Flexy Privacy Policy

Effective Date: 1 August 2025

Flexy Limited (“we”, “us”, “our”) is committed to protecting the privacy of our clients, investors, and website visitors. This Privacy Policy explains how we collect, use, store, and share your personal information in accordance with the Privacy Act 2020 and other applicable New Zealand laws, including the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act).
 

By providing your personal information to us, you agree to the terms of this Privacy Policy.

1. Information We Collect
 

We collect personal information that is necessary to:

• Provide lending and investment services

• Comply with our legal and regulatory obligations, including AML/CFT requirements

• Improve our services and manage client relationships

The personal information we may collect includes:

• Name, date of birth, and contact details

• Identification documents (e.g., passport, driver licence)

• Proof of address (e.g., utility bill, bank statement)

• Financial information (e.g., bank account details, income, assets, liabilities)

• Credit history and credit reports

• Business information (for company or trust clients)

• Any other information required to meet our obligations under the AML/CFT Act

We may collect this information directly from you, through your authorised representatives (such as brokers or solicitors), or from third parties including credit reporting agencies, government registers, and AML verification service providers.

2. How We Use Your Information

We use your personal information to:

• Assess and process loan and investment applications

• Verify your identity and conduct customer due diligence (CDD) as required by law

• Monitor transactions for suspicious activity

• Communicate with you about your account, transactions, or our services

• Meet our obligations to regulators, auditors, and service providers

• Manage risk, prevent fraud, and protect our business interests

3. Disclosure of Your Information

We may share your personal information with:

• Our employees, contractors, and related companies

• Authorised brokers, advisers, or solicitors acting on your behalf

• Service providers including AML/CFT verification providers, credit agencies, cloud hosting providers, and IT support

• Banks and payment processors to facilitate transactions

• Regulatory bodies such as the Department of Internal Affairs, Financial Markets Authority, Reserve Bank of New Zealand, or the Police Financial Intelligence Unit, as required by law

• Third parties where required to comply with our legal obligations or to enforce our agreements

We do not sell your personal information to third parties.

4. AML/CFT Compliance

Under the AML/CFT Act, we are required to:

• Conduct identity verification and customer due diligence

• Keep records of the information collected for at least five years after the end of our relationship with you

• Report suspicious activities and prescribed transactions to the appropriate authorities

Failure to provide the information we request may mean we are unable to provide our services to you.

5. Storage and Security

We store your personal information securely in electronic or physical form. We take reasonable steps to protect your information from loss, misuse, unauthorised access, alteration, or disclosure.

Where we use third-party service providers (including those located overseas), we ensure they are subject to privacy and security obligations that are at least as strict as those under New Zealand law.

6. Access and Correction

You have the right to request:

• Access to the personal information we hold about you

• Correction of that information if you believe it is inaccurate, incomplete, or outdated

Requests should be made in writing to our Privacy Officer (contact details below). We may require verification of your identity before processing your request.

7. Website and Cookies

When you visit our website, we may collect information about your device, browser, and browsing behaviour using cookies or similar technologies. This helps us improve our website and tailor content to you. You can disable cookies in your browser settings, but some site features may not function properly as a result.

8. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes to our practices or legal obligations. The updated version will be published on our website with the effective date.

9. Contact Us

If you have any questions about this Privacy Policy or our handling of your personal information, please contact:

Privacy Officer – Flexy Limited
Email: hello@flexy.co.nz
Phone: 021 294 8742