    For the purposes of confidentiality and personal data protection, we will need to identify you in order to respond to your request. You will be asked to include a copy of an official piece of identification, such as a driver’s license or passport, along with your request.

    If your personal data is inaccurate, incomplete or not up to date, please send the appropriate amendments to the Data Privacy department as indicated above.

    All requests will receive a response as swiftly as possible and in accordance with applicable law.

    You may also exercise your rights in respect of your personal data that is stored and processed by a hotel following a stay. To do this, you must contact the hotel directly.

    1. UPDATES

    We may modify this policy from time to time. Consequently, we recommend that you consult it regularly, particularly when making a reservation at one of our hotels.


    For any questions concerning Russell TOP 10 Holiday Park personal data protection policy, please contact the Data Privacy department (details above in clause 13).

    AJC  Investment Holdings Limited trading as Russell TOP10 Holiday Park.


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