Privacy and Credit Reporting Policy
Last updated 30 September 2021
Commitment to Privacy
Latitude Innovation Holdings Limited, trading as Genoapay (“us”, “we” or “our”) is committed to respecting the privacy of personal information and complying with the New Zealand Privacy Act 2020 (the Act) when dealing with personal information. Personal information is information about an identifiable individual. We also collect information about Businesses and we treat business information under the same privacy guidelines.
Collection of Personal Information
We collect personal information about people who choose to pay for products or services using the Genoapay system or use Genoapay as a method to sell their products or services (whether or not personal information is sent to us by computer, mobile phone or any other access device). This includes, but is not limited to:
- Information identifying you: such as your Name, Email, Drivers licence number, date of birth, NOK (next of kin);
- Contact details: Email, phone numbers, fax numbers, residential address, social media accounts;
- Billing information: Billing Name and Address, goods and services purchased and their value, structure of payment plans, payment methods, previous payment plan history;
- Financial Details: Genoapay provides payment gateways from audited PCIDSS LV1 compliant payment processors and does not store or log any credit card or bank account information;
- Information about your current employer and employment status; and
- Credit history from various credit agencies.
We may also keep a record of any information that you acquire from us.
How We Collect the Information
We may collect personal information from you:
- When you provide information to us via the website specifically the Genoapay online form and the Genoapay online contract form and / or hard copy form, plus any related service, through any registration or subscription process, through any contact with us (e.g. telephone call, SMS/MMS, email, letter, online form, visiting our website), or when you use Genoapay as a payment method for products or services from merchants that use Genoapay service.
- When you purchase goods or services using Genoapay the supplier of the goods or service may choose to supply Genoapay with your personal information for the purpose of providing the Genoapay service to you.
- From third parties where you have authorised this or the information is publicly available. If possible, we will collect personal information from you directly however it may be necessary to collect information about you from third parties where this has been authorised by you.
How We Use Your Personal Information
Genoapay collects, holds and handles information about you that is necessary for us to perform the services you request from us, that is otherwise reasonably necessary for our business activities or if required by New Zealand law or court or tribunal order.
We may use your personal information to:
- verify your identity and provide you with the Genoapay payment solution;
- improve the services and products that we provide to you; and
- to bill you and to collect money that you owe us or providers offering Genoapay, including authorising and processing credit card transactions and direct debit transactions, to protect and/or enforce our legal rights and interests, including defending any claim, to market our services and products directly to you including contacting you, to undertake credit checks of you (if necessary) , to respond to communications from you, including a complaint, to conduct research and statistical analysis (on an anonymised basis).
Generally, we may use your personal information for the purposes for which we collect it and for related purposes which would be reasonably expected by you.
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.
Disclosing Your Personal Information
We collect personal information that is necessary for the purpose of operating our business and providing our services to you and providing you with a flexible method to pay for goods and services.
We may disclose your personal information to 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 to provide the website or other services and products.
We may also disclose your personal information to third parties, such as advisors, lawyers, accountants, acquirers (or potential acquirers) of all or any part of our business, or resellers who sell our services, or business partners with whom we exchange customer data for the purposes of providing our services to you, including to debt collection agencies for the purposes of collecting debts, or for the purposes of due diligence enquiries or in order to run the business or part of the business acquired.
We will disclose your information to any person authorised by you any other person authorised by the Act or another law (e.g. a law enforcement agency).
Some of the third parties to which we may disclose your personal information may be located outside of New Zealand. Where they are located outside of New Zealand we ensure they will handle your Personal Information in accordance with the Act.
Protecting Your Personal Information
We will take reasonable steps to keep your personal information safe from loss, unauthorised activity, or other misuse. However, data protection and security measures are never completely secure and, despite the measures we have put in place, we cannot guarantee the security of your personal information. You must take care to protect your personal information. You should also notify us via our contact details listed below as soon as possible if you become aware of any security breaches.
Accessing and Correcting Your Personal Information
Subject to certain grounds for refusal set out in the Act, you have the right to access your readily retrievable personal information that we hold and to request a correction to your personal information. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.
- access would be unlawful;
- denying access is required under New Zealand law or an order of a court or tribunal; or
- access would prejudice enforcement action or appropriate action relating to unlawful activity or serious misconduct.
In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the personal information, we will make the correction. If we do not make the correction, we will take reasonable steps to note on the personal information that you requested the correction.
If you want to exercise either of the above rights, email us at email@example.com. Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information, or the correction, that you are requesting).
We may charge you our reasonable costs of providing to you copies of your personal information or correcting that information.
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 your personal information on the website’s message board/ chat room / social media pages, you acknowledge and agree that the information you post is or may be publicly available.
If you have a complaint about how we have used or disclosed your information then please email the Genoapay support team firstname.lastname@example.org, call 0800 436 625 or write to 8 Tangihua Street, Auckland Central, Auckland, New Zealand.
Please ensure you are providing proof of your identity when making either a request or complaint.
Credit Reporting Policy
The Credit Reporting Privacy Code permits credit providers like Genoapay to share information with credit reporting agencies, on an ongoing basis. This means that Genoapay may provide credit reporting agencies with certain credit related information about its customers’ accounts, such as:
- type of credit account e.g. credit card
- amount of credit extended (but not current balance)
- status of account e.g. open (including account open date
- details of credit provider i.e. the lender who provided the credit
- monthly reporting of repayment history e.g. whether an account was paid on time, and
- changes in personal details such as address, contact details, etc
For further information on comprehensive credit reporting, please see the following website www.privacy.org.nz/credit-reporting-privacy-code/
Thank you from The Genoapay Team