Noho matatapu

Privacy policy

Version 2.0 2021-06-16


Sparefish creates software tools for Unit Title developments and their associates. To monetize the initiative Sparefish offers optional general insurance advice and facilitates the procurement of general insurance products for customers and risks in New Zealand.

This document details Sparefish’s policy pertaining to the treatment of private information of its customers.

References to “we” and “our” refer to Sparefish Limited, its employees, and anyone contracted to provide advice on Sparefish Limited’s behalf.

References to “you” and “your” refer to our customers.



We understand that we are custodians of your information. We respect the trust you have afforded us and we promise to hold your information securely and carefully.

Our privacy policy is aligned with New Zealand’s Privacy Act 2020 and draws on the thirteen principles that are defined in it. Detailed information about the Act and the core principles can be found at the Office of the Privacy Commissioner here:

We are in the business of providing free software tools and finding you the best insurance options we can. We are not in the business of selling your private information.

Principle 1 - Purpose for collection

We collect personal and other information from you for the purpose under which it was collected. This may include

We also use the information you give us for analytics and benchmarking purposes. If we choose to do this we will anonymise and aggregate your data.

We offer opt-out and unsubscribe services through our website. On request we will remove your data from our environments, however, this may not be possible with some records due to our statutory requirements.

Principle 2 - Source of information

We trust you as the source of your information. Where possible we make efforts to fetch data from external sources (like Waka Kotahi NZ Transport Agency or Google Places), so we can give you a better experience by reducing the amount of typing needed.

Where we source information externally, we will present this to you and ask for your confirmation. You may correct inaccurate information. If anything looks wrong and you cannot change it, please let us know so we can work together on fixing the problem.

Principle 3 - What to tell an individual

When we collect information from you we have an obligation to explain why this information is being collected, who will receive the information, whether the information is compulsory or voluntary, and what will happen if the information isn’t provided.

Generally, we collect information so that we can analyse and understand your risks. We then disclose your information to different insurance companies with the intent of seeking quotations and a subsequent contract of insurance. In most cases insurers will only provide favourable insurance terms if they know more about your risks. Where there is missing information, the insurer may refrain from offering you cover. Where incorrect information has been disclosed, an insurer may choose to decline a claim.

Principle 4 - Manner of collection

We collect information from you in a fair and legal manner. It is our preference to capture your information in a digital medium so that we have an electronic record.

Where information has been collected from you in conversation, either in person or over the phone, we will present you with the information electronically and request that you confirm its accuracy.

Principle 5 - Storage and security

We take reasonable measures to protect your information from unintended loss, misuse or disclosure. We encrypt your information in a segregated layer of our network with adaptive threat protection and detection measures. We also enforce strict access control measures for employees and monitor anomalous behaviour in our environments.

Principle 6 - Access

On request we will provide you with electronic access to all of the information we hold about you. If you have any queries or need help navigating your files, you can contact us for assistance.

Principle 7 - Correction

If you notice that any of the information we hold about you is incorrect, and we haven't given you an obvious facility to edit the information, you can contact us and we will work with you to fix the problem.

Where we have sourced the information from a third party, we may need you to have the information corrected there before we can action the change at our end.

Principle 8 - Accuracy

When we pass your data to insurers we do our best to make sure that it is accurate, up to date, complete, relevant, and not misleading.

If you notice that any of the information is incorrect then we need to know straight away so that we can work with you to fix the problem.

Principle 9 - Retention

We only retain information for as long as we need it, which is in line with New Zealand’s statute of limitations. In most cases this is seven years. After the information is no longer needed we “digitally shred” the data.

Principle 10 - Use

We only use your data in accordance with Principle 1 - Purpose for collection. If we intend to use your information in a different manner to the purpose then we will seek explicit agreement from you.

Principle 11 - Disclosure

We may disclose your information to other organisations for purposes that are in accordance with Principle 1 - Purpose for collection. We will ask for your permission before we disclose your information.

We may be required to disclose your information to government organisations who have a legal right to view your information. We will contact you prior to disclosing any information so that you can provide any objection.

Principle 12 - Disclosure outside New Zealand

We may disclose your information to organisations outside New Zealand. An example of this may be a complex insurance placement that requires the backing of a large global insurer or reinsurer.

The organisations that we disclose the information to need to prove they will protect your information by either doing business in New Zealand, being subject to privacy laws that provide comparable safeguards to the Privacy Act, agreeing to adequately protect the information, or are being subject to the privacy laws of a country prescribed by the New Zealand Government.

Principle 13 - Unique identifiers

We collect unique identifiers from you so that we can validate your identity. These may be, for example, your driver’s licence number or passport number. We do not use that unique identity in any other capacity and may only store it as a one-way cryptographic hash.

Contact Information

Nicholas Robertson

Managing Director and Co-Founder

36 Summer Street, Ponsonby, Auckland

+64 274 129 384