UNO Society Privacy Statement

Introduction

UNO Society Limited ("UNO Society", "we", "us", or "our") is committed to protecting the privacy, confidentiality, and security of personal and business information in accordance with the Privacy Act 2020 (New Zealand).

This Privacy Statement explains how we collect, hold, use, disclose, process, and protect information in connection with our consumer and commercial lending activities, related financial services, business operations, digital platforms, and interactions with customers, applicants, referral partners, employers, guarantors, and other third parties.

This Privacy Statement applies to information collected through our website, online forms, mobile or digital applications, referral arrangements, email communications, customer support interactions, automated systems, and any other interaction with UNO Society.

By engaging with UNO Society, applying for services, or providing information to us, you acknowledge and agree to the practices described in this Privacy Statement.

Information We Collect

We may collect personal and business information reasonably necessary to provide lending and related financial services, manage customer relationships, comply with legal obligations, and operate our business.

Identity and Contact Information

This may include:

• full name;
• date of birth;
• gender;
• residential or postal address;
• phone number;
• email address;
• driver licence details;
• passport details;
• government-issued identification numbers; and
• other identity verification information.

Business Information

This may include:

• company or trading name;
• NZBN;
• business structure;
• ownership and shareholding information;
• trustee and beneficial ownership details;
• financial statements;
• bank statements;
• GST information;
• trading history;
• business performance information; and
• related business records.

Financial and Credit Information

This may include:

• income and employment information;
• assets and liabilities;
• repayment history;
• transaction information;
• banking information;
• credit reports;
• credit scores;
• affordability information; and
• other information relevant to assessing financial position or creditworthiness.

Director, Shareholder, Trustee, and Guarantor Information

We may collect personal and financial information relating to company directors, trustees, shareholders, beneficial owners, or guarantors where relevant to assessing or administering a lending relationship.

Transactional and Account Information

We may collect information relating to:

• applications;
• repayments;
• account activity;
• communications;
• service interactions; and
• operational records associated with your relationship with UNO Society.

Device and Usage Information

When you interact with our website or systems, we may collect:

• IP address;
• browser type;
• operating system;
• device identifiers;
• access times;
• geolocation data where permitted; and
• website or application usage information.

Cookies and Analytics

We may use cookies, analytics tools, pixels, tracking technologies, and similar technologies to:

• improve website functionality;
• monitor system performance;
• understand user behaviour;
• support security and fraud prevention;
• personalise content and communications; and
• support marketing and advertising activities.

You may disable cookies through your browser settings, although this may affect functionality of certain services or website features.

Indirect Collection of Personal Information

In some circumstances, UNO Society may collect personal or business information about you from third parties rather than directly from you.

These third parties may include:

• employers;
• recruitment agencies;
• introducers or referral partners;
• brokers;
• credit reporting agencies;
• trade references;
• finance partners;
• guarantors;
• company directors or shareholders;
• trustees;
• professional advisers;
• publicly available registers or databases; and
• other lawful sources relevant to assessing or managing a lending relationship.

This information may include identity information, employment information, financial information, business information, credit information, or other information relevant to assessing or administering services provided by UNO Society.

Where required under the Privacy Act 2020, including Information Privacy Principle 3A ("IPP3A"), we will take reasonable steps to notify you as soon as reasonably practicable after collecting your information indirectly.

Such notification may include:

• the fact that information has been collected;
• the purpose of collection;
• the intended recipients of the information;
• the name and address of the agency holding the information;
• your rights of access and correction; and
• any other information required under the Privacy Act 2020.

Notification may occur directly, electronically, verbally, through linked privacy notices, through our application processes, or through the third party providing the information where appropriate.

In some circumstances, the Privacy Act 2020 permits exceptions to notification requirements, including where:

• you have already been informed;
• the information is publicly available;
• compliance is not reasonably practicable;
• notification would prejudice the purpose of collection;
• notification would prejudice law enforcement activities; or
• another lawful exception applies.

Purpose of Collection

We collect, hold, and process information for legitimate business and legal purposes, including:

Provision of Services

To evaluate, process, approve, administer, and manage:

• consumer lending;
• commercial lending;
• asset finance;
• bridging finance;
• working capital facilities;
• acquisition funding; and
• related financial services.

Customer Communication and Relationship Management

To:

• respond to enquiries;
• provide updates and notifications;
• manage customer relationships;
• deliver customer support; and
• communicate regarding applications, accounts, products, and services.

