Privacy – GetWise

General Programme and website – privacy notice

Introduction
1. GetWise is a financial capability Programme delivered by a dedicated team at EY to young people in schools across New Zealand (the “Programme”) on behalf of ASB Bank Limited (“Organisation”).
2. This Privacy Notice is intended to describe the practices EY follows in relation to the GetWise Programme and its website www.getwise.co.nz (the “Website”) with respect to the privacy of all individuals whose personal data is processed and stored because of their use of the Website or participation in the Programme.

Who manages the Website and the Programme?
1. “EY” refers to one or more of the member firms of Ernst & Young Global Limited (“EYG”), each of which is a separate legal entity and can act as a data controller in its own right. The entity that is acting as data controller by collecting, processing, and storing your personal data in connection with the Programme (including via the Website) is Ernst & Young. The information you provide is being collected by EY, as a service provider to the Organisation.
2. The personal data you provide may be shared by Ernst & Young with one or more member firms of EYG (see “Who can access your information” section below).
3. The Website is hosted on EYG’s servers in Australia.

Why do we need your information?
1. We may collect personal information from you when you submit an enquiry or expression of interest through the Website, participate in the GetWise Programme, or when we have other business dealings with you in connection with the Programme.
2. The ways in which we may collect this information may be via the Website, Programme booking forms, Programme evaluation surveys, interviews and focus groups, email correspondence or in-person as part of the Programme delivery at your school or workplace.
3. Your personal data processed in connection with the Programme may be used as follows:
  1. To respond to your enquiry or expression of interest in the Programme;
  2. To contact you in order to book the Programme;
  3. To provide you with Programme resources; or
  4. To contact you to invite you to events or for other direct marketing purposes.
4. EY relies on the following basis to legitimize the processing of your personal data: You have given consent to the processing of your personal data for one or more specific purposes.
5. The provision of your personal data to EY is optional. However, if you do not provide all or part of your personal data, we may be unable to carry out the purposes for processing.

What type of personal data is processed?
1. EY may process the following categories of personal data in connection with the Programme (including through the Website): First name, last name, job title, email and telephone number.
2. This data is sourced from you directly unless it is unreasonable or impracticable to do so.

Sensitive Personal Data
1. Sensitive personal data reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation. EY does not intentionally collect any sensitive personal data from you via the Website or otherwise in connection with the Programme. EY’s intention is not to process such information.

Who can access your information?
1. Your personal data is accessed by the following persons/teams: The Programme team, including facilitators or Programme and administrative staff, and ASB Bank Limited.
2. From time to time, EY may also share your personal data with other third parties who may be providing, offering, sponsoring or otherwise assisting in the conduct of the Programme you are participating in, or expressed your interest to participate in.
3. The access rights detailed above involves transferring personal data in various jurisdictions (including jurisdictions outside the European Union) in which EY operates (EY office locations are listed at www.ey.com/ourlocations). EY will process your personal data provided in connection with the Programme (including via the Website) in accordance with applicable law and professional regulations in your jurisdiction. Transfers of personal data within the EY network are governed by EY’s Binding Corporate Rules (www.ey.com/bcr).

Data retention
1. All information collected in connection with the Programme, including via the Website, is retained in accordance with EY Global Records Retention policies and procedures.
2. Your personal data will be retained in compliance with privacy laws and regulations. After the end of the data retention period, your personal data will be deleted.

Security
1. EY is committed to making sure your personal data is secure. To prevent unauthorized access or disclosure, EY has technical and organizational measures to safeguard and secure your personal data. All EY personnel and third parties EY engages to process your personal data are obliged to respect your data’s confidentiality.

Controlling your personal data
1. EY will not transfer your personal data to third parties (other than any external parties referred to in section 6 above) unless we have your permission or are required by law to do so
2. You are legally entitled to request details of EY’s personal data about you. To confirm whether your personal data is processed by or to access your personal data collected in connection with the Programme, contact your usual GetWise representative or email your request to support@getwise.co.nz or global.data.protection@ey.com.

Rectification, erasure, restriction of processing or data portability
1. You can confirm your personal data is accurate and current. You can request rectification, erasure, restriction of processing or a readily portable copy of your personal data by contacting your usual GetWise representative or email your request to support@getwise.co.nz or global.data.protection@ey.com.

Our Privacy Statement
1. Our Privacy Statement provides more information about how we manage and protect the personal information we hold about individuals.

Complaints
1. If you are concerned about an alleged breach of privacy law or any other regulation, contact EY’s Global Privacy Officer, Office of the General Counsel, 6 More London Place, London, SE1 2DA, United Kingdom or via email at global.data.protection@ey.com or support@getwise.co.nz or via your usual GetWise representative. An EY Privacy Officer will investigate your complaint and provide information about how it will be handled and resolved.
  If you are not satisfied with how EY resolved your complaint, you have the right to complain to your country’s data protection authority. You can also refer the matter to a court of competent jurisdiction

Contact us
1. If you have additional questions or concerns, contact your usual GetWise representative or email support@getwise.co.nz or global.data.protection@ey.com.

