Privacy Policy – All Apps Limited

ALL APPS Limited

PRIVACY POLICY

This Privacy Policy shall be effective for all customers on 19 July 2021.

We at All Apps Limited (AAL) respect and protect the privacy of visitors to our website and our customers. This Privacy Policy describes our information handling practices when you access our services, which include our content on the website located at AAL and related services (referred to collectively hereinafter as “Services”).

Please take a moment to read this Privacy Policy carefully. If you have any questions about this Policy, please submit your questions to All Apps Ltd, The Heritage House Level 1, 15-17 Dudley St Lower Hutt 5010, Email:contact@allapps.co.nz or Phone:0800 765 555.

ACCEPTANCE OF THIS PRIVACY POLICY

By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. We may provide additional “just-in-time” disclosures or information about the data processing practices of our Services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data.

If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.

CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time which will be indicated by changing the date at the top of this page. If we make any material changes, we will notify you by email (sent to the email address specified in your contract), by means of a notice on our Services prior to the change becoming effective, or as otherwise required by law.

OUR RELATIONSHIP TO YOU

AAL (“we”, “us” and “our”) operates from a place of business in New Zealand, in order to provide Services to our customers. We only provide services to you if you reside in New Zealand.

You may be asked to provide personal information anytime you are in contact with us. AAL may combine your information to provide and improve our products, Services, and content (additional details below) available to you.

If you have any questions about your AAL account, your personal information, or this Privacy Policy, please submit your request to All Apps Ltd, The Heritage House Level 1, 15-17 Dudley St Lower Hutt 5010, Email:contact@allapps.co.nz or Phone:0800 765 555.

THE PERSONAL INFORMATION WE COLLECT

Personal information is data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties.

Information you provide to us

To establish an account and access our Services, we’ll ask you to provide us with some important information about you. This information is either required by law (e.g., to verify your identity), necessary to provide the requested Services, or is relevant for certain specified purposes, described in greater detail below. As we add new features and Services, you may be asked to provide additional information.

Please note that we may not be able to serve you as effectively or offer you our Services if you choose not to share certain information with us. Any information you provide to us that is not required is voluntary.

We may collect the following types of information from you:

Personal Identification Information: Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email.
Formal Identification Information: Government issued identity document such as Passport, Driver’s Licence, National Identity Card, Tax number, passport number, driver’s license details, national identity card details, visa information, and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.
Institutional Information: Employer identity, New Zealand Business Number, proof of legal formation (e.g. Certificate of Incorporation), personal identification information for all material beneficial owners.
Financial Information: Bank account information, transaction history, assets, liabilities, income, expenditure and tax identification.
Transaction Information: Information about the transactions you make on our Services, such as bank account information for the originator of a transfer, name, amount, and/or timestamp.
Employment Information: Office location, job title, remuneration and/or description of role.
Correspondence: Survey responses and information provided to our staff.

Information we collect from you automatically

We receive and store certain types of information automatically, such as whenever you interact with our Site or use the Services. This information helps us address customer support issues, improve the performance of our Site and applications, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:

Online Identifiers: Geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses.
Usage Data: Authentication data, security questions, click-stream data and other data collected via cookies and similar technologies.

For example, we may automatically receive and record the following information on our server logs:

How you came to use the Services;
Device type and unique device identification numbers;
Device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);
How your device interacts with our Sites and Services, including pages accessed and links clicked;
Broad geographic location (e.g. country or city-level location); and
Other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser.

We may also use identifiers to recognize you when you access our Site via an external link, such as a link appearing on a third-party site.

Information collected from third parties

From time to time, we may obtain information about you from third party sources as required or permitted by applicable law. These sources may include:

Credit Bureaus & ID Verification Partners: We obtain information about you from public databases and ID verification partners for purposes of verifying your identity in accordance with applicable law. ID verification partners use a combination of government records and publicly available information about you to verify your identity. We obtain such information to comply with our legal obligations, such as anti-money laundering laws. In some cases, we may process additional data about you to ensure our Services are not used fraudulently or for other illicit activities. In such instances, processing is necessary for us to continue to perform our contractual obligations with you and others.
Public Databases: We may analyse public data to ensure parties utilising our Services are not engaged in fraudulent or illegal activity.

HOW YOUR PERSONAL INFORMATION IS USED

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customised experience. We generally use personal information to create, develop, operate, deliver, and improve our Services, content and advertising; and for loss prevention and anti-fraud purposes.

We may use this information in the following ways:

1) To maintain legal and regulatory compliance

Most of our core Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, AAL must identify and verify customers using our Services in order to comply with anti-money laundering laws in New Zealand. This includes collection and storage of your photo identification. In addition, we may use third parties to verify your identity by comparing the personal information you provide against third-party databases and public records. When you seek to link a bank account to your AAL account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. If you do not provide personal information required by law, we will not provide you an ability to use our Services.

2) To enforce terms in our contract

AAL handles sensitive information, such as your identification and financial data, so it is very important for us and our customers that we actively monitor, investigate, prevent, and mitigate any potentially prohibited or illegal activities, enforce our agreements with you and third parties, and/or prevent and detect breaches of our contracts for Services. We may need to collect missed payments, interest and fees from you based on your use of our Services. We may need to use your personal information to enforce breaches of your contract against you, either by repossession of secured property, mortgagee sale and/or by bringing proceedings against you. We collect information about your account usage and closely monitor your interactions with our Services. We may use any of your personal information collected for these purposes. The consequences of not processing your personal information for such purposes will mean that we will not provide you an ability to use our Services.

