Welcome to EverBright Finance!

We’re here to provide you with tools and services that are designed to help you make financial progress. Before you get started, we’d like to tell you more about what we do with information we collect about you.

When you use, access or interact with our Services (which we define for you in Section 1 of our Terms of Service, accessible here), you are agreeing to our Terms of Service and consenting to how we collect, share and otherwise use information about you as described in this Privacy Policy. Since we do collect information about you, you should also know we’re committed to securing our systems and the protection of your data.

What This Policy Covers

This Privacy Policy covers how EverBright Finance and its affiliated companies (collectively, “EverBright Finance,” “we,” “us” or “our”) collect, use, and share information in connection with your access and use of our Services. It does not cover the privacy practices of third parties that we do not own or control.

That said, you should know that we may provide third party content or links to third-party web sites or applications, or include features that allow you to connect your EverBright Finance account with your accounts with third parties, such as financial institutions or social media platforms like Facebook. When you leave our Services or interact with a third-party feature, you should also read the applicable third party’s privacy policies and terms of service to make sure you understand how they might collect and share information about you (everybody is different).

What Information We Collect

To put it simply, there are three main ways we collect information about you: when you give it to us, with automatic technologies and when we ask others for it. Allow us to explain.

Information You Provide to Us

You may provide information to us in various ways, such as through forms, features or other means offered through our Services. A couple of examples include information you provide to us when registering as a member, and feedback forms where you send us comments, questions, or other feedback. The types of information you provide us fits into two general categories:

• Personal Information: This is information that identifies you personally, such as your full name, street address, email address, Social Security number or phone number.
• Non-Personal Information: This is information about you or your household that doesn’t identify you personally, like your gender, income or what types of financial products you’re interested in.

When we combine information that isn’t Personal Information (like Non-Personal Information or Usage Information, which we explain below) with Personal Information, we treat it like Personal Information for as long as it is combined.

Information We Automatically Collect

In addition to information you provide to us, we automatically collect certain information about how you access and interact with our Services (“Usage Information”). This Usage Information is a key part of how we improve your EverBright Finance experience and provide you with more personalised insights and recommendations. We and our partners may use various technologies to collect and store Usage Information in connection with our Services. These may include things like cookies, browser web storage (e.g., HTML5), web beacons and similar technologies. There are three types of Usage Information we may collect:

• Device Information. This is information about how you access our Services, such as the operating system, hardware model, application or browser type and version, and unique identifiers associated with your device. We may also integrate with built-in device features (e.g., when you turn on fingerprint access for your EverBright Finance account).
• Log Information. There are certain pieces of information we automatically collect in system logs or similar files about how you interact with our Services, such as which features you visit or click on. This Log Information may also include things like your IP address, browser or device configuration, date and time of access and cookie information.
• Location Information. We may use certain information like your IP address or other Device Information or Log Information to estimate your location (e.g., your city or state). We may also request to use location-enabled services on your device (which typically provide GPS or Wi-Fi access point details) to enhance our Services. We will only use these location-enabled services on your device with your consent, though.

Information Third Parties Provide About You

Many of our features rely on information about you that we collect from third parties, such as the free credit reports and credit scores we request on your behalf from TransUnion and Equifax. We may also work with different third party partners to supplement the Usage Information and other information we collect directly from you. For example, our partners may provide us with information such as employment or income data, vehicle or driver information, or information about special offers available based on your credit profile so that we can give you more personalised recommendations. We might also collect information from other users like you through things like a member referral program.

How We Use the Information We Collect

We use the information we collect from you and third parties to operate our Services, communicate with you, conduct research and development to improve or enhance our Services and our users’ experience, and promote our Services. These are a few examples:

