Privacy Policy

Simfuni Limited NZCN 8459867 (we, us or our), understands that protecting your personal information is important. This Privacy Policy and Credit Information Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our insurance premium funding services (Services) to you.

This Privacy Policy and Credit Information Policy takes into account the requirements of privacy laws, codes and regulations in New Zealand, including the Privacy Act 2020 (Privacy Laws).

This Privacy Policy and Credit Information Policy explains:
• how we might collect your personal information;
• how we may use and disclose your personal information;
• how we will store your personal information;
• our use of cookies and analytics tools in connection with our Services;
• your rights to request access to and correction of your personal information; and
• how you can contact us if you have any other questions regarding our collection, use, storage and disclosure of your personal information.

Personal information
Personal information means identifiable information about you, for example your name, email, address, telephone number and so on. If you cannot be identified (for example, when personal information has been aggregated and anonymised) then certain parts of this policy may not apply to that information.

The personal information we collect
The types of personal information we may collect about you include:
• Identity Data including first name, middle name, last name, and date of birth.
• Contact Data including billing address, email address and telephone numbers.
• Financial Data including bank account details, payment card details, and your credit score. 
• Background Verification Data including your passport number, driver licence number, photographic identification or other details requested as part of our verification process to comply with our due diligence obligations, anti-money laundering laws and related ongoing monitoring commitments.
• Transaction Data including details about payments from you to us and other details of loans you have entered into with us.
• Technical and Usage Data including internet protocol (IP) address, your login data, your browser session and geo-location data, your location information (for example your GPS location), device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour, information about your access and use of our website, including through the use of Internet cookies, your communications with our website, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider.
• Profile Data including your username and password for our Services, with us, support requests you have made, your interests, preferences, feedback and survey responses, additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications or accounts from which you permit us to collect information.
• Interaction Data including information you provide to us when you participate in any interactive features of our Services.a
• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
• Professional data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience. 
• Requested data including any other personal information requested by us and/or provided by you or a third party.
• Credit Information is a term used throughout this Privacy and Credit Information Policy and refers to “credit information” and “credit eligibility information” as these terms are defined in the Credit Reporting Privacy Code 2020 and the Privacy Act 2020 (Privacy Act).

The types of “credit information” we may collect about you include:
• your name, address, contact number and email address;
• the fact that you applied for credit from us;
• the amount of credit applied for by you 
• the amount of credit provided to you by us (if any);
• the terms of payment of credit provided to you by us, including any credit term;
• details of your payment history, including details of any default of payment by you;
• information regarding credit that was provided to you that has otherwise been discharged;
• information retrieved from any credit referees;
• information regarding your personal insolvency; and
• information about your involvement in any court proceedings.

The types of “credit eligibility information” we may collect about you from a credit reporting body include:
• a credit report; and
• a credit assessment score.

How we collect personal information
We collect personal information in a variety of ways, including:
• Directly: We collect personal information which you directly provide to us, including when you register for an account, complete a loan application, through the ‘contact us’ form on our website or when you request our assistance via email, our online chat or over the telephone.
• Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries.
• From third parties: We collect personal information from third parties, such as details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.
• From publicly available sources: We collect personal information from publicly available sources such as the New Zealand Companies Office and professional networking sites such as LinkedIn.

Collection and use of personal information
Personal information: We may collect, hold, use and disclose personal information for the following purposes:
• to enable you to access and use our Services, including to provide you with a login; 
• to assess whether to take you on as a new client, including to perform anti-money laundering, anti-terrorism, sanction screening, fraud and other background checks on you;
• to provide our Services to you, including to assess your loan application and provide you with and administer your loan and collect any overdue payments under your loan;
• to enable you to access and use our associated applications;
• to contact and communicate with you about our Services and any enquiries you make via our website;
• for internal record keeping, administrative, invoicing and billing purposes;
• for analytics, market research and business development, including to operate and improve our Services, associated applications;
• to detect and/or prevent any illegal activity that may threaten us or our Services;
• for advertising and marketing, including to send you promotional information about our products and services and information that we consider may be of interest to you, noting we will comply with all laws that are relevant to marketing (including the Unsolicited Electronic Messages Act 2007 and Fair Trading Act 1986);
• to comply with our legal obligations and resolve any disputes that we may have; 
• if you have applied for employment with us; to consider your employment application; and
• if otherwise required or authorised by law.

