Privacy policy
 

First Home Coach Limited trading as First Home Coach (“FHC” or “we”) value the privacy of anyone who visits our website https://partner.firsthomecoach.co.nz/ (Website) or App (together, the Platform).  

We are committed to ensuring that the confidentiality and security of your information is protected.  In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. 

This privacy policy covers how we process your personal information when you interact with our Platform and the rights you have in relation to your personal information. Please take a moment to familiarise yourself with our privacy policy and let us know if you have any questions.

This privacy policy is governed by New Zealand law.  When you use our Platform, you agree to the terms of this privacy policy.
 

1. “Personal information” and other defined terms

1.1. “Personal information” means any information that can identify you either directly or indirectly (i.e. by reference to other information we have access to).

1.2 The term “processing” includes the collection, storage, and all of the ways we use personal information when we provide the Platform to you.

1.3 “Data controller” means the entity which determines the purposes and means of the processing of personal information. For the purpose of this privacy policy, FHC is the data controller of your personal information collected through the Platform.
 

2. How we collect your personal information
 

2.1 Personal information you provide to us

We collect the following personal information you provide to us:

• Profile/identity information – We may collect your first name, last name, job title, employer (or contractor) and profile picture when you create a profile on our Platform;
   
• Contact information – We may collect your phone number(s), address(es) and email address(es) when you create a profile on our Platform;
   
• Log-in information – When you log-in to your profile we collect your username/email address, time of log-in, where you log-in from and the type of device you are using;
   
• Marketing/Communication information – When you sign up for a profile, we collect your preference in receiving marketing information and other information from us; and
   
• Customer support information – When you contact us for customer support, or you provide feedback we collect your name, email address, contact number and details of your query/feedback.
   

2.2 Personal information we may collect automatically

We may collect the following personal information automatically:

• Technical information – Each time you to log into your profile or when you interact with our Platform, we may collect technical information about your equipment, browsing actions and patterns.  This includes your internet protocol (IP) address, browser type and version and time zone settings, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Platform.  We collect this personal information by using cookies and other similar technologies.  Please refer to our cookies policy for further details on our use of cookies.
• Location – When you access our services through a location-enabled device, such as your mobile phone, we collect and process real-time GPS-based information about your device’s location. If you do not consent to us collecting location-based information you can either (a) disable the GPS or other location-tracking functions from your device if your device allows you to do this or (b) delete the app from your device.
   

2.3 Aggregated Information

• We also collect, use and share aggregated information such as “60% of our partners currently receive 5 referrals per week”.  Aggregated information could be derived from your personal information but is not personal information as this information will not directly or indirectly reveal your identity.  However, if we combine or connect aggregated information with your personal information so that it can directly or indirectly identify you, we treat the combined information as personal information which will be used in accordance with this privacy policy.
   

3. How we process your personal information

We set out the type of personal information we collect and the reason we process your personal information below.
 

3.1 Identity information

You will need to include personal information about your identity when you set up a profile on the Platform so that:

• the content you create is linked to your profile;
• you can contract with us under our Terms of Service;
• we can keep our records up-to-date and analyse how partners use our services;
• we can connect you with users of the Platform; and
• we can prevent fraud, money-laundering and counter the financing of terrorism.
   

3.2 Contact information

We collect your contact information so that:

• we can contact you with information that may be of interest and to alert you to updates with your profile;
• users of the Platform can contact you when they have requested your services; and
• we can respond to any queries that you may have.
   

3.3 Log-in information

We collect your log-in information so that:

• we can verify and grant you access to the Platform;
• keep your profile secure; and
• provide you with the Platform.
   

3.4 Marketing/Communication information

We collect your marketing and communication preferences so that:

• we can send you information about the Platform and other information that you may be interested in;
• we can keep our Platform updated and relevant, develop our business and inform you about our marketing strategy; and
• we can produce the Platform.
   

3.5 Customer support information/feedback

We collect customer support information/feedback from you to:

• respond to your queries or concerns; and
• improve our Platform.
   

3.6 Technical and location information

We automatically collect technical and location information from you to:

• administer and protect the Platform including troubleshooting, information analysis, testing, system maintenance, support, reporting and hosting of information;
• improve our website, products/services, marketing, customer relationships and experiences;
• provide of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise; and
• be able to comply with all legal obligations surrounding information collection, processing and retention.
   

4. How we may share your personal information

We may disclose or share your personal information with third parties in the following circumstances:

• With your consent. We may share your personal information with third parties, such as users of the Platform when you have provided your consent or requested us to do so.  
   
