Privacy Policy

Introduction

HCL Finance Limited (we, us, our) is committed to protecting the privacy of all of our customers.

We collect and store personal information about you to allow us to provide you with our services. Our collection of personal information is subject to the New Zealand Privacy Act 2020 (Act). This privacy policy (Policy) outlines how we collect, use, disclose and protect your personal information in accordance with our obligations under the Act.

Nothing in this Policy alters your rights under the Act. If you would like to learn more about these rights,
please visit www.privacy.org.nz

Changes To This Policy

Please note that we may make changes to this Policy at any time by providing you with an updated version via email.

This policy was last updated on 9th July 2021.

Your Consent To Our Collection Of Your Personal Information

By engaging us you consent to your personal information being collected, held and used in accordance with this Policy or for any other use that you authorise.

This includes the collection of your:
a. Name.
b. Date of birth.
c. Identity documents (Such as your passport, drivers licence, or other government issued identity
document).
d. Address.
e. Email address.
f. Telephone and/or mobile number.
g. IRD number.
h. Employment information.
i. Credit history, statement of financial position and other financial details.

Where you engage us on behalf of a company, trust or partnership, we may also request the above personal information of any owner or controlling entity of your organisation or of anyone who has authority to act on your organisation’s behalf.

You are free to choose not to give us any or all of your personal information. However, please be aware that this may mean that we are unable to provide some or all of our services to you.

Why We Collect Your Personal Information

We collect personal information from you for the following purposes (Purposes):
a. To verify your identity.
b. To provide our services to you and to improve the services we provide.
c. To communicate with you (including for marketing purposes where you have authorised us to do so) and to respond to communications from you.
d. To undertake credit checks of you.
e. To investigate any suspected unlawful activity or to address security concerns.
f. To bill you and to collect money that you owe us.
g. To conduct research and undertake statistical analysis (on an anonymised basis where possible).
h. To protect and/or enforce our legal rights and interests, including defending any claim.
i. For any other purposes authorised by you, the Act, or any other legislation.

In some scenarios we may be required by law to collect your personal information, including under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 and the Land Transfer Act 2017. Should we be required by law to collect any information about you we will explain what information is required and why we are required to collect it (where possible).

We only collect your personal information for the purposes outlined in this section. If we are to use your personal information for any purpose other than any outlined in this section, we will first obtain your consent.

How We Collect Your Personal Information

We may collect your personal information from:
a. You, when you provide that information to us, whether that be via the use of our Website or when you otherwise voluntarily provide us with information that is relevant to the Purposes of this Policy.
b. Third parties including, co-borrowers, guarantors, your agents or authorised signatories, your employer, your parents (if you are under 18), credit agencies or brokers and other third parties that are interacting with us on your behalf.
c. Other third parties where you have authorised that your information be shared with us.
d. Other sources where the information is publicly available.

Who We May Disclose Your Personal Information To

We may disclose your personal information to:
a. Any business that supports our services and products, including any person that hosts or maintains any underlying IT system or data centre that we use, including any fraud detection partners, marketing and advertising partners, and customer support partners.
b. Banks and financial institutions
c. Credit agencies and debt recovery agencies.
d. Any potential assignee or sub mortgagee of your loan facility.
e. Our external accountants and auditors.
f. Any credit reference agency.
g. Any reputable third party that we have a business relationship with, including marketing companies and other third parties that process anonymised statistical information.
h. A person who can require us to supply your personal information (such as any regulatory or government authority, including the Inland Revenue Department, the Financial Markets Authority, and the New Zealand Police).
i. Any other person authorised by you.

We may also disclose your personal information to any entity that we enter into any joint venture with or any other business that we are sold to or merged with.

We will only disclose personal information to the parties listed above if it is necessary and appropriate to facilitate the Purposes for which your personal information was collected pursuant to this Policy.

Direct Marketing

Where you have given consent to do so, we will use your personal information to directly market our services to you.

We may carry out this direct marketing by online advertising, email, phone, or post.

You have the right to revoke your consent to receive direct marketing at any time by contacting us.

How Long We Will Store Your Personal Information

We will hold your personal information for as long as it is required to provide you with our services.

You may request that we delete your personal information as outlined in clause 12.

How We Protect Your Personal Information

We take all reasonable steps to keep your personal information safe from loss, unauthorised activity or other misuse. These steps include:

a. Adopting and regularly reviewing the performance and terms of our internal data security policies and systems to ensure that they are fit for purpose and protect your personal information from unlawful processing, accidental loss, destruction and damage.
b. Adopting technologies for our internal use that meet the standards required by the Act.
c. Verifying the suitability of security systems in place with third parties that we work with to ensure that they meet the standards required by the Act.

In some cases, the personal information that we collect from you may be processed outside of New Zealand. Where this is the case, these third parties are also obliged to comply with the Act when dealing with your personal information. We make all reasonable endeavours to ensure that all entities that we work with outside of New Zealand offer satisfactory protection for your personal information. If you wish for your personal information to not be disclosed outside of New Zealand, please let us know, however, this may mean that you may be unable to use any or all of our services.

Notification In Event Of A Security Breach

We will advise you at the first reasonable opportunity upon discovering or being advised of any security breach in which your personal information is lost, stolen, accessed, used, disclosed, copied, modified or disposed of by any unauthorised person or in any unauthorised manner.

Should such a breach occur we are committed to taking all reasonable steps to remediate the issue that gave rise to the security breach to prevent subsequent security breaches.

Your Rights To Access, Correction And Deletion Of Your Personal Information

Under the Act, you have the following rights:

a. The right to be informed about how your data is being used. If you would like further information beyond that provided in this Policy, please contact us.
b. The right to access readily retrievable personal information held by us about you. This right is subject to certain grounds for our refusal as outlined in the Act.
c. The right to request corrections to the personal information that we hold about you. Should you request a correction, we will make the correction should the correction be reasonable and we are reasonably able to make it. If we are unable to, we will take reasonable steps to note the requested correction in our records against your data.

If you would like to exercise the above rights, please email us. Please clearly state what information you are requesting, provide evidence of your identity, and notify us of anything else you deem relevant to your request.

Customers Outside Of New Zealand

The information we collect may be processed in and transferred between your location and New Zealand. New Zealand may not have equivalent data protection laws to those in force in your location.

How You Can Contact Us About Privacy Matters

If you have any queries or requests concerning this Policy, please contact us at admin@hclfinance.co.nz