Privacy:

The Service is an online financial literacy platform provided by Spring. In order to provide the Service, Spring may collect some personal information about you. Personal information is information that can be used to personally identify you, such as your name, address, telephone number and email address.

 

Privacy Protected

Where you provide personal information to us, we will comply with the New Zealand Privacy Act 2020 and other applicable privacy laws and data protection laws (if applicable). This document is our privacy policy and it tells you how we collect and manage your personal information.

 

Personal information is information about an identifiable individual (a natural person) and includes personal data, personally identifiable information and equivalent information under applicable privacy and data protection laws.

 

This policy does not limit or exclude any of your rights under Privacy Laws. For further information on the New Zealand Privacy Act 2020, see www.privacy.org.nz. 

 

This policy was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal information. We are happy to provide any additional information or explanation needed. Any request for further information should be sent to info@spring.kiwi.

 

Definitions

In this privacy policy:

 

Organisation means a company, business or other legal entity that facilitates the use of the Service and invites users to use the Service

 

User Data means any Content, materials or other information that you post to the Service or provide to us or in connection with accessing the Service

 

User Submissions means User Data that is intended to be visible to other users

 

and any further capitalised terms used in this policy have the meanings given to them in Spring’s Terms of Use.

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Kinds of personal information we collect:

We may collect the following types of personal information:

 

• any additional information relating to you that you provide to us directly or indirectly through use of our Website or the Services, through our representatives or otherwise; and

• information you provide to us through our customer surveys or our representatives from time to time.

 

We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use our Website or Services.

 

We may collect the following information from the following types of users:

Employer / business representative

• If you are an employer or a representative of your business: Full name, title, email address, organisation’s name. We may also collect additional information generated by your use of the Services, including the state of learning modules and your user preferences;

 

Users (employees)

• We may collect your full name, email and location. We may also collect personal information generated by your use of the Services, such as transactional information, test results from quizzes, surveys and your behaviour while using the Service;

• We may also collect certain optional demographic information from you, including your gender, ethnicity, information about your income and employment status and information about your family’s financial status (“Demographic Information”). Your responses to these demographic questions are always optional and you may choose not to respond. Not responding to these questions will not impact our provision of the Service to you. 

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Collection of personal information:

We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect in ways including:

• through your access and use of our Website, including when you fill in a contact or enquiry form or sign up to our newsletter or other electronic alerts;

• during conversations between you and our representatives; or

• when you use the Services, including when you create an account, respond to surveys or quizzes and post User Submissions.

 

We may also collect personal information from third parties including:

• If you are an employee: from your employer or business representative; and

• If you are a business representative: from your employer; and.

 

What happens if we can’t collect your personal information?

If you do not provide us with the personal information described above, some or all of the following may happen:

• we may not be able to provide the Services to you (either to the same standard or at all);

• we may not be able to provide you with information about Services that you may want; or

• we may be unable to tailor the content of our Website or Services to your preferences and your experience using these may not be as enjoyable or useful.

• Your response to a survey collecting demographic information such as your ethnicity, age, or any personal questions about you or your family’s financial situation is always optional and will not impact the quality of the Services or experience with the Website.

 

Use of personal information:

We collect personal information about you so that we can perform our business activities and functions (such as providing you with the Services) and to provide the best quality of customer service.

 

The personal information provided by you to us is collected, and may be used, for:

• providing or improving the Service (including processing or responding to any request or complaint made by you);

• monitoring Website usage and compliance with any contracts you have entered into with us;

• carrying out internal research and development;

• providing information to you about additional products or services that may be of interest to you (including direct marketing);

• if you are an Organisation: providing billing details (names and email addresses) of users accessing the Service under that plan to Spring’s sponsorship partner, for auditing purposes only; or

• compliance with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in cooperation with any governmental authority of any country.

• for any other purpose authorised by you or applicable law

 

In addition to any circumstances allowing us to use or disclose personal information under the Privacy Laws, we may use or disclose your personal information where reasonably necessary to investigate any complaint or to protect your, our or another person’s rights or safety.

 

You can stop receiving our marketing emails by following the unsubscribe instructions included in those emails or contacting us at info@spring.kiwi

 

Disclosure of personal information:

We may disclose your information to:

• our employees, related bodies corporate, contractors or service providers for the purposes of operating of our Website, our business or the Services, fulfilling requests by you, and to otherwise provide the Services to you including, without limitation, web hosting providers, IT system administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators and professional advisors (such as accountants, solicitors, business advisors and consultants);

• suppliers and other third parties with whom we have commercial relationships (such as our sponsorship partners) for internal business audits. Aggregate and anonymised data may also be provided for marketing campaigns and related purposes; and

• person who can require us to supply your personal information (e.g. a law enforcement agency or regulatory authority) or authorised by applicable law; and

• any other person for any authorised purpose with your express consent.

