1. Collection of personal information
1.1 What personal information do we collect?
In order to use the App, the Site and to access the Services, you will need to provide us with any information that we need to collect about you from time to time in accordance with applicable laws and regulations (including anti-money laundering or taxation laws such as FATCA) and to comply with our internal compliance policies.
1.2 How we collect your personal information
We will collect information from:
- you directly;
- third parties, such as independent identification companies; and
- any individuals or companies that you authorise to provide personal information about you to us.
It is very important that any personal information you provide to us directly is accurate and complete and relates to you only. We will never ask you to provide us with information about someone else.
1.3 Please tell us if your personal information changes
If you know or suspect that any information we hold about you is (or has become) incorrect or incomplete, please contact us immediately and ask us to update the information. It will not cost you anything for us to update your personal information.
1.4 What if you do not want to provide your personal information?
If you do not provide us with all the personal information we ask you to, or if you do not update incorrect personal information, you may not be able to access the App, the Site or the Services, or you may have only partial access.
You may opt out of having your personal information disclosed to third parties, or for it to be used or disclosed for any purpose other than those for which we originally collected it. You can opt-out by contacting us at firstname.lastname@example.org.
2.Why do we collect your personal information?
We collect, store, use and disclose your personal information for the following purposes (Permitted Purposes):
- To identify you and to verify your identity, including by using third party verification service providers and databases;
- To provide the Services, including to provide customer support, to send transaction notifications, to resolve disputes, and to collect fees;
- To undertake research, analytics and/or benchmarking on our App, our Site and our Services, and to customise and improve our App and Site and their content and our Services;
- To communicate with you, including by sending you promotional offers and targeted marketing and information about our existing or new Services in accordance with section 5 (Direct Communications) below;
- To meet our compliance obligations under applicable laws and regulations in New Zealand and other jurisdictions. (We may need to retain your personal information and transaction records after you cease your relationship with us to meet these obligations);
- To improve our business operations; and
- For any other purpose you have consented to or which is permitted under the Privacy Act or other applicable law.
We will not collect, use or disclose your personal information for any other purpose. In particular, we will never sell your personal information to third parties.
3. How we store and access your personal information
3.1 How we store your personal information
We will store your personal information on external servers and transmit it over networks.
3.2 Access to your personal information
You can ask for access to any of the personal information we hold about you at any time.
You can make a request by contacting us at email@example.com.
You will have to pay for any third party costs we incur in retrieving and supplying the information to you.
In the rare circumstances where we do not or cannot give you access to any personal information that we hold about you, we will give you a full explanation unless we are prevented from doing so by law.
4. Disclosure of your personal information
4.1 Your consent to disclosure of your personal information
You consent to your personal information being disclosed for the Permitted Purposes to any of the following persons:
- To our employees, contractors, service providers (such as providers of marketing, bill collection and technology services, and legal, accounting and business advisers), to the extent reasonably necessary to fulfil our obligations to you;
- To our related companies and businesses, to the extent reasonably necessary for the purposes set out in the section above;
- To any financial institution that provides us with funding or transactional services;
- To any network or server we use to transmit or store your information;
- To any third party to identify or verify your identity and/or to undertake anti-fraud or money-laundering and terrorism financing checks;
- To any law enforcement, legal, government or regulatory agency in any jurisdiction, where such disclosure is required or authorised by any law that applies to us;
- To any business or person that is considering buying an interest in our business or assets, or to any person we are considering merging with; and
- To any person that you authorise us to share your personal information with.
These entities may be located in New Zealand or overseas.
5. Communications with you
5.1 Direct communications
From time to time we may use your personal information to send you information about or offers relating to:
- the App, the Site and/or our current Services;
- a new Services or promotions; and
- other information relevant to our business.
By providing us with your personal information, you consent to us using your information to contact you on an on-going basis for these purposes, including by mail, email, SMS, social media and telephone.
5.2 “Unsubscribe” function
If we send you any communications which are not specifically related to you, we will provide you with an “unsubscribe” mechanism through which you can opt out of receiving similar communications in the future.
When you access our App or Site or use any Services, we or any other company we engage with may place small data files called “cookies”, pixel tags, web beacons or other tracking technologies (collectively, Cookies) in your computer or other device.
We may use these tracking technologies to:
- understand how you came to visit the Site (that is, which websites you visited prior);
- tailor our Services, App or Site content, communications or advertising;
- measure the effectiveness of any promotions or advertising; and/or
- collect information about your computer or other device to mitigate risk, help prevent fraud, and promote trust and security.
6.2 Data analytics
At any time, we may engage a third party to analyse the activities of our [Users]. That third party will have access to information about our Users – including you – by using Cookies.
6.3 How to switch off Cookies
- to meet our legal obligations in New Zealand or in any relevant jurisdiction
- to meet the reasonable requirements of our service providers or business partners
- to reflect any changes to our App, Site or Services or to our data or business processes
8. Complaints and disputes
We are committed to providing a very high level of customer service, and your satisfaction is very important to us.
If you would like to make a complaint, we encourage you to contact us in the first instance by email at firstname.lastname@example.org. We will acknowledge your complaint within 5 business days and make sure your complaint is investigated properly.
9. Additional Terms
9.1 New Zealand law applies
9.2 Policy survives use
9.3 Our contact details