EMPIXO Legal

EMPIXO Privacy Policy

Effective date: 11 September 2026
Version: 1.0

EMPIXO respects your privacy and recognises that financial, household, business and personal information can be particularly sensitive.

This Privacy Policy explains how EMPIXO collects, uses, stores, shares and protects personal information.

EMPIXO intends to handle personal information in accordance with applicable New Zealand privacy law, including the Privacy Act 2020, and other privacy obligations that apply to the services we provide.

1. Who is responsible for your information

EMPIXO is the trading name of:

TEAM YCBC ENTERPRISES LIMITED
New Zealand Limited Company

Company Number: 5196522
NZBN: 9429041223437
GST Number: 114070378

Registered Office:

222 Milson Line
Milson
Palmerston North 4414
New Zealand

Email: info@empixo.com
Website: http://www.empixo.com

In this Privacy Policy, “EMPIXO”, “we”, “us” and “our” mean TEAM YCBC ENTERPRISES LIMITED trading as EMPIXO.

2. What this Privacy Policy covers

This Privacy Policy may apply when you:

• visit an EMPIXO website;
• contact EMPIXO;
• make an enquiry;
• book an appointment;
• purchase a coaching or mentoring service;
• participate in an EMPIXO coaching or mentoring session;
• use EMPIXO Money Map or another EMPIXO tool;
• complete an intake form, questionnaire or worksheet;
• provide financial documents or information;
• communicate with EMPIXO;
• participate in a programme;
• work with EMPIXO as a small business, club or community organisation;
• receive financial mentor supervision from EMPIXO;
• are referred to or from another professional;
• subscribe to EMPIXO communications; or
• otherwise interact with EMPIXO.

Additional privacy requirements may apply if EMPIXO later introduces regulated financial advice services.

3. Information we may collect

Depending on the service and your relationship with EMPIXO, we may collect information including the following.

Identity information

This may include:

• your name;
• date of birth;
• age;
• occupation;
• identification information where reasonably required; and
• other information reasonably needed to identify or work with you.

Contact information

This may include:

• email address;
• telephone number;
• residential or postal address;
• preferred communication method; and
• other relevant contact information.

Household and family information

Where relevant to coaching, this may include information about:

• your spouse or partner;
• children;
• dependants;
• household composition;
• shared financial arrangements;
• family goals; and
• other relevant household circumstances.

Financial information

This may include information about:

• income;
• employment;
• expenses;
• budgets;
• bank accounts;
• debts;
• creditors;
• loans;
• mortgages;
• assets;
• property;
• savings;
• KiwiSaver;
• investments;
• insurance;
• tax;
• Inland Revenue obligations;
• net worth;
• financial hardship;
• financial goals; and
• other relevant financial circumstances.

Banking information

For Banking Help or related coaching, we may collect information about:

• bank accounts;
• account structures;
• statements;
• automatic payments;
• direct debits;
• banking authorities;
• business banking;
• suspected fraud or scam concerns;
• disputed or unusual transactions; and
• other banking issues you ask us to help you understand.

EMPIXO does not need your secret internet-banking credentials to provide these services.

Tax and IRD information

For Tax & IRD Coaching, this may include:

• IRD correspondence;
• tax debt;
• repayment arrangements;
• tax obligations;
• income information;
• financial records;
• Xero information;
• overdue amounts; and
• other information relevant to understanding and organising your position.

Small-business information

For Small Business Coaching, this may include:

• business income and expenses;
• cashflow;
• bank accounts;
• debts;
• accounting information;
• Xero records;
• tax obligations;
• business structures;
• business goals;
• financial systems; and
• other operational information relevant to the coaching engagement.

Club and community-organisation information

Where EMPIXO works with a club, sporting organisation or community group, we may collect information about:

• committee members;
• authorised contacts;
• financial records;
• budgets;
• bank accounts;
• funding;
• grants;
• policies;
• accounting information;
• membership administration;
• governance processes; and
• other organisational information relevant to the service.