 

Collection and use of aggregate personal information:

You agree that we may retain and aggregate personal information, including your User Data and User Submissions, for marketing purposes and may provide aggregate personal information to third parties, provided that such use does not enable the identification of any individual, i.e. is anonymised. If you are acting on behalf of someone else as an agent for the purposes of the Privacy Laws, you agree to ensure that you collect, use, hold and process any personal Information in accordance with your obligations under the Privacy Laws.

 

Protecting your personal information:

As required by applicable law, we will take steps to keep your personal information safe from loss, unauthorised activity, or other misuse. We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks inherent in processing personal information.

 

You play an important role in keeping your personal information secure by maintaining the confidentiality of any password and accounts used in relation to our products and services. You should not disclose your password to third parties.

 

If you become aware or suspect that any unauthorised person has obtained, or attempted to obtain, access to personal information or has used or attempted to use personal information for purposes not authorised or permitted by our Terms of Use or this privacy policy:

• you must immediately notify us; and

• we may at our discretion take such steps as are reasonably available to us to identify that unauthorised person and to prevent that access. To avoid doubt, where the unauthorised access or use is by, or is caused by a breach of the Terms of Use or any part of this privacy policy, the relevant unauthorised or breaching person must pay us reasonable costs related to taking such steps.

 

Cookies:

We may store personal information through the use of cookies. Cookies are alphanumeric identifiers that the Website transfers to your computer’s hard drive to enable our systems to recognise your browser.

 

For visitors to our Website that have not created an account with us, we may use cookies to track the user as they navigate the Website and to improve the Website’s usability. These cookies do not collect any personal information about the user.

 

If you set up an account with us, we may use cookies to manage the signup process, to remember who you are while you are using the Service, to track your use of the Service and to improve the Service’s usability. These cookies will usually be deleted when you log out of the Service, however in some cases they may remain after you have logged out to enhance the experience when you return to the Service at a later date.

 

From time to time we may test new features and make subtle changes to the way the Service is presented. When we are testing new features, cookies may be used to ensure that you receive a consistent experience while using the Service, whilst also ensuring we understand which changes our users appreciate the most.

 

We also use cookies provided by Google Analytics to track things such as how long you spend on the Service and the pages that you visit. For more information on Google Analytics cookies, see the official Google Analytics page.

 

You can prevent the use of cookies by adjusting the settings on your browser (see your browser help for how to do this). Be aware that disabling cookies will affect, or may disable, some or all of the functionality and features of the Service.

 

Personal information:

To the extent that we collect, hold or process any personal information contained in your personal information in the course of providing the Service to you, you acknowledge that we act as your agent for the purposes of the Privacy Laws. You must obtain all necessary consents to enable us to collect, use, hold and process that information in accordance with this privacy policy and our terms of use.

 

Accessing or updating your personal information:

You have the right to access and request correction of any personal information that we hold about you, subject to certain exceptions (for example, where disclosure would interfere with the privacy of others or breach confidentiality). If you believe any information we hold about you is incorrect, incomplete or inaccurate, then you may request that it be amended. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.

 

Where we hold information that you are entitled to access, we will try to provide you with a suitable means of accessing it (for example, by emailing it to you).

 

Please contact info@spring.kiwi if you would like to request access to or update your personal information. Your email should provide evidence of who you are and the details of your request (e.g. the personal information to be corrected and the correction that you are requesting).

 

Subject to applicable law, 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 post a User Submission, you acknowledge and agree that the information you post is publicly available.

 

If you follow a link on our website to another website, the owner of that website will have its own privacy policy relating to your personal information. We suggest you review that website’s privacy policy before you provide personal information to that owner or website.

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Data retention policy:

The personal information that we collect and use will not be kept longer than necessary for the purposes for which it is collected, or for the duration required for compliance with applicable law, whichever is longer.

 

Complaints:

Under the Privacy Act 2020, if Spring experiences a data breach that is likely to cause anyone serious harm (e.g. leaked personal information used in identity theft or published online), we will inform all affected parties as soon as practically able. We will also be notifying the Office of the Privacy Commissioner.

 

If you believe that your privacy has been breached, please contact us on info@spring.kiwi and provide details of the incident so that we can investigate it.

 

Please make this request in writing. We will attempt to confirm with you as appropriate and necessary your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will inform you whether we will conduct an investigation and who will handle the investigation process.

 

After we have completed our investigation, we will contact you to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view.

 

Contact us:

If you have any questions about this privacy policy, please use the contact link on our Website or contact us using the details set out below.

 

Please contact us at: info@spring.kiwi

 

Changes to our privacy policy:

We may change this policy from time to time. Any updated versions of this privacy policy will be posted on our Website. Please review it regularly. The change will apply from the date that we upload the revised privacy policy.

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This privacy policy was last updated on 14 September 2021