Privacy policy.

Who we are and how to contact us

Traction Financial Services Limited (Traction, we, us or our) provides mortgage and lending advice in New Zealand. We are responsible for the personal information we collect and hold in connection with our business.

This policy explains how we collect, use, store and share personal information when you visit our website, contact us, use our online tools, subscribe to our emails or receive our services. We handle personal information in accordance with the Privacy Act 2020.

Privacy officer

Patrick Sargisson

Email

hello@tractionfinancialservices.co.nz

Phone

022 076 0524

Address

21 Humphreys Drive, Ferrymead, Christchurch

FSP number

FSP1013239

NZBN

9429053876546

What personal information we collect

We collect information that is reasonably necessary for the purpose of the interaction. The information needed for a simple enquiry or guide request is different from the information needed for mortgage advice or a loan application. Depending on what you ask us to do, this may include:

• Your name, contact details, address and preferred way to communicate.
• Your home-buying plans, borrowing goals, property details, deposit and the answers and results from our first-home readiness quiz.
• Your income, employment, expenses, assets, liabilities, existing loans and other information relevant to your financial circumstances.
• Documents needed for advice or an application, such as identity and address evidence, bank statements and income records, and information about credit history where relevant and lawfully obtained.
• Advice records, application information, correspondence, feedback, complaints and your communication preferences.
• Website and email interaction information, such as device and browser details, IP address, pages visited, referral information, form-submission events and email engagement, where the relevant features are enabled.

Please do not send internet-banking passwords or unnecessary identity documents through a general enquiry form or by email. If documents are needed, we will explain the appropriate way to provide them.

How we collect information and your choices

We usually collect information directly from you through website forms, quiz and guide requests, our client portal, email, phone calls, meetings and the advice or application process.

With your authority, or where the law otherwise permits, we may also collect relevant information from a co-applicant, guarantor, lender, referrer, professional adviser, public register or verification service.

If we collect information about you from another source, we take reasonable steps to tell you about that collection as soon as reasonably practicable, unless an exception applies. This includes explaining why it was collected, the intended recipients, who is collecting and holding it, and your access and correction rights. Where collection is required or authorised by a particular law, we identify that law where required.

If you provide information about someone else, please ensure you are authorised to do so and make them aware of this policy. This does not replace our own notification responsibilities.

You can choose not to provide information. However, if information is necessary to respond to your request, assess your circumstances or complete an application, we may be unable to provide that part of our service. We will explain any information that is required by law and the consequences of not providing it.

Why we use personal information

We use personal information for the purposes explained when we collect it, including to:

• Respond to enquiries, deliver a guide or quiz result you request, arrange appointments and understand how we can help.
• Understand your circumstances, provide mortgage and lending advice, prepare applications and communicate with lenders or other people involved in your application.
• Manage our relationship with you, maintain advice records and provide relevant ongoing service, such as a mortgage review.
• Send newsletters and marketing communications where you have consented, and manage your preferences or unsubscribe requests.
• Operate, protect and improve our website and business systems, and understand the performance of our content and advertising.
• Handle complaints, manage risk, meet our legal and regulatory obligations and establish, exercise or defend legal rights.

If we want to use information for a materially different purpose, we will explain that purpose and obtain your authority where required, or ensure the use is otherwise permitted by law.

Who we share information with

We share information only where it is necessary for an explained purpose and you have authorised the sharing, or the law otherwise permits or requires it. Recipients may include:

• Our advisers and other people working for us who need the information to carry out their role.
• Banks, lenders and relevant product providers involved in advice or an application you have asked us to assist with.
• Your solicitor, accountant, insurance adviser or another professional or referrer, where you have authorised an introduction or exchange of information.
• Co-applicants, guarantors and authorised representatives, to the extent appropriate for a joint application or the authority you have given.
• Technology and support providers that help us deliver our services, as described below.
• Regulators, auditors, compliance advisers, professional advisers, dispute resolution services, courts or other authorities, where there is a lawful basis to provide the information.

Our technology providers

We use Squarespace for our website and enquiry collection, Trail as our client relationship management system for client information and advice records, and HubSpot for monthly emails and subscriber preferences. Google Workspace supports business email and documents. Where a website form is connected to Formspree, its submission is also processed through that service.

Providers acting on our behalf receive information needed to perform their service. Some providers may also process certain information for their own purposes under their privacy policies, depending on the features used. You can read the Trail privacy policy and HubSpot privacy policy, or ask us about the providers involved in your interaction.

Joint applications

Information in a shared application or client portal may be visible to other applicants on that shared profile. Please tell us before submitting information if you need it handled separately from a co-applicant or guarantor so we can discuss a suitable process.