Coaching and mentoring information

We may collect:

• session notes;
• goals;
• agreed actions;
• progress information;
• meeting summaries;
• homework;
• budgets;
• debt schedules;
• financial plans;
• working documents;
• Money Map information;
• questions;
• concerns; and
• information you choose to discuss with us.

Financial mentor supervision information

Where EMPIXO provides professional supervision to financial mentors, we may collect information relating to:

• the supervisee;
• professional development;
• supervision discussions;
• learning goals;
• practice issues;
• action points; and
• supervision records.

Supervisees should take care not to unnecessarily disclose identifiable client information during supervision.

Booking and payment information

We may collect information about:

• the service selected;
• appointment dates and times;
• booking information;
• rescheduling;
• cancellations;
• payment status;
• invoices;
• receipts;
• transaction references; and
• related administrative information.

Complete payment-card information may be processed directly by an independent payment provider rather than stored by EMPIXO.

Website and technology information

Depending on the technology used, we may receive information such as:

• IP address;
• browser type;
• device information;
• website activity;
• referral source;
• cookie identifiers;
• analytics data;
• form submissions; and
• technical logs.

4. You do not have to provide everything

You are not required to provide every piece of information EMPIXO requests.

However, some information may be necessary for us to:

• identify you;
• understand your circumstances;
• provide the requested service;
• complete a booking;
• process payment;
• prepare for a session;
• communicate with another organisation where authorised; or
• comply with a legal requirement.

If relevant information is not provided, we may not be able to provide some services effectively.

5. Do not give EMPIXO secret banking credentials

Do not give EMPIXO your:

• internet-banking password;
• PIN;
• card PIN;
• one-time passcode;
• authentication-app code;
• security token;
• complete security answers; or
• other secret banking or financial-account credentials.

If EMPIXO helps you understand information displayed within an online account, you should remain in control of logging in.

6. Why we collect and use information

We may collect and use personal information for purposes including:

• responding to enquiries;
• assessing whether an EMPIXO service may be appropriate;
• booking appointments;
• providing coaching, mentoring or supervision;
• preparing for sessions;
• understanding your financial circumstances;
• creating budgets, plans or working documents;
• operating EMPIXO Money Map;
• helping organise financial information;
• providing implementation support;
• providing accountability and follow-up;
• communicating with you;
• processing payments;
• issuing invoices and receipts;
• maintaining business and client records;
• providing customer support;
• improving services;
• quality assurance;
• dealing with complaints;
• managing referrals;
• protecting EMPIXO, clients and systems against fraud, misuse or security risks;
• meeting legal requirements; and
• operating and improving the EMPIXO business.

We will not intentionally use personal information for an unrelated purpose without an appropriate basis for doing so.

7. Where information may come from

Most information will come directly from you.

With your authority, or where otherwise permitted by law, information may also come from sources such as:

• your spouse or partner;
• family members or support people;
• your business;
• your club or organisation;
• banks;
• lenders;
• creditors;
• Inland Revenue;
• government organisations;
• accountants;
• lawyers;
• financial advisers;
• insurers;
• KiwiSaver providers;
• referral partners;
• publicly available sources; or
• other organisations relevant to your circumstances.

Where appropriate, EMPIXO may require a separate authority before obtaining information from another organisation.

8. Authority to deal with third parties

Your coaching agreement does not automatically authorise EMPIXO to obtain information from or communicate with another organisation on your behalf.

Where EMPIXO needs to deal with a third party such as:

• a bank;
• lender;
• creditor;
• Inland Revenue;
• government organisation;
• insurer;
• KiwiSaver provider;
• accountant;
• lawyer; or
• another organisation,

we may require a separate written authority.

An authority may specify:

• the organisation involved;
• the information that may be obtained or disclosed;
• the purpose;
• any limitations; and
• how long the authority remains valid.

Having authority to communicate with another organisation does not make EMPIXO your lawyer, accountant, tax adviser or regulated financial adviser.

9. Couples, partners and joint coaching

Where coaching involves a couple or household, personal information may relate to more than one person.

