Privacy Policy
Purpose
We know that how we collect, use, disclose and protect your information is important to you, and we value your trust. That’s why protecting your information and being clear about what we do with it is a vital part of our relationship with you.
The purpose of this Privacy Policy is to inform our clients and any users of our digital platforms (i.e. our website) about how we comply with the requirements of the New Zealand Privacy Act 2020 (“the Privacy Act”) in managing your personal information.
Consent to Privacy Policy
Please note that when you contact us through our website, you are agreeing to this Privacy Policy. If you do not agree with this Privacy Policy, please do not contact through any of our digital platforms but call us on 0800 34 62 63.
Collection of personal information
Personal information is defined in the Privacy Act as information about an identifiable individual (a natural person as opposed to a company or other legal entity).
Types of personal information we collect
The types of personal information we will collect will vary on the nature of your dealings with us.
We will only collect personal information that is necessary. Were reasonable and practicable, we will collect your personal information directly from you and inform you that we are collecting it.
We mainly collect personal information directly from you, for example:
- When you use our website, linsa.co.nz;
- When you complete an application form through our website, or in any of our branches.
- Over the telephone when you contact, or are contacted by, our staff;
- When you email or write to us;
- When you ask us to deal with any professional adviser e.g. Budget Services
- When you participate in a marketing campaign, competition or promotion (or similar even) administered by us or our representatives.
If it is not obvious that we are collecting personal information from you, we will do our best to make it clear to you so that you are always aware when information is being collected.
We may also collect personal information about you from publicly available sources e.g. via the internet, phone book, social media platforms.
Generally, the types of personal information we collect and hold include your:
- Name
- Date of Birth
- Contact details (such as your email address, postal and residential address, phone number(s), drivers licence or passport number)
- Details relating to your use of any product or service offered by us
- Information about your financial situation (including your budget, bank transaction history, purpose for borrowing)
- Information about your credit and repayment history
- Information about your residential and employment status and personal circumstances
- Details of any contact with our staff, either electronically, by phone or in person
Online device information and cookies
If you are visiting us through our website, then we collect information about your use and experience on these by using cookies. Cookies are small pieces of information stored on your hard drive or on your mobile browser. They can record information about your visit to the site, allowing it to remember you the next time you visit and provide a more meaningful experience.
The cookies we send to your computer, mobile phone or other device cannot read your hard drive, obtain any information from your browser, or command your device to perform any action. They are designed so that they cannot be sent to another site or be retrieved by any non-Linsa Finance Limited website.
When you interact with us through our website, the information collected through cookies may include:
- The date and time of visits.
- Website page (or pages) viewed.
- The website from which you accessed the internet and our website;
- How you navigate through the website and interact with pages (including any fields completed in forms and application completed (where applicable));
- Information about your location’
- Information about the device used to visit our digital platform; and
- IP address and the type of web browser used.
We will not ask you for personal information publicly over any social media platform. Sometimes we may invite you to send your details to us through a private message, for example, to answer a question.
Purpose of collection and use of personal information
Any personal information you provide us may be used to:
- Check whether you are eligible for the product or services offered by us;
- Manage, assess or enforce any agreement and/or security you have with us;
- To assess your credit history and financial position from time to time;
- To notify a credit agency or provider of your repayment history and account details, if you are in default of repayments and/or breach an agreement or arrangement you have with us;
- To verify your identity as required from time to time by applicable law or regulations, including the Anti-Money Laundering and Countering Financing of Terrorism Act 2009;
- Monitor your account for fraud or crime detection purposes
- Collect any outstanding debt from you;
- Share with third parties where you have expressly consented for us to do so;
- Monitor and maintain our systems and networks, and provide staff training;
- Respond to any query or complaints you may have;
We also have an obligation to maintain personal information to disclose to regulatory and similar bodies – see disclose of your personal information below. These bodies have a legal right to such information.
Storage and protection of your personal information
We may electronically record and store personal information which we collect from you. When we do so, we will take all reasonable steps to keep it secure and prevent unauthorised disclosure.
However, we cannot promise that your personal information will not be accessed by an unauthorised person (e.g. a hacker) or that unauthorised disclosures will not occur. If we provide you with any passwords or security devices, it is important that you keep these confidential and do not allow them to be used by any other person. You should notify us immediately if they security of your password or security device is breached, this will help prevent the unauthorised disclosure of your personal information.
Some of the information we hold about you will be stored in paper files while your loan with us is active. At the same time, and after your loan is closed, it will be stored electronically on physical hard drives and backed up on the cloud, by cloud service providers – see Cloud-based service providers below.
We use a range of physical and electronic security measures to protect the security of the personal information we hold, including:
- Access to information systems is controlled through identity and access management, including secure passwords and firewall control on our server;
- Our buildings are secured with locks and in some cases security cameras. Only staff have access to keys. In the event of employment being terminated, the key is recovered, or the locks changed with new keys issued;
- Employees are bound by internal information security policies and are required to keep information secure;
- Employees are required to complete training about information security and privacy;
- When we sent information overseas or use service providers to process or store information, we put arrangements in place to protect your information, including reviewing the applicable privacy policy;
- We regularly monitor and review our compliance with internal policies and industry best practice;
- We only keep information for as long as we need it, or as long as the law requires us to. We have a records management policy that governs how we manage our information and records to make sure we destroy any information that is outdated, irrelevant or unnecessary.
Cloud-based service providers
We use third party cloud service providers to backup and store the information we collect. We use Acronis Data Centre cloud servers located in Sydney Australia. We ensure that our cloud-based service providers are subject to appropriate security and information handling arrangements and that the information stored or processed by them remains subject to confidentiality obligations.
