This Privacy Policy governs the use of your personal information by Debut Limited (Debut).
We must comply with our obligations under the Privacy Act 1993, and from 1 December 2020, the Privacy Act 2020 (as relevant, the Privacy Act) when dealing with your information. When we say “your information” in this privacy policy, we mean personal information as defined in and protected by the Privacy Act. Any personal information you provide to use will be stored, used and disclosed by us in accordance with this Privacy Policy.
Your information will be collected and held by:
Debut Limited, 155 Fanshawe Street, Auckland CBD, Auckland 1010.
Acceptance of this privacy policy
You accept this Privacy Policy, and authorise the collection, use, disclosure, storage and retention of your information by Debut as described in this Privacy Policy when you access or use the Service or otherwise provide us with any of your information.
What information we can collect about you
We collect information you give us.
When you create your Account and use our Service, we may collect information from you, such as: name, date of birth, email, phone number, address, photo ID, bank information, account information, communication transcripts of support enquiries you may make and feedback on our Service.
You are not required to provide us with your information. However, if you don't, or we can't otherwise collect your information, it may affect our ability to do business with you and perform the services set out below.
We collect information created when you use the Service.
We may collect information about you when you use the Service, such as the details of your deposits, withdrawals, investment options, and information on how you interact with our Service.
We collect information from third parties
We may collect information about you from third parties, for example from service providers that help us to verify your identity, or make or receive payments from you, or to provide onboarding or marketing services. We may also collect information about you from publicly available sources.
How we can use your information
We use your information in accordance with your specific instructions or consent, or in accordance with this Privacy Policy, including for the following purposes:
We can use your information to provide the Service
We use your information to provide, personalise, maintain, and improve our Service. For example, we may use your information to create and update your account, verify your identity, process payments, improve operational processes, tailor investment opportunities provided to you and carry out testing and research.
We can use your information to keep things safe, secure and legal.
We may use your information to detect, prevent, and protect against fraud and crime and to comply with the Law.
We can use your information for customer support.
We may use your information to communicate with you to provide and improve our customer support and resolve disputes.
We can use your information for research and development.
We can use your information to test, research, analyse, and develop our Service to make it better, safer, and easier to use. We may use your information to create our own market data and for making comments about the market. We may use your information to obtain your feedback through a third party.
We can use your information to promote Debut and other stuff we think you’ll like.
We can use your information to send targeted emails, text messages, ads, and other content about our Service or the services of our business partners.
Who we can share your information with.
We may share your information with our service providers, subsidiaries, and business partners, such as:
- members of the Debut Group in connection with the purposes set out in this Privacy Policy;
- third parties that help us to carry out the Service (for example, to verify your identity, custody of funds, or complete payments);
- software-as-a-service providers that we use to provide the Service (for example, our customer experience analytics platform provider or customer service platform provider);
- cloud-storage providers;
- marketing partners;
- data analytics or research partners;
- third parties that help us to enhance the safety and security of the Service;
- where required, to the regulators (for example, FMA);
- with third party providers (such as Google, Facebook and programmatic display) for marketing purposes; and
- our consultants, lawyers, accountants, insurers, and professional advisors.
Some of these service providers, subsidiaries and business partners are located outside of New Zealand and may not be subject to New Zealand privacy laws. However, we will take such steps as are reasonable in the circumstances to confirm that those organisations are required to protect the information in a way that, overall, provides comparable safeguards to those under the Privacy Act. By using the Service and otherwise providing us with your information, you authorise such disclosure.
We may also share your information if we believe it’s allowed by Law or is appropriate due to fraud, security, or similar concerns. If you use another person’s credit card, payment or other information, we may share your information with that person.
We may share your information if we sell to, or merge some or all of our business or assets with, another company.
We can also use and share your information in other ways if you give your consent.
We can use and share information that does not identify you for any purpose.
A note on cookies and similar tech
Cookies and other similar technology are used to remember your browser or device during and between website or app visits. Our Service may include cookies and other tech with a similar purpose. We can use this technology to do things, such as remember your preferences and settings, improve security, analyse traffic and trends, and measure the effectiveness and popularity of features or marketing.
This technology is linked to your browser or device and usually it doesn’t identify you. The sort of information collected includes your device type, date and time of use, referring website, IP address, and advertising identifiers. We may link this information to other information we collect about you.
We may allow others to provide analytics, send messages and ads for us, and to track and report on performance. These entities may use cookies and other similar tech to identify your browser or device when you use our Service, as well as when you visit other online sites and services.
Retaining and deleting your information
We may keep your information:
- for as long as you have an Account;
- for a minimum of 7 years (after your Account is closed) to comply with regulatory, tax, insurance, and other requirements;
- for as long as we believe necessary for the purposes set out in this Privacy Policy; or
- for an indefinite time if we believe necessary, for example for fraud prevention, safety, and security.
We’re committed to keeping your information safe and secure.
We continuously implement and update security measures to help protect your information. However, despite all of our measures, we can’t guarantee the security of the transmission or storage of your information.
Your rights regarding your information
You may:
- withdraw any consents given in relation to the handling by us of your information;
- request access to your information (we may charge a fee); or
- request that we correct information that is inaccurate or out of date,
by contacting our Privacy Officer using the details at the bottom of this Privacy Policy. We will take reasonable steps, consistent with our obligations under the Privacy Act, to correct or update that information if you so request.
If at any time you no longer wish to receive any additional marketing emails from us or our business partners, or do not want your information disclosed for direct marketing purposes, contact our Privacy Officer using the details at the bottom of this Privacy Policy. Alternatively, you can opt out using the function in any electronic marketing communications sent from us or our business partners.
Third-party links
Our Service may contain links to third-party websites. Our terms don't apply to any third-party websites. We take no responsibility for the content, operation, or privacy practices of other websites.
Changes to our Privacy Policy
This document sets out our current Privacy Policy, last updated 10 April 2022. We may review this policy from time to time and will notify you of any changes by posting an updated version on our Website.
Contact Us
If you have any questions regarding our Privacy Policy or wish to access or amend the information that we hold about you, please contact our Privacy Officer at:
Attention: The Privacy Officer
Email: contact@getdebut.app
If you have concerns that we have not met our obligations to you as required by the Privacy Act and the Information Privacy Principles of that Act, you may contact us and make a complaint at the address and/or email listed above.
More information about your rights and our obligations in respect to privacy and information on making a privacy complaint are available from the Office of the Privacy Commissioner at:
Website: www.privacy.org.nz
Email: investigations@privacy.org.nz