• To create your account and provide the Services to you. We use the information we collect to create and secure your account, create and maintain your Member Profile, and to provide the Services to you.
• To provide features to you, such as your free credit reports and scores. We use the information we collect to provide you with free credit reports and scores from our credit bureau partners. EverBright Finance offers much more than free credit reports and scores though; the information we collect also goes into developing and bringing you various other features like free credit monitoring, ID monitoring, tracking your spending, and personalised offer recommendations.
• To improve our recommendations and insights. The information we collect also helps us tailor our content and improve the way we match you to recommended offers or insights. We’re constantly working on ways to better identify and present the information that’s most relevant to you.
• To communicate with you. We use information we collect to provide you with member support or to send you things like service-related announcements, credit or ID monitoring alerts, recommendations, offers from our partners and other updates or promotions. Most of the time we’ll communicate with you by email, but we may also send you push notifications, browser notifications, or even snail mail.
• To conduct research and to improve and promote our services. We use the information we collect to conduct research and to improve or enhance and promote our Services.
• For legal reasons. We reserve the right to access, use, preserve, transfer or disclose, at any time without notice to you, any information (including Personal Information) as reasonably necessary to:
  • Comply with any applicable law, regulation, subpoena or legal process, or respond to any governmental requests and cooperate with law enforcement, if we believe such action is required or permitted by law;
  • Enforce our Terms of Service, including investigating any potential violations;
  • Protect the safety, integrity, rights or security of our members, our Services or equipment, or any third party; or
  • Detect, prevent or otherwise address fraud, security or technical issues related to our Services or our partners.

When We Share the Information We Collect

First, we want to be clear about how we do not share information about you (what we call the “No-Nos”):

• We do not share your credit reports or scores with unaffiliated third parties (except agents acting on our behalf; we explain that below).
• We do not sell your Personal Information to or share your Personal Information with unaffiliated third parties for their own advertising or marketing purposes.

Now that we’ve covered the No-Nos, let us explain how we could share with third parties. We may share information about you, including Personal Information, with third parties in a variety of ways, such as:

• Agents acting on our behalf. We may share information about you with service providers or agents in order to have them perform on our behalf any of the activities we are permitted to conduct under this Privacy Policy and our Terms of Service. This includes things like designing or operating features, helping us research and test feature improvements, identifying offers or personalised recommendations, performing analytics and marketing our Services. These third parties are acting on our behalf so while they may have access to your information, including things like your credit reports and scores, they’re required to follow our instructions and meet the standards explained in our Privacy Policy when handling information about you that we provide them.
• When we collaborate with third parties to provide and improve our Services. We may sometimes share information about you with third parties we collaborate with in connection with providing or improving our Services. This can occur, for example, when we’re providing an integrated or co-branded feature with a partner (e.g., our Credit Score Simulator) or doing a joint research project with another organisation to help improve our Services. We may also share information like the feedback you submit to us if it relates to both our Services and a partner’s products. When we share information with third-party collaborators, our collaborators are obligated to follow the No-Nos above, but may also use the information in connection with their own activities to the extent allowed under their own privacy practices (e.g., respond to your feedback, conduct additional research, or improve a feature of theirs).
• Our partners when you ask for their services. We may also give you opportunities to interact with third party partners through our Services, such as when we provide you with the opportunity to review and send your personal information to a partner in order to pre-populate your application on the partner’s site or we send you to the partner’s site for you to provide the information directly to them. In some cases, if you click through to go to a partner’s site, you will automatically be sending your personal information to that partner. When this happens, you will still have to submit your application on the partner’s site. Remember that any information you provide to the partner, whether through us or on your own, will be subject to their privacy practices and terms and conditions.
• When you publicly post the information. As part of our Services, we may provide opportunities for you to publicly post reviews, questions, comments, suggestions or other content, which may include Personal Information and portions of your Member Profile designated as public profile information, like your name or user name. Anything you share in a public forum is, obviously, public, so think carefully about what you decide to share. If you would like us to remove Personal Information included in Community Content, contact us here. In some cases, we may not be able to remove your Personal Information, but we will try to respond to let you know why.
• As Part of a Corporate Change. We may disclose and transfer information about you to a third party as part of, or in preparation for, a change of control, restructuring, corporate change, or sale or transfer of assets. If such a business transfer results in a material change in the treatment of your Personal Information, you will be notified by e-mail (using the primary email address on your account) or by a prominent notice on our site.
• For Legal Reasons. We reserve the right to transfer or disclose information about you to third parties for certain legal purposes.
• With Your Consent. There may also be other limited contexts in which we share specific types of personal information with your express consent.