Time frames for keeping personal information
We take reasonable steps to destroy or permanently de-identify any personal information as soon as practicable after the date of which it has no legal or regulatory purpose, or we have no legitimate business purpose with it.
In the case on information that relates to products or services we have provided; we are required by law to hold this information for seven years. After this time, provided that the personal information in no longer relevant to any services we are providing you, we will take reasonable steps to destroy or de-identify any personal information.
We have a records management policy that governs how we manage our information and records to enable us to destroy any information that is outdated, irrelevant or no longer necessary.
If there is a privacy breach
We work hard to keep your personal information safe. However, despite applying strict security measures and following industry standards to protect your personal information, there is still a possibility that our security could be breached. If we experience a privacy breach, where there is a loss or unauthorised access or disclosure of your personal information that is likely to cause you serious harm, we will, as soon as we become aware of the breach:
- Seek to quickly identify and secure the breach to prevent any further breaches and reduce the harm caused;
- Assess the nature and severity of the breach, including the ty[e of personal information involved and the risk of harm to affected individuals;
- Advise and involve the appropriate authorities where criminal activity is suspected;
- Where appropriate, notify any individuals who are affected by the breach (where possible, directly);
- Where appropriate, put a notice on our website advising our clients of the breach; and
- Notify the Privacy Commissioner.
Disclosure of your personal information
We may disclose your personal information to others outside of Linsa Finance Limited where:
- It is necessary to enable us to achieve the purpose that we collected the information for;
- We are authorised or required by law or where we have a public duty to do so;
- You have expressly consented to the disclosure or your consent can be reasonably inferred from the circumstances; or
- We are permitted to disclose the information under the Privacy Act 2020.
Parties we may disclose your information to
Your personal information may be used by us for the purpose of providing advice and services to you and may also be used by agencies such as, but not limited to:
- Any outsourced service provider who assists in the services we are required to carry out such as auditors and external compliance reviewers;
- Our external disputes resolution service;
- The Regulator;
- Credit reporting and debt collecting organisations;
- Any person listed on the loan as a co-borrower or guarantor;
- Work and Income New Zealand;
- The Ministry of Justice;
- The Department of Corrections;
- The Inland Revenue Department;
- Customs Service New Zealand;
- New Zealand Transport Agency;
- Any of your representatives, e.g. lawyer or budget advisor; and
- Your employer.
If we don’t need to share your information with a third party in order to provide advice and services to you, we will not pass on your information without your consent. Under no circumstances will we sell or receive payment for disclosing your personal information.
Third party websites
Through our website or any other social media pages, you may be able to link to other websites which are not under our control. We are not responsible for the privacy or security practices of those third party websites and the sites not covered by this Privacy Policy. Third party websites should have their own privacy and security policies and we encourage you to read them.
In addition, we have no knowledge of (or control over) the nature, content, and availability of those websites. We do not sponsor, recommend, or endorse anything contained on those linked websites. We do not accept any liability of any description for any loss suffered by you by relying on anything contained or not contained on these linked websites.
Right to access, correct and delete personal information
You have the right to request access to, correct, and, in some circumstances, delete your personal information. You can do so by contacting us at:
Linsa Finance Limited
P O Box 14020
Tauranga 3141
Phone: 07 578 7717
Email: robert@linsa.co.nz
When you contact us with such a request, we will take steps to update or delete your personal information, provide you with access to your personal information and/or otherwise address your query within a reasonable period after we receive your request. To protect the security of your personal information, you maty be required to provide identification before we update or provide you with access to your personal information.
We are only able to delete your personal information to the extent that it is not required to be held by us to satisfy any legal, regulatory, or similar requirements.
There is no fee for requesting that your personal information is corrected or deleted or for us to make corrections or deletions. In processing your request for access to your personal information, a reasonable cost may be charged. This charge covers such things as locating the information and supplying it to you.
There are some circumstances in which we are not required to give you access to your personal information. If we refuse to give you access or to correct your personal information, we will let you know our reasons, except if the law prevents us from doing so.
If we refuse your request to correct or delete your personal information, you also have the right to request that a statement be associated with your personal information noting that you disagree with its accuracy.
If we refuse your request to access, correct or delete your personal information, we will also provide you with information on how you can complain about the refusal.
What happens if you do not provide us your information?
If you do not provide information we have requested, you may be unable to obtain or access our services for which the information is required. Please ask us if you are unsure what information is important and how this might affect you.
Changes to this Privacy Policy
We review this Privacy Policy periodically to keep it current and available on our website, and in our branches. If the changes are significant, we may advise you directly. You may also obtain a copy of the latest version by calling us on 0800 34 62 63 or emailing robert@linsa.co.nz
Privacy Policy queries and concerns
If you are concerned about how your personal information is being handled or if you feel that we have compromised your privacy in some way, please contact us at:
Linsa Finance Limited
P O Box 14020
Tauranga 3141
Phone: 07 578 7717
Email: robert@linsa.co.nz
We will acknowledge your complaint within three working days of its receipt. We will let you know if need any further information from you to investigate your complaint.
We aim to resolve complaints as quickly as possible. We strive to resolve complaints within 5 working days, but some complaints take longer to resolve. If you complaint is taking longer, we will let you know what is happening and a date by which you can reasonably expect a response.
If you are not satisfied with our response to any privacy related concern you may lodge a formal complaint on the Privacy Office website (www.privacy.org.nz) or send a complaint form to the Privacy Commissioner at:
Office of the Privacy Commissioner
P O Box 10-094
Wellington 6143, New Zealand
Fax: 04-474 7595
Email: enquiries@privacy.org.nz
Telephone: 0800 803 909
Website: www.privacy.org.nz