Last updated: 15/05/2023
When handling personal information, we comply with the New Zealand Privacy Act 2020 (Privacy Act), the New Zealand Information Privacy Principles (included in the Privacy Act) (IPPs) and, where applicable, other applicable data protection laws, such as the General Data Protection Regulation of the United Kingdom, as defined in section 3 of the UK Data Protection Act 2018 (UK GDPR).
The information we collect and where we collect it from
We collect and process personal information which:
- you give to us when you register with us, such as your name and contact details
- we obtain from credit reporting agencies on your behalf
- we obtain from our third party service providers and, if applicable, our Cybercheck Partners
- we collect about you based on your use of our website or from your mobile device if you are using our app
- we receive from other sources, such as third parties who give us information about you
- is collected from cookies.
Information you give us. You may give us personal information about you when you use our website or services or by communicating with us. This includes personal information you provide when you participate in discussion boards, answer specific questions on our website, provide us with feedback, participate in surveys, and when you report a problem.
The personal information you give us may include:
- Email address
- Date of birth
- Phone number
- Monthly expenditure
- Residential details
- Employment details
- Address history
- Bank details
- Property value
- Deposit amount
- Monthly rental income
- Mortgage details
- Driving licence details
- Passport details
- Energy and gas tariff details
- Lifestyle information
Personal information we collect from credit reporting agencies on your behalf. If you register to use our services, we will obtain your personal credit score and other credit information (as defined in the New Zealand Credit Reporting Privacy Code 2020) about you (Credit Information) from one or more credit reporting agencies on your behalf. You authorise us to obtain Credit Information about you from any credit reporting agency to confirm your identity, verify your current credit obligations, and otherwise as required to provide you with our services.
Personal Information we collect about you based on your use of our website or apps. Each time you visit our website or use our app we may automatically collect the following personal information:
- technical information, including the Internet protocol (IP) address, your login information, browser type and version, time zone setting, operating system and platform
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number
Personal information we collect from our Cybercheck Partners on your behalf. If we offer our ClearScore Protect service and you have registered to receive this service, to provide you with this service, we share the email address connected with your ClearScore account with our Cybercheck Partners, who use this information to identify whether the account details associated with your email account may have been compromised. The Cybercheck Partners will not use your email address for any other purpose (including marketing) and will only keep it for the time necessary to conduct the check after which it will be deleted.
Personal information we receive from other sources. We may receive personal information about you if you use any of the websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, service providers, advertising networks, analytics providers, search information providers, social media) and may receive personal information about you from them, such as your credit report information, whether or not you have taken out a product with them, what other products you may have used, and other such details.
Recording telephone calls and other communications. We may monitor or record telephone conversations or other communications between you and us.
When we use or disclose your personal information we may combine personal information we receive from other sources with personal information you give to us and use this information and the combined information for the purposes set out below.
How and why we use your information
We use your information where you have given us your consent, where use is necessary for the performance of a contract with you (such as delivering our core services to you) and/or for our legitimate interests.
If you have any questions about the purposes for which we collect and use your personal information, you can contact our Privacy Officer at firstname.lastname@example.org.
Performance of a contract. We may process your personal information to:
- verify your identity as part of our identity authentication process
- create and administer your account within the website
- provide you with our information, products and services
- undertake analysis and profiling of your Credit Information in order to identify and inform you of credit and other products and services that may interest you or be relevant to your credit circumstances or to enhance our services
- notify you about changes to our services
- respond to communications from you (including complaints) relating to our website and our services
- identify you when you sign-in to your account and verify that your account is not being used by others
- enforce compliance with our agreement you have with us
- administer your account and relationship with us and to communicate with you by telephone, mail, email, text (SMS) message or other electronic means
and such processing is necessary for the performance of the contract between you and us. We cannot provide our services to you without collecting and processing your personal information because we need certain information from (or about) you in order to be able to seek your Credit Information and to show relevant financial offers to you.
Legitimate interests. We may process your personal information to:
- display general information on products or services that may be of interest
- analyse our users' behaviour and preferences, and information collected from users' devices in order to have information required to be able to improve the services we provide to our customers and the user experience on our website
- conduct analysis, segmentation and profiling of your personal information in order to provide you with direct marketing communications
- where you have provided your consent for us to market to you, provide you with information about other products and services that may interest you
- ensure that content from our website is presented in the most effective manner for you and your device
- analyse, assess and improve our services (such as understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you)
- provide training to our customers and personnel
- administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
- manage our customer relationships
- keep our website safe and secure and to protect you and us from fraud or other threats
- comply with our obligations to our third-party service providers, suppliers and resellers
- investigate any complaint you may make (including the use of telephone recordings or transcripts of communications as evidence in any dispute between you and us)
- protect and/or enforce our legal rights and interests, including defending any claim
- comply with our legal obligations, including any notification and reporting obligations and any access directions imposed on us by a government agency or regulatory authority. This will include complying with any notification and reporting obligations and any access directions imposed on us by a government agency, and otherwise where the law requires or allows us to do so
and such processing is necessary for the purposes of a legitimate interest pursued by us, and we have assessed that our interests are not overridden by your interests or fundamental rights and freedoms.
