Privacy Policy

Introduction

At Limelight Group Limited and Limelight Financial Services Limited (together with our successors and assignees, “Limelight”, “we”, “us”) we are committed to protecting your personal information. We recognise that privacy is very important and that providing us with your personal information is an act of trust, and we take that seriously.

This privacy policy sets out how we collect, use, store, disclose and protect information that relates to an identified or identifiable individual (“Personal Information”). If an individual can’t be identified (for example, when Personal Information is aggregated and anonymised) then the information is not Personal Information and this privacy policy doesn’t apply.

This privacy policy covers:

(a) all products and services supplied by the various businesses and brands operated by Limelight (each a “Business Unit”), as follows:

• dtr
• Thorn Finance
• Finance Central
• Need A Car
• BuyerScore
• Motorcentral

(b) all Websites operated by Limelight (“Websites”), including:

• https://www.limelightgroup.co.nz
• https://www.dtr.co.nz
• https://www.thornfinance.co.nz
• https://www.financecentral.co.nz
• https://www.needacar.co.nz
• https://www.buyerscore.co.nz
• https://www.motorcentral.co.nz

(c) all online applications operated by Limelight (“Apps”).

By using any of our products and services, interacting with any of our Websites or Apps, or otherwise providing us with your Personal Information, you consent to us handling your Personal Information in accordance with this privacy policy.

The Personal Information we collect

The Personal Information that we collect about you will depend on the product or service we are supplying to you and the Business Unit, Website and/or App that you are interacting with. We only collect Personal Information as necessary for a lawful purpose connected with the relevant product or service. The Personal Information we collect may include:

• Information about your identity, like your name, age, identification document details, biometric data and image.
• Your location and contact details, like your address, telephone number and email address.
• Information about your requirements, objectives and purpose in connection with our products and services.
• Financial information, like your income, expenses, liabilities and banking history.
• Your involvement in (or relationship to) any business entity or trust.
• Information about your credit history (including repayment history and any defaults), credit accounts, credit limits and other financial commitments, any court judgments against you, any bankruptcy or insolvency arrangements and any outstanding fines.
• Information about your assets, including those you are purchasing using our services and assets over which we may take security.
• Information regarding your ownership of a vehicle, vehicle purchasing activity, driver licence status, and insurance.
• Information about your citizenship, residency or visa status.
• Information about your personal circumstances such as marital status, number of dependants, current and previous addresses, and living situation.
• Information about your employment and type of work you do.
• Other relevant information about your personal situation, the type of product or service you would like to apply for and your plans, like plans to start a family or your own business.
• Any other information provided in any application you make to us or any interaction you have with any of our Business Units, Websites or Apps.

Providing your Personal Information and allowing us to use it in accordance with this privacy policy is optional. However, we may not be able to provide some or all of our products or services to you should you choose not to provide some or all of the requisite Personal Information.

How we collect information about you

Directly from you

We collect Personal Information directly from you when you:

• Apply to use, or use, one of our products or services.
• Communicate with one of our Business Units regarding any product or service.
• Access, use or otherwise interact with one of our Websites or Apps.
• Interact with us or any of our Business Units on social media.
• Contact us with queries or feedback (including via any of our Websites, Apps or Business Units).
• Enter competitions or other promotions that we facilitate through any of our Business Units.
• Subscribe to receive marketing communications from any of our Business Units.

From third parties and publicly available sources

We may also request (and collect) your Personal Information from the authorised third parties set out below under the heading “How we share information with third parties”.

Additionally, we may collect your Personal Information from publicly available and subscriber sources including registers (such as the Personal Property Securities Register), databases and social media platforms.

Automatically from your use of our Websites or Apps

We may also collect other information, which may not necessarily be Personal Information, automatically when you access and use any of our Websites or Apps. This information could include your IP address, location, device type, session information, cookies and what pages you looked at and what links you clicked on as you navigated through the relevant Websites or Apps. We use this information to understand what content and features are effective and improve our Websites, Apps, products and services.

Some of this information is collected via cookies and similar tracking technologies. More detail about how we use cookies is set out below under the heading “Cookies”.

How we use information we collect

The primary purposes for which we collect, store, use and disclose your Personal Information are to enable the Business Unit(s) that you have requested products or services from to:

To enable the Business Unit(s) that you have requested products or services from to:

• Provide you with those products or services.
• Confirm your identity.
• Verify your income and expenses.
• Communicate with you (including responding to feedback and information requests relating to those products and services).
• Send administrative messages, reminders, notices, updates, security alerts, and other information relevant to your use of the products and services, the Websites or the Apps.
• Process, assess and acknowledge any request for finance you have made with us.
• Assess whether our products and services are suitable for you.
• Provide you with quotes for the cost of credit.
• Assess your creditworthiness and financial position from time to time.
• Monitor, manage, assess and enforce any finance agreements you have with us (including collecting any outstanding debts from you and repossessing any secured assets).
• Notify a credit reporting agency of your credit information, as required.
• Enable third parties that we partner with (including motor vehicle dealers) to provide you with their products and services.
• Refer you to an alternative provider of products and services, if appropriate.
• Undertake funding and capital activities relating to our business.
• Comply with our obligations and exercise our rights under any agreement we have with you or as required by law.

