In this policy, “Personal Information” means information about an identifiable individual. By way of example, this type of information includes your name and contact details. Bettersaver Limited and its related companies and affiliates ("we”, “us”, “our") are committed to respecting your privacy. We will always collect, store, use and disclose your Personal Information in accordance with the Privacy Act 2020.
- information and services offered on, and provided by our website ("Website");
- mobile operating applications including applications for smart phone, tablet and other handheld devices ("Apps");
- social media pages, including Facebook and LinkedIn; and
- email communications and subscription services.
1 WHAT INFORMATION DO WE COLLECT?
(a) Information you provide
You may give us information about yourself, such as your name, date of birth, address, email address, telephone number, IRD number, details about your KiwiSaver scheme such as your fund choice and PIR and details about your finances when, for example, you use or contact us via our Online Services.
(b) Information collected about you
When you visit our Website or other Online Services, we may collect more information, such as the address of your Internet service provider, the name of the web page directing you, and your clicks and activity on our site.
Clickstream data and other related information about visits to our Apps and related Online Services may be collected. In addition to this, usage and performance data through our Apps using various platform specific tracking technologies available to the Apps may be collected.
(c) Information collected from third parties
Information may be collected about you from third parties such as your KiwiSaver provider, our third party affiliates or partner companies or from marketing or advertising companies who may provide us with such information as a part of their relationship with us. We may combine this information with other information that we hold.
Third party service providers may be allowed to use technologies including mobile monitoring and tracking technologies in relation to our Online Services. These third party service providers may collect information sent by your browser or mobile device.
Additional information may be collected about you when you use our Online Services.
(d) Cookies and other monitoring devices
We may use services such as Google Analytics, which will issue cookies from their own servers and which will be able to track website visitors throughout relevant websites. We do not control how those cookies are issued, or the data that they store.
We may use “web beacons” (electronic images also known as pixel tags or clear gifs) to recognise a cookie on your computer when you view or act upon a web page, an advertisement that we have placed on a third party web page, or an email or other electronic communication that we have sent.
We may also use Local Shared Objects, sometimes referred to as “Flash” cookies. Use of Local Shared Objects can help deter, detect and prevent fraud and can support our Online Services.
2 HOW IS YOUR PERSONAL INFORMATION USED?
We may (and may authorise third parties to) use your Personal Information to facilitate the transfer of your KiwiSaver to a different provider, to help us develop, improve, manage, administer and facilitate our services and operations (including to provide the Online Services), to help us to develop our Online Services, to administer your account, for safety and security issues, for our own internal purposes (such as risk management, staff training, system development, and quality assurance), to conduct market research including the development and use of anonymised, aggregated data sets, for employment opportunities within and outside of our organisation, for any purpose permitted by law, and for any other use associated with such purposes or which you may authorise.
In addition, we may use your Personal Information to promote and market our products and services, or the products and services of others. However, we will not do this by email or text (except as part of an email which facilitates, completes or confirms a transaction with you) unless we have your express or deemed consent to do so. These emails and texts will always include an “unsubscribe” facility (see section 6 for more information on email and text communication).
3 IN WHAT CIRCUMSTANCES MIGHT WE DISCLOSE YOUR PERSONAL INFORMATION?
We do not sell, trade or rent your Personal Information to others.
We may disclose your information to your existing KiwiSaver provider and any new KiwiSaver provider you nominate when using our Online Services.
We may also use other companies and individuals to perform services on our behalf, such as sending emails. They will have access to your Personal Information needed to perform these services, but we will not authorise them to use your information for other purposes.
In addition, we may provide statistics about our customers, traffic patterns and related site functions to reputable third parties.
We will not otherwise disclose your Personal Information unless we believe on reasonable grounds that you have provided your authorisation. However, you should be aware that we may be required to disclose your Personal Information without your consent in order to comply with any court orders, subpoenas or other legal process or investigation including by tax or other regulatory authorities, if such disclosure is required by law. We may also disclose your Personal Information to the Financial Markets Authority as part of their oversight and regulation of our business. Where possible and appropriate, we will notify you if we are required by law to disclose your Personal Information.
4 STORAGE, SECURITY AND PRIVACY BREACHES
We may store the Personal Information we collect from you on servers located in New Zealand or Australia. We will only keep your Personal Information for as long as we require it for the purpose for which it was collected. However, we may also be required to keep some of your Personal Information for specified periods of time, for example under certain laws relating to companies, money laundering, financial markets, and financial reporting legislation.
We are committed to protecting the security of your Personal Information and we take all reasonable precautions to protect it from Privacy Breaches, namely:
a) unauthorised or accidental access, disclosure, alteration, loss, destruction of your Personal Information; and
b) actions which prevent us from accessing your Personal Information on a temporary or permanent basis.
If your Personal Information is subject to a Privacy Breach which causes or is likely to cause serious harm, we will notify you and the Privacy Commissioner in accordance with our obligations under the Privacy Act 2020.
5 WHAT ABOUT LINKS TO OTHER WEBSITES?
6 EMAIL AND TEXT COMMUNICATIONS
We are committed to complying with the Unsolicited Electronic Messages Act 2007.
By subscribing to emails and/or text communications, or otherwise providing your email address and/or mobile number, you consent to receiving emails and/or texts (as the case may be) which promote and market our products and services, or the products and services of others, from time to time.
You can unsubscribe from our email communications and/or text communications at any time by clicking the “Unsubscribe” link in any promotional or marketing email or text received or by emailing [email protected].
Once you have unsubscribed from the email or text communications, you will be removed from the corresponding marketing list as soon as is reasonably practicable.
7 HOW YOU CAN REQUEST ACCESS OR CORRECT YOUR PERSONAL INFORMATION OR REQUEST DELETION
In some cases, you may have the right to ask us to delete your personal information. You can make a request for it to be deleted by contacting us at [email protected]. We may not be able to delete everything, but we will let you know if there is any information we can’t delete and why. For instance, we may need to keep some information about our financial recording obligations.
If you ask us to delete all your information, we will be unable to reverse this in the future.
The process to delete information
Contact us at [email protected] with a request for us to delete any information we hold about you.
Our team will review your request and check what our compliance and legal obligations with the information you have requested to delete are. When you make your request, we will need to confirm that you’re authorised to request the information be deleted. This might involve asking you some security questions, checking your identity documents. Please understand that we must do this in order to protect your privacy.
If no issues, we will delete your information from our systems. Please note that this request will take up to 30 days to process, we will keep you informed throughout.
What if we are unable to delete your information?
All requests we receive for deletion of personal information will be done on a case by case basis, please note that in some circumstances we will not be able to delete all personal information. We will let you know if and when that applies. Some personal information may need to be retained for compliance with other applicable laws.
Queries and Complaints
If we do not address your concerns or resolve a complaint to your satisfaction, you may make a complaint with the Office of the Privacy Commissioner.