Consent. We may process your personal information for other purposes that you consent to from time to time.
We may also process personal information collected for such other purposes that are compatible with the original purposes described above.
Anonymised information. We may also process de-identified and anonymous information (and aggregate it on an anonymous basis with other data for data analytical and reporting purposes), provided that there is only a low risk that any person could be re-identified from the information.
Right to object. You have the right to object to the way we process your personal information where the processing is based on legitimate interests.
What we will never do. Rest assured, we will never sell your personal information, where you may be identified, to third parties.
Who we may share your information with
We may need to disclose your personal information to others to ensure the smooth provision to you of the products, services and information you request and as otherwise described above (under the heading “How and why we use your information” above).
We may share your personal information with the following types of third parties.
Group companies. We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
Service providers (sub-processors). We may share your personal information with third party service providers and suppliers who provide us with services that we need in order to operate the website, apps and supply the services. These service providers do not have permission to use any of your personal information that we provide to them for any purpose other than the purpose for which we provide it to them. These third parties act on our instructions and are processors of your information.
Other selected third parties. We may also share your personal information with other third parties including:
- Product providers, such as our business partners who offer you credit cards, loans, car finance, mortgages, insurance, pensions, investments and other related products, to:
- assess whether you are an existing customer and for fraud prevention purposes
- conduct analysis to provide you with better products and services in the future, and for segmentation purposes
- pre-fill an application form with the product provider
- assess your probability of being accepted for a product
- if applicable, Cybercheck Partners, to obtain details of any recorded cybersecurity incidents affecting your nominated email account
(please see "Product providers" below for more detail)
- Credit reporting agencies, to obtain your information (as defined in the New Zealand Credit Reporting Privacy Code 2020) on your behalf and to provide our services to you (please see "Credit reporting agencies" below for more detail)
- Fraud prevention agencies, to prevent crime and trace those responsible (please see "Fraud prevention agencies" below for more detail)
Details of the kinds of product providers we use in connection with the website and services are set out below:
- providers we use (such as comparison sites and aggregators) for analysis and profiling of your Credit Information (and any other factual information provided by you or on your behalf) to identify and inform you of credit products that may be relevant to your credit circumstances. When you click to search for credit offers on our website or our apps, these providers may record an access by you on your credit file, but this record will be invisible to other lenders, so by itself it will not affect their lending decision and it will not affect your credit score
- advertisers that require data, to perform services on our behalf, including selecting and serving relevant adverts
- analytics and search engine providers that assist us in the improvement and optimisation of our service
- if we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets (or the buyer or seller's advisers)
- if we, or part, or all, of our assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets
- if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our Terms and other agreements; or to protect the rights, property, or safety of ClearScore NZ Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Credit reporting agencies. If you register to use our services we will obtain on your behalf as your authorised agent, in accordance with our Terms, copies of your Credit Information from designated credit reporting agencies. In order to provide these services to you, we will share your personal information with such credit reporting agencies.
Credit reporting agencies 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/.
The information which we provide to credit reporting agencies may be supplied by them to other organisations such as fraud prevention agencies and used by those organisations for the purposes of checking identity, preventing fraud, tracing and collection of debt. Credit reporting agencies may also use personal information to undertake statistical analysis.
Fraud prevention agencies. The personal information we have collected from you may be shared with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. Law enforcement agencies may also access and use this information. We and other organisations may also access and use the personal information recorded by fraud prevention agencies from other countries.
Cybercheck Partners. If we offer our ClearScore Protect service, and you register for this service, we will partner with web monitoring service providers to provide you with the service (Cybercheck Partners), which helps you to identify whether or not information associated with your email account has been compromised online. To provide this service, we share your email address (the one we use to send you service emails regarding our services) with our Cybercheck Partners. These partners will then check their databases to identify whether there are any recorded instances of your account details having been compromised. Your email address is processed solely on our instructions and it will not be used by our Cybercheck Partners for any other purpose, including marketing. We will notify you of the results of the cybercheck in the manner set out in our Terms. We would not use the results of these cyberchecks conducted on your behalf for any other purpose.