Your Personal Information will only be accessed and used for these primary purposes by our head office or the Business Unit that is providing you with products or services, and not any of our other Business Units.

We may also collect, store and use your Personal Information for the following associated purposes:

• To communicate with, and comply with our obligations to, our third-party service providers and suppliers.
• To verify your identity and monitor and screen accounts as required from time to time by the Anti-Money Laundering and Countering Financing of Terrorism Act 2009.
• To comply with our legal obligations and assisting government and law enforcement agencies or regulators.
• To train our staff, monitor and maintain our systems and networks.
• To analyse and report on usage of the Websites, Apps, products and services, so we can improve the Websites, Apps, products and/or services.
• To provide you with information about us and/or the products and services offered by our different Business Units.
• To enable third parties that we partner with to provide you with information about products and services that they believe may be of interest to you.
• To market our products and services, including future products and services which we believe may be of interest to you (including via email, unless you tell us not to as detailed below under the heading “Marketing and opting out”).
• For such other purposes that are compatible with the original purposes described above, or that you otherwise consent to.

Your Personal Information may be shared between our different Business Units (and with third parties in accordance with this privacy policy) for these associated purposes.

Any sharing of your Personal Information between our different Business Units remains subject to the protections contained in this privacy policy, and at all times, Limelight is the legal entity collecting and holding your Personal Information for the purposes of applicable privacy laws.

We may anonymise and aggregate information such that no person could be re-identified from the information. This aggregated and anonymised data is not Personal Information and this privacy policy does not apply to it. We will own all right, title and interest in such anonymous and aggregate information.

How we share information with third parties

For the purposes set out above and for credit reporting purposes, we may provide your Personal Information to (and request and collect your Personal Information from) third parties. Such third parties may include:

• Third parties that we partner with in connection with our product and service offerings (including motor vehicle dealers).
• Any trading bank, finance company, credit union, insurance company or other financial institution.
• Any online bank statement retrieval service, credit reporter, or identity verification service or agency (including but not limited to Credit Sense, Equifax, Centrix, Illion and APLYiD).
• The New Zealand Transport Agency’s ‘Driver Check’ service or any other register or holder of information relating to the ownership (or prior ownership) of motor vehicles.
• Other government agencies and regulators, including the Ministry of Justice, Department of Internal Affairs, Department of Corrections, New Zealand Police, Work and Income, Immigration New Zealand, Inland Revenue Department and Kāinga Ora Homes and Communities (and related agencies).
• Any joint borrower or guarantor under a finance agreement you request or have with us.
• Your referees, past and present employers and third-party service providers (including telecommunications/utilities providers).
• Owners, occupiers or neighbours of any address reasonably believed to be your current or recent address.
• Your authorised representatives and advisers (including budget advisers).
• Our agents or service providers like debt collection agencies, introducers, professional advisers, direct debit companies, private investigators, marketing agencies and market research and data and analytics products providers, mailing houses, call centre operators and technology service providers offering online services used by us in connection with our business.
• Third parties used to anonymise and aggregate statistical information.
• Our assignees or potential assignees or other entities who acquire, or may acquire, an interest in our business.
• Anyone else you agree or to whom we are required by law to provide information

You authorise us to request and collect your Personal Information from (and disclose your Personal Information to) the third parties referred to above.

Where we collect or disclose your Personal Information from or to third parties in accordance with this privacy policy, you acknowledge that the handling of your Personal Information by that third party is also governed by that third party’s privacy policy, which should be available for you to view on the relevant third party’s website. We recommend that you read any applicable third party privacy policy to understand the rights and protections you have in respect of that party’s use of your Personal Information. If you have any concerns, you should contact the third party’s privacy officer (details of which should be available in their privacy policy).

We may disclose your credit information, including account information, default information, repayment history (including whether payments are made on time), the fact that you have applied for a loan or sought a quotation for the cost of credit, and identification information to credit reporting agencies. Information disclosed by us to credit reporting agencies may be listed in their systems, used by them to provide credit reporting services or other information services, and supplied to their customers who use their services to make credit decisions about you or any applicable organisation you are representing. Credit reporters will hold your Personal Information on their terms and treat your information in accordance with their own privacy policies. Credit reporters are subject to specific requirements in relation to credit information they hold. You can find out more about those obligations and your rights at https://www.privacy.org.nz/privacy-act-2020/codes-of-practice/crpc2020

Please note that we may share your Personal Information with third parties at any appropriate time in accordance with this Privacy Policy. We may disclose your Personal Information to, or receive it from, credit reporters when you apply for a loan (for instance, to assess your creditworthiness and to provide information to the credit reporter about what you have applied for) and at any later stage (for instance, to monitor your position and to provide ongoing information to the credit reporter about your repayment history and any defaults).

