Buffer Builder

Privacy Statement

Last updated: 22 July 2026

1. Introduction

This Privacy Statement explains how CAP Initiatives Limited (“CAP Initiatives”, “we”, “us”) collects, uses, and protects your personal information when you use the Buffer Builder mobile application (“the App”).

CAP Initiatives is associated with Christians Against Poverty New Zealand, but Buffer Builder operates as a standalone digital product.

We are committed to protecting your privacy in accordance with the New Zealand Privacy Act 2020.

2. What Information We Collect

We may collect the following types of information:

a. Information You Provide

  • Name and email address (if you create an account)
  • Savings goals, targets, and progress
  • Notes, preferences, and other information you enter
  • Information on what or who brought you to the app

b. Usage and Analytics Information

We use Mixpanel, an analytics service, to understand how users interact with the App.

This may include:

  • Screens viewed
  • Features used
  • Actions taken within the App
  • Time spent in the App

This information helps us improve functionality and user experience.

c. Technical and Device Information

  • Device type and operating system
  • App version
  • Crash and performance data
  • App-generated identifiers (user ID)

d. Open Banking Information

Connecting a bank account using open banking services is required to use Buffer Builder. Once connected, Buffer Builder can access:

  • Account balance information
  • Transaction information
  • Other related financial data required to support the App’s functionality

Your transaction history stays at your bank. Buffer Builder does not keep a copy of your bank statements or transaction feed. Each time you use the App, balances and transactions are retrieved securely through Akahu, displayed to you, and not retained by CAP Initiatives.

To make the App work, we store a small amount of information derived from your banking data:

  • the income patterns we detect (who pays you, the typical amount, and how often),
  • summaries produced when we analyse your finances (such as your typical spending and saving),
  • records of the saves the App makes for you (amounts, dates, and the accounts involved).

CAP Initiatives never receives or stores your internet banking username, password, or other banking credentials.

3. How We Use Your Information

We use your information to:

  • Provide and operate the App
  • Track your progress toward savings goals
  • Personalise your experience
  • Improve App features and performance (including via Mixpanel analytics)
  • Maintain security and prevent misuse

We may also use aggregated and de-identified information to evaluate the effectiveness of Buffer Builder, measure outcomes, support programme improvement, and contribute to approved research and impact measurement activities.

We do not use your data for advertising or sell it to third parties.

4. Analytics (Mixpanel)

We use Mixpanel to collect usage data and analyse user behaviour within the App.

Mixpanel may process:

  • Device-level identifiers
  • Interaction data (e.g. events, clicks, feature usage)

This data is used only for product improvement and analytics purposes.

We configure analytics to:

  • Avoid collecting unnecessary personal data
  • Limit data to what is required for App functionality and improvement

5. Open Banking Services (Akahu)

Buffer Builder uses Akahu Technologies Limited (“Akahu”) to provide open banking functionality. Connecting a bank account through Akahu is required in order to use the App.

To use Buffer Builder, you must connect a bank account. When you connect an account:

  • You authorise Akahu to access banking information on your behalf.
  • You provide consent through Akahu’s secure authorisation process.
  • Akahu accesses banking information directly from participating financial institutions.
  • CAP Initiatives receives only the information necessary to provide Buffer Builder functionality.
  • CAP Initiatives does not receive, store, or have access to your internet banking passwords or security credentials.

Akahu’s handling of your information is governed by its own terms and privacy documentation. We encourage you to review Akahu’s Consent Privacy Notice and End User Terms before connecting your accounts.

CAP Initiatives and Akahu each have separate responsibilities for the personal information they access and process.

6. Sharing of Information

We do not sell personal information.

We may share information with:

a. Service Providers

Including:

  • Cloud hosting providers
  • Analytics providers (such as Mixpanel)

These providers:

  • Process data on our behalf
  • Are required to protect your data

Additional service providers may include:

  • Akahu (open banking services)
  • Hosting and infrastructure providers
  • Approved research, evaluation, and cohort-tracking partners

b. Research, Evaluation, and Cohort-Tracking Partners

CAP Initiatives may use information from Buffer Builder to understand user outcomes, evaluate effectiveness, improve financial wellbeing services, and measure impact.

Information may be shared with approved research, evaluation, or cohort-tracking partners, including Te Ara Ahunga Ora Retirement Commission.

Unless otherwise stated:

  • Information shared will generally be aggregated and de-identified.
  • Individual users will not be identified by the information shared.
  • Names, email addresses, account and transaction information, and other directly identifying information will not be shared with research partners without additional notice or consent where required by law.

If a future project requires information to be shared differently, we will provide additional information about how your data will be used and shared.

c. Legal Requirements

We may disclose information where required by law, or where reasonably necessary to protect the safety, rights, or property of users or CAP Initiatives, or to prevent fraud or misuse.

7. International Storage and Processing

Personal information may be stored or processed in New Zealand and other countries where our service providers operate.

Where information is processed outside New Zealand, CAP Initiatives takes reasonable steps to ensure it receives protections comparable to those required under the New Zealand Privacy Act 2020.

You may contact us for more information about where your personal information is stored or processed.

8. Data Storage and Security

We take reasonable steps to protect your data, including:

  • Encryption in transit
  • Secure infrastructure
  • Restricted access controls

Additional safeguards include authentication controls, monitoring, security reviews, and the use of trusted third-party providers that maintain security controls appropriate to the services they provide.

Open banking connections are provided through Akahu, which maintains security controls designed to protect banking connections and authorised financial information. Akahu is an accredited requestor under New Zealand’s Consumer Data Right (CDR) framework and is required to meet the security, privacy, and regulatory standards that apply to accredited providers under that regime.

However, no system can guarantee complete security.

9. Data Retention

We retain your information only as long as necessary to:

  • Provide the App
  • Improve services
  • Meet legal obligations

We aim to minimise retained data wherever possible.

10. Your Rights

You have the right to:

  • Access your personal information
  • Request correction

You may also request deletion of your Buffer Builder account and information held by CAP Initiatives where appropriate. In some circumstances we may be required to retain information to meet legal, regulatory, audit, or operational requirements.

These rights align with the New Zealand Privacy Act 2020.

11. Managing Your Data

You can:

  • Update your information within the App
  • Request deletion of your account and data

Requests can be made by contacting us.

As Buffer Builder requires connecting a bank account through Akahu, deleting the information held by CAP Initiatives does not delete the information held by Akahu. To fully remove your data, you will also need to withdraw your consent or make a deletion request directly with Akahu, in accordance with Akahu’s privacy processes.

12. No Cross-App Tracking

Buffer Builder:

  • Does not track you across other apps or websites
  • Does not use your data for targeted advertising

13. Relationship to CAP Services

Using Buffer Builder:

  • Does not create a client relationship with Christians Against Poverty New Zealand
  • Does not integrate with CAP NZ client systems

Any engagement with CAP NZ services is subject to separate privacy terms.

14. Changes to This Statement

We may update this Privacy Statement from time to time.

Updates will be published within the App.

15. Contact Us

For questions or requests regarding your data:

Privacy Officer

CAP Initiatives Limited

PO Box 12041, Penrose, Auckland 1642

Email: [email protected]

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner via the Privacy Commissioner’s website.