Privacy Policy

This policy explains how JFK Capital Limited (IVF Funders) collects, uses, stores and shares personal information in accordance with the Privacy Act 2020. We are a New Zealand consumer lender that provides unsecured personal lending to finance IVF and fertility treatment under the Credit Contracts and Consumer Finance Act 2003 (CCCFA).

Protecting personal information is a core part of our obligations to borrowers, guarantors and staff. If anything in this policy is unclear, please contact our Privacy Officer (details below).

1. What personal information we collect

We collect only the personal information that is reasonably necessary to consider and manage a loan, comply with the law, manage risk and enforce loan agreements.

This typically includes:

• identity information including full legal name, date of birth, residential address, and government-issued photo ID
• contact details including phone numbers and email addresses
• financial information including employment details, income, expenses, existing debts, credit history and bank account details
• information about the treatment you are funding, including the type of treatment, the estimated cost, and your chosen fertility clinic
• transaction and payment data including direct debit activity throughout the life of the loan
• communications with us (phone calls, emails, support chats)
• information obtained from credit reporting agencies, anti-money-laundering (AML) verification providers and public registers

We may collect information directly from you, or from authorised third parties such as:

• credit reporting agencies (e.g. Centrix, Equifax, illion)
• banks and payment providers
• your fertility clinic (only where you ask us to confirm treatment or cost details)
• government databases and public registers
• identity, fraud and AML verification services

2. Why we collect personal information

We use personal information to:

• conduct the responsible-lending affordability and suitability assessment required by the CCCFA
• verify your identity and meet our obligations under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009
• set up, document, settle and manage your loan
• process repayments and manage direct debits
• communicate with you about your loan
• recover unpaid amounts and enforce our loan contract
• detect and prevent fraud and financial crime
• resolve disputes and respond to complaints
• comply with our legal, regulatory and audit obligations

We do not sell personal information.

3. Who we share personal information with

We only share personal information where it is reasonably necessary for the purpose, and only with parties such as:

• credit reporting agencies (for credit enquiries and account reporting)
• payment processors and direct debit providers
• identity, fraud and AML verification providers
• your fertility clinic, only where you ask us to confirm treatment or cost details
• debt collection agencies (only if your loan goes into default)
• solicitors, process servers and enforcement agents (only if recovery action is required)
• government registers, where required by law
• our external dispute resolution scheme, Financial Services Complaints Limited (FSCL)
• regulators including the Commerce Commission, Department of Internal Affairs and the Office of the Privacy Commissioner
• our auditors and insurers

We only share the information required for the specific purpose, and require third parties to handle it consistently with our obligations under the Privacy Act 2020.

4. Overseas storage and processing

Some of our systems, cloud platforms and service providers store or process information outside New Zealand. Where we use overseas providers, we take reasonable steps to ensure they are subject to contractual or legal protections comparable to those under the New Zealand Privacy Act 2020.

5. How we keep personal information safe

We use physical, technical and organisational safeguards including:

• access controls, role-based permissions, and multi-factor authentication for staff
• encryption in transit and at rest
• monitoring, alerting and audit logs
• contractual confidentiality and data-protection obligations on our service providers
• regular review of our information security controls

No system is perfectly secure, but we take reasonable steps to protect personal information from unauthorised access, loss, misuse, modification or disclosure.

6. How long we keep personal information

We keep personal information only as long as required for:

• providing and managing your loan
• enforcing our loan agreement and recovering unpaid amounts
• meeting our legal and regulatory obligations

Records relating to a loan are generally kept for at least seven years from the end of the loan, in line with our obligations under the CCCFA, the AML/CFT Act, and tax legislation.

7. Cookies and website analytics

Our website uses cookies and similar technologies for two purposes: making the site work (essential cookies) and measuring how the site is used so we can improve it (analytics cookies). We use Google Analytics 4 for site analytics. Analytics data is aggregated and is not used to identify individual visitors.

You can disable cookies in your browser settings. If you do, some site features may not work as intended. We do not use third-party advertising or behavioural tracking cookies.

8. Privacy breaches

If a privacy breach occurs that is likely to cause serious harm, we will:

• contain the breach and investigate the cause
• notify affected individuals as soon as practicable
• notify the Office of the Privacy Commissioner as required under the Privacy Act 2020

9. Your rights: access and correction

Under the Privacy Act 2020 you have the right to:

• ask for confirmation of whether we hold personal information about you
• request a copy of the personal information we hold
• request correction of information you believe is inaccurate, outdated or incomplete

Requests can be made to our Privacy Officer:

We may need to verify your identity before we provide access. We respond to requests within 20 working days. There is no fee for a standard access request, though we may charge a reasonable fee for substantial or repeated requests.

10. Privacy complaints

If you have concerns about how IVF Funders has handled your personal information, please contact our Privacy Officer first. We will work to resolve your concern promptly.

If you remain unsatisfied, you may also complain to the Office of the Privacy Commissioner at www.privacy.org.nz or by phoning 0800 803 909.