Privacy policy

Introduction

Emoney Financial Services Limited, trading as Insure My Mortgage (we, us, our), is a licensed Financial Advice Provider (FSP1006283). We provide mortgage, lending and personal insurance advice to clients in New Zealand.

We comply with the New Zealand Privacy Act 2020 (the Act), including the Information Privacy Principles, when we deal with personal information. When we handle health information for insurance advice, we also comply with the Health Information Privacy Code 2020.

This policy explains what personal information we collect, how we collect it, how we use, share, store and protect it, and how you can access or correct it. It does not limit or exclude any of your rights under the Act. For more information about your privacy rights, visit the Office of the Privacy Commissioner at www.privacy.org.nz.

Our contact details

Privacy Officer: Amit Munjal
Address: 1/35 Pah Road, Epsom, Auckland 1023
Phone: +64 22 0000 049
Email: amit@insuremymortgage.co.nz

Changes to this policy

We may update this policy from time to time, for example to reflect changes in the law or in how we work. We will publish the revised policy on our website, and the change will apply from the date it is published. The "last updated" date at the top shows when it was last changed.

What is personal information?

Personal information is information about an identifiable individual (a natural person). Depending on the advice and services you ask for, we may collect:

• Identity details — name, date of birth, gender, residency or citizenship status, and copies of identity documents (such as a passport or driver licence).

• Contact details — address, phone numbers and email address.

• Financial information — income, expenses, assets, liabilities, bank statements, credit history, KiwiSaver details, and evidence of source of funds or source of wealth (in some cases).

• Employment and education — occupation, employer, employment history, qualifications and business details if you are self-employed.

• Property information — details of properties you own or plan to buy, valuations and sale and purchase agreements.

• Insurance information — existing policies, cover needs, beneficiaries and claims history.

• Health and lifestyle information — medical history, current health, family medical history, and lifestyle details such as smoking status or hazardous activities (only where needed for insurance advice — see section 7).

• Payment details, testimonials and feedback, and records of our communications with you.

• Website and device information — such as how you use our website (see section 14).

Information about other people

If you give us personal information about someone else — for example a partner, co-borrower, guarantor, dependant or beneficiary, please make sure they know you are sharing it with us, why, and that they can contact us to access or correct it.

How we collect your personal information

We collect most personal information directly from you — in meetings, by phone or email, through our online forms, and in fact-find and application documents.

With your authority, or where the law allows, we may also collect information about you from others, including:

• lenders, insurers and other product providers;

• credit reporting agencies (usually through a lender as part of a loan application);

• your lawyer, accountant, employer, real estate agent, valuer or other professional advisers;

• your doctor or other health providers (for insurance applications and claims, with your written authority);

• people who refer you to us, and other financial advisers (for example where we take over the management of your existing cover or lending); and

• publicly available sources, such as property records and the Companies Office register.

When we collect information from someone other than you

Where we collect your personal information from someone other than you, we will take reasonable steps to make sure you are aware of:

• the fact that we have collected it, and the purpose of the collection;

• the intended recipients of the information;

• our name and address as the agency collecting and holding it;

• whether the collection is authorised or required by law and, if so, which law; and

• your right to access and request correction of the information.

We will do this as soon as reasonably practicable after collection, unless you are already aware of these matters or an exception applies under the Act (including Information Privacy Principle 3A, which applies to information collected from 1 May 2026). This policy forms part of how we make you aware of these matters.

How we use your personal information

We will use your personal information:

• to verify your identity;

• to understand your needs and objectives, and to provide financial advice, products and services to you;

• to prepare and submit loan and insurance applications, and to help you with insurance claims, on your behalf;

• to review your lending and insurance arrangements over time, as agreed with you;

• to meet our legal and regulatory obligations, including under the Financial Markets Conduct Act 2013, the Code of Professional Conduct for Financial Advice Services, and anti-money laundering laws where they apply;

• for record-keeping, compliance monitoring, audits and quality assurance;

• to market our services and products to you, including contacting you electronically (for example by call, text or email) — you can opt out at any time (see section 15);

• to improve the services and products we provide;

• to respond to communications from you, including a complaint;

• to protect and/or enforce our legal rights and interests, including defending any claim; and

• for any other purpose authorised by you or the Act.

Health information

Some insurance advice and applications need health information. We only collect the health information we need to give you advice, complete an application or support a claim, and we handle it in line with the Health Information Privacy Code 2020.

We share health information only with the insurer you are applying to or claiming from (and their reinsurers, medical assessors and claims providers), or with others you authorise. We do not use health information for marketing.