Credit Assessment and Risk Management

To:

• verify identity and financial position;
• assess suitability and affordability;
• evaluate creditworthiness;
• monitor lending risk;
• manage repayment obligations; and
• protect against fraud or financial crime.

Compliance and Legal Obligations

To comply with obligations under applicable laws and regulations, including:

• Privacy Act 2020;
• Credit Contracts and Consumer Finance Act 2003;
• Anti-Money Laundering and Countering Financing of Terrorism Act 2009;
• Financial Markets Conduct Act 2013;
• Financial Service Providers (Registration and Dispute Resolution) Act 2008; and
• other applicable laws, regulatory requirements, and industry obligations.

Fraud Prevention and Security

To detect, investigate, prevent, and manage:

• fraud;
• cybersecurity threats;
• unlawful conduct;
• suspicious transactions;
• unauthorised access; and
• operational or financial risks.

Marketing, Research, and Business Improvement

To:

• communicate products, services, or opportunities that may be relevant to you;
• conduct market research;
• improve customer experience;
• undertake analytics and reporting; and
• improve our products, systems, services, and operational performance.

You may opt out of marketing communications at any time where applicable.

Use of Personal and Business Information

We may use information collected by UNO Society to:

• facilitate lending and related financial services;
• assess and manage lending relationships;
• verify information provided to us;
• communicate with customers and third parties;
• conduct internal administration, auditing, and reporting;
• improve products, services, systems, and processes;
• manage legal or regulatory obligations;
• enforce agreements and recover debts;
• protect our legal rights and interests; and
• support operational decision-making and risk management activities.

Artificial Intelligence and Automated Processing

UNO Society may use artificial intelligence ("AI"), machine learning technologies, automated systems, and related digital tools to support our operations, service delivery, compliance functions, risk management activities, and customer experience.

These technologies may be used for purposes including:

• assisting with loan and credit application processing;
• analysing financial, identification, or supporting documentation;
• conducting fraud detection and risk monitoring;
• identity verification and compliance screening;
• supporting customer communications and service interactions;
• document drafting, summarisation, transcription, and workflow automation;
• operational analytics and reporting;
• identifying trends, anomalies, or risk indicators;
• improving efficiency, consistency, and service delivery; and
• enhancing our systems, products, internal processes, and operational capabilities.

This processing may involve information being processed, analysed, or stored using third-party technology providers, cloud-based systems, software platforms, or AI-enabled service providers engaged by UNO Society.

Where third-party providers are engaged, UNO Society takes reasonable steps to ensure those providers are subject to appropriate confidentiality, privacy, data protection, and security obligations.

Where commercially and technically practicable, UNO Society seeks to use AI and technology providers that provide contractual or technical controls designed to prevent customer information processed through those systems from being used to train publicly available, shared, or third-party artificial intelligence models.

For example, UNO Society may use enterprise AI environments or business-grade technology platforms that provide protections restricting customer or workspace data from being used for general AI model training.

UNO Society also maintains internal controls and processes intended to support the secure, responsible, and commercially appropriate use of AI-assisted technologies in connection with customer information and commercially sensitive data.

UNO Society does not solely rely on fully automated decision-making for material lending decisions affecting individuals. Relevant lending decisions, assessments, approvals, declines, or risk determinations may involve human review, oversight, and discretion.

AI-generated outputs, recommendations, analyses, summaries, or insights are used as decision-support tools only and may be reviewed, verified, amended, or overridden by UNO Society personnel.

We may use information processed through AI-enabled systems to:

• improve operational efficiency;
• maintain service quality;
• support compliance activities;
• reduce fraud and financial crime risk;
• improve customer experience; and
• develop or enhance products and services.

Where information is processed using systems or providers located outside New Zealand, UNO Society will take reasonable steps to ensure the information is protected in a manner consistent with the Privacy Act 2020 or subject to comparable safeguards.

By engaging with UNO Society, applying for services, or providing information to us, you acknowledge and authorise the use of automated systems, AI-assisted technologies, and related digital processing tools for the purposes described in this Privacy Statement.

Data Sharing and Disclosure

We do not sell identifiable personal or business information. However, we may disclose information where lawful, reasonably necessary, or connected with the operation of our business and services.

Third-Party Service Providers

We may engage trusted third-party providers to support our operations, including:

• cloud hosting providers;
• software providers;
• AI technology providers;
• workflow automation providers;
• payment processors;
• data storage providers;
• customer support providers;
• analytics providers;
• identity verification providers;
• compliance service providers; and
• information technology providers.

