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New Zealand Privacy Policy

Last Updated: 21/10/2024


Privacy Policy

Effective from: 21 October 2024

ClearScore NZ Limited (NZCN 8713780) and its related and New Zealand associated bodies corporate (us, we, our) maintain a policy of strict confidence concerning your (you, your) personal information. This Privacy Policy and our Terms, explains how we collect, store, use and disclose information about you when you use or interact with our website, apps and services, and where we otherwise obtain or collect personal information about you.

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).

Please read this Privacy Policy carefully before using our website or apps or registering to use our services.

By accessing our website (at www.clearscore.com/nz) or apps you are accepting and consenting to the processing activities described in this Privacy Policy.

References to “website” in this Privacy Policy, include references to both our website and our apps.

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. For more information about cookies, please see our Cookies Notice.

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:

Title
Name
Income
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. All our registered customers benefit from our ClearScore Protect service, upon email verification. To provide you with this service, we share the email address and your passport number (if provided) connected with your ClearScore account with our Cybercheck Partners (see more here), who use this information to identify whether any of your information may have been compromised. The Cybercheck Partners will not use the information you’ve shared 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.
If you verify your email and activate the ClearScore Protect service to include dark web monitoring, we may also receive information about you such as:

Name
Addresses
Social profiles
Email addresses
Passport details
Phone numbers
Usernames
Date of birth
Education and professional history

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.

Personal information collected from cookies. We and our service providers collect information about your use of our website from cookies. For more on how we use cookies and how to decline them or turn them off please read our Cookies Notice.

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 will not process personal information that you make available to use and/or that we collect from other sources (as outlined above), other than as outlined in this Privacy Policy, without having a lawful basis to do so. 

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 privacy@clearscore.nz.

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:

Conduct analysis, profiling and segmentation

  • analyse our users' behaviour and preferences and usage of our services, 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 if you have consented to receive direct marketing

Conduct marketing on social media and other platforms

  • share information about your visits to our sites and app, and/or your email address (in a hashed or other masked format)  with our advertising partners, including social media networks like TikTok and Meta/Facebook, for interest-based advertising or targeted advertising campaigns. That will help us manage and deliver our marketing, including by:
      • excluding you from seeing targeted adverts if you have opted out of ClearScore marketing
      • creating audiences for our advertisements to social media network users who may be similar to you based on the data that the social media network holds about you
      • including you in audiences to receive marketing when you’re on a social media network

You can opt out of the above data processing activities at any time by adjusting your cookies settings (see out Cookies Notice for more details) or your ClearScore account settings.

Personalise your experience 

  • display general information on products or services that may be of interest
  • 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)

To improve and deliver our services

  • 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

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.

Comply with legal obligations. We may process your personal information to 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

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 or passport

(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)

Product providers. Product providers will have their own privacy policies that will explain how your personal information will be collected and handled by them. We do not accept any responsibility or liability for their use of your personal information, and we suggest you review that website’s privacy policy before you provide access to your personal information.

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 and advertising networks that require data, to perform services on our behalf, including selecting and serving relevant adverts, to you and others and to make sure these adverts reach their intended audience. For example, we may share your personal information with:
      • advertising partners for interest-based advertising or “targeted” advertising campaigns. You may see certain “interest-based advertising” or “targeted advertising” on other websites or online services based on information relating to your access to and use of our Services and other websites;
      • advertising partners that help analyse our site, run contests, special offers, or other events or activities, and track metrics on our behalf or in connection with our Services; and
      • third party service providers to deliver ClearScore advertisements on third party websites that may be tailored to your individual interests. These interest-based advertising platforms may also use personal information about you that they have independently collected in accordance with their privacy policy and practices, including through the use of cookies;

  • analytics and search engine providers that assist us in the improvement and optimisation of our service
  • external affiliate network partners (for example, lending partners), with whom we share the fact that you have clicked on a sponsored link from our website or app. We use a unique ClearScore URL or “hyperlink,” and will not share any personal identifiers or personal information with our external affiliate partners. However, our external affiliate network partners may track you through their website, including connecting our unique ClearScore hyperlink with you in order to calculate a potential commission to ClearScore in accordance with their own privacy policies and practicesif 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 assetsif 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. You authorise the credit reporting agencies to hold, use and disclose any information about you that we provide to the credit reporting agencies on your behalf, for the purpose of providing their credit reporting and debt collection services (including to other customers). Further information about how the credit reporting agencies handle your personal information can be found at www.illion.co.nz.

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. We have partnered with web monitoring services to provide you with our ClearScore Protect service, which helps you to identify whether or not information associated with your email account or passport 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 on a monthly basis, alongside your passport number, if you have chosen to provide this. These providers will then check their databases to identify whether there are any recorded instances of your account details having been compromised. Your email address and passport number are processed solely on our instructions and will not be used by our partners for any other purpose, including marketing. We will notify you of the results of the dark web monitoring check in the manner set out in our Terms. For more details about our ClearScore Protect service, please refer to our Terms here. We would not use the results of these dark web monitoring checks 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 privacy@clearscore.nz.

Overseas transfers

We utilise the services of third party processors (or sub-processors, as applicable) in various countries (including New Zealand, Australia, United Kingdom and India) who may access your personal information for the matters specified under the heading “Who we share your information with” above. Consequently, we may transfer personal information to persons or entities located in these countries. Although we will endeavour to ensure that personal information is treated securely and in accordance with this Privacy Policy as well as applicable privacy laws, we advise that some of these countries may not have an equivalent level of privacy laws as those in New Zealand.

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.

If you follow a link to or from our website to a third party website, please be aware that these websites have their own privacy policies that will govern their use of your personal information. We do not accept any responsibility or liability for their use of your personal information, and we suggest you review that website’s privacy policy before you provide access to your personal information.

 

Your rights

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 privacy@clearscore.nz. 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).

Changes we make to our Privacy Policy

We may vary the terms of this Privacy Policy at any time.

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where we decide it is appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.

Contacting us and complaints

You can address any questions, comments, complaints or requests regarding this Privacy Policy to our Privacy Officer at privacy@clearscore.nz.

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/.

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