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.
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:
‘Privacy Act’ means the Privacy Act 2020 and any laws that change or replace it.
4_OVERVIEW (OR THE TL:DR)
Personal information is needed so we can operate SquareOne. We use it when we:
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.
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:
We also have a cookies policy. That’s available in the footer, over at getsquareone.app.
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:
When you’re a member, or use SquareOne, we collect the following information.
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:
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:
We may also use your information to decide when to:
We may also use your information to do things that are out of the everyday, like help:
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:
If you do opt out, we still have to send you operational communications. These can include messages that:
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:
And some of this work is the kind of thing financial services companies have to do, for example:
We constantly look for ways to improve what we do, and our standard of service to you. We use personal information to help us:
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:
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 share personal 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:
We have to share information with government and regulatory bodies for two reasons:
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:
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:
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:
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:
Phone: 0800 803 909
(From overseas) +64 (0)4 474 7590
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: