SquareOne - Privacy Policy

‍1_WHO WE ARE
Emerge Group Limited - trading as SquareOne - is a registered financial services provider. Our registered address is Level 8, 60 Airedale st, Auckland, New Zealand.

2_DEFINITIONS
In this document:

‘SquareOne’, ‘we’, ‘us’ or ‘our’ means Emerge Group Limited, a New Zealand registered company (company number 8060798 with NZBN 9429048472920) and registered on the Financial Services Provider Register (FSP1000546).

‘Our related companies’ means companies who are part of the same group.

‘You’ and ‘your’ means our members (parents / caregivers and children / young people). If you give us information about another person, please ensure you have their permission first. ‘You’ and ‘your’ includes the person:

whose name was used to set up the account
that uses our products and services
who gives us personal information

‘Privacy Act’ means the Privacy Act 2020 and any laws that change or replace it.

3_HOW OUR PRIVACY POLICY WORKS
At SquareOne, we value your trust and respect your privacy. We’ll use examples below to illustrate some points – please just remember that these will be common examples, but don’t cover every possible situation. This privacy policy applies to all our products and services (even the ones you can use without paying) and all your interactions with us. That means using our apps and website, phone calls with us, in-app chat, SMS… Basically everything.

4_OVERVIEW (OR THE TL:DR)
This privacy policy sets out how we collect, use, share and protect your personal information. Personal information includes any information that could identify you, for example:

your name, and personal details like your address or phone number
recordings of our phone conversations and help chats
information we collect when you use our website, social media, and apps

Personal information is needed so we can operate SquareOne. We use it when we:

Imagine, build (and deliver you) the epic products and services that you love
recommend things we think will make your life better
comply with the law, and our duties as a financial services business
We only use information if we’re allowed to - or if the law requires us to. Whenever we work with personal information, we comply with New Zealand laws, including the Privacy Act, and laws of other countries that apply to us. We’re allowed to use personal information when:
you agree to let us use it
we fulfil a contract, and to give you the products / services you’ve asked for
we run and develop our businesses
we meet our legal obligations

You have rights to access your personal information. We respect the trust you give us to hold your personal information because we know that your information - and your privacy - are important. For more information on your rights, including how to make a request to access or correct your personal information, see point 10.

Get in touch if you have any questions (or problems). We’re completely open and straightforward about how we work with personal information.

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5_Using 'Sendit' to send and receive money with other SquareOne customers

To make money transfers fast, simple and transparent, we built ‘Sendit.’ This feature in SquareOne will sync your mobile phone contacts. This means that when you use Sendit you can instantly identify which of your ‘trusted phone contacts’ are also SquareOne customers.

Likewise, other SquareOne customers that have you saved as a ‘trusted phone contact’ will also be able to see if you’re a SquareOne customer, when they use Sendit.

We use technological safeguards to ensure a ‘trusted phone contact’ is somebody you already know.

We only show basic details about you in the SquareOne app to other SquareOne customers. If they have you saved as a ‘trusted phone contact’ they’ll see:
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The mobile number, as created by them, in their phone contacts list
The name, as created by them, in their phone contacts list
Your SquareOne profile image (if you have one - as uploaded by you in your SquareOne profile)
If you haven’t set a profile image, they’ll see an initial (or initials) as per the name they saved

If you prefer, you can choose not to sync your contacts list with SquareOne. You’ll be offered this option in Sendit. If you choose not to sync your contacts, this will mean that you won’t be able to identify which of your ‘trusted phone contacts’ are SquareOne customers. Other SquareOne customers (who have your number saved as a ‘trusted phone contact’) aren’t affected by this - they’ll still see the same, as outlined in the 4 points above.

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6_OTHER POLICIES
We also have a cookies policy. That’s available in the footer, over at getsquareone.app.

7_HOW WE’LL TELL YOU IF THIS PRIVACY POLICY CHANGES
We might change this privacy policy to reflect changes in our products and services, and changes in laws we have to comply with. We’ll tell you about those changes at least 14 days before they happen. If we have to make changes to protect the security of your information, or to comply with a change in the law, we can tell you after we’ve made the change. Our website will always have the current version of this privacy policy. Depending on how significant the changes are, we’ll tell you about changes either through a notice on our site, an email, or through our apps.

8_HOW WE COLLECT PERSONAL INFORMATION
We collect information when you interact with us, and from third parties. When you apply for SquareOne, we collect information to help confirm your identity:

Personal and contact details, signatures
Your interactions with us

When you’re a member, or use SquareOne, we collect the following information.