• Third party service providers.  We may share your personal information with companies who provide us with services so that we can administer the Platform.  We require such service providers to contractually commit to protect the security and confidentiality of personal information they process on our behalf.   
   
• Legal purposes.  Where it is legally required by a third party or law enforcement authority in any jurisdiction (in which case we will generally require a production order or similar court order unless necessary to prevent or lessen a serious threat to public health or public safety or the life or health of you or someone else).
   
• To enforce our rights, prevent fraud and for safety.  To protect and defend our rights, property or safety or that of third parties, including enforcing this privacy policy and any terms of use, or in connection with investigating and preventing fraud or other suspected illegality or security issues.
   
• To protect the Platform.  Where it is needed to detect, prevent or address fraud, security or technical issues.
   
• Business sale.  In the event we sell our business, we may disclose your personal information to the prospective buyer. If substantially all of our assets are acquired by a third party, your personal information will be one of the transferred assets.
   
• Aggregated or de-identified information.  We may disclose or use aggregated or de-identified information for any purpose. For example, we may share aggregated or de-identified information with business prospects, users of the Platform or partners.
   

5. Access and other rights   

We are committed to protecting and respecting your privacy; therefore, we have extended the following rights granted under the GDPR to all users of the Platform. Regardless of where you live, you can:

• ask to receive information regarding the nature, processing and disclosure of your personal information (right to information);
• request a copy of your personal information we hold (right to access);
• request that we update or correct your personal information held by us at any time (right to rectification);
• request, on legitimate grounds that we erase your personal information (right to erasure);
• request, on legitimate grounds that we restrict the processing of your personal information (right to restrict processing);
• ask for a copy of your personal information in a machine-readable form that supports re-use, and you can request that we transfer your personal information to another data controller (right to data portability);
• where our processing of your personal information is based solely on your consent (refer to paragraph 3 to understand the legal basis we process your personal information), you have the right to withdraw your consent at any time (right to withdraw consent). One we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to unless we have another legitimate basis for doing so; and
• raise a complaint with us or a supervisory authority relating to the processing of your personal information (right to lodge a complaint).

The contact details for any such requests are set out in paragraph 14 below.
 

6. Opt-out of marketing promotions

• You can ask us to stop sending you marketing messages at any time by clicking the “unsubscribe” button found within one of our marketing emails or by contacting us at any time.
• Where you opt-out of receiving these marketing messages, we will continue to retain other personal information provided to us as a result of interactions with us not related to your marketing preferences.
   

7. Age limit for our users

You must not use our Platform unless you are 18 years or older.  The Platform is not intended for children, and we do not knowingly collect data relating to children.
 

8.  Security

We take reasonable precautions, including administrative, technical, and physical measures, to safeguard your personal information against loss, theft, and misuse, as well as against unauthorised access, disclosure, alteration, and destruction. Unfortunately, no information transmissions over the Internet can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately. Our contact details are set out in paragraph 14 below.
 

9. Storage of personal information

We process and store your personal information both in New Zealand and on servers located overseas. We have two data stores (NZ CMS and Database) that hold personal information. The NZ CMS is hosted on a DigitalOcean server in Singapore. The Database is hosted on a Amazon Web Services server in Australia and the United Kingdom.  This means that personal information we hold may be transferred to, or accessed from countries other than New Zealand.  To the extent we transfer your information to any other country, we will put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected.
 

10. How long do we keep your personal information

We will retain your personal information for the period necessary to fulfil the purposes outlined in this privacy policy, subject to your right to withdraw consent as set out above.
 

11. Third-party sites and services

Our Platform may contain links to third-party websites, including social media platforms (such as Facebook, Instagram, Twitter, LinkedIn (Social Media Sites)), products, and services. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices.  We encourage you to learn about the privacy practices of those third parties.
 

12. Social Media Platforms

• When you post to one of our Social Media Sites, the personal information you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to submit in these instances. For example, if you list your name or upload a picture or video of yourself in a forum posting, that information is public. Please take care when using these features.
• To request the removal of your personal information from one of our Social Media Sites’ pages, please contact us using the information provided the “How to contact us” section. In some circumstances, we may not be able to remove your personal information. 
   

13. Updates

We may update this privacy policy from time to time by publishing an updated privacy policy on our Website.  We encourage you to check our Website regularly. We will notify you by email of any material changes to this privacy policy.
 

14. How to contact us

If you:

• have any questions or feedback about this privacy policy or your rights;
• would like to exercise any of your rights as set out above; or
• have a complaint,

You may reach us at hello@firsthomecoach.co.nz.
 

This policy was last updated on 3 June 2020.