WEBSITE PRIVACY STATEMENT

Introduction

Welcome to the ChangeGroup privacy statement. 

ChangeGroup is a group of Companies (which includes The Change Group Denmark ApS, ChangeGroup Sweden AB, The Change Group Helsinki Oy, The Change Group International Plc, The Change Group Corporation Ltd, ChangeGroup ATMs, The Change Group London Ltd, Prosegur Change UK Limited, Alpha Centurion Services Limited, Prosegur Foreign Exchange Pty Limited or any of their subsidiaries or holding companies from time to time and any subsidiary of any holding company from time to time (each, as applicable, referred to throughout this document as ‘The Company’)) respects your privacy and is committed to protecting your personal data. This privacy statement will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. 

This privacy statement is provided in a layered format, so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy statement.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION 

9. YOUR LEGAL RIGHTS 

10. GLOSSARY

1. Important information and who we are

Purpose of this privacy statement

This privacy statement aims to give you information on how The Company collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service.

This website is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy statement together with any other privacy statement or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy statement supplements the other notices and is not intended to override them. 

Controller

The Company is part of the ChangeGroup group of companies operating in various geographical regions, including where The Company operates, and includes The Change Group Denmark ApS, ChangeGroup Sweden AB, The Change Group Helsinki Oy, The Change Group International Plc, The Change Group Corporation Ltd, ChangeGroup ATMs, The Change Group London Ltd, Prosegur Change UK Limited, Alpha Centurion Services Limited, Prosegur Foreign Exchange Pty Limited or any of their subsidiaries or holding companies from time to time and any subsidiary of any holding company from time to time (referred to herein as "ChangeGroup", "we", "us" or "our".)

Within the European Union 

  • For the purposes of compliance with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and any applicable data protection laws, the Company, namely the local ChangeGroup entity in the country, to which the local website version you are visiting, relates, is the Data Controller and responsible for your personal data and adhering to data protection and privacy laws within  the European Union.  

Outside the European Union

  • If you are based outside of the European Union and have questions or concerns about our use of your personal data, then you may contact your local ChangeGroup Company, or The Change Group International PLC, whose contact details are listed below.  

The Change Group International Plc operates several websites to which this Privacy Statement applies and will be published on them. 

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy statement. If you have any questions about this privacy statement, including any requests to exercise your legal rights, please contact the Data Protection Officer using the details set out below. 

Contact details for the Company

If you have any questions or comments about our Privacy Policy or the terms mentioned you may contact us at any time

Our full details are: Prosegur Foreign Exchange Pty Ltd. NZBN: 9429051304201 Level 14, 88 Shortland Street, Auckland Central, 1010, NZ

Full name of legal entity: Prosegur Foreign Exchange Pty Limited

Privacy Officer: Prettys Solicitors LLP

Email address: changegroupdpo@prettys.co.uk (please ensure to include lopd@changegroup.com in the CC field).

Local Compliance Officer: Duminda Horanagama

Email address: duminda.horanagama@prosegur.com

Postal address: Level 14, 88 Shortland Street, Auckland Central, 1010, NZ

Changes to the privacy statement or to your personal data

This version was last updated in August 2024. Previous versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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 their privacy statements. When you leave our website, we encourage you to read the privacy statement of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, last name, username or similar identifier, title and date of birth.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Technical Data includes internet protocol (IP) addresses (your login data, browser type and version, time zone setting and location, browser plug-in types and version, operating system and platform) and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, feedback and survey responses.  
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy statement.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time. 

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us via our website, or by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our products or services;
  • subscribe to our service or publications; 
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us. 

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.  Please see our cookie policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below: 

  • Technical Data from analytics providers or search information providers.
  • Contact from providers of technical and delivery services.
  • Identity and Contact Data from data brokers or aggregators.
  • Publicly available sources - including from agencies such as the Companies Office, NZBN Register, internet search platforms and social media platforms, such as Facebook and Linkedin.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract, we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Considering feedback and complaints that you may make to us.
  • To determine your product or service preferences and preferred outlet locations (for example, through the use of mobile applications), or to direct you to your closest outlet when using our websites or mobile applications.
  • To undertake data processing, data analysis, market research or trend analysis.
  • Managing and monitoring our risks, including complying with our legal and regulatory obligations and any lawful requests from New Zealand government agencies or regulators.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal. 

