Website Privacy Policy

Last updated: 28/09/2025
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1. WHO WE ARE
Emerge Group Limited - trading as Emerge - is a registered financial services provider. Our registered address is Level 9, 110 Symonds Street, Auckland, New Zealand.

‍2. DEFINITIONS
In this document:

Emerge, ‘we’, ‘us’ or ‘our’ means Emerge Group Limited, a New Zealand registered company (company number 8060798 with NZBN 9429048472920) and registered on the Financial Services Provider Register (FSP1000546).

‘Our related companies’ means companies who are part of the same group.‘You’ and ‘your’ means you, as our customer and/or customer  or anyone else that provides personal information to us. If you give us information about another person, you must ensure you have their permission first.‘Privacy Act’ means the Privacy Act 2020 and any laws that change or replace it.

‍3. HOW OUR PRIVACY POLICY WORKS
At Emerge, we value your trust and respect your privacy.This privacy policy applies to all our products and services (even the ones you can use without paying) and all your interactions with us. That means using our apps and website, phone calls with us, in-app chat, SMS… Basically, everything.

4. OVERVIEW (OR THE TL;DR)
This privacy policy sets out how we collect, use, share and protect your personal information. Personal information includes any information that could identify you, for example: your name, and personal details like your address or phone number.
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We may collect personal information when you interact with us, such as in our online forms when you onboard with us, when you interact with our help chat functionality, when you interact with our website, social media, or when you use our apps.  We need your personal information  so we can provide you theEmerge products and services, to help us run and develop our business (such as improving our products and building new ones), and to meet our legal obligations. We only use information if we need to, or if the law requires us to.

You have the right to access your personal information. We respect the trust you give us to hold your personal information because we know that your information - and your privacy - are important. For more information on your rights, including how to make a request to access or correct your personal information, see point 10.

Get in touch if you have any questions (or problems). We’re completely open and straightforward about how we work with personal information.
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5. COOKIES
Emerge uses cookies to analyse website performance and improve our services. This data is anonymised and cannot be traced back to you or your device.

Third-party platforms

When you interact with our content through platforms like Meta or Google while logged in, those platforms may track your activity according to their own privacy policies. We don't control or store this data.

What we use cookies for:

Performance – understanding how visitors use our website so we can improve your experience

Marketing – measuring campaign effectiveness and delivering relevant content on our site and other platforms

You can manage cookie preferences in your browser settings anytime.

6. HOW WE’LL TELL YOU IF THIS PRIVACY POLICY CHANGES
We might change this privacy policy to reflect changes in our products and services, and changes in laws we have to comply with. We’ll tell you about those changes at least 14 days before they happen. If we have to make changes to protect the security of your information, or to comply with a change in the law, we can tell you after we’ve made the change. Our website will always have the current version of this privacy policy. Depending on how significant the changes are, we’ll tell you about changes either through a notice on our site, an email, or through our apps.

7. HOW WE COLLECT PERSONAL INFORMATION
We collect information when you interact with us, and from third parties. When you apply for Emerge, we collect information to help confirm your identity: Personal and contact details, signatures, your interactions with us. When you use Emerge, we collect the following information: Payment and transaction data including the amount, date, time, type, location, origin and recipients. Any audio recordings we make when you interact with us. Your views on Emerge and how we’re doing, or information that might help us better understand this.Information you give us to confirm or update our records. We collect personal information when you use our websites, apps, and social media profiles. This information could include your social media handles, IP address and location data from your devices. Sometimes our apps and websites have links to third-party apps and websites. We take care when we choose websites we link to, but we aren’t responsible for their content, accuracy, or privacy practices.

You can choose not to give us some of your personal information. However, if you don’t, we might not be able to: offer you the products, services or help that you want, confirm your identity, protect you against fraud, manage your products or services, respond to, or help out with your questions.
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8. HOW WE USE PERSONAL INFORMATION
We use your personal information when you apply, or join Emerge as a customer, and when you use Emerge. We also use this information to manage our business efficiently, and imagine, improve and build new products for you to enjoy.

We use your information to:

  • confirm your identity, process your application, and confirm your eligibility and comply with our legal obligations. We may also use the information to confirm you can act on behalf of another customer.
  • communicate with you about those products and services. We’ll keep a record of how we can contact you – for example, by email, phone, or text.  This may include marketing messages (where you’ve agreed to receive them), or operational messages (such as information about your account). We use your personal information to decide what messages are right for you and how to communicate best with you. You can opt out of our email marketing by: clicking the ‘unsubscribe’ links when you get marketing emails. If you do opt out, you will still receive operational messages;
  • provide you with our products and services, including making and managing payments, protecting you from fraud, and keep transaction records;
  • keep people safe – for example, by helping the police get in touch with people if they need to track payments and transactions.
  • Improve our business and products/services – for example, we may use recorded calls for staff training and quality improvement, add new features to our products or services, and develop new products or services make sure we can correct any errors in the services you have received, such as contacting you to arrange refunds, come up with ideas on ways to help people be great with money. 
  • to comply with our obligations to agencies that prevent or investigate unlawful activities like fraud, money laundering or other illegal activities to regulatory or government bodies like Inland Revenue and the police under the Anti-Money Laundering and Counter Financing of Terrorism Act 2009.

