Privacy Policy

Small Change Software Limited, trading as smallChange

Last updated: 5 March 2026

Small Change Software Limited, trading as smallChange ("we", "us", or "our"), is a company registered and based in New Zealand. This Privacy Policy explains how we collect, use, store, and protect personal information in connection with our software platform and services (collectively, the "Services").

We are committed to protecting your privacy and complying with the New Zealand Privacy Act 2020 (the "Privacy Act"). By using our Services, you agree to the terms of this Privacy Policy.

This Privacy Policy will be reviewed from time to time to reflect changes in our Services, applicable laws, or business practices. The most recently updated version will always govern how we handle your personal information.

1. Definitions

In this Privacy Policy:

• "Authorised Users" means the Customer's personnel who have been authorised by the Customer to access and use the Services.
• "Customer Data" means any documents, files, or data uploaded to the Services by a Customer or their Authorised Users.
• "Personal Information" has the meaning given in the Privacy Act 2020 — that is, information about an identifiable individual.
• "Services" means the software platform, tools, and related services provided by smallChange.
• "Website" means www.smallchange.co.nz or such other website as we may operate from time to time.

2. Information We Collect

We collect Personal Information that is necessary to provide you with our Services. This may include:

• Your name and contact details (email address, phone number, postal address)
• Your employer or organisation name, job title, and industry
• Login credentials and account information
• Billing and payment information (processed securely via our third-party billing provider)
• Usage data and activity logs related to your use of the Services
• Communications you send to us, including support requests and feedback
• IP address, browser type, and device information collected automatically when you use the Website or Services

We collect this information directly from you when you register for an account, use the Services, contact us, or otherwise interact with us.

We do not collect Personal Information from you without your knowledge.

3. How We Use Your Personal Information

We use Personal Information to:

• Create and manage your account
• Provide, maintain, and improve the Services
• Process billing and payments
• Communicate with you regarding your account, the Services, or support requests
• Comply with our legal obligations
• Monitor and ensure the security and integrity of the Services

We will not use your Personal Information for any purpose that is incompatible with the primary purpose for which it was collected, unless you have given your consent or the use is permitted by applicable law.

4. Disclosure of Personal Information

We treat your Personal Information with care and will not share it with third parties except in the following limited circumstances:

• Billing and payment processing: We share necessary billing information with our third-party payment processor solely for the purpose of processing payments. This provider is bound by its own privacy and security obligations.
• Legal obligations: We may disclose Personal Information if required to do so by law, regulation, court order, or other legal process, or if we believe in good faith that disclosure is necessary to protect our rights or the safety of others.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of our business, Personal Information may be transferred as part of that transaction. We will notify you of any such change.

We do not sell, rent, or trade your Personal Information to any third party for marketing or commercial purposes.

5. Customer Data and File Storage

Files, documents, and other Customer Data uploaded to our secure storage remain the property of the Customer at all times. We do not claim ownership over Customer Data and will not use it for any purpose other than providing the Services.

While Customer Data remains your property, please be aware that:

• We may occasionally scan uploaded files and documents for illegal or harmful content (including malware, prohibited materials, or content that violates applicable law or our Terms of Service). This scanning is automated and is performed solely to protect the integrity and security of our platform and its users.
• Any such scanning will be conducted in a manner designed to protect the confidentiality of your data and will not involve human review of your files except where we are required to investigate a specific concern.
• We will not access, review, or disclose Customer Data except as described in this Privacy Policy or as required by law.

6. Data Security

We take the security of your Personal Information seriously. We implement appropriate technical and organisational measures to protect Personal Information from unauthorised access, disclosure, alteration, loss, or destruction.

While we take all reasonable steps to protect your information, no internet-based service can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

If you suspect any unauthorised access to or misuse of your Personal Information, please contact us immediately at the details below.

7. Data Retention

We retain Personal Information for as long as is necessary to fulfil the purposes for which it was collected, or as required by law. When your account is closed or your information is no longer required, we will take reasonable steps to delete or de-identify it.

Note that certain information may be retained for longer periods where we are required to do so for legal, tax, or regulatory purposes (for example, financial records may be retained for up to seven years).

8. Cookies and Tracking Technologies

Our Website may use cookies and similar technologies to improve your browsing experience, analyse usage, and support the functionality of the Services. Cookies do not personally identify you but may be associated with your account or device.

You may configure your browser to decline cookies, though doing so may affect the functionality of some parts of the Website or Services.

9. Your Rights

Under the New Zealand Privacy Act 2020, you have the right to:

• Request access to the Personal Information we hold about you
• Request correction of any Personal Information that is inaccurate or out of date
• Request deletion of your Personal Information, subject to any legal obligations we may have to retain it
• Make a complaint to us or to the Office of the Privacy Commissioner if you believe we have interfered with your privacy

To exercise any of these rights, please contact our Privacy Officer using the details in Section 11 below. We will respond to your request within a reasonable timeframe.

10. Links to Third-Party Websites

Our Website or Services may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites. We encourage you to review the privacy policies of any third-party sites you visit.

11. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your Personal Information, please contact our Privacy Officer:

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner at www.privacy.org.nz .

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Where changes are significant, we will notify you by displaying a notice on our Website or by sending you an email. Your continued use of the Services after any update constitutes your acceptance of the revised policy.