Afirmo NZ Limited – Privacy Policy

  1. Your privacy: Afirmo NZ Limited (Afirmo, we or us) is committed to ensuring the privacy of your information, and to meeting the requirements of the New Zealand Privacy Act 2020. We want to make sure that you understand how we collect and treat personal information in the course of your use of the Afirmo platform, so please read this Privacy Policy carefully.
  2. Application of this Privacy Policy: This Policy applies to all personal information that you submit on or through the Afirmo platform (regardless of which tools you use or whether you access via your web browser or the Afirmo app) (the Services), and any information that may be automatically retrieved through your use of the Afirmo app and website. This Policy should be read in conjunction with our Terms and Conditions, and terms which are defined in those Terms shall have the same meaning when used in this Policy.
  3. Changes to this Privacy Policy: We are a new service, so we keep our Privacy Policy under regular review and may change it at any time (for example, as we add new functionalities and Services).  We will provide notice of such changes to this Privacy Policy on our website at and, for significant changes, either when you next sign into the platform or by email to you.  By continuing to use the Services after a change, you are acknowledging and agreeing to the changes in the amended Privacy Policy.This version was last updated on 12 August 2022.
  4. Types of personal information: There are two broad types of personal information that we may receive in the course of our relationship with you, as a user of the Services:
    1. information about users of the Service, collected when an account is registered and an Afirmo Business Profile is created, and when the Services are used (e.g., names and email addresses of users of the Services) (User Information); and
    2. personal information which may be incorporated in information that users choose to input into or store on the Services (e.g. names of your current or prospective customer contacts) (Customer Data).

    This Policy applies to both User Information and Customer Data, but each type of information is used in a different way (as described in this Policy).  Importantly, you remain responsible for any Customer Data that you choose to input into the Services, so it is your responsibility to ensure that use of the Services in respect of that Customer Data is carried out in a way that complies with laws applicable to you.

  5. Your consent: By accessing or using the Services or the Afirmo website or app, you consent to the collection, use, disclosure, storage and processing of User Information and Customer Data in accordance with this Policy.


  1. What User Information we collect: We collect User Information about you when you register an account and use the Services.  The User Information we collect includes:
    1. identity and contact details (for example, names, dates and cities of birth, addresses, phone numbers, email addresses, IRD numbers) (certain modules);
    2. financial information including bank account and payment card details (certain modules), and information collected from our third-party service providers which may include your balance, transaction, and identity-related data from connected financial accounts;
    3. usage information (for example, traffic volumes, time spent on pages and which Services you use) (certain modules);
    4. technical information including your IP address and/or other device identifying data (to help detect unauthorised account use);
    5. information available from public sources (for example, the Companies Register);
    6. information that you disclose to third party providers of the Services (Service Partners) in the course of using such Services (for example, information relevant to the Afirmo insurance services including insurance policy details, criminal history and claims history); and
    7. any other information that you may disclose to us during the course of our relationship with you.

    You are under no obligation to provide us with any such information.  However, if you choose to withhold requested information, that may impact our ability to provide you with the Services.  For example, we need to hold certain minimum information about users in order to maintain access controls to the Services and for security and user verification purposes.

  1. What we do with the User Information we collect: We will use the User Information we collect to:
    1. provide the Services;
    2. identify you when you sign-in to your account and verify that your account is not being used by others;
    3. communicate with you in relation to the Services and related issues (for example, quotes for other services, support requests and billing matters);
    4. carry out research and marketing analysis so we can better understand and serve you;
    5. monitor and enforce compliance with the law and applicable terms and conditions;
    6. continually improve our website and the Services;
    7. verify and carry out financial transactions in relation to services we provide; and
    8. co-operate with any government, industry or regulatory authorities where required or permitted by applicable law.
  2. Disclosures of User Information: Unless you have authorised us to do so, we will not rent or sell any User Information and will not disclose it to any third party except:
    1. where disclosure is connected to the purposes for which the information was collected as listed in clause 6;
    2. to our third-party service providers (such as hosting providers and Service Partners) in connection with the purposes described in clause 6. Those third parties include our hosting provider Amazon Web Services Australia Pty. Ltd., which is located in Sydney, Australia;
    3. to relevant authorities, parties and/or applicable intellectual property rights holders (or their representatives) if we consider that you are in breach of the law or our rights;
    4. to comply with our legal, regulatory, tax and/or accounting requirements; or
    5. to Afirmo group companies in the normal course of business; or
    6. where required, or permitted, by law.

    We may choose to sell our business.  In these types of transactions, User Information is typically one of the business assets transferred to the third party purchaser.  You acknowledge and agree that such transfers may occur, and that any acquirer of us or our assets may continue to use your User Information as set out in this Policy.


  1. What Customer Data we hold: If any Customer Data you input into the Services includes personal information, then we will hold that personal information on your behalf.  Typically, we would expect that users might include your customer’s names, contact details and invoice details as personal information within Customer Data.We have no control over what personal information you choose to include within Customer Data, so it is important that you are satisfied that the level of security we are able to offer, and the terms of this Policy, are adequate and appropriate with regard to the sensitivity of that personal information.
  1. What we do with Customer Data: Customer Data remains your property.  We will only use your Customer Data for the purposes of providing the Services and providing aggregate information to users for customer trends.
  2. Disclosures of Customer Data: Unless you have expressly authorised us to do so (or where we’re required to do so by law), we will not rent, sell or disclose any Customer Data to any third party.  You agree that:
    1. your Customer Data may be accessed by other users associated with your business on the Afirmo platform;
    2. your Customer Data will be stored and may be accessed by our third-party service providers (such as hosting providers and Service Partners) for the purposes of delivering the Services to you [and/ or your business. Those third parties include our hosting provider Amazon Web Services Australia Pty. Ltd located in Sydney, Australia; and
    3. if we sell our business to a third party, then our rights and obligations in respect of your Customer Data (as set out in our Terms of Use) will be transferred to that third party.


  1. Cookies: We may use session-based cookies to collect information relating to usage of the Services and analyse website and API traffic. Cookies are small pieces of information that are stored in a browser-related file on your computer or device when you use the Services.  The cookies we use do not collect any personally identifiable information.
  2. Opting-out: You can unsubscribe from any marketing communications from us by following the instructions on any communications sent to you. You can also exercise this right at any time by contacting us using the details at the end of this Privacy Policy.
  3. Access and correction: You have rights under the Privacy Act 2020 to access and/or correct your personal information held by us at any time. You can do this by contacting us using the details at the end of this Privacy Policy.
  4. Storage and security of information: You should be aware that information transmitted over the internet is not always secure. We will take all reasonable steps to securely store any personal information we collect.  This information may (for the avoidance of doubt) be transferred and stored on servers outside of New Zealand.
  5. Retention of your information: We will only retain your personal information for as long as is required for any of the purposes described in clause 6 or 9 above.
  6. Third-party links: This website may include links to third-party websites, plug-ins and applications.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third-party websites and are not responsible for how they may use your personal information.
  7. Contact us: If you have any questions about this Privacy Policy or if you would like to request access to, or correction of, your personal information, you can get in touch by writing to us at:

    Afirmo NZ Limited

    Email address:

    Postal address: FAO Privacy Officer, Afirmo NZ Limited, Level 26, 188 Quay Street, Auckland, 1010, New Zealand

    There may be charges associated with providing copies of your personal information to you, where permitted by applicable law.  We will always advise you of those charges in advance.

  1. More information about privacy: This Privacy Policy is governed by New Zealand law.  For more information about privacy issues in New Zealand and protecting your privacy, visit the New Zealand Privacy Commissioner’s website:

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