1. About our Privacy Statement
Emergence NZ Limited (Emergence, we, us, and our) is committed to protecting the personal information of all our customers (who we refer to as customer, you or yours) in accordance with the Privacy Act 2020 (Privacy Act) and the Information Privacy Principles as set out in the Privacy Act.
Our Privacy Statement will help you understand how and why we collect information, how that information is stored, how you can access and correct that information and when we might disclose your information to third parties.
Our Privacy Statement does not limit or exclude any rights that you have or may have under the Privacy Act.
If you require further information about privacy in New Zealand, please see www.privacy.org.nz.
2. How we use our Privacy Statement
Our Privacy Statement applies to all instances where we collect your personal information. By using the products and/or services that we Emergence, each customer consents to the collection, use, disclosure, storage and processing of personal information in accordance with our Privacy Statement.
3. Collection of Personal Information
Emergence will collect the following personal information:
- any communication with us directly, via phone and/or email;
- through our website;
- through our underwriting portal;
- information obtained by or submitted to Emergence from you through your use (or prospective use) of our services, including your information that we obtain from your insurance broker;
Emergence may supplement the information that is provided to us with information that we receive from third parties.
We do not collect any other personal information about you, including any details about your race, ethnicity, religious beliefs, sexual orientation, medical information, political information or any other genetic or biometric data, unless we collect that personal information as part of an assessment of a data breach of an Emergence insured client.
We also automatically collect certain information when you visit our website, some of which may be capable of personally identifying you. Please see Clause 11 ‘Cookies’ below for more detail.
4. Personal Information that may be collected
Emergence may, in addition to other information, collect the following information about you:
- your name and contact information (phone number and email address);
- information relating to the insured risk;
- other reference information for underwriting purposes including information about third parties that you may conduct, or are interested in conducting business with;
- information that is necessary for us to provide our services to you;
- financial information and account details such as your payment card number; bank account number and account details;
- other sensitive information – in certain cases, we may receive sensitive information about you. In addition, we may obtain information about your criminal record or civil litigation history in the process of preventing, detecting and investigating fraud;
- information enabling us to provide services – your status as director or partner, or other ownership or management interest in an organisation, your employment details and any other insurance you hold, and;
- marketing preferences and customer feedback – a customer may provide us with their marketing preferences, enter a contest, prize draw or other sales promotion, or respond to a voluntary customer satisfaction survey.
If any customer chooses not to provide information when we ask for it, they may not be able to use the services.
You can make general enquiries about our products and services without identifying yourself.
5. Use of your Personal Information
The information that you provide to Emergence may be used:
- to verify your identity;
- in connection with the provision (or potential provision) of the services to you, including the provision of information to underwriters as part of the services;
- to communicate with you in relation to the services;
- to market the services to customers, including contacting you electronically (i.e. by text, email or an online messaging platform);
- to undertake credit checks of any customer (if necessary);
- to undertake sanction checks of any customer;
- to invoice you and to collect money that you owe, including authorising and processing credit or debit card transactions;
- to respond to communications from you, including any complaints;
- to co-operate with any government, industry or regulatory authorities;
- to protect and/or enforce our legal rights and interests, including defending any claim;
- for any other purpose authorised by a customer and/or the Privacy Act.
Emergence reserves the right to use data (on a strictly anonymous basis) in relation to any customer’s use of the services for marketing and accounting purposes.
Customers may request Emergence to stop sending marketing messages at any time, by emailing info@emergenceins.co.nz.
6. Disclosure of your Personal Information
We will only disclose your personal information where it is required or reasonable to providing or administering a product or service that you have requested, or for any of the purposes outlined in this privacy policy. Where appropriate, we will disclose your personal information to:
- our related body corporates, your broker or third parties as is required in order to provide our products and services, including our external service providers, such as payment system operators, lawyers, accountants, other advisers, financial institutions and information technology providers;
- to agents, Lloyd’s underwriters; insurers, reinsurers, other insurance intermediaries, insurance reference bureaus and industry bodies and groups;
- claims management and related service providers;
- the insurance and Financial Ombudsman Service or other alternative dispute resolution schemes;
- administrative service providers;
- any government organisation or agency, and;
- any other entities notified to you at the time of collection.
You authorise us to contact such third parties for the purposes of providing you with the products and services that you have requested.