Direct marketing and how you can change your preferences
We offer you the opportunity to receive marketing information from us. You can easily opt out of receiving marketing from us at any time.
We will normally send direct marketing by email if we have your email address but may choose to contact you via other methods.
You may receive the following types of communications from us:
- Product advertising. We'll get in touch with general information on product and service offers that may be relevant and of interest to you. We will only ever send these if you explicitly consent to receiving them and you can unsubscribe whenever you like.
- Content communications. We'll send you content such as tips, research, features and news, coaching programmes on how to keep on top of your money and other related content. You can unsubscribe from these at any time and we will never spam your inbox.
- Core communications. We’ll send you your credit report every month, security alerts pertaining to your ClearScore account, significant changes which may impact our service and other such related content. These communications are an intrinsic part of owning a ClearScore account and cannot be opted-out of.
If you would like us to stop sending direct marketing to you, we offer simple ways to do this. Whenever you receive direct marketing you will be given an option to unsubscribe. You may also update your preferences in ‘My Account’.
You can also tell us that you do not wish to receive any more marketing communications at any time by writing, with your full name, address and other contact details (to enable us to find your records), to email@example.com.
If we (or our service providers) transfer personal information outside of New Zealand to a country that we do not consider to be bound by privacy laws similar to the Privacy Act and IPPs we will enter into a contractual mechanism with them to enforce your privacy rights.
Part of our customer services function is based in India. We have put in place safeguards to protect personal information processed in or accessed from India.
How we keep your information secure
We take the security of your personal information very seriously and use strict procedures to protect it. Whenever we transfer personal information outside of New Zealand, we ensure that appropriate safeguards are in place to protect the information.
All personal information you provide to us is stored on our secure servers.
We do our best to protect your personal information, but we cannot guarantee the security of your information transmitted to our website; any transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to try to prevent unauthorised access, loss or damage.
If we no longer need your personal information, unless we are required under New Zealand law or a court or tribunal order to retain it, we will take reasonable steps to destroy or de-identify your personal information, in accordance with our document and information retention policy.
Notwithstanding the reasonable steps taken to keep information secure, breaches may occur. In the event of a security incident, we have in place procedures to promptly investigate the incident and determine if there has been a data breach involving personal information, and if so, to assess if it is a breach that would require notification. If it is, we will notify affected parties in accordance with Privacy Act requirements.
HOW LONG WE KEEP YOUR INFORMATION
We will keep your personal information:
- until we no longer have a valid reason for keeping it;
- until you request us to stop using it; and/or
- for as long as required by law e.g. we keep invoice information for 7 years to fulfil our tax obligations.
After termination of your account, we may continue to use anonymised data (which does not identify individual users) which is aggregated with anonymised data of other users. We use this aggregated anonymised data for data analysis, profiling and research purposes, for example to gain insights about our users. We may also keep your email address to ensure that you no longer receive any communications from us as well as your name, date of birth and latest address for fraud prevention purposes and for the exercise or defence of a legal claim.
Links to and from third party websites
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.
You can exercise specific rights with regards to the personal information that we hold about you.
You have the right to access your readily retrievable Personal Information that we hold about you, and to ask for it to be corrected if you think it is wrong,
For the exercise of any of your rights, you can also contact us at firstname.lastname@example.org. Your email should provide evidence of who you are and set out the details of your request (for example, the personal information, or the correction, that you are requesting).
Contacting us and complaints
If you have a complaint you must send it to us in writing and we will deal with it within a reasonable timeframe, usually 30 days. If you are not happy with our response you may make a complaint to the regulator, the Office of the New Zealand Privacy Commissioner. More information is available at: https://www.privacy.org.nz/your-rights/making-a-complaint/.
Overview of our Cookies Policy
By accessing our website (at www.clearscore.com/nz) or apps you are accepting and consenting to this Cookies Policy.
If you wish to use our website, but would like us not to set cookies in your browser, you can disable or remove the cookies. Details on how to do this are set out below. Please note that disabling or removing the cookies we or our third party service providers set may impact the functionality and security of our website and our ability to provide our services to you.
We reserve the right to make changes to our Cookies Policy. Any changes we may make to our Cookies Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Cookies Policy. Your continued use of our website is taken as your agreement to any such changes.
What are cookies?
Cookies are files containing small amounts of information which are downloaded to the device you use when you visit a website. Your web browser (such as Internet Explorer, Mozilla Firefox, Google Chrome or Safari) then sends these cookies back to our website or application on each subsequent visit.
