Privacy Policy

1.1. User Information: Information about the mortgage broker (User), including name, contact details, financial adviser license/registration numbers, billing information, and platform usage metrics.

1.2. Client Information: Personal and financial data about the end consumer (Client), submitted by the User. This includes identity details, income records, employment history, loan application parameters, credit profiles, and supporting documentation (e.g., payslips, bank statements).

2.1. Direct Input: Provided by the User through data entry forms, application interfaces, and account settings.

2.2. Document Uploads: Information extracted from files and documents uploaded to the Platform by the User.

2.3. Automated Processing: Data generated through your interaction with the Platform, including log data, IP addresses, and device identifiers.

3.1. Deliver, operate, and support the Platform's core functionalities (e.g., structuring loan applications, generating compliance documents).

3.2. Verify the identity and professional standing of Users.

3.3. Bill for services and manage User accounts.

3.4. Monitor performance, detect fraud, and maintain platform security.

3.5. Monitor and improve Platform features and service quality. We do not use Client Information to train AI or machine learning models. AI functionality within the Platform is provided by third-party AI providers (currently Anthropic, Inc.) and data submitted for AI processing is subject to those providers' data processing terms. We do not permit our AI providers to use your data to train their models.

4.1. The Platform utilizes Artificial Intelligence (AI) and statistical models to parse documents, categorize expenses, and facilitate data entry.

4.2. Client Information uploaded to the Platform is processed dynamically by these AI tools to generate administrative efficiencies for the User.

4.3. We do not use Client Information to make automated financial decisions, credit approvals, or lending determinations.

5.1. Platform Role: The Platform acts exclusively as a data processor. We do not own the Client Information, nor do we sell or monetize it to third-party marketers.

5.2. Service Providers: We may share data with trusted third-party sub-processors (e.g., cloud hosting, email delivery, AI infrastructure providers) strictly to enable the operation of the Platform. These providers are bound by confidentiality obligations.

5.3. Legal Obligations: We may disclose data if required to do so by New Zealand law, valid court order, or formal request from a regulatory authority.

6.1. We implement robust, industry-standard technical and organizational security measures—including encryption at rest and in transit—to protect personal data from unauthorized access, loss, or alteration.

6.2. Despite our best efforts, no electronic transmission or digital storage is entirely secure. The User remains responsible for transmitting data to the Platform securely.

7.1. To provide highly available and secure services, your data may be stored or processed in secure data centers located outside of New Zealand (e.g., via AWS or similar enterprise cloud providers).

7.2. In accordance with the New Zealand Privacy Act 2020, we ensure that any offshore third-party providers are subject to comparable privacy safeguards or are bound by binding contractual agreements that protect your data to New Zealand standards.

8.1. We retain User Information for as long as the account remains active and for a reasonable administrative period thereafter.

8.2. Client Information is retained securely on the Platform for the duration of the User's subscription, unless the User actively deletes the data. Upon account termination, Client Information will be permanently deleted or anonymized in accordance with our standard data lifecycle policies, except where retention is legally required.

9.1. Under the New Zealand Privacy Act 2020, individuals have the right to request access to, and correction of, their personal information.

9.2. User Rights: Users may access or update their personal account information directly within the Platform settings.

9.3. Client Rights: Because the User (broker) is the agency collecting the data directly from the Client, Clients seeking to access or correct their information should contact their broker. The Platform will assist the User in fulfilling these legal obligations upon request.

10.1. The Platform uses cookies and similar tracking technologies to maintain session states, process login authentication, and analyze site performance.

10.2. You can control cookie preferences through your browser settings, though disabling essential cookies may impact the functionality of the Platform.

11.1. It is the sole responsibility of the User to secure explicit, legally valid consent from their Clients to collect, upload, and process their data on third-party cloud applications and AI-enabled platforms.

11.2. The User must ensure their own external privacy disclosures adequately reflect the use of the Platform.

12.1. We may update this Privacy Policy periodically to reflect technological advancements, changes in operations, or regulatory updates.

12.2. Changes will be communicated via the Platform. Continued use of the Platform after the effective date of an update constitutes acceptance of the revised policy.

For any questions regarding this Privacy Policy or data handling practices, please contact our Privacy Officer:

Privacy Officer, Twio Technologies Ltd.
Email: privacy@twio.ai
Or via our contact form or the support channels within the Platform.

If you have a privacy complaint, please raise it with your broker in the first instance. Where appropriate, the broker may escalate the matter to us at privacy@twio.ai so we can assist with investigation and resolution.