This Privacy Policy (“Policy”) governs the collection, use and disclosure of Personal Information by MCA Investments Limited (trading as “Dosh”). In this Policy, “Dosh”, “we”, “us”, or “our” means MCA Investments Limited and any reference to “you” or “yours” refers to you.
We collect and use your Personal Information to provide you with access to our websites, App, social media channels, products and services (“Services”).
Your privacy rights
Dosh is committed to complying with its obligations under the Privacy Act 2020 (“Privacy Act”) when dealing with your Personal Information. Any Personal Information you provide to us will be stored, used and disclosed by Dosh in accordance with this Policy.
If you have any questions regarding this Policy or wish to access or amend the Personal Information that we hold about you, please contact our Privacy Officer at contact@Dosh.nz.
Acceptance of this privacy policy
By accessing or using our Services, and/or otherwise providing us with your Personal Information, you acknowledge that you have read and understood this Policy and that you authorise us to collect, hold, use and disclose your Personal Information in accordance with this Policy.
This Policy is in addition to any other applicable terms and conditions that may apply to your relationship and/or engagement with us, including our Terms and Conditions available here.
Amendments to this privacy policy
We may amend and update this Policy from time to time by posting a revised version on our website or otherwise notifying you through our Services. Any changes will apply from the date we post the updated Policy on our website or through our Services. If we make any significant changes, we will endeavour to provide you with reasonable notice of such changes through our website, or via other means such as email. By accessing or using our Services after such notice period, you will be deemed to have accepted the updates to this Policy. If you do not agree to any change, you must immediately notify us and cease accessing our Services.
How and what type of information we collect about you
Your Personal Information will be collected and held by MCA Investments Limited, Level 10, 21 Queen Street, Cbd, Auckland, 1010, New Zealand.
We collect Personal Information in order to manage, market and conduct our business, to provide our Services, and to meet our legal obligations. Depending upon the nature of your relationship with us, the type of Personal Information we collect and hold may include:
your name and contact details (including your email address, phone number and postal address);
your payment and purchase history through use of the Services (e.g. merchant name and value of spend);
passport or drivers licence details, including date of birth, to verify your identity for AML compliance purposes;
proof of address, e.g. a utility bill for AML compliance purposes; and
bank account for the purpose of adding money to your Dosh account (in accordance with your instructions); records of our communications with you, including any complaints, requests or queries;
information provided by you in application for a Dosh product, including a Dosh loan;
any other Personal Information that may be required in order to facilitate your dealings with us and/or to assist us in conducting our business, providing and marketing our Services and meeting our legal obligations; and
information we create in the course of our relationship with you, such as personal preferences and other details or evaluations of your interactions with us and our Services.
for merchants, their business type, business address, GST details, and directors and shareholder details (which will include the Personal Information listed above).
Who we collect Personal Information from
We use different methods to collect your Personal Information. We will generally collect Personal Information directly from you (e.g. through information you submit through the Service or through correspondence that you submit to us). However, we may also collect Personal Information:
from third parties and government databases in some instances, for example to verify your identity for AML compliance purposes;
from other third parties that we partner with for product, marketing and promotional purposes, e.g. loan providers, event organisers and merchants who use Dosh; and/or
from publicly available websites or sources.
If you have provided us with information about another person, you warrant that you have that person’s permission to do so. Your obligations under privacy laws may also mean that you need to tell that person about the disclosure and let them know that they have a right to access their Personal Information and that we will handle their Personal Information in accordance with this Policy.
When you access our Services, we may collect information that is sent to us by your device. Generally, this information is not personally identifiable data, but to the extent that it is considered Personal Information for the purposes of the Privacy Act, we will comply with our legal obligations under any such law or regulation when processing that information.
You are not required to provide us with your Personal Information. However, if you choose not to provide Personal Information to us on request we may be unable to provide certain Services to you or it may affect the functionality of our Services.
How we use Personal Information
We collect, hold, use and disclose your Personal Information for the following purposes:
to provide you with our Services;
to send, receive, process, administer, and collect payments from you on behalf of merchants and registered users of the Dosh app;
to communicate with you (for example to provide customer support or to ask you for feedback about our Services);
to enable the assessment of applications and management of services, such as loans;
to help provide a more tailored and personalised experience;
to research and help improve and enhance our Services and to conduct market analysis and perform data analytics on customer behaviour and insights in relation to our Services;
to undertake administrative functions associated with the Services and our business;
to comply with any legal obligations, including our obligations under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009;
to send you electronic messages and push notifications to promote and market our Services and/or other services we consider you may be interested in, including any promotions and deals available through the Dosh App.
You can opt out of receiving marketing material, push notifications and other promotional communications at any time by disabling notifications in the App, notifying us at contact@dosh.nz or by clicking the unsubscribe function included in our marketing communications.