Website tools, cookies and advertising

Our website may use cookies and similar technologies for essential functions, analytics and advertising measurement. Where enabled, tools such as Squarespace analytics, the Meta Pixel or HubSpot tracking may collect browser or device identifiers, IP addresses, visited pages, referral information and actions such as a form submission. Advertising services may associate this activity with an account or other information they hold about you.

These tools can help us understand which content and campaigns lead to enquiries and may support relevant advertising or remarketing. The information collected depends on the tools and settings in use. Detailed mortgage documents and financial records belong in our advice and application process, rather than advertising event data.

You can manage cookies through your browser and, where provided on our website, through cookie settings. You can also review advertising preferences with the relevant platform. Blocking cookies may affect some website features. Where consent is required for a particular technology, we will seek it before using that technology.

Quizzes, guides and email updates

Enquiries and requested resources

When you enquire or request a guide, we use the details you provide to respond and deliver what you requested. Making an enquiry or requesting a resource does not, by itself, give us unrestricted permission to send unrelated marketing.

First-home readiness quiz

We use your quiz answers and any calculated score or readiness category to provide an indicative result, understand your plans and guide our follow-up. Quiz results are a starting point for a conversation, not a lending decision or mortgage approval. A lender makes its own lending decision.

Newsletters and marketing preferences

We send our monthly emails and other marketing communications where you have consented. This can include signing up through a quiz or other offer that clearly explains, before you submit, that email updates are included. We use HubSpot to manage these emails and subscription preferences.

You can unsubscribe at any time using the link in a marketing email or by contacting us. We action unsubscribe requests within five working days. Unsubscribing from marketing does not stop communications needed to respond to a request, manage your application, provide a service you have asked for or meet a legal obligation. You do not need to subscribe to marketing to receive mortgage advice.

Where enabled, our email tools may record delivery, opens and link clicks to help us understand engagement and improve our communications. Opening information is not always accurate.

Storage, security and overseas service providers

We take reasonable physical, technical and organisational steps to protect personal information against loss, unauthorised access, misuse, alteration or disclosure. Access is limited to people who need it for their role. We also take reasonable steps to ensure that providers processing information on our behalf protect it appropriately. No internet transmission or storage system can be guaranteed completely secure.

Personal information may be stored or processed outside New Zealand by our technology providers or their service providers. The locations depend on the service and its configuration; we do not represent that all information stays in New Zealand.

Where an overseas provider acts only on our behalf to store or process information, we remain responsible for the information. Where a transfer is an overseas disclosure under the Privacy Act, we take reasonable steps to meet the applicable requirements, such as ensuring comparable safeguards or obtaining informed authorisation where that is the lawful basis. We can explain the arrangements relevant to your information if you contact us.

How long we keep information

We keep personal information only for as long as it is reasonably needed for a lawful purpose, including providing services, maintaining advice records, dealing with complaints and meeting legal or regulatory requirements.

Records relating to our financial advice service must generally be retained for at least seven years under our Financial Advice Provider licence conditions. A longer period may be needed where a continuing legal or business purpose justifies it. This does not mean that every website visitor record or newsletter contact must be kept for seven years.

When information is no longer required for a lawful purpose, we take reasonable steps to delete it securely or anonymise it. We may retain a limited record of an unsubscribe request so we can respect your preference. You may ask us to delete information, but we may need to retain records we are lawfully required or permitted to keep.

Your access and correction rights

You can ask us whether we hold personal information about you, request access to it and ask us to correct information you believe is wrong. Contact our privacy officer using the details above. We may need to verify your identity and, if someone acts for you, their authority.

We respond to access and correction requests as soon as reasonably practicable and generally make a decision within 20 working days. If a lawful extension or another applicable procedure is needed, we will explain it. If we withhold information or decline a correction, we will explain the decision and your complaint rights, subject to any lawful restrictions.

If we do not make a correction you request, you can ask us to attach a statement of the correction you seek. We take reasonable steps to keep information accurate, up to date, complete and not misleading for its intended use.

Privacy concerns, complaints and breaches

If you have a privacy question or concern, please contact Patrick Sargisson, our privacy officer, at hello@tractionfinancialservices.co.nz or 022 076 0524. Please describe the issue and the outcome you are seeking so we can investigate and respond.

If we cannot resolve your concern, or you want information about your privacy rights, you can contact the Office of the Privacy Commissioner. Our financial services complaints process is also explained on our public disclosure page.

Privacy breaches

If a privacy breach occurs, we take steps to contain it, assess the risks and reduce harm. Where a breach has caused or is likely to cause serious harm, we notify the Privacy Commissioner and affected people as soon as practicable, unless a legal exception applies.

Changes to this policy

We may update this policy as our services, systems or legal obligations change. The current version will be available on this page with its update date. Where a change affects how we handle your information, we will provide further notice or seek authority where required.

If you would like a copy of this policy or have a question about a particular use of your information, please contact our privacy officer.