Payment and transaction data including the amount, date, time, type, location, origin and recipients.
Any audio recordings we make when you interact with us
Your views on SquareOne and how we’re doing, or information that might help us better understand this.
Information you give us to confirm or update our records.

We collect personal information when you use our websites, apps, and social media profiles. This information could include your social media handles, IP address and location data from your devices. Sometimes our apps and websites have links to third-party apps and websites. We take care when we choose websites we link to, but we aren’t responsible for their content, accuracy, or privacy practices.

You can choose not to give us some of your personal information. However, if you don’t, we might not be able to:

offer you the products, services or help that you want
confirm your identity
protect you against fraud
manage your products or services
respond to, or help out with your questions

9_HOW WE USE PERSONAL INFORMATION
We use your personal information when you apply, when you’re a member, and when you use SquareOne. We also use this information to manage our business efficiently, and imagine + build new products for you to enjoy.

We’ll use your personal information to confirm your identity, process your application, and tell you if we can or can’t offer you SquareOne. We may also use the information to confirm you can act on behalf of another customer.

When you apply for SquareOne, we have to decide if it’s right for you. We’ll use your personal information to decide if you meet the conditions we set for SquareOne and any legal requirements too.

When you use our products and services, including the free ones, we’ll use your personal information to communicate with you about those products and services. We’ll keep a record of how we can contact you – for example, by email, phone, or text.

We use personal information to do the things you expect us to do when you sign up for a product or service. This includes:

managing our day-to-day business and keeping business records
making and managing payments
providing you statements
working with other companies to deliver or improve SquareOne

We may also use your information to decide when to:

suggest better ways to use SquareOne, or tell you about new features
tell you about something we think will meet your needs
inform you when your account requires attention or action.

We may also use your information to do things that are out of the everyday, like help:

keep people safe – for example, by helping the police get in touch with people if they need to
track payments and transactions

We use your personal information to decide what marketing information to send you. We also use it while working with our advertising partners to decide where to place adverts on websites and social media. Marketing messages we send you may include news about products or services we believe will be relevant to you. If you ask us not to send you email marketing materials or research surveys, we’ll make that change in our systems ASAP. You can opt out of our email marketing by:

clicking the ‘unsubscribe’ links when you get marketing emails
Contacting us through any channel

If you do opt out, we still have to send you operational communications. These can include messages that:

are about SquareOne - for example an account update
we have to send, to comply with New Zealand laws

We use your information to run SquareOne. It helps us run our business efficiently and securely, for your benefit. We use personal information to do the kind of things most companies do, for example:

preparing management reports and business plans
recovering money that customers owe us

And some of this work is the kind of thing financial services companies have to do, for example:

imagining, building and monitoring systems for handling money
monitoring our systems for fraud or financial crime

We constantly look for ways to improve what we do, and our standard of service to you. We use personal information to help us:

find ways to improve customer service – for example, we may use recorded calls for staff training and quality improvement
add new features to our products or services, and develop new products or services
make sure we can correct any errors in the services you have received, such as contacting you to arrange refunds
come up with ideas on ways to help people be great with money

We have to comply with several New Zealand laws and some overseas laws. We may have to use personal information to comply with our obligations:

to agencies that prevent or investigate unlawful activities like fraud, money laundering or other illegal activities
to regulatory or government bodies like Inland Revenue and the police
under the Anti-Money Laundering and Counter Financing of Terrorism Act 2009.

10_WHEN WE SHARE PERSONAL INFORMATION AND WHO WE SHARE IT WITH
We share information with SquareOne group companies and, where required, other third parties. We only share personal information when we’re allowed to under New Zealand or international laws, or when we’re legally required to.

We share personal information with third parties who aren’t SquareOne group companies when:

we do something for you that’s part of a product or service
we need to protect you, or our business interests – for example, to identify transactions that may be fraudulent, and manage our risk
we develop or update our systems and make changes to our products or services
you, or someone with authority over your account, says we can – for example,if you give us permission to share your information with a credit reporting agency
we have to defend or enforce our rights – for example, to collect money owed to us
we have to comply with our legal obligations in New Zealand or overseas

We share personal information with:

our related companies
companies we work with to offer products or services
companies who help us deliver and manage our products or services
government and regulatory bodies
companies and individuals, and service providers you’ve given us permission to share information with

Some of the organisations we share information with may be overseas. These organisations may have to comply with laws that require them to disclose your personal information. We share and combine personal information SquareOne holds with our group related companies to get a better picture of your needs, to run our business, meet our obligations, and deliver products + services that require collaboration between our specialist entities.

