Privacy and Credit
Effective from November 2021
Latitude Financial Services Limited (and our related entities) (“Latitude”), 8 Tangihua Street, Auckland Central, Auckland, New Zealand, take our obligations for protecting personal information seriously. We are bound by, and will abide by, the requirements of the Privacy Act 2020.
You may interact with us anonymously or by using a pseudonym if the interaction is general in nature. However, if the interaction is specific to an account or relates to your personal information, we will need to identify you before we can engage in further discussions and correspondence.
What Personal Information do we Collect and Hold?
We offer a wide range of products and services and as a result we collect and hold a range of personal information from and about people (particularly people who wish to purchase our products or use our services).
In the process of conducting our businesses, we are likely to collect a broad range of information about our customers, prospective customers, employees, prospective employees, contractors, suppliers, brokers, introducers, agents, service providers and the people who run the businesses we deal with. This information can include such things as contact details, financial information and supporting documentation (including credit history details), identification information, transaction history information, billing information, banking details and personal references. In order to satisfy our legal obligations, we may need to retain that information even after a transaction has come to an end (subject to our obligations under the Privacy Act or any other applicable Act).
How we Collect Personal Information?
Wherever it is possible and practical to do so, we collect personal information directly from the person concerned. For example, we will collect personal information when a person deals with us in person or over the telephone, sends us a letter, e-mail or fax, or gives or sends us a completed form (such as an application form). There may be occasions, however, where we need to collect personal information we require for a particular purpose from a third party. This might occur, for example, where it is important for us to obtain personal information from an independent third party or from a Merchant who you choose to use one of our services or products through.
Why do we Collect and Hold Personal Information?
We collect this information in order to undertake and complete the many transactions we have with our customers, suppliers, and other parties with whom we do business, to administer the products we provide and to maintain the business relationships we have that enable us to carry on our business. Personal information collected may also be used to:
- provide you with product(s) or service(s),
- verify your identity,
- improve the services and products we provide,
- keeping our customers informed of the products and services we have, which may include using it for direct marketing purposes,
- to meet our legal and regulatory requirements under various legislations such as the Privacy Act 2020, Anti-Money Laundering and Countering Financing of Terrorism Act, Credit Contracts and Consumer Finance Act, any other applicable legislation or regulation.
To what Other Organisations do we Disclose Personal Information?
In providing and managing our products and services, we contract with other businesses and may disclose personal information to them in the process. These organisations provide services to us and may need access to the personal information we hold in order to enable them to perform those services. We require these companies to adhere to our strict confidentiality requirements for handling personal information and also seek to ensure that they adhere to the requirements of the Privacy Act.
We may disclose your personal information to third parties , such as advisors, lawyers, accountants, acquirers (or potential acquirers) of all or any part of our business (including our related entities within the Latitude Group), or resellers who sell our services, or business partners with whom we exchange customer data for the purposes of providing our services to you, including to debt collection agencies for the purposes of collecting debts, or for the purposes of due diligence enquiries or in order to run the business or part of the business acquired.
We will disclose your information to any person authorised by you any other person authorised by the Act or another law (e.g. a law enforcement agency).
Some of the third parties to which we may disclose your personal information may be located outside of New Zealand. Where they are located outside of New Zealand we ensure they will handle your Personal Information in accordance to the Privacy Act.
How to Access and Correct the Personal Information we Hold About you?
If you wish to obtain details of your personal information that we hold, please contact using the 'Contact Us' table at the end of this policy. There is no charge to request access to your personal information. Subject to certain grounds, we may refuse access to your data, however, we will advise you the reasons why.
If you wish to request correction to the personal information we hold, we will correct your personal information. If we do not make the correction, we will take reasonable steps to note on the personal information that you requested the correction.
To correct your personal information please contact us using the table below. Your request should provide evidence of who you are and set out the details of your request (e.g. the personal information, or the correction, that you are requesting).
We may charge you our reasonable costs of providing to you copies of your personal information or correcting that information.
How you can Make a Complaint Regarding your Personal Information?