EMPIXO will seek to make clear:

• who the coaching relationship is with;
• what information is being shared;
• whether information relates to one or both participants; and
• how joint information will be handled.

Joint coaching generally requires a reasonable degree of openness.

A participant should not assume that significant information privately disclosed to EMPIXO can always remain confidential from another participant where withholding it would make the joint coaching relationship misleading, unsafe or inappropriate.

Where necessary, EMPIXO may recommend separate sessions or independent professional assistance.

10. Children and young people

Standard EMPIXO coaching is primarily intended for adults unless a programme states otherwise.

Where EMPIXO works with someone under 18, we may require:

• parent or guardian consent;
• parent or guardian involvement;
• different privacy arrangements;
• additional safeguarding measures; or
• limits on information collected.

We will seek to collect only information reasonably necessary for the relevant service.

11. Businesses, clubs and organisations

When EMPIXO works with a business, club or organisation, information supplied to us may contain personal information relating to:

• owners;
• employees;
• committee members;
• volunteers;
• members;
• customers;
• beneficiaries; or
• other individuals.

The organisation providing information to EMPIXO is responsible for ensuring it has an appropriate basis for sharing that information with us.

EMPIXO will use that information only as reasonably required for the engagement or another lawful purpose.

12. Sensitive financial information

Financial information may be particularly sensitive.

EMPIXO may receive information concerning:

• financial hardship;
• debt;
• overdue payments;
• insolvency concerns;
• IRD debt;
• suspected fraud;
• family financial problems;
• business difficulties;
• income;
• assets; and
• financial behaviour.

We will take reasonable care in how such information is accessed, stored, used and disclosed.

13. Bank security, fraud and scam information

If you contact EMPIXO about suspected fraud, scams or banking-security concerns, we may collect information about:

• suspicious communications;
• transactions;
• account activity;
• payment requests;
• organisations or individuals involved;
• dates and amounts; and
• steps already taken.

EMPIXO is not a bank fraud department, cybersecurity provider, fraud investigator, Police service or emergency service.

If you believe an account has been compromised or money fraudulently transferred, you should contact your bank promptly using an independently verified official contact method rather than waiting for an EMPIXO appointment.

14. EMPIXO Money Map

Where you use EMPIXO Money Map or another EMPIXO financial tool, we may collect and process information required to operate that tool.

This may include:

• income;
• expenses;
• debts;
• assets;
• balances;
• categories;
• financial goals;
• progress information; and
• information you enter or import.

Money Map outputs may depend on the accuracy and completeness of information supplied.

EMPIXO may retain relevant historical information or snapshots where this forms part of the service.

Additional product-specific privacy information may be introduced as Money Map develops.

15. Artificial intelligence and technology

EMPIXO may use AI-assisted or other technology for purposes including:

• administration;
• session preparation;
• meeting summaries;
• transcription;
• organising notes;
• workflow management;
• document preparation;
• financial data organisation;
• research support;
• quality checking; and
• client follow-up.

AI systems can make mistakes.

EMPIXO does not treat information as automatically accurate merely because it was produced or processed by an AI system.

Where appropriate, human judgement and review remain part of the process.

16. AI and personal information

Where personal information may be processed using an AI-assisted or other technology provider, EMPIXO will take reasonable steps to consider matters including:

• whether the information is necessary;
• whether identifiable information is required;
• the sensitivity of the information;
• the provider being used;
• security;
• access;
• retention; and
• applicable privacy obligations.

Where appropriate, EMPIXO may limit, remove or de-identify information before using particular systems.

17. Recording and transcription

EMPIXO does not state that every coaching session will automatically be recorded.

Where EMPIXO intends to make an audio or video recording of a private session, appropriate notice or consent will be obtained where required.

Where an AI note-taking or transcription system materially records or processes a private conversation, appropriate notice or consent will also be used where required.

Automated transcripts and summaries can contain errors and should not automatically be regarded as a perfect record of a meeting.