- to recognise your device(s) when you visit our website and to remember if you've set any preferences on our website. This enables us to personalise our content for you and greet you by name
- to temporarily store data as part of, for example, customer surveys
- to test new content and evaluate its effectiveness
- to recognise and count the number of visitors to our website and see how you navigate our website when you are visiting it (including tracking page usage and paths used by visitors through our website; and tracking use of our Internet banner advertisements and other links from our marketing partners' websites to our website)
- to improve our website's usability and keep our services easy to use and up to date
- to allow you to share pages with social networks such as LinkedIn, Facebook and Twitter / to support social media components, like Facebook or Twitter (where our website uses a plugin from these third party platforms)
- to ensure you don't miss information that is relevant to you (including targeting our website content, targeting our marketing campaigns and direct marketing emails, targeting our Internet banner advertisements on our website and on other websites)
- to analyse use of our website (including for performance and statistical analysis, sales and marketing research). To stop us setting these cookies you will need to set up your browser to reject all cookies (see further below)
We may also combine this web usage data with other information we have collected about you. We store this information so that we have a better and more specific understanding of the way users are using our website, and their preferences and interests, for the purposes set out above.
Cookies may be either "persistent" cookies or "session" cookies, depending on how long they are used.
Persistent cookies remain on your device after you have closed your browser and allow a website to remember your actions and preferences. They are activated each time you visit the website where the cookie was generated. Sometimes persistent cookies are used by websites to provide targeted advertising based on the browsing history of the device. They are stored by the browser and remain valid until their set expiry date (unless deleted by the user before the expiry date).
Session cookies only last for the duration of your visit and are deleted when you close your browser. They facilitate tasks such as allowing a website to identify that a user of a particular device is navigating from page to page, supporting website security or basic functionality.
Many of the cookies we use are session cookies. For example, they help us to ensure the security of your session, and can also keep you signed in to your ClearScore account while you move between pages.
More about the cookies we use
This section describes more about the different types of cookies we use. The cookies are both cookies that we set (first party cookies) and cookies that are managed for us by third parties.
Whether a cookie is a first or third party cookie depends on which website the cookie comes from.
First party cookies are those set by or on behalf of the website visited. All other cookies are third party cookies.
Third party cookies: In some cases, some of these cookies are managed for us by third parties, but we don't allow the third party to use the cookies for any purpose other than those listed above.
Web analytics services
In order to keep our products and services easy to use and up-to-date, we also use web analytics services to help us understand how people use our website. For example, we can see which parts of our services are most popular, identify when errors occur and test different versions of a page or feature to see which one works best. These web analytics services may be designed and operated by other companies on our behalf. They do this using small invisible images known as "web beacons" or "tracking pixels" that may be included in the digital products and services on our website.
These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. We use retargeting and online behavioural advertising to market ClearScore which employs targeting cookies to deliver you more targeted advertising.
You can read more about the cookies we and our trusted service providers use below.
By using our website, you agree that we can place both first party and third party cookies and web analytic services on your device.
Specific cookies we use
Below is a full list of the cookies we use together with a description of what they are used for, and whether they are 'first' or 'third' party. Where a cookie is a third party cookie, please visit the providers' website for more information.
|Cookie Name or Type
|Session (30 minutes)
|This is a first party cookie allowing users to log into the site when changing page or returning to the site.
|Session (30 minutes)
|This is a first party cookie providing unique tracking for users and allowing tracking across services.
|Session (30 minutes)
|This is a first party cookie used to provide a better customer experience, track first time visitors and calculate marketing performance.
|Persistent (30 minutes)
|This is a first party cookie used to record user cookie preferences and stop displaying the banner.
|Persistent (1 year)
|This is a first party cookie used to identify returning users over a long period of time.
|Session (30 minutes)
|This is a first party cookie used to track for internal ab testing of products.
Third Party cookies
These are third party cookies used to track visitors, collect information about how visitors use our site and improve site performance. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the website from and the pages they visited.
Turning cookies off
In all modern browsers you may elect to reject cookies and/or enable do not track features, and we provide instructions on how to do this below. Please note however that by doing so parts of our website may no longer function as expected. For example, if you delete cookies any preferences they record will be lost. This includes for example where you have opted out from cookies, as this requires an opt-out cookie to be set.
If your concerns are based around third party cookies, then we recommend you just reject those cookies, rather than all cookies so that we can still provide you with the functionality you expect.
If you do wish to stop your browser from accepting cookies, see the following pages:
To learn more about cookies and how you can manage them in your web browser, visit: www.allaboutcookies.org.
If you have any questions about our cookies or this Cookies Policy, please contact us on email@example.com.