If you believe that we have failed to comply with the Privacy Act, please contact us by using the table below or visiting https://www.gemfinance.co.nz/complaints/ or https://help.genoapay.com/hc/en-nz/requests/new?ticket_form_id=360001435393 and we will then follow our Internal Dispute Resolution process to review your concerns.
If the complaint remains unresolved, you may refer it to Privacy Commissioner who will independently and impartially review and resolve the dispute.
The contact details for the Privacy Commissioner are:
Office of the Privacy Commissioner
PO Box 10094
Phone: 0800 803 909
Fax: 04 474 7595
Your Personal Information and emails
If you send us an e-mail we will store and make use of your name, address and other information about you contained in your e-mail and in any attachments. When you submit feedback or questions via e-mail, it is very important that you do not disclose any details that could be used by others to gain access to your account. This includes private details such as your username, password or card number.
If you receive an e-mail from us, you should only re-transmit, distribute or commercialise the material or information in the e-mail if you are authorised to do so (under the Privacy Act or otherwise).
Your Personal Information on the Web
We do not collect personal information about you when you visit our web sites unless you apply for credit online or register for access to our Latitude Service Centre.
Your Personal Information and Direct Marketing
By providing us with your personal information, you agree to us using that personal information for the purpose of informing you about our products and services, or providing your information to our related entities within the Latitude Group and third parties we have dealings with to market our products and services or to market their products and services to you. If you do not wish to receive marketing materials from us, please complete the opt-out provision on the marketing information sent to you or contact us using the table below. If you choose not to receive any marketing materials from us, you acknowledge you may miss out on special product and service offerings and opportunities.
Tracking Information on the Web
For statistical purposes, we collect information on website activity such as the number of users who visit our websites, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site and, when entering one of our websites from another website, the address of that website. This information is obtained through the use of ‘cookies’ (refer below for more information about ‘cookies’).
Our websites may also contain links to other websites. While these links are provided for convenience, if you are navigating these sites please be aware that the information handling practices of the linked websites may differ from ours. While we try to link only to sites that share our high standards and respect for privacy, we are not able to guarantee the privacy practices of other websites.
Protecting Your Personal Information
We will take reasonable steps to keep your personal information safe from loss, unauthorised activity, or other misuse. You must take care to protect your personal information. You should also notify us via our contact details listed below as soon as you become aware of any security breaches relating to your account.
Whenever personal information is sent via our website we use high security levels to protect it. These security levels are standard for internet banking and large scale e-commerce sites and involve the use high levels of encryption. The security level of a web page can be viewed by clicking on the internet browser's padlock or key icon.
Your browser can be individually set to accept all cookies, reject all cookies, or notify when a cookie is sent. If cookies are rejected, there may be limits on how our websites can be used.
From time to time we place advertisements on other websites. This may involve installing a cookie on a computer when our advertisement is viewed. This simply allows us to keep track of how many unique visitors we have to our site and from what advertisements they entered.
To evaluate the effectiveness of our website advertising, we may use third parties to collect statistical data. No personal data is collected on these occasions.
Latitude Service Centre
When you register for access to our Latitude Service Centre (including our mobile app), the information collected is compared with the details we already have stored, such as your name, date of birth and card number, which we have previously collected from you so we can verify that you are the person seeking access to your personal information. If you do not provide the information requested, you will not be able to access the Latitude Service Centre.
Credit Reporting Policy
The Credit Reporting Privacy Code permits credit providers like Latitude to share information with credit reporting agencies, on an ongoing basis. This means that Latitude may provide credit reporting agencies with certain credit related information about its customers’ accounts, such as:
- type of credit account e.g. credit card
- amount of credit extended (but not current balance)
- status of account e.g. open (including account open date)
- details of credit provider i.e. the lender who provided the credit
- monthly reporting of repayment history e.g. whether an account was paid on time, and
- changes in personal details such as address, contact details, etc.
For further information on comprehensive credit reporting, please see the following website www.privacy.org.nz/privacy-act-2020/codes-of-practice/crpc2020/