Disclosure of personal information to third parties
We may disclose personal information to:
• third party service providers for the purpose of enabling them to provide their services, to us, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, couriers, maintenance or problem-solving providers, marketing or advertising providers, 
• professional advisors and payment systems operators;
• insurance companies and insurance brokers;
• our employees, contractors and/or related entities;
• our existing or potential agents or business partners and professional advisers;
• anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
• credit reporting agencies, financial institutions, debt collection agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you. We may use the services of credit reporting and debt collection agencies on an on-going basis and may exchange information about you with those agencies (including information about your default and repayment history). Those agencies may retain that information and provide that information to other customers who use their services;
• courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; 
• third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Facebook Pixel or other relevant analytics businesses; and
• any other third parties as required or permitted by law, such as where we receive a subpoena.

Google Analytics: We may have enabled Google Analytics Advertising Features including Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Store Visits, Google Display Network Impression reporting etc.. We and third-party vendors may use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together. 
You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here.  To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device. 

Overseas disclosure: Where we disclose your personal information to third parties listed above, these third parties may store, transfer or access personal information outside of New Zealand which may not have an equivalent level of data protection laws as those in New Zealand. Before disclosing any personal information to an overseas recipient, we will comply with Information Privacy Principle 12 and only disclose the information if: 
• you have authorised the disclosure after we expressly informed you that the overseas recipient may not be required to protect the personal information in a way that, overall, provides comparable safeguards to those in the Privacy Act 2020; 
• we believe the overseas recipient is subject to the Privacy Act 2020; 
• we believe that the overseas recipient is subject to privacy laws that, overall, provide 
• comparable safeguards to those in the Privacy Act 2020; 
• we believe that the overseas recipient is a participant in a prescribed binding scheme;
• we believe that the overseas recipient is subject to privacy laws in a prescribed country; or
we otherwise believe that the overseas recipient is required to protect your personal information in a way that, overall, provides comparable safeguards to those in the Privacy Act 2020 (for example pursuant to a data transfer agreement entered into between us and the overseas recipient).

Your choice: Please read this Privacy Policy and Credit Information Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy and Credit Information Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy and Credit Information Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us. 

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. You also have the right to contact the Office of the New Zealand Privacy Commissioner.

Storage and security
We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is stored by us or transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. 

Cookies
We may use cookies on our online Services from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online Services and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online Services with personal information, this information may be linked to the data stored in the cookie.

We use the following cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of our online Services. They include, for example, cookies that enable you to log into secure areas of our online Services, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. These are cookies that allow us to recognise and count the number of visitors to our online Services and to see how visitors move around our online Services when they are using them. This helps us to improve the way our online Services work, for example, by ensuring that users find what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our online Services. These cookies enable us to personalise our content for you and remember your preferences (for example, your choice of language or region).

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our online Services.

Links to other websites
Our Services may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy and Credit Information Policy.

Use of Google API Services (this section applies to personal information accessed through Google API Services)
We use Google’s Application Programming Interface (API) Service to access and verify your arrangement with insurance providers and brokers. 
Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements (set out in the Google API Services User Data Policy). 
We limit our use of the personal information that we collect to providing or improving our Services. We do not use the personal information for any other purposes. 
We only transfer the personal information to others if it is necessary to provide or improve our Services or as necessary to comply with applicable law or as part of a merger, acquisition or sale of assets where we notify you of this. 
We do not use or transfer the personal information for serving ads, including retargeting, personalised or interest based advertising.
These restrictions apply to the raw data we obtain from the restricted scopes and data that is aggregated, anonymised or derived from them. 
We have policies and procedures in place setting out appropriate safeguards for protecting your personal information obtained with the Google APIs. We will also ensure that our employees, agents, contractors and successors comply with the Google API Services Data Policy.

Use of geo-localisation data
We collect your precise or approximate location via our website and/or mobile application for the following purposes:
• to provide you access to the appropriate website and/or mobile application based on your location;
• for security and safety; 
• to prevent and detect fraud; and
• as permitted by law.

We collect this information when our website and/or mobile application is open (whether on-screen or not). If you do not want us to use your location for the purposes above, you should turn off the location services in your account settings in the website and/or mobile application or in your website browser/mobile phone settings. If you do not provide location information to us, we may not be able to provide our Services to you. 

Amendments
If you are in New Zealand, we may, at any time and at our discretion, vary this Privacy Policy and Credit Information Policy by publishing the amended Privacy Policy and Credit Information Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy and Credit Information Policy.

For any questions or notices, please contact our Privacy Officer at:
Simfuni Limited NZCN 8459867
Address: 18 Anzac Street, Takapuna, Auckland, 0622, New Zealand 
Email: info@simfuni.com
Last update: 10 July 2023