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity 

(b) Contact

Performance of a contract with you

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity 

(b) Contact 

(c) Profile 

(d) Marketing and Communications

(a) Performance of a contract with you 

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity 

(b) Contact 

(c) Profile 

(d) Usage 

(e) Marketing and Communications

(a) Performance of a contract with you 

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)  

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity 

(b) Contact 

(c) Profile 

(d) Usage 

(e) Marketing and Communications 

(f) Technical 

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical 

(b) Usage 

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity 

(b) Contact 

(c) Technical 

(d) Usage 

(e) Profile 

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have requested information from us or purchased goods from us or if you provided us with your details when you entered a competition or registered for promotion and, in each case, it is in our Legitimate Interests to use your personal data in this way and we have obtained your consent to this where necessary. 

Third-party marketing 

We will get your express opt-in consent before we share your personal data with any other company outside ChangeGroup for marketing purposes. 

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please refer to the Cookie Policy.

Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is related to the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. 

  • Internal third parties. These include other ChangeGroup companies and organisations who are based in Australia, Austria, Denmark, Estonia, France, Finland, Germany, Spain, Sweden, United Kingdom and USA. 
  • External Third Parties.  These include:
    • IMX Software (UK) Ltd, who provide us with Point of Sale and Reserve and Collect systems.
    • Zen Managed Services, who maintain our IT managed services
    • Pritesh Patel, who provides us with website development services.
    • Professional advisers including lawyers, bankers, auditors and insurers who provide various professional services to us.
    • Third parties to whom we may choose to sell, transfer or merge parts of our business or assets.  Alternatively, we may seek to acquire other businesses or merge with them.  If that happens then the new owners may use your personal data in the same ways as set out in this privacy policy.  
    • Other persons disclosed to you at the time the relevant personal information is collected.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We may share your personal data within ChangeGroup.  Due to the locations in which ChangeGroup companies are based, this may involve transferring your data to locations outside of New Zealand and may include Australia, the UK and the EU.  Data sharing agreements are also in place within ChangeGroup.

Whilst we do not otherwise currently transfer your personal data to companies within ChangeGroup or to service providers outside of the EU (which has been identified by the Office of the New Zealand Privacy Commissioner as a jurisdiction which has data privacy standards no less onerous than those required by New Zealand law), it is possible that if we change our service providers or engage a new service provider then they may be based outside of the EU.  In this case we will ensure that the recipients of the data must provide a similar degree of protection to your personal data to that required under New Zealand law, by ensuring that at least one of the following safeguards is implemented: 

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries. 
  • Where we use certain service providers, we may use specific contracts terms approved by the European Commission which give personal data the essentially equivalent protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Please contact our Data Protection Officer if you want further information on the specific mechanism used by us when transferring your personal data out of the EU.

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data breaches 

In the unlikely event that you become aware of a potential data breach involving the Company, please let us know so we can review and if required remedy the breach as quickly as possible. Please contact our Privacy Officer by emailing changegroupdpo@prettys.co.uk (please ensure to include lopd@changegroup.com in the CC field).

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights: 

  • Request access to your personal data.
  • Request correction of your personal data.
  • Complain to the New Zealand Privacy Commissioner (NZPC).
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us. 

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

Where we have refused a request for access to, or correction of, personal information or where you have any other concerns about the way we have handled your personal information, you have the right to make a complaint.

In the first instance, please let us know about your concerns by contacting our Privacy Officer using the contact details set out above.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. 

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (in accordance with APP 12). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. To make a subject access request please contact our Data Protection Officer via email changegroupdpo@prettys.co.uk.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Make a complaint with respect to your personal data. If we can’t resolve your complaint for you, then you have the right to make a complaint to the Office of the Privacy Commissioner by:

  • Completing an online complaint form at www.privacy.org.nz; or
  • Writing to the Office of the Privacy Commissioner, PO Box 10-094, The Terrace, Wellington 6143.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to the processing carried out by automated means which is based on your prior consent provided to us or on a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing based on your consent carried out before its withdrawal. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Last updated in August 2024