We may also share with third parties de-identified or aggregated data we collect, such as de-identified or aggregated credit reports or scores, de-identified demographic information, or information about the computer or device from which you access the Service. We share such information for a variety of purposes, including to analyse Service usage, develop shared services, and improve our own products and features.

How to Access, Update or Deactivate Your Account

Accessing and Updating Your Account Information

You are responsible for maintaining the accuracy of the information you provide to us, such as your Member Profile information. You can access and make changes to certain Personal Information by logging in to your account through our website and updating your “Personal Information” page.

Communications Preferences

You can manage your communications preferences by visiting your account profile. For example, you can choose which types of monitoring alerts you want to receive. We’ll also include “unsubscribe” instructions in marketing emails. You may also have the ability to adjust app- or browser-specific communications settings (e.g., for things like push or browser notifications) within the settings screen of your mobile app or browser. Technology moves fast, so the types of communications and communication preference options might change from time to time.

Canceling Your Membership and Deactivating Your Account

We hope this never happens, but if you decide you no longer want to use our Services, you can cancel and deactivate your account on our help page.

One more thing to note: Due to our record-keeping and information retention requirements, we do not delete information about you upon deactivation. We will, however, disable your account and stop sending you further communications. Furthermore, except to the extent necessary for legal or regulatory record-keeping purposes, we anonymise the data in your Member Profile two years after you deactivate your account. It may take a little more time for our automated backup systems to fully process the anonymised account, though.

Our Interest-Based Advertisement Practices

Advertising Service Providers

Some of our third-party service providers or partners are advertising networks, marketing partners, publishers and other entities who perform analytics and advertise our products and services on websites not affiliated with us (“Advertising Service Providers”). In connection with these advertising services, we or our Advertising Service Providers, like Google Analytics (more on this below) may use cookies, web beacons, and similar technologies to collect behavioral information about how you use our site or other websites in order to perform tracking and marketing analytics or serve advertisements that are more likely to be of interest to you (“Interest-Based Advertisements”). Our Advertising Service Providers may permit you to opt out of all or some Interest-Based Advertisements on designated websites.

Disclosure Regarding Google Analytics Advertising Features

In addition to services from other Advertising Service Providers, we use the following Google Analytics Advertising Features as part of our marketing analytics and advertising: Remarketing with Google Analytics, Google Display Network Impression Reporting, DoubleClick Platform integrations and Google Analytics Demographics and Interest Reporting. We may also use other services provided by Google Analytics from time to time. At present, Google provides users an opportunity to opt-out of the Google Analytics Features through Google’s Ads Settings and their web browser opt-out plugin. However, we do not control these opt outs, which may be updated or removed by Google in accordance with its own policies. For additional information on opting out of interest-based ads by Google, you can visit Google’s Opt out page here.

Do Not Track Signals

At this time, we do not respond to automated signals regarding tracking mechanisms, including “do not track” instructions from your browser. Please note that blocking cookies may affect your browsing experience on many sites and may limit your ability to use certain features of our Services, including many of the personalized features we provide for our members.

Our Security Practices and Social Security Protection Policy Statement

EverBright Finance maintains physical, electronic, administrative and procedural safeguards intended to protect the confidentiality of Personal Information that we collect about you, including Social Security numbers. We limit access to Social Security numbers to help protect against their loss or misuse and we do not disclose Social Security numbers to third parties except with your consent, or where such disclosure is required or permitted by law.

If you have any questions about security on our Services, you can contact us here.

Changes to Our Privacy Policy

We reserve the right to change this Privacy Policy at any time without notice to you. If there are any material changes in the way we treat your credit report information or Personal Information, EverBright Finance will send a notice to the primary email address on your account or place a prominent notice on our platform before the change goes into effect. EverBright Finance will also promptly make an updated Privacy Policy publicly available on our platform. Changes will be effective as soon as the revised Privacy Policy is posted unless otherwise stated.

Want More Information?

Please contact us on Info@everbright.co.nz if you have any questions about this Privacy Policy, the Website, our Terms of Use or any of our services.

This Privacy Policy does not limit the information privacy principles set out in the Privacy Act 1993.