9. WHEN WE SHARE PERSONAL INFORMATION AND WHO WE SHARE IT WITH
We share information with Emerge group companies and, where required, other third parties. We only share personal information when we’re allowed to under New Zealand, or when we’re legally required to.

We share personal information with third parties who aren’t Emerge group companies when:

  • We need to protect you, or our business interests – for example, to identify transactions that may be fraudulent;
  • We verify your personal information, we will share your information with the relevant agency such as NZ Transport Agency Waka Kotahi, the Department of Internal Affairs, Companies Office, or MyMahi. 
  • we defend or enforce our rights  – for example, to collect money owed to us.
  • The third party is providing us services to enable us to provide our products and services, such as cloud storage providers, our partner financial institutions (such as Mastercard and ANZ).
  • The law requires us to share information with the New Zealand police, Inland Revenue Department or similar. 
  • You have explicitly consented, such as when you would like to take up  a third party offer made to our customers.

Some of the organisations we share information with may be overseas. We only do so where these organisations agree to comply with the NZ Privacy Act.

10. HOW WE PROTECT YOUR PERSONAL INFORMATION
At Emerge, your privacy is important to us, and we take protecting your personal information seriously. We store personal information electronically, in facilities in New Zealand and overseas that we manage, or, that are managed by third parties, for example, cloud storage like AWS.

We protect your information in a range of ways: We have a cybersecurity policy to look after and protect your information. This helps us prevent, detect and respond to cybersecurity events and incidents. We check third parties we share personal information with, to make sure they work to agreed standards. When we transfer your information outside Emerge, it may be to a company in New Zealand or overseas. Our contract with the company will require the company to protect your personal information to the same standard as the NZ Privacy Act. 

We’ll always use reasonable security safeguards - for example, file encryption, to protect your personal information. 

If we believe that there has been a privacy breach, we’ll identify the issue and take steps to minimise any harm. If we believe the breach has caused, or is likely to cause serious harm, we’ll contact the Office of the Privacy Commissioner. We’ll also contact customers who may be affected by the breach.

If you believe there has been a privacy breach, please contact us as soon as possible.
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We’re required to collect and  hold personal information by the Companies Act 1993, the Anti-Money Laundering and Counter Financing of Terrorism Act 2009, the Financial Transactions Reporting Act 1996, and other New Zealand and international laws. We usually have to hold personal information for at least 7 years. But we have to keep certain types of information for longer, even if you’re no longer a customer.


11. YOU HAVE THE RIGHT TO ACCESS AND CORRECT YOUR PERSONAL INFORMATION
You have the right to request access to or correct your personal information. You can also request to access, or correct someone else’s information if you have legal authority – for example, if you have a power of attorney.

In most cases you can access or correct your information yourself and you won’t need to ask our help. The fastest way for you to access or correct your information is via our apps. Or you can contact us, and we’ll gladly do it for you. If the information you want is unusual, complex or sensitive, you may need to make an official request for your personal information so we can gather it for you. You can do this by contacting us. Please tell us if your request is urgent, and why, and we’ll take this into account, and keep you updated through the process. Depending on the volume and format of the information requested, you may be charged an administrative fee. 


12. HOW TO GET IN TOUCH WITH US
If you have any questions, feel your privacy has been compromised in any way, or want to make a complaint, please contact us: 

In our apps

by email, at hello@emerge.nz

by letter at: Emerge, Level 9, 110 Symonds Street, Gafton, Auckland 

If you’ve been through our complaints and resolution process but aren’t satisfied, you can use one of these independent dispute resolution services:To escalate a privacy complaint, contact the Office of the New Zealand Privacy Commissioner:

Online: privacy.org.nz
Phone: 0800 803 909(From overseas) +64 (0)4 474 7590Email: enquiries@privacy.org.nz
Have a general complaint you think deserves escalation? Sorry to hear that and we’ll work hard to fix things.We’re really confident we can get you to a happy place! But if for some strange reason, we can’t agree on how to resolve things, you can contact Financial Services Complaints Limited. FSCL are an independent, not-for-profit, external dispute resolution scheme, approved by the Minister of Consumer Affairs.FSCL’s service does not cost you anything and they’ll help resolve the complaint. You can contact FSCL by:Phone: 0800 347 257Email: complaints@fscl.org.nzThrough FSCL’s website: www.fscl.org.nz
By writing to: FSCL PO Box 5967 WELLINGTON 60112_DEFINITIONS