Who we may disclose your Personal Information to
We may disclose your Personal Information to:
merchants, in order to facilitate payment for the goods or services you purchase from them using our Services.
any third party service providers that we have engaged to provide a service to us in relation to our Services and/or to carry out functions on our behalf, including those who provide us with IT and marketing services;
financial services dispute resolution providers (where required by law or with your consent);
third party providers of identity verification services to enable us to meet our obligations under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009;
a third party for application and management of loan products;
potential investors and/or purchasers of our business;
our professional advisors, including accountants, insurers and lawyers;
any other person or organisation that you have authorised us to disclose your information to; and/or
any other third party where such disclosure is permitted or required under the Privacy Act and/or any other applicable law;
registered users of the Dosh app, to enable them to see your name and phone number in their contacts and transaction information.
If we disclose Personal Information to a third party outside of New Zealand who uses that information for their own purposes, we will ensure that such third party is subject to comparable privacy laws to New Zealand or is required to protect the Personal Information in a way that is comparable to New Zealand’s privacy laws.
Access, correction and retention of your Personal Information
You agree that any information you give to us will be accurate, correct and up to date and you will inform us if any of Personal Information changes to ensure that the details we hold about you are up to date and correct. You can update your personal details at any time through your customer account or by contacting us at contact@Dosh.nz.
You are entitled to access the Personal Information we hold about you, and to request that we amend it if it is incorrect. If we are not willing to correct errors that you have identified in your Personal Information, you may request that we take reasonable steps to attach a statement to the Personal Information noting the correction sought.
We will only retain your Personal Information for as long as it is required to achieve the purposes set out in this Policy or as otherwise required by law.
Security of information
We take reasonable steps to protect Personal Information from misuse, loss and unauthorised access, modification or disclosure.
Although we take reasonable steps to ensure Personal Information held by us (or on our behalf) is protected and held securely, we do not make any warranties in relation to the security of any information you disclose or transmit to us and we are not responsible for the theft, destruction, or inadvertent disclosure of your Personal Information where our security measures have been breached. Any transmission of Personal Information is conducted at your own risk.
Where we hold your Personal Information
We use third party cloud service providers, such as Microsoft Azure, to store data on our behalf. Those providers are generally based in Australia and Europe.
Cookies
“Cookies” are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.
Like many other websites on the internet, we use Cookies and other third party web tracking and analytic tools to collect and track information about you when you are using our Service for the purposes of:
providing more customised content and material to you through our Services;
improving our Services and your customer experience;
conducting business and marketing analysis; and
If you do not wish to allow Cookies you may change your browser settings to disable Cookies. However, if you disable Cookies some parts of our Services may not function properly.
Links to other websites
Our Services may have links or references to third party websites or material. This Policy does not apply to those websites, and any information collected by such third parties is governed by that third party’s privacy practices or policies. We accept no responsibility or liability for the content or privacy practices of any third party website or App.
How to contact us
If you have any queries or concerns about this Policy or our handling of your Personal Information please contact our Privacy Officer at MCA Investments Limited, Level 10, 21 Queen Street, Cbd, Auckland, 1010, New Zealand, or by emailing us at contact@Dosh.nz.
When applying for a Dosh loan, you also agree to the following authorisation for our third party provider Avanti Finance Limited (NZB 9429038556692).
Avanti Privacy Act Authorisation
By submitting an application for a Dosh Personal Loan, you authorise Avanti Finance Limited (Avanti, we or us) to collect, use and share your personal information in accordance with our Privacy Statement, which you can find at www.avantifinance.co.nz /privacy-policy. Dosh has a contractual arrangement with Avanti to provide the Dosh Personal Loan to approved customers.
1. THE INFORMATION WE COLLECT
The Privacy Statement includes a full list of the personal information which we may collect from you. That information includes (but is not limited to):
information about your identity, like your name (and any previous or other names you are or have been known by), age, gender, identification, biometric data and image; your contact details, like your address and or current whereabouts, telephone number and email address (including any arrival and departure records held in New Zealand); financial information, like your income, expenses and liabilities and banking history; information about your past and current bank accounts, including bank statements; and information about your employment and type of work you do.
2. WHO WE COLLECT YOUR PERSONAL INFORMATION FROM AND SHARE IT WITH
The Privacy Statement also includes a full list of the people and organisations from whom we may request and collect your personal information, and with whom we may share it. Those people and organisations include (but are not limited to):
any registered bank or other credit provider in New Zealand; your past and present employers; your past and present service providers, including your telecommunications providers; and government agencies and services, including NZ Customs Service, the Ministry of Justice, Department of Corrections, New Zealand Police, the Ministry of Social Development
(including Work and Income), Immigration New Zealand, Inland Revenue Department, Kainga Ora (and related agencies), NZTA's Driver Check service, Housing New Zealand Corporation, Office of the Privacy Commissioner and the Commerce Commission.
3. AUTHORISATION
By submitting a loan application, you confirm that:
you have read and understood the Privacy Statement and this authorisation;
you authorise us to collect, use and share your personal information in accordance with the Privacy Statement and this authorisation; all representations that you have made to us and all information and documents that you, or any other person acting with your knowledge or permission, has given to us in connection with this loan agreement are and remain complete, accurate and not misleading and have not been given fraudulently.
Last updated: 8 May 2024