18. Payment providers

EMPIXO may use independent payment providers to process:

• card payments;
• payment links;
• invoices;
• refunds;
• payment confirmations; and
• other payment functions.

Those providers may collect payment information directly from you.

EMPIXO may receive information about a transaction without receiving or retaining your complete card details.

Payment providers operate under their own privacy and security arrangements.

19. Booking and scheduling providers

EMPIXO may use independent scheduling systems to:

• display appointment availability;
• collect booking information;
• manage appointments;
• manage rescheduling;
• manage cancellations;
• send reminders;
• generate meeting details; and
• coordinate calendars.

Information provided during booking may therefore be processed by the relevant scheduling provider.

20. Email, video meetings, storage and cloud services

EMPIXO may use third-party services for:

• email;
• cloud storage;
• file sharing;
• video conferencing;
• calendars;
• administration;
• website hosting;
• client management;
• accounting;
• software; and
• other business functions.

These providers may process or store personal information on EMPIXO’s behalf.

21. Overseas processing and storage

Some technology providers used by EMPIXO may operate or store information outside New Zealand.

This means personal information may in some circumstances be processed or stored in another country.

Where overseas disclosure or processing is subject to New Zealand privacy requirements, EMPIXO will seek to use appropriate arrangements and safeguards required by applicable law.

Privacy protections in other countries may differ from those in New Zealand.

22. Who we may share information with

EMPIXO does not sell client personal information.

Personal information may be disclosed where reasonably necessary to:

• provide the service you requested;
• complete a transaction;
• operate technology used by EMPIXO;
• comply with an authorised request from you;
• communicate with a professional or organisation you have authorised;
• obtain professional advice for EMPIXO;
• investigate or respond to a complaint;
• manage security or fraud concerns;
• comply with a legal requirement; or
• exercise or protect a lawful right.

Where appropriate, disclosure will be limited to information reasonably necessary for the purpose.

23. Referrals

If EMPIXO refers you to another provider, we will not automatically send that provider your complete financial file.

Where information needs to be shared to facilitate a referral, we may seek your permission or rely on another appropriate lawful basis.

The provider receiving the referral may have its own privacy policy and information-handling practices.

24. Financial abuse, coercion, fraud and safety

Financial coaching can sometimes reveal concerns involving:

• financial abuse;
• coercive control;
• exploitation;
• intimidation;
• family violence;
• fraud;
• scams; or
• serious safety concerns.

EMPIXO will normally treat information confidentially.

There may nevertheless be circumstances where disclosure is required or permitted by law or otherwise justified by a serious safety, fraud or legal concern.

EMPIXO is not an emergency service.

25. Marketing communications

EMPIXO may offer:

• newsletters;
• financial education;
• business updates;
• new-service information; or
• other marketing communications.

Where consent is required, marketing consent will be obtained separately from acceptance of the Terms applying to your service.

Purchasing an EMPIXO service does not require you to agree to optional marketing communications.

You may unsubscribe from marketing communications using the method provided in the communication or by contacting EMPIXO.

Necessary administrative and service-related communications may still be sent.

26. Testimonials and client stories

Participation in an EMPIXO service does not automatically give us permission to publicly use your:

• name;
• photograph;
• story;
• testimonial;
• video;
• financial information;
• business information; or
• identifiable results.

Appropriate permission will be obtained before identifiable client material is used for marketing.

27. De-identified and aggregated information

EMPIXO may use appropriately de-identified or aggregated information for purposes such as:

• service improvement;
• understanding common financial issues;
• business planning;
• research;
• product development;
• education; and
• reporting.

We will seek to avoid presenting de-identified information in a way that reasonably identifies an individual.

28. Website cookies and analytics

The EMPIXO website may use cookies or similar technologies.

These may help us:

• operate the website;
• remember preferences;
• understand website usage;
• improve performance;
• analyse traffic;
• measure marketing activity; and
• understand how visitors find EMPIXO.

Where required, further cookie information or consent mechanisms may be provided.

You may also be able to manage cookies through your browser settings.

29. External websites and services

The EMPIXO website may link to independent third-party websites or services.