These providers are required to protect information and only use it for authorised purposes.

Employers and Referral Partners

We may collect, use, and disclose information with employers, recruitment agencies, introducers, referral partners, or brokers where reasonably necessary for purposes connected with a lending relationship, including:

• verifying employment or income;
• confirming application information;
• administering referral or employer-supported lending arrangements;
• managing repayment arrangements authorised by you; or
• assessing or managing credit risk.

We will not disclose unrelated or sensitive personal information without lawful authority, consent, or another lawful basis under the Privacy Act 2020.

Credit Reporting Agencies and Finance Providers

We may disclose information to:

• credit reporting agencies;
• finance providers;
• funding partners;
• debt collection agencies;
• trade credit providers; and
• other lenders or financial institutions,

for purposes including:

• credit assessment;
• account management;
• fraud prevention;
• collections;
• funding arrangements; and
• risk management.

Credit reporting agencies may retain information provided to them and use it in accordance with their own privacy policies and applicable laws.

Professional Advisers

We may disclose information to:

• accountants;
• auditors;
• legal advisers;
• trustees;
• insurers; and
• other professional advisers,

where reasonably necessary in connection with services provided to UNO Society or to you.

Research, Analytics, and De-identified Data

UNO Society may compile, analyse, use, share, commercialise, license, or otherwise utilise aggregated or de-identified information that does not reasonably identify an individual or business.

This may be used for:

• analytics;
• benchmarking;
• service improvement;
• operational insights;
• reporting;
• product development;
• research; and
• commercial purposes.

UNO Society retains ownership of lawfully created de-identified datasets.

Legal and Regulatory Requirements

We may disclose information where required or permitted by:

• law;
• regulation;
• court order;
• regulator;
• government agency; or
• enforcement authority,

or where reasonably necessary to:

• protect our legal rights or interests;
• protect the safety or security of individuals;
• prevent fraud or unlawful conduct; or
• enforce agreements or obligations.

With Your Consent

We may disclose identifiable information where you have expressly authorised us to do so.

Overseas Disclosure and Storage

Some providers, systems, or technology platforms used by UNO Society may store or process information outside New Zealand.

Where information is transferred overseas, we will take reasonable steps to ensure the recipient protects the information in a manner consistent with the Privacy Act 2020 or is otherwise subject to comparable safeguards.

Data Security

UNO Society implements reasonable technical, administrative, organisational, and physical safeguards designed to protect information against:

• unauthorised access;
• misuse;
• disclosure;
• alteration;
• interference;
• loss; or
• destruction.

Security measures may include:

• encryption;
• access controls;
• authentication measures;
• firewalls;
• secure hosting environments;
• monitoring systems;
• confidentiality obligations; and
• staff training and governance controls.

Despite these measures, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

Access and Correction

You may request access to personal information we hold about you and request correction of inaccurate, incomplete, or outdated information.

Requests may be made using the contact details below.

We may require verification of identity before processing requests and may charge a reasonable fee where permitted by law.

Retention of Information

UNO Society retains information only for as long as reasonably necessary to:

• fulfil the purposes for which it was collected;
• comply with legal or regulatory obligations;
• resolve disputes;
• maintain records; and
• enforce agreements or legal rights.

Retention periods may be influenced by obligations under:

• Privacy Act 2020;
• Anti-Money Laundering and Countering Financing of Terrorism Act 2009;
• Companies Act 1993;
• Financial Service Providers (Registration and Dispute Resolution) Act 2008; and
• other applicable laws or regulations.

When information is no longer required, we will securely destroy, delete, anonymise, or de-identify it.

Your Rights Under the Privacy Act 2020

You may have the right to:

• access personal information we hold about you;
• request correction of inaccurate or incomplete information;
• object to direct marketing communications;
• withdraw consent where consent applies;
• make a complaint regarding our handling of your information; and
• seek further information regarding privacy practices at UNO Society.

If you believe your privacy has been breached, you may contact us directly or lodge a complaint with the Office of the Privacy Commissioner at: www.privacy.org.nz

Changes to This Privacy Statement

UNO Society may update this Privacy Statement from time to time to reflect changes in:

• legislation;
• regulation;
• regulatory guidance;
• technology;
• operational practices; or
• our services.

Updated versions will be published on our website and will take effect from the date of publication.

Contact Information