Other than when required or permitted by law, as specified in this Privacy Statement or where you have provided your consent, we will not disclose your personal information for any other purpose.
Nothing in this Privacy Statement prevents us from using and disclosing to others de-personalised aggregated data.
7. Disclosure of your Personal Information overseas
We may disclose your personal information overseas (such as certain countries located in Asia and Europe, and the United States of America) where it is required or reasonable in relation to providing or administering a product or service that you have requested, or for any of the purposes outlined in this Privacy Statement.
If we wish to disclose your personal information overseas, we will inform you of this and we will take reasonable steps to ensure that the overseas recipient does not breach the applicable privacy principles.
8. Disclosure of Personal Information
Unless expressly authorised to do so by the relevant customer or under this privacy statement, we will not disclose any of your personal information to any third party except where disclosure relates to the purposes for which the information was collected (as stated in Clause 5 above)
9. Security of your Personal Information
We take reasonable steps to protect any personal information that we hold from misuse, interference and loss, and from unauthorised access, alteration and disclosure.
For example, we maintain physical security over our paper and electronic data stores and premises, such as locks and security systems. We also maintain computer and network security. For example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to computer systems.
However, data protection measures are never completely secure and, despite the measure we have put in place, we cannot guarantee the security of your personal information. You must take care to ensure you protect your personal information (i.e. by protecting any usernames and passwords). You should notify us as soon as possible if you become aware of any security breaches.
10. Privacy Officer
Emergence will at all times have a Privacy Officer.
The Privacy Officer must be familiar with the provisions of this Privacy Statement and be available to assist on any privacy matters referred to Emergence.
The Privacy Officer may be contacted at info@emergenceins.co.nz.
11. Cookies
Like many website operators, we may use standard technology called cookies on our website. Cookies are small data files that are downloaded onto your computer when you visit a particular website. Cookies help provide additional functionality to the site or to help us analyse site usage more accurately. For instance, our server may set a cookie that keeps you from having to enter a password more than once during a visit to one of our sites.
In all cases in which cookies are used, the cookie will not collect personal information except with your consent. You can disable cookies by turning them off in your browser; however our website may not function properly if you do so.
12. Protection and Retention of Personal Information
Emergence will take all reasonable steps to ensure the personal information collected, used or disclosed with this Privacy Statement is stored in a secure environment protected from unauthorised access, modification or disclosure.
Emergence will hold personal information collected in accordance with this Privacy Statement both before and after the provision of its services in order to fulfil the purposes for which it was collected, but only for so long as we are legally entitled to do so.
13. Legal Rights and Access to Personal Information
You have the following rights in relation to your personal information:
- you can request access to your personal information;
- you can request a correction to your personal information;
- you can request the deletion or removal of your personal information;
- you can object to the processing of your personal information;
- you can request a restriction on the processing of your personal information;
- you can request a transfer of your personal information to you or a third party;
- you can withdraw consent to the use of their personal information.
If at any time you wish to exercise any of the rights above, please contact us at info@emergenceins.co.nz.
14. How to make a complaint
If you wish to make a complaint about how we have treated your personal information, you can lodge a complaint by using the contact details below. You will need to provide us with sufficient details regarding your complaint together with any supporting evidence and information.
We will refer your complaint to our Privacy Officer who will investigate the issue and determine the steps that we will undertake to resolve your complaint. We will contact you if we require any additional information and will notify you in writing of the outcome of the investigation. We will try to resolve any complaint within 14 working days. If this is not possible, you will be contacted within that time to let you know how long it is likely to take us to resolve your complaint.
If you are not satisfied with our determination, you can contact us to discuss your concerns or complain to the Privacy Commissioner by visiting www.privacy.org.nz.
15. Privacy Policy changes
We may make changes to this policy as a result of operational or legislative changes. When changes are made to this policy, the updated policy will be uploaded to our website and the effective date updated accordingly.
16. How to contact us
If you wish to gain access to your personal information, want us to correct or update it, have a complaint about how we have treated your personal information or any other query relating to our privacy policy, please contact our Privacy Officer during business hours as follows:
The Complaints Officer
Emergence NZ Limited
E: info@emergenceins.co.nz
P: 0800 129 237
M: Level 11, Shortland Centre, 55 Shortland Street, Auckland 1140 New Zealand.