We share personal information with companies we work with to offer our products or services to their customers. We might also share information with partner companies we agree can offer their products and services to our customers.

We share personal information with a range of third parties who help us deliver and manage our products or services. These third parties include:

companies and individuals who provide a service to us that requires them to process or store personal information on our behalf, such as social media platforms and other digital advertisers for targeted advertising
companies and individuals who help us develop new products or services
financial institutions that help us deliver our products and services - for example, Mastercard.
companies that collect or buy-up debts, or help with financial recoveries

We have to share information with government and regulatory bodies for two reasons:

The law requires us to tell them. For example, when a customer gives us fraudulent information, or commits – or tries to commit – an offence.
The law requires us to share information with authorities like the Inland Revenue or with the Office of the Privacy Commissioner. These authorities may share this information with other parties.

We’ll share information with companies when you ask us to. You may give us permission to share your information with others.

11_HOW WE PROTECT YOUR PERSONAL INFORMATION
At SquareOne, your privacy is important to us, and we take protecting your personal information seriously. We store personal information electronically, in facilities in New Zealand and overseas:

that we manage, or,
that are managed by third parties, for example, cloud storage like AWS

We comply with international laws that set out how to protect both SquareOne, and customer information. We protect your information in a range of ways:

We have a cybersecurity policy to look after and protect your information. This helps us prevent, detect and respond to cybersecurity events and incidents

We train all our customer-facing staff on privacy and security, and make sure they get regular updates

We check third parties we share personal information with, to make sure they work to agreed standards

When we transfer your information outside SquareOne, it may be to a company in New Zealand or overseas. Our contract with the company will require the company to protect your personal information. We’ll always use reasonable security safeguards - for example, file encryption, to protect your personal information. If we believe that there has been a privacy breach, we’ll identify the issue and take steps to minimise any harm.

If we believe the breach has caused, or is likely to cause serious harm, we’ll contact the Office of the Privacy Commissioner. We’ll also contact customers who may be affected by the breach.

If you believe there has been a privacy breach, please contact us as soon as possible.

We’re required to hold personal information by the Companies Act 1993, the Anti-Money Laundering and Counter Financing of Terrorism Act 2009, the Financial Transactions Reporting Act 1996, and other New Zealand and international laws. We usually have to hold personal information for at least 7 years. But we have to keep certain types of information for longer, even if you’re no longer a customer.

12_ YOU HAVE THE RIGHT TO ACCESS AND CORRECT YOUR PERSONAL INFORMATION
You, or someone you give authority to, has the right to request access to or correct your personal information. You can also request to access, or correct someone else’s information if you have legal authority – for example, if you have a power of attorney.

In most cases you can access or correct your information yourself and you won’t need to ask our help. The fastest way for you to access or correct your information is via our apps. Or you can contact us, and we’ll gladly do it for you.

If the information you want is unusual, complex or sensitive, you may need to make a request for your personal information so we can gather it for you. You can do this by contacting us. Please tell us if your request is urgent, and why, and we’ll take this into account, and keep you updated through the process.

13_HOW TO GET IN TOUCH WITH US
At SquareOne, we care about your privacy, and welcome your feedback. If you have any questions, feel your privacy has been compromised in any way, or want to make a complaint, please contact us:

In our apps
by email, at team@getsquareone.app
by letter at: SquareOne, Level 8, 60 Airedale St, Auckland 1010

If you’ve been through our complaints and resolution process but aren’t satisfied, you can use one of these independent dispute resolution services:

To escalate a privacy complaint, contact the Office of the New Zealand Privacy Commissioner:

Online: privacy.org.nz
Phone: 0800 803 909
(From overseas) +64 (0)4 474 7590
Email: enquiries@privacy.org.nz

Have a general complaint you think deserves escalation? Sorry to hear that and we’ll work hard to fix things.

We’re really confident we can get you to a happy place! But if for some strange reason we can’t agree on how to resolve things, you can contact Financial Services Complaints Limited. FSCL are an independent, not-for-profit, external dispute resolution scheme, approved by the Minister of Consumer Affairs.

FSCL’s service does not cost you anything and they’ll help resolve the complaint. You can contact FSCL by:

Phone: 0800 347 257
Email: complaints@fscl.org.nz
Through FSCL’s website: www.fscl.org.nz
By writing to: FSCL PO Box 5967 WELLINGTON 6011

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squareone privacy policy