Date last revised: March 2023

Star Shopper App – Privacy Policy

We respect your privacy
1. ASB Bank Limited (ASB) respects your right to privacy and is committed to safeguarding the privacy of our customers and software application users. We adhere to the information privacy principles set out in the Privacy Act. This policy sets out how we collect and treat your personal information.
2. “Personal information” is information ASB holds which is identifiable as being about you.
3. “Privacy Act” means the Privacy Act 1993 until 1 December 2020 and the Privacy Act 2020 thereafter.

Collection of personal information
1. ASB will not ask you to provide any personal information or enter such personal information into our software application, the StAR Shopper App (“App”, “Application”).
2. ASB may collect additional information at other times, including but not limited to, when you provide feedback, respond to surveys and/or promotions, or communicate with our technical support.
3. Additionally, ASB may collect some anonymized device information such as your IP address and/or geolocation data for aggregated analysis of geographical areas from where users are generally accessing the StAR Shopper App. This will help us design more such free educational resources keeping our users’ geographies and cultures in mind.

How we collect your personal information
1. ASB collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access the StAR Shopper App and when we provide our services to you. We may receive personal information from third parties, for example when you provide a public review of the App using your account on the mobile application marketplace you are using. If we do, we will protect this information as set out in this Privacy Policy.

Use of your personal information
1. ASB may use personal information collected from you to provide you with updates to the StAR Shopper app and our services in relation to that app. We may use your personal information to better understand students’ learning needs and improve our related free and publicly available educational products and services.
2. The StAR Shopper App does not make any third-party social media features available to its users. However, ASB cannot ensure the security of any information you choose to make public through the review features available on the mobile application marketplace you are using. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy.
3. ASB will not contact you unless we are required to respond to a public review you’ve posted on the mobile application marketplace you are using.

Disclosure of your personal information
1. ASB may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Policy. Personal information is only supplied to a third party when it is required for the delivery of our services in relation to the StAR Shopper app.
2. ASB may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.
3. ASB may also use your personal information to protect the copyright, trademarks, legal rights, property or safety of ASB, its software applications, website and customers or third parties.
4. Information that ASB collects may from time to time be stored, processed in or transferred between parties located in countries outside of New Zealand.
5. If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.
6. By providing us with personal information, you consent to the terms of this Privacy Policy and the types of disclosure covered by this Policy. Where we disclose your personal information to third parties, we will request that the third party follow this Policy regarding handling your personal information.

Security of your personal information
1. ASB is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
2. The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

Access to your personal information
1. You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act. A small administrative fee may be payable for the provision of this information. If there’s a fee, we will let you know how much it is likely to be so you can choose if you want to go ahead. If you would like a copy of the information which we hold about you or believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at support@getwise.co.nz
2. We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act.

Complaints about privacy
1. If you have any complaints about our privacy practices, please feel free to contact one of our Customer Care managers directly on 09 377 8930. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

Opt-out right
1. You can stop all collection of information by the StAR Shopper App easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You can also request to opt-out via email, at support@getwise.co.nz

Changes to Privacy Policy
1. Please be aware that ASB may change this Privacy Policy in the future. We may modify this Policy at any time at our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or on the StAR Shopper App by way of an update. Please check back from time to time to see if an update to the StAR Shopper App is available and to review our up to date Privacy Policy.

Software Application
1. When you use the StAR Shopper App
  When you come to the StAR Shopper App, ASB may collect certain information such as mobile unique device ID, the IP address of your mobile device, mobile operating system, the type of mobile internet browsers you use, and information about the way you use the Application. This information is used in an aggregated manner to analyse how people use the Application, so that we can improve our service.
2. Cookies
  ASB may, from time to time, use cookies on our software applications associated with the StAR Shopper App. Cookies are very small files which a web service uses to identify you when you come back to the Application and to store details about your use of the Application. Cookies are not malicious programs that access or damage your computer, tablet or smartphone. Most devices automatically accept cookies, but you can choose to reject cookies by changing your device settings. However, this may prevent you from taking full advantage of our Application.
3. Automatic collection
  The Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the Application.
4. Third parties
  The StAR Shopper App may, from time to time, have links to other applications or websites owned and controlled by us. These links are meant for your financial literacy awareness only, and will never be aimed at promoting any commercial and/or financial products. Please be aware that the privacy policies of such applications and websites will apply when you interact with these platforms. We encourage our users to be aware, when they leave the StAR Shopper App, to read the privacy statements of each and every application or website that collects personal identifiable information.
5. Geolocation
  When you use the StAR Shopper App, we may use GPS technology (or another similar technology) to determine your current location in order to aggregate information on the geographical regions where our users are located. This will help us cater our free educational resources to our users’ geographical and cultural contexts. We will not share your current location with other users, or use your individual location data in isolation from the aggregated data on all user locations.