Crown Financial Services Limited (we, us, our) is an institution offering financial services. We comply with the New Zealand Privacy Act 1993 and the Australian Privacy Act 1988 and the Privacy Principles of each Privacy Act (collectively, Privacy Laws), when dealing with personal information.
This policy sets out how we collect, use, disclose and protect your personal information and does not limit or exclude any of your rights under Privacy Laws. Further information on Privacy Laws can also be accessed via www.privacy.org.nz or www.oaic.qov.au
By using our websites, applications and services, or otherwise providing us with your personal information, you consent to us collecting, holding, using and disclosing your personal information as set out in this Policy.
What does Personal Information mean?
Personal Information is any information about an identifiable individual (a natural person) whose identity can be reasonably determined. (You and your) refers to the person accessing or using our website.
Updates to this Policy
This Policy may be reviewed from time to time to reflect news laws, changes to our operations and any change in our business environment. The changes will apply from the date that we upload the revised policy.
We may use your personal information for the following purposes
The personal information you provide to us (whether on our website or in an application form for Crown or elsewhere) will be collected and held by Crown Financial Services Limited or any of its subsidiaries or related entities (together, the Crown Group), and any of the Crown Group’s employees, contractors, advisers, and agents including Crown Private Limited, Make-It Fund Operating Manager L.P., Clearing House Limited and Cybercom Hospitality Solutions Limited, for the following purposes (as applicable):
· processing and responding to your queries
· providing you with information by us
· providing you with our services, as requested by you
· making a decision to provide you with our services or provide you with information about the services we provide
· including evaluating your credit worthiness
· verifying your identity, and carrying out credit and other checks, for the purpose of registering you as a Borrower
· managing the products and services we provide, preventing and defending instances of fraud, unlawful conduct, and other risks to our products and services Internal and external dispute resolution
· enforcing our rights including debt collection, where necessary instituting legal action, and assigning debts to third parties
· undertaking securitisation activities and other activities relating to funding and capital requirements
· providing your personal information when requested by our Funders
· enabling our associated entities and other selected entities to promote their products and services to you
· ensuring that we comply with relevant legislation and regulations in providing any services to you or providing you with access to any services that we provide
· any specific purpose which we notify you of at the time personal information is collected
· marketing products and services provided by us, our related entities and third parties we have dealings with compiling statistical data for example credit scoring information
· we (and our third party service providers) may use, sell, licence, distribute and disclose data which we develop from personal information, provided that such data has been stripped of all personally identifiable information
· to understand our users’ preferences and interests, for internal research, development, and optimisation of our website and the services we provide and targeting our advertising or marketing and letting you know about new features and services we offer
· compliance with any laws, rules and regulations whether in New Zealand, Australia or in any other country that make it mandatory for us to collect your personal information which is necessary for us to comply with our Privacy obligations
· evaluation and improvement to our client service
To whom do we disclose your personal information (including your identity) to third parties
Your personal information may be disclosed to, and held and used by, the following entities:
· carrying out credit and identity checks
· borrowers / co-borrowers: if you have registered and/or provided your personal information relation to or on behalf of a borrower or co-borrower, each of you agree and consent to the Crown Group providing your personal information to the other of you. The Crown Group will be entitled to accept instructions from either of you (unless requested otherwise) to the access to, use of or amendment to your personal information by the Crown Group
· Crown Financial Services Limited or any of its subsidiaries or related entities (together, the Crown Group), and any of the Crown Group’s employees, contractors, advisers, and agents.
· Other bodies such as government agencies, regulators, and legal and professional advisers.
· Any other person or entity where it is relevant to do so for the purposes set out above.
We can also disclose personal information to third parties as instructed by you and in other ways permitted by the Privacy Laws and Principles.
Your personal information may also be used by, and you consent to the use of your personal information by, any Crown Group member to keep you informed about other financial opportunities, products and services of any Crown Group member, including by email, by text message, by Crown Group’s online portals (if any) or by any other electronic means. Any electronic communication offering other financial opportunities, products or services will include an unsubscribe facility.
How do we collect personal information?
We collect most personal information directly from you. Sometimes we may (and you authorise us to) collect personal information about you from other people. We may also collect information about you from publicly available sources of information.
Cookies and similar technologies
We may share information collected through cookies (or similar technologies) with third parties (who may also use that information for ad targeting and the other purposes described above).
Opting out of cookies
You can prevent new cookies from being installed and delete existing cookies. The procedure depends on which browser you are using. For information on how to remove cookies, check your internet browser. You may be unable to make full use of our website or its integration with Facebook unless you accept cookies.
How do we hold personal information?
We will take all reasonable steps to keep your personal information safe from loss, unauthorised activity or other misuse.
Data security around your personal information
We take reasonable steps to preserve the security of personal information we collect and the personal information is kept safe and secure using generally accepted standards of security. Only authorised employees, contractors, advisers and agents (who have agreed to keep information secure and confidential) have access to this information. All stored client information is protected from unauthorised access through the use of secure passwords and user logons or other security procedures.
Ensuring your personal information is up-to-date and accessing your personal information
We rely on the personal information we hold about you to efficiently conduct our business of providing financial products and services so use all reasonable endeavours to ensure that the personal information is accurate, complete and up-to-date. So we encourage you to contact us to correct any personal information we hold about you.
You have the right to correct any personal information we hold about you in accordance with Privacy Act laws and Principles. However, this is subject to exceptions set out in Privacy Act laws and Principles and this can be done by contacting us by email firstname.lastname@example.org or phone +64 9 973 5888.
As some of the information we hold about you may be of a sensitive nature, we will need to verify your identity or anyone requesting access to your sensitive personal information. Any request for information must be as specific as possible so we can accommodate your request. You may be charged a fee for providing access. If a fee is to be charged, we will inform you of the likely cost in advance.
What happens if personal information is not provided?
If you do not provide us with all the personal information we have requested from you, we may not be able to complete registration as a Borrower, and we may be unable to approve your application for a loan, or to provide you with any of the services or information you are seeking from us.
What do you need to do if you have a complaint?
If you have any questions about privacy related issues or wish to complain about the handling of your personal information by us, please contact us using the contact details below. We may ask you to lodge your complaint.
Your complaint will be investigated by our Managing Partner or someone from our Senior Management Team and you will be notified of the decision relating to your complaint as soon as practicable after it is made, usually within 30 working days.
If you are unable to satisfactorily resolve your concerns about our handling of your personal information, you can either contact us or you can contact the Office of the Privacy Commisioner via www.privacy.org.nz or the Australian Privacy Commissioner via www.oaic.qov.au .
If calling from Australia or New Zealand: +64 9 973 5888 or by email email@example.com
Application of European privacy laws
If you are an individual in a country in the European Economic Area (EEA), we may be required to comply with the EU General Data Protection Regulation 2016/679 (the GDPR) which applies to us when processing the personal information of individuals (Data Subjects) who are in countries in the EEA in relation to offering you our products or services or if we monitor any of your behaviour when in those countries. This includes additional information we are required to tell you about in relation to your privacy, including the basis on which we collect your personal information and your data subject rights under the GDPR.