When we transfer information overseas

We utilise the services of entities in various countries (including, New Zealand, Australia, USA and India) for the matters specified above under the heading “How we share information with Third Parties”. Consequently, we may transfer your Personal Information to parties located in these countries.

Although we will endeavour to ensure that your Personal Information is treated securely and in accordance with this privacy policy and the Privacy Act 2020, you acknowledge that the overseas recipients of your Personal Information will be subject to the privacy laws of their local jurisdiction, and some of these countries may not have an equivalent level of data protection laws as those in New Zealand.

How long we keep your information

We will keep your Personal Information:

• until we no longer require it for the purposes for which it may lawfully be used; or
• for as long as required by law.

Cookies

Cookies are text files containing small amounts of information which are downloaded to your browsing device, e.g. a computer or smartphone, when you visit a website or online application. Cookies can be recognised by the website or online application that downloaded them, or other websites or online applications that use the same cookies. This helps websites and online applications know if the browsing device has visited them before.

Cookies do many things, like helping us understand how our Websites and/or Apps are being used, letting users navigate between pages effectively, remembering your preferences, and generally improving your browsing experience. Cookies can also help ensure marketing you see online is more relevant to you and your interests.

The length of time a cookie will stay on your browsing device depends on whether it is a persistent or session cookie. Session cookies will only stay on your device until you stop browsing a Website (or close an App). Persistent cookies will stay on your browsing device until they expire or are deleted.

We may use cookies and other similar tracking technologies from third-party partners such as Google to help us distinguish between different end users and understand how often a particular end user may visit our Websites or open our Apps, how the end user got to our service, the end user’s activity on our Websites and Apps, and to deliver advertisements that we believe are relevant to your interests using Personal Information we hold about you.

If you do not wish to receive any cookies, you may manually adjust the cookie settings on your website browser. In some instances, this may mean you will not be able to take full advantage of parts of our Websites.

Marketing and opting out

Where you have consented to receiving such communications, we may use your Personal Information to provide you with marketing and promotional information by electronic message.

If, at any stage, you no longer wish to receive these marketing communications, you may unsubscribe by using the unsubscribe facility in any communication or by contacting us using the relevant contact details specified below under the heading “Contact details”.

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.

We provide links to websites outside of the Limelight Websites. These linked sites are not under the control of Limelight and we do not accept responsibility for the conduct of companies linked to our Websites. Before disclosing your Personal Information on any other website, we advise you to read the terms and conditions and privacy policy of that website.

Protection of Personal Information

We will take all reasonable steps to keep secure any Personal Information we hold about you and to keep this information accurate and up to date. Your Personal Information is stored on secure servers that are protected in controlled facilities.

In addition, our employees and the contractors who have access to the information systems of any of our Business Units are obliged to respect the confidentiality of any Personal Information that they have access to. However, except as required by applicable privacy laws, we will not be held responsible for events arising from unauthorised access to your Personal Information.

You can also play an important role in keeping your Personal Information secure by maintaining the confidentiality of any password and accounts used on the Websites or Apps. Please notify us immediately if there is any unauthorised use of your account by any other Internet user or any other breach of security.

If you suspect any misuse or loss of, or unauthorised access to, your Personal Information, please let us know immediately.

How you can access or correct your information

If you wish to access and/or correct Personal Information we hold about you, you can request this information by getting in touch with us by writing to the Limelight Privacy Officer, or by contacting the Business Unit that you have been receiving products or services from, using the relevant contact details specified below under the heading “Contact Details”.

We will try to respond to your request within 10 working days.

What to do if you have a complaint?

Limelight complies with the requirements of the Privacy Act 2020. Should you feel Limelight has breached your rights under this Act please write to the Limelight Privacy Officer using the relevant contact details specified below under the heading “Contact Details”.

Changes to this privacy policy

We will continuously review our privacy policy to ensure that it protects your privacy while also supporting your user experience on the Websites and Apps. We encourage you to keep visiting our privacy policy to see if any updates have been made.

Contact details

Email:

For complaints or enquires related to Privacy:

Email: [email protected]

For complaints or enquiries related to marketing:

Email: [email protected]

For general enquiries:

Email: [email protected]

Post:

Attention: The Privacy Officer

Limelight Financial Services Limited
PO Box 204365
Highbrook
Manukau 2161

Last updated: November 2022