Privacy Policy

Guise Trading Ltd (NZBN 9429049725508) trading as FinchKeep (hereinafter referred to as "FinchKeep") is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.

We comply with the New Zealand Privacy Act 2020 (the 'Privacy Act'). The Privacy Act governs the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.

A copy of the New Zealand Privacy Principles may be obtained from the website of the Office of the Privacy Commissioner at www.privacy.org.nz.

What is Personal Information and why do we collect it?

Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include: names, addresses, email addresses, phone numbers, organization names, and financial information related to your use of our accounting services.

This Personal Information is obtained in many ways including via our website, through your use of our Services, from third-party integrations (such as bank feeds and payment processors), and from correspondence with you. We don't guarantee website links or policy of authorised third parties.

We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.

When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

Sensitive Information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

1. For the primary purpose for which it was obtained
2. For a secondary purpose that is directly related to the primary purpose
3. With your consent; or where required or authorised by law.

Third Parties

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

We may use the following third-party services:

• Stripe - for payment processing
• Amazon Web Services (AWS) or Oracle Cloud Infrastructure - for secure data hosting and storage
• Akahu - for New Zealand bank feed integration services
• Email service providers - for transactional and marketing communications

New Zealand Bank Feeds & Akahu

FinchKeep may utilise services from Akahu, an open finance platform based in New Zealand, to deliver bank feed functionality within our service. When you choose to link a bank account to FinchKeep via Akahu, personal information will be handled in connection with that service.

In these interactions involving Akahu and the handling of associated personal information, FinchKeep complies with the New Zealand Privacy Act 2020.

When you link a bank account through Akahu, Akahu collects and processes your personal information according to its own terms and the New Zealand Privacy Act 2020. Through this integration, we may receive personal information from Akahu, such as your account details, transaction history, balances, name, and date of birth, where you have authorised this transfer. We may also share information you provide to us with Akahu to enable the provision of our integrated Service.

FinchKeep does not store any credentials you provide directly to Akahu (such as login information for your bank or other financial accounts). These details are handled exclusively by Akahu. We encourage you to review Akahu's privacy policy and any usage notices they provide. For further information on the New Zealand Privacy Act, see www.privacy.org.nz.

Disclosure of Personal Information

Your Personal Information may be disclosed in a number of circumstances including the following:

1. Third parties where you consent to the use or disclosure;
2. Service providers who assist us in operating our business (such as payment processors, hosting providers, and email service providers);
3. Professional advisors (such as accountants, lawyers, and auditors);
4. Where required or authorised by law;
5. In connection with a merger, acquisition, or sale of assets (with notice to affected users).

We will never sell, rent, or trade your Personal Information to third parties for their marketing purposes.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.

We implement industry-standard security measures including:

• Encryption of data in transit (TLS/SSL) and at rest
• Secure authentication and password requirements
• Regular security audits and vulnerability assessments
• Access controls and logging
• Employee training on data protection

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years in accordance with New Zealand tax and business record-keeping requirements.

Data Location

Your data is primarily stored in secure data centers located in New Zealand and/or Australia. Some third-party services we use may process or store data in other jurisdictions. We ensure that all third parties handling your data maintain appropriate security standards and comply with applicable privacy laws.

Access to your Personal Information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

FinchKeep will not charge any fee for your access request, but may charge a reasonable administrative fee for providing a copy of your Personal Information.

In order to protect your Personal Information we may require identification from you before releasing the requested information.

Maintaining the Quality of your Personal Information

It is important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

Your Rights Under the Privacy Act

Under the New Zealand Privacy Act 2020, you have the following rights:

• Right of access - You can request access to your Personal Information
• Right to correction - You can request correction of inaccurate Personal Information
• Right to deletion - You can request deletion of your Personal Information (subject to our legal retention obligations)
• Right to data portability - You can request an export of your data in a portable format
• Right to object - You can object to certain processing of your Personal Information
• Right to withdraw consent - You can withdraw previously given consent at any time

To exercise any of these rights, please contact us using the details provided below.

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to improve your experience on our website. Cookies are small files stored on your device that help us:

• Remember your preferences and settings
• Keep you logged in to your account
• Understand how you use our services
• Improve our services and fix bugs

You can control cookies through your browser settings. However, disabling cookies may affect your ability to use certain features of our services.

Marketing Communications

We may send you marketing communications about our products, services, and promotions that we think may interest you. You can opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email
• Updating your communication preferences in your account settings
• Contacting us directly

Please note that even if you opt out of marketing communications, we will still send you essential transactional emails related to your account and use of our services.

Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect Personal Information from children. If you become aware that a child has provided us with Personal Information, please contact us so we can take appropriate action.

International Data Transfers

While we primarily store data within New Zealand and Australia, some of our third-party service providers may process data internationally. When we transfer your Personal Information outside of New Zealand, we ensure appropriate safeguards are in place to protect your information in accordance with the Privacy Act.

Data Breach Notification

In the event of a privacy breach that is likely to result in serious harm to you, we will notify you and, where required, the Office of the Privacy Commissioner in accordance with our obligations under the Privacy Act.

Policy Updates

This Policy may change from time to time and is available on our website. We will notify you of significant changes to this Privacy Policy by email or through a prominent notice on our website. Your continued use of our services after such notice constitutes acceptance of the updated Privacy Policy.

Privacy Policy Complaints and Enquiries

If you have any queries or complaints about our Privacy Policy or how we handle your Personal Information, please contact us at:

We will investigate and respond to your complaint or enquiry within a reasonable timeframe, typically within 20 working days.

If you are not satisfied with our response, you have the right to contact the Office of the Privacy Commissioner:

Additional Information for EU/UK Residents

If you are located in the European Union or United Kingdom, you may have additional rights under the General Data Protection Regulation (GDPR) and UK GDPR, including:

• The right to be informed about how your data is used
• The right to restriction of processing
• The right to object to automated decision-making
• The right to lodge a complaint with a supervisory authority

For EU/UK residents, our lawful basis for processing your Personal Information includes:

• Contract - Processing necessary to provide our services to you
• Consent - Where you have given explicit consent
• Legitimate interests - For our business operations and improvement of services
• Legal obligation - Where required by law

This Privacy Policy was last updated on January 24, 2026. We recommend reviewing this policy periodically to stay informed about how we protect your information.