PRIVACY POLICY

Last Updated: 28 November 2024

This Privacy Policy governs the collection and use of personal information by Aera 22 Opco Limited and related companies ("Aera"). 

Your privacy rights 
  1. Aera is committed to complying with its obligations under the Privacy Act 2020 when  dealing with your personal information. Any personal information we collect and hold  will be stored, used and disclosed in accordance with this Privacy Policy.  
  2. This Privacy Policy should be read in conjunction with any applicable terms and  conditions relating to the use of and access to our website, platform, products and/or  services (collectively referred to in this policy as, Services). 
  3. If you have any questions regarding this Privacy Policy or wish to access or amend the  personal information that we hold about you, please contact us at support@aera.nz. 
Acceptance of this privacy policy 
  1. You acknowledge that you have read and understood this Privacy Policy, and authorise  us to collect, use, disclose, and retain your personal information as described in this  Privacy Policy when you apply for, access or use any of our Services, or otherwise  provide us with any personal information. 
Amendments to this privacy policy 
  1. We may amend and update this Privacy Policy from time to time by posting a revised  version on our website. Any changes will apply from the date we post the updated  Privacy Policy on the website. If we make any significant changes, we will provide  you with reasonable notice of such changes through the website or via other means  such as email. By using our Services after such notice period, you will be deemed to  have accepted the updates to this Privacy Policy. If you do not agree to any change,  you must immediately notify us and stop using and/or accessing our Services. 
How we collect information about you 
  1. Your personal information will be collected and held by Aera 22 Opco Limited, Level  9/55 Shortland Street, Auckland, 1010, New Zealand. 
  2. The type of personal information that we collect will depend on the purpose for which  it is collected and the Services you have requested, but may include: 
    7.1 name and contact details, including your email address, phone number and postal  address; 
    7.1 a) name and contact list information required to use our Services such as sending and receiving payments.
    7.2 information relevant to assessing your eligibility for our Services, including your residency status, date of birth, previous addresses, and dependents; 
    7.3 employment information, including your occupation, current and previous  employer, duration of employment, salary;  
    7.4 biometrics including photos you provide as part of identity verification;
    7.5 information relating to your credit history and credit worthiness;  
    7.6 financial information, including your financial history, assets, investments, savings and debt; and 
    7.7 any other information that we may require from time to time for the purposes set out in this Privacy Policy.  
  1. We may collect Personal information about you when: 
    8.1 you register interest in or apply for our Services, including our high yield savings  accounts and rent-to-own products; 
    8.2 you access one of our digital platforms like our website; 
    8.3 you subscribe to any newsletter or publication of Aera;  
    8.4 you participate in, or otherwise attend, any event, marketing campaign,  competition, promotion or similar event run by Aera or our representatives;  
    8.5 you provide details to us in any feedback or contact us form; 
    8.6 you grant access to collect information from your financial accounts (which we may collect and process using service providers);
    8.7 you otherwise contact us through social media, email, telephone or other  means; 
    8.8 you apply for employment or a volunteer position with us; or 
    8.9 we are required to do so by law. 
  1. If you provide us with personal information relating to another individual, e.g. a joint  applicant, you warrant and represent to us that you have obtained that individual’s  authorisation to provide us with their personal information and have informed them of  the terms of this Privacy Policy.  
  2. When you use our website, we may collect non-personally identifiable information that  is sent to us by your computer, mobile device or other access device. The information  that is sent to us may include your computer IP address, referral URL, geo-location and data about the webpages that you access. 
  3. When you use our mobile application, we may access your contact list for the purpose of improving your experience. For example, you may search your contact list when creating a list of favourite payees, or to quickly find a contact to send money to using peer to peer transfer. In most cases, in order to access your contacts you will be asked to grant us permission, which you can allow or deny. You select what contact list information you provide to us. You consent to Aera accessing your contact list and personal information for the purposes consistent with this policy.
  4. If you choose not to provide personal information to us on request, we may be unable to provide certain Services to you, or it may affect the quality of those Services. Please contact us if you are unsure what information is important and how this might affect  you. 
How we use and disclose information that we collect about you 
  1. We will only use and disclose your personal information in accordance with your  authorisation and/or for the purposes set out in this Privacy Policy, which shall include: 
    (a) to assess your eligibility and suitably for our Services and process your  application for our Services;  
    (b) to provide you with access to and use of our Services, including monitoring your  ongoing use of our Services and compliance with our terms and conditions;
    (c) to communicate with you about our Services; 
    (d) to verify your identity and complete background checks (for example to comply  with our legal obligations under the Anti Money Laundering and Counter  Financing of Terrorism Act 2009); 
    (e) to facilitate your use of our Services and help provide a more personalised  experience;  