Disclosing your personal information

We may disclose your personal information to:

• product providers — such as banks and other lenders, insurance companies and KiwiSaver providers — to obtain quotes, submit applications, manage your products and process claims;

• Kiwi Adviser Network Limited, which provides our licensing and compliance support, lender aggregation services, and the client management (CRM) software in which your records are held;

• other companies or individuals who assist us in providing services or perform functions on our behalf — such as IT, hosting and data storage providers, specialist consultants, valuers and legal advisers;

• a locum adviser engaged to look after your needs if your adviser is unavailable;

• referral partners, but only with your consent;

• companies or individuals who carry out compliance reviews and audits that are necessary or desirable under the law on our behalf;

• companies, agencies or individuals that maintain databases against which your identity may be verified, such as the Department of Internal Affairs and the New Zealand Transport Agency;

• courts, tribunals and regulatory authorities — such as the Financial Markets Authority, the Ministry of Justice and the New Zealand Police — where we are required or permitted by law;

• our independent dispute resolution scheme, [scheme name — confirm], where you make a complaint;

• the Office of the Privacy Commissioner, where a complaint relates to a breach of the Privacy Act 2020, or where we are required to notify a privacy breach;

• the National Cyber Security Centre (NCSC) and any other person or agency we believe could assist in responding to a serious privacy breach or cyber security incident;

• an overseas privacy regulator, where a complaint relates to the actions of an overseas agency; and

• anyone else to whom you authorise us to disclose it.

Except as described above, we will not disclose your personal information without your written or verbal consent, unless we are required or permitted to do so by law. We do not sell your personal information.

If you would like a list of the lenders and insurers we may share your information with, and their contact details, please contact our Privacy Officer.

Overseas storage and disclosure

Some of the service providers we use — for example, for website hosting, email and cloud software — may store or process information outside New Zealand. Where this happens, we take reasonable steps to make sure your information is protected by safeguards comparable to those in the Act, or we will only disclose it where the Act otherwise allows.

Protecting your personal information

We take reasonable steps to keep your personal information safe from loss, unauthorised access, use, modification or disclosure, and other misuse. These include:

• holding client records in secure, access-controlled software;

• encryption of data in transit and during storage, with access only over secure network connections;

• limiting access to people who need it to do their work, and requiring them to keep it confidential;

• regular security audits of our software; and

• secure handling and storage of any paper records.

Storing and retaining your personal information

Your information is stored mainly in our secure client management software. All data stored online is backed up and can be retrieved in the event of data loss or corruption. Information given to us outside our software (for example on paper) may sometimes be held at our office at 1/35 Pah Road, Epsom, Auckland 1023.

We only keep personal information for as long as we need it for the purposes it may lawfully be used for, and to meet our legal and regulatory record-keeping obligations — generally at least seven years after our advice or services end [confirm with compliance]. After that, we securely destroy or de-identify it.

Accessing and correcting your personal information

Subject to certain grounds for refusal set out in the Act, you have the right to access the readily retrievable personal information we hold about you, and to ask us to correct it. Before we act on your request, we will need evidence to confirm that you are the person the information relates to.

We will respond to your request as soon as reasonably practicable, and no later than 20 working days after we receive it. We will not usually charge you for access.

If you ask for a correction and we think it is reasonable and we are reasonably able to change the information, we will make the correction. If we do not make the correction, we will tell you why, and you can ask us to attach a statement of the correction you sought to the information.

To make a request, email our Privacy Officer at amit@insuremymortgage.co.nz. Please include evidence of who you are and the details of your request (for example, the information you want, or the correction you are asking for).

Privacy breaches

We have processes in place to respond to a privacy breach. If one occurs, we will act promptly to contain it, assess it and reduce any harm. If a breach has caused, or is likely to cause, serious harm, we will notify the Office of the Privacy Commissioner and the affected people as soon as practicable, as required by the Act.

Our website and internet use

While we take reasonable steps to maintain secure internet connections, if you provide personal information to us over the internet, you do so at your own risk.

If you follow a link from our website to another site, that site's owner will have its own privacy policy. We suggest you review it before providing any personal information.

Our website uses cookies (small files that allow your browser to be recognised) and similar tools to help it work and to understand how it is used. You can disable cookies in your browser settings, although some features of the website may then not work.

We may use information about your use of our website and IT systems to prevent unauthorised access or attacks. We may use third-party suppliers to monitor our systems, and they will have access to monitoring and logging information as well as information processed on our website and systems.

We have a presence on social media sites such as Facebook, Instagram and LinkedIn. Information you share with us on those platforms is also subject to their own privacy policies.

Marketing

We may send you information about our services, market updates or reminders to review your lending and insurance. You can opt out at any time by using the unsubscribe link in our emails or by contacting us. Opting out of marketing will not affect service communications about your existing loans or policies.

Questions and complaints

If you have a question or concern about how we have handled your personal information, please contact our Privacy Officer first at amit@insuremymortgage.co.nz. We will acknowledge your complaint promptly, look into it, and let you know the outcome.

If you are not satisfied with our response, you can make a complaint to the Office of the Privacy Commissioner:

• Website: www.privacy.org.nz

• Phone: 0800 803 909

For complaints about our financial advice services more generally, please see our Disclosure Guide, which explains our internal complaints process and our independent dispute resolution scheme.