Introduction

Investor Mandate Ltd, trading as finappster, (we, us, our) complies with the New Zealand Privacy Act 1993 (the Act) when dealing with personal information. Personal information is information about an identifiable individual (a natural person).

This policy sets out how we will collect, use, disclose and protect your personal information.

This policy does not limit or exclude any of your rights under the Act. Please refer to see privacy.org.nz if you wish to seek further information on the Act.

Changes

We may change this policy by uploading a revised policy onto our website. The change will apply from the date that we upload the revised policy.

Who do we collect your personal information from

We collect personal information about you from:
▲ you, when you provide that personal information to us, including via the website and any related service, through any registration or subscription process, through any contact with us (e.g. phone call or email), or when you buy or use our services and products, and
▲ third parties where you have authorised this or the information is publicly available.

If possible, we will collect personal information from you directly.

How we use your personal information

You are not required to provide personal information to us, although in some cases if you choose not to do so then:
▲ we will be unable to make certain features of finappster available to you. For example, we may need to have your contact information in order to provide you with updates from finappster, and
▲ the data returned to you may not reflect the accuracy you are looking for. For example, if you do not include your tax rate, this will not be included in your returns calculations.

When you provide personal information to us, we will comply with the New Zealand Privacy Act 1993.

The personal information you provide to us (including any information provided if you register for an account) is collected and may be used for:
▲ verifying your identity
▲ providing products and services to you
▲ responding to communications from you, including a complaint
▲ communicating with you via alerts that:

‒ may be turned on by default. They may then be customised, deactivated or reactivated by you. These alerts allow you to choose alert messages for your accounts. finappster may add new alerts from time to time, or cease to provide certain alerts at any time upon its sole discretion. Each alert has different options available, and you may be asked to select from among these options upon activation of your alerts service;

‒ may be delayed or prevented by a variety of factors. We will make commercially reasonable efforts to provide alerts in a timely manner with accurate information, but cannot guarantee the delivery, timeliness, or accuracy of the content of any alert. finappster shall not be liable for any delays, failure to deliver, or misdirected delivery of any alert; for any errors in the content of an alert; or for any actions taken or not taken by you or any third party in reliance on an alert;

‒ will be sent to the email address you have provided. If your email address changes, you are responsible for informing us of that change. Changes to your email address will apply to all of your alerts; and

‒ are not encrypted, so will never include your passcode. However, alerts may include your Login ID and some information about your investments. Anyone with access to your email will be able to view the content of these alerts. At any time you may disable future alerts.

▲ billing you and to collect money that you owe us, including authorising and processing credit card transactions
▲ anonymous statistical analysis
▲ marketing by us of products and services to you 
▲ research and development (to improve the products and services we provide to you)
▲ to protect and/or enforce our legal rights and interests, including defending any claim, and/or
▲ for any other purpose authorised by you or the Act.

We may also collect technical information whenever you log on to, or visit the public version of, finappster. This may include information about the way users arrive at, browse through and interact with finappster. We may collect this type of technical information through the use of cookies and other means. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive to enable our systems to recognise your browser. If you want to disable cookies, you may do so by changing the settings on your browser. However, if you do so, you may not be able to use all of the functions on finappster. We use the technical information we collect to have a better understanding of the way people use finappster, to improve the way it works and to personalise it to be more relevant and useful to your particular needs. We may also use this information to assist in making any advertising we display on finappster more personalised and applicable to your interests.

finappter uses Google AdWords remarketing to advertise finappster across the internet. Google AdWords remarketing will display relevant ads tailored to you based on what parts of finappster you have viewed by placing a cookie on your device. The cookie is used to say “This person visited this page, so show them ads relating to that page.” Google AdWords remarketing allows us to tailor our marketing to better suit your needs and only display ads that are relevant to you.

Disclosing your personal information

Generally, we do not disclose personal information to third parties for them to use for their own purposes. However, you give finappster permission to disclose your data in certain circumstances, and to combine your and other users’ non-identifiable, aggregated data. Some of the circumstances in which we may disclose your data or combine aggregated data are:
▲ to provide such data to any business that supports our services and products, including any person that hosts or maintains any underlying IT system or data centre, both in New Zealand and overseas, that we use to provide the website or other services and products 
▲ to improve or develop finappster’s functionality
▲ to design promotions
▲ to present news, general tips or educational material
▲ to present third party products or services that you may be interested in
▲ to other third parties (as anonymised statistical information)
▲ in relation to the proposed purchase or acquisition of our business or assets, and/or
▲ where required by applicable law or any court, or in response to a legitimate request by a law enforcement agency. 

Protecting your personal information

We will take reasonable steps to keep your personal information safe from loss, unauthorised activity, or other misuse.

Any personal information you provide to us may be stored on the secure servers of our trusted service providers, which may be located outside New Zealand. This may involve the transfer of your personal information to countries which have less legal protection for personal information than New Zealand. We will ensure information submitted on the login and signup pages is transferred between you and our servers using HTTPS encryption or similar.

Accessing and correcting your personal information

Subject to certain grounds for refusal set out in the Act, you have the right to access your readily retrievable personal information that we hold and to request a correction to your personal information. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.

In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the personal information, we will make the correction. If we do not make the correction, we will take reasonable steps to note on the personal information that you requested the correction.

Email info@finappster.co.nz if you want to exercise either of the above rights. Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information, or the correction, that you are requesting).

We may charge you our reasonable costs of providing to you copies of your personal information or correcting that information.

Internet use

While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet the provision of that information is at your own risk.If you follow a link on our website to another site, the owner of that site will have its own privacy policy relating to your personal information. We suggest you review that site’s privacy policy before you provide personal information.