Privacy

The Service is an online financial literacy tool provided by Banqer.

In order to provide the Service, the Website, and to otherwise conduct its business, Banqer 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) (together, “Privacy Laws”). 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 privacy 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 privacy 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 hello@banqer.co.

Definitions

In this privacy policy:

Banqer High means the Service provided for secondary school students

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

Private User means an individual accessing the Service for private non-commercial use

Service means the services offered on the Website

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

Website means the internet sites Banqer owns and operates, including www.banqer.co, www.banqer.co.nz, www.banqer.com.au, primary.banqer.co and high.banqer.co

Any further capitalised terms used but not defined in this privacy policy have the meanings given to them in Banqer’s Terms of Use

Kinds of personal information we collect:

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

Organisations

1. If you are a teacher: Full name, title, phone number, email address, country, school and classroom name. We may also collect additional information generated by your use of the Services, including the state of learning modules and your user preferences.
2. If you are a representative of an Organisation (e.g. an administrator): Full name, title, phone number, country, email address and Organisation name.

Parents and legal guardians

1. If you are a parent or legal guardian and your child is using the Services through a school program, we may collect your full name and email address:
   1. from your child’s teacher; or
   2. if your child is using Banqer High, from your child.
   Collection and disclosure of personal information by your child’s teacher is subject to any privacy policies of the teacher’s school.
2. If you are a parent or legal guardian and you or your child is using the Services as a Private User, we may collect your full name, phone number, country and email address plus, if you use the Services, the information in the Users section below.

Users (students and private users)

1. We may collect your full name, year level (if applicable) and your gender.
2. 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.
3. If you are using Banqer High, we may also collect your date of birth.

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.

The ways we collect 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 it in different ways including:

1. 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;
2. during conversations between you and our representatives (including telephone phone and email); or
3. 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:

1. If you are a student: from your teacher, parent or legal guardian;
2. If you are a parent or legal guardian: from your child’s teacher or from your child; and
3. If you are a user accessing the Service at the invitation of your workplace: from your workplace.

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

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

1. we may not be able to provide the Services to you (either to the same standard or at all);
2. we may not be able to provide you with information about Services that you may want; or
3. 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.

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 Website) and to provide the best quality of customer service.

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

1. providing or improving the Service and Website (including processing or responding to any request or complaint made by you);
2. monitoring Service and Website usage and compliance with any contracts you have entered into with us;
3. if you are a parent or guardian of a child using the Service, to provide you with email updates on your child’s progress;
4. carrying out internal research and development;
5. providing information to you about additional products or services that may be of interest to you (including direct marketing);
6. if you are either an Organisation or a Private user:  providing billing details (names and email addresses) of users accessing the Service under that plan to Banqer’s sponsorship partner, for auditing purposes only;
7. compliance with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country; or
8. 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 hello@banqer.co

Disclosure of personal information:

We may disclose your information to:

1. our employees, related bodies corporate, contractors or service providers for the purposes of operating our Website, our business or the Services, fulfilling requests by you, and to otherwise provide the Services and Website 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);
2. 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;
3. persons who can require us to supply your personal information (e.g. a law enforcement agency or regulatory authority) or authorised by applicable law; and
4. any other person for any authorised purpose with your express consent.

If we enter into an agreement for a bona fide sale of our business (assets or shares, whether in whole or in part) to a third party, your personal information may be transferred to the third party purchaser. You acknowledge and agree that such transfers may occur, and that any acquirer of Banqer or its assets may continue to access and use the User Data and User Submissions as set out in the Terms of Use and this privacy policy.

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.

International transfer of personal information:

A business that supports our website, products and services may be located outside of New Zealand (the country where we are incorporated) and also outside of the country where you are located. This means that the personal information we collect may be transferred to, and stored in, a country outside of New Zealand and the country where you are located.

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:

1. you must immediately notify us; and
2. 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 a Private User or a student, teacher or employee of an Institution, or is caused by a breach of the Terms of Use or any part of this privacy policy by a Private User or a student, teacher or employee of an Institution, 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 or Services transfer to your computer’s hard drive to enable our systems to recognise your browser.

We use the term cookies in this privacy policy to mean cookies or similar technologies such as web beacons, clear GIFs, and pixel tags.

The cookies we use may be first party cookies (i.e. set by us) or third party cookies (i.e. cookies set on our website by a person other than us). The third party companies that place cookies on our website will have their own privacy policies.

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 use cookies provided by Google Analytics to track things such as how long you spend on the Website 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 or Website.

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).

We may charge a fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge you for simply making a request.

Please contact hello@banqer.co if you would like to request access to or update your personal information. Your email should provide evidence of who you are and set out 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.

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:

If you believe that your privacy has been breached, please contact us on hello@banqer.co 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: hello@banqer.co

Changes to our privacy policy:

We may change this privacy 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.

This privacy policy was last updated on Thursday 30th November 2023.

Law:

For the purposes of this Privacy Policy, Banqer means Banqer Limited, a New Zealand Company with the company number 5525528. The relationship we have with you in connection with this Privacy Policy is governed and construed in accordance with the laws stated of New Zealand, and is subject to the exclusive jurisdiction of the courts of New Zealand.