3) To detect and prevent fraud and/or funds loss

We process your personal information in order to help detect, prevent, and mitigate fraud and abuse of our Services and to protect you against account compromise or funds loss.

4) To provide AAL’s Services

We process your personal information to provide the Services to you. We cannot provide you with Services without such information.

5) To provide Service communications

We send administrative or account-related information to you to keep you updated about our Services and provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services. You may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes.

6) To provide customer service

We process your personal information when you contact us to resolve any questions, disputes, collect payments and fees, or to troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.

7) To ensure quality control

We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services such as inaccurate transaction records or other interruptions.

8) To ensure network and information security

We process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. The threat landscape on the internet is constantly evolving, which makes it more important than ever that we have accurate and up-to-date information about your use of our Services. Without processing your personal information, we may not be able to ensure the security of our Services.

9) For research and development purposes

We process your personal information to better understand the way you use and interact with AAL’s Services. In addition, we use such information to customise, measure, and improve AAL’s Services and the content and layout of our website and applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services.

10) To enhance your experience

We process your personal information to provide a personalised experience, and implement the preferences you request. For example, you may choose to provide us with access to certain personal information stored by third parties. Without such processing, we may not be able to ensure your continued enjoyment of part or all of our Services.

11) To facilitate acquisitions, mergers, or transactions

We may process any information regarding your account and use of our Services as is necessary in the context of acquisitions, mergers, or other corporate transactions. You have the option of paying your account in full and closing your account if you do not wish to have your personal information processed for such purposes.

12) To engage in marketing activities

Based on your communication preferences, we may send you marketing communications (e.g. emails or mobile notifications) to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers. Our marketing will be conducted in accordance with applicable law.

13) For any purpose

We may disclose your personal information for any purpose you consent to.

14) Third Party Marketing

We will obtain your express consent before we share your personal information with any third parties for marketing purposes.

WHY WE SHARE PERSONAL INFORMATION WITH OTHER PARTIES

We take care to allow your personal information to be accessed only by those who require access to perform their tasks and duties, and to share only with third parties, including third parties located overseas, who have a legitimate purpose for accessing it. AAL will never sell or rent your personal information to third parties without your explicit consent. We will only share your information in the following circumstances:

With Co-borrowers (or potential co-borrowers), your executors, administrators or persons representing you or acting on your behalf.
With third party identity verification services in order to prevent money laundering and counter financing of terrorism.
With financial institutions with which we partner to process payments you have authorized.
With service providers who help with parts of our business operations. Examples of the types of service providers we may share personal information with (other than those mentioned above) include:
- Network infrastructure
- Cloud storage
- Payment processing
- Transaction monitoring
- Security
- Document repository services
- Customer support
- Internet (e.g. ISPs)
- Data analytics
- Information Technology
- Marketing
- Licensed repossession agents
- Credit reporting bureaus
- Debt collection agencies
With companies or other entities that we plan to merge with or be acquired by. You will receive prior notice of any change in applicable policies.
With our professional advisors who provide banking, legal, compliance, insurance, accounting, or other consulting services in order to complete third party financial, technical, compliance and legal audits of our operations or otherwise comply with our legal obligations.
With law enforcement, officials, or other third parties when we are compelled to do so by law, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our contracts or any other applicable policies.
You acknowledge and agree that in addition to potentially obtaining personal information about you from a Credit Reporter, we may disclose your personal information to a Credit Reporter. The personal information about you that we may disclose to a Credit Reporter may include that you have sought a quotation for the cost of credit or made an application for a loan, information about your credit accounts (including credit limits and repayment history), credit defaults, credit infringement and credit non-compliance information, and updates of that information from time to time. A Credit Reporter may hold your information on their credit reporting database and use it for providing credit reporting services, including making this information available to other credit providers (or potential credit providers) and other persons who use the Credit Reporter’s services and for any other lawful purpose. Credit Reporters will hold your personal information on their terms and treat your information in accordance with their own privacy policies. Credit Reporters are subject to specific requirements in relation to credit information they hold. You can find out more about those obligations and your rights at https://www.privacy.org.nz/privacy-act-2020/codes-of-practice/crpc2020/.

HOW WE PROTECT AND STORE PERSONAL INFORMATION

We understand how important your privacy is, which is why AAL maintains (and contractually requires third parties it shares your information with to maintain) appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you entrust to us.

We may store and process all or part of your personal and transactional information, including certain payment information, such as your New Zealand registered bank account details and transactions. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

For example, we use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfil their job responsibilities. However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognise that you play a vital role in protecting your own personal information.

Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us using the contact information provided in this Privacy Policy.

RETENTION OF PERSONAL INFORMATION

We store your personal information throughout the life of your AAL account. We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes.

HOW TO MAKE A PRIVACY REQUEST

You can make personal information requests relating to the information we hold about you at All Apps Ltd, The Heritage House Level 1, 15-17 Dudley St Lower Hutt 5010, Email:contact@allapps.co.nz or Phone:0800 765 555.

HOW TO LODGE A PRIVACY COMPLAINT

If you believe that we have infringed your privacy rights, we encourage you to first submit a complaint by sending us an email detailing your complaint to All Apps Ltd, The Heritage House Level 1, 15-17 Dudley St Lower Hutt 5010, Email:contact@allapps.co.nz or Phone:0800 765 555 so that we may try to resolve the issue or dispute informally.

The relevant data protection authority in New Zealand is the Privacy Commissioner. If we are unable to resolve the issue that you have complained about in a reasonable time, then you may complain to the Privacy Commissioner, whose contact details are, Level 8, 109 – 111 Featherston Street, Telephone (04) 474 7590, email: investigations@privacy.org.nz .