    (f) to facilitate, develop, run and improve events and competitions operated by  Aera; 
    (g) to research and help improve and enhance our Services; 
    (h) to undertake regulatory compliance and administrative functions associated  with our business; 
    (i) to conduct market analysis and perform data analytics on customer behaviour and insights in relation to our Services; 
    (j) to comply with any legal obligations or as otherwise permitted by the Privacy Act 2020; and 
    (k) subject to you providing your consent (in accordance with the Unsolicited  Electronic Messages Act 2007), sending you electronic messages to promote  and market our Services. 
  2. Where you consent to us using your personal information for marketing and  promotional communications, you can opt out at any time by notifying us at  support@aera.nz or by clicking the unsubscribe function included in any of our marketing  communications. 
Who we may disclose your personal information to 
  1. We may disclose your personal information to: 
    (a) our related companies; 
    (b) your joint applicants or any guarantors of your obligations to us;
    (c) any lenders or advisors that we may partner with to facilitate the provision of our Services;
    (d) credit reporting and debt collection agencies; 
    (e) any service providers that we have engaged to provide a service to us in relation  to our Services. For example, we may engage third parties to provide us with  IT, marketing or customer support services; 
    (f) our professional advisors, including accountants, insurers and lawyers; 
    (g) any other person or organisation that you have authorised us to disclose your  information to; and/or 
    (h) government departments, regulators, and any other third party where such  disclosure is permitted under the Privacy Act 2020 and/or any other applicable  law.
Credit checks 
  1. We may use credit reporting agencies to check your financial status when applying for certain Services, and to monitor your creditworthiness during your relationship with us.  We may give your information to those agencies, and they may supply us other  information they hold about you in relation to your financial status. We may also let them know when you have and have not met your payment obligations to us.  
  2. Credit reporting agencies use of your personal information is governed by their own  privacy policies and they may use the information we provide to update their credit reporting databases. When other individuals and organisations use the credit reporting agencies’ services, they may also be provided with this updated information. 
Access, correction and retention of your personal information 
  1. You confirm that any information you give to us will be accurate, correct and up to date.  You can update your personal details at any time by contacting us at support@aera.nz.  
  2. You are entitled to access the personal information we hold about you, and to request  that we amend it if it is incorrect. If we are not willing to correct errors that you have  identified in your personal information, you may request that we take reasonable steps  to attach a statement to the personal information noting the correction sought. 
  3. We will only retain your personal information for as long as it is required to achieve the  purposes set out in this Privacy Policy or as otherwise required by law.  
Security of information 
  1. Although we take reasonable steps to ensure personal information in our possession  is protected and held securely, we do not make any warranties in relation to the security of any information you disclose or transmit to us and we are not responsible for the  theft, destruction, or inadvertent disclosure of your personal information where our security measures have been breached. Any transmission of personal information is conducted at your own risk. 
  2. We generally hold your information in New Zealand. However, certain personal  information may be transferred and/or stored outside of New Zealand by our third party service providers, such as Amazon Web Services who hosts our data in their servers in the United States, Singapore or Australia. Where personal information is disclosed to a third party outside  of New Zealand and that third party will use or disclose the personal information for  their own purposes, we will ensure that such third party is subject to comparable privacy  laws to New Zealand or is required to protect the personal information in a way that is  comparable to New Zealand’s privacy laws.  
Cookies 
  1. Like many other websites on the internet, we use cookies to store and track information  when you are on our website for the purposes of:  
    (a) providing more customised content and material to you on our website; and
    (b) conducting business and marketing analysis.
  2. All information collected via cookies will be held by us. This information will not be  made available to any third party in a manner that enables you to be identified. If you do not wish to allow cookies you may change your browser settings to disable cookies.  However, if you disable cookies some parts of the website may not function properly.  
Links to other sites 
  1. Our website may have links or references to third party websites or material. Our  Privacy Policy does not apply to those websites, and any information collected by such  third parties is governed by that third party’s privacy practices or policies. We accept  no responsibility or liability for the content or privacy practices of any third party websites.  
How to contact us
  1. If you have any queries or concerns about our Privacy Policy or our handling of your  personal information, please contact us at Aera 22 Opco Limited, Level 9/55 Shortland  Street, Auckland, 1010, New Zealand or by emailing us at support@aera.nz. 
  2. If you remain unsatisfied with our response or otherwise consider we may have  breached our obligations under the Privacy Act 2020 you may wish to contact the Office  of the Privacy Commissioner at: PO Box 10-094, The Terrace, Wellington 6143, phone  0800 803 909, or through https://www.privacy.org.nz/about-us/contact/. 

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