EMPIXO does not control how those providers collect, use or protect personal information.

You should review the privacy information provided by the relevant third party.

30. How we protect information

EMPIXO will take reasonable safeguards appropriate to the nature of the information held.

These may include:

• access controls;
• passwords;
• multi-factor authentication;
• device security;
• reputable service providers;
• restricted access;
• secure storage;
• data minimisation;
• confidentiality requirements;
• backups; and
• security procedures.

No system can be guaranteed to be completely secure.

31. Access within EMPIXO

Access to personal information will be limited to people who reasonably require it for legitimate EMPIXO purposes.

This may include:

• authorised EMPIXO personnel;
• contractors;
• professional advisers;
• technology providers; and
• other authorised service providers.

Access should be proportionate to the role being performed.

32. How long we retain information

EMPIXO may retain personal information for as long as reasonably required for purposes including:

• providing services;
• maintaining appropriate records;
• responding to queries;
• managing complaints;
• accounting and tax requirements;
• legal requirements;
• resolving disputes;
• security;
• business continuity; and
• other legitimate purposes.

Different types of information may have different retention periods.

Information that is no longer reasonably required will be deleted, securely destroyed, anonymised or otherwise dealt with appropriately, subject to applicable legal and operational requirements.

33. Keeping information accurate

We encourage you to tell us when important information changes or appears incorrect.

This is particularly important where information affects:

• budgets;
• cashflow;
• Money Map;
• debt schedules;
• financial plans;
• business information;
• household information; or
• other calculations.

You may request correction of personal information held by EMPIXO where applicable.

34. Accessing your personal information

Subject to applicable law, you may request access to personal information EMPIXO holds about you.

There may be circumstances where information cannot lawfully be provided in full.

We may need to verify your identity before releasing information.

Requests can be made to:

info@empixo.com

35. Correcting your personal information

If you believe personal information held by EMPIXO is incorrect, you may ask us to correct it.

Where applicable, we will consider the request in accordance with New Zealand privacy law.

If a requested correction is not made, you may have the right to ask for a statement of correction to be associated with the information.

36. Privacy and security breaches

If EMPIXO becomes aware of a privacy or security incident involving personal information, we will assess the circumstances and take reasonable steps appropriate to the incident.

These may include:

• containing the incident;
• investigating what happened;
• reducing potential harm;
• improving safeguards;
• notifying affected people where required or appropriate; and
• notifying the New Zealand Privacy Commissioner where required by law.

37. Privacy complaints

If you have a concern about how EMPIXO has handled your personal information, contact:

EMPIXO Privacy
TEAM YCBC ENTERPRISES LIMITED
Email: info@empixo.com

Please explain:

• what happened;
• your concern;
• the information involved; and
• the outcome you are seeking.

We will make reasonable efforts to consider the matter fairly.

You may also have the right to complain to the Office of the Privacy Commissioner in New Zealand.

38. Future regulated financial advice

EMPIXO intends to introduce regulated financial advice in the future once the appropriate qualifications, licensing and/or Financial Advice Provider authorisation arrangements, adviser requirements and compliance processes are in place.

A future regulated financial advice service may create additional privacy, disclosure and record-keeping requirements.

This Privacy Policy may therefore be updated before those services commence.

Nothing in this section means that regulated financial advice is currently available through EMPIXO.

39. Changes to this Privacy Policy

EMPIXO may update this Privacy Policy where:

• services change;
• technology changes;
• new products are introduced;
• legal requirements change;
• privacy practices change; or
• future regulated financial advice services are introduced.

The current version will be published on the EMPIXO website with an updated effective date where appropriate.

40. Contact EMPIXO about privacy

For privacy questions, access requests, correction requests or privacy complaints, contact:

TEAM YCBC ENTERPRISES LIMITED
Trading as EMPIXO

Company Number: 5196522
NZBN: 9429041223437
GST Number: 114070378

222 Milson Line
Milson
Palmerston North 4414
New Zealand

Email: info@empixo.com
Website: http://www.empixo.com