Effective Date: 01 December 2020
1. Our commitment to protect your privacy.
We understand how important it is to protect your personal information. This document sets out our privacy commitment in respect of personal information we hold about you and what we do with that information.
It is important to us that you are confident that any personal information we hold about you will be treated in a way which ensures protection of your personal information.
2. Who are we
3. Your authorisation
5. What personal information do we collect?
When we refer to personal information, we mean information that identifies or can identify you. This includes, for example, your name, date of birth, address, contact details, account details and occupation.
If you engage us to provide services to you, we may collect personal information about your financial situation or goals to recommend insurance and investment products that we are permitted to advise on (Products).
6. Why do we collect your personal information?
We collect your personal information for the purposes of our and relevant third parties’ services and relationship with you (refer to section 9 below: “Who do we disclose your personal information to?”). For example:
- responding to your requests or inquiries
- Providing services to you (e.g. to enable us to recommend Products to you);
- sending communications and direct marketing to you about products and services we think may be of interest to you (whether through mail, telephon or electronic means (including email and SMS/MMS);
- market research; and
- any other purpose authorised by you or the Privacy Act.
If you do not wish to receive marketing information, you may ‘opt out’ at any time by
7. How do we collect your personal information?
Generally, we will collect your personal information directly from you. For example, we collect your personal information directly via out fact-find document and from your use of our website and the information that you submit to the website. We also collect your personal information if you use the “contact us” functionality on our website and you provide the personal information during conversations between you and us.
We may also collect your personal information from:
- Product Providers (e.g. during the term of any insurance or investments we have arranged on your behalf, in order to answer your queries or assist you with your financial arrangements as your circumstances change). If applicable, the Product Providers may also periodically disclose your investment balances or premiums to us in connection with the payment of ongoing commission to us over the term of your investment or insurance;
- and any other person authorised by you or the Privacy Act.
If you provide any personal information about anyone else to us, you confirm that you have collected that personal information in accordance with the Privacy Act and that the individual concerned has:
- has been informed of their right to access and request correction of their personal information.
8. Updating your personal information
We will generally rely on you to ensure the information we hold about you is
accurate. If any of your details change, please let us know as soon as possible by
9. Who do we disclose your personal information to?
We may disclose your personal information to the following people if we consider it
necessary to do so for the purposes described in section 6 above:
- Product Providers and other prospective third parties or other intermediaries in relation to your insurance or investment requirements
- our referral partners who can help you with other services, contractors or service providers.
- investors, or any entity that has an interest in our business or any entity to whom we consider assigning or transferring any of our rights or obligations or selling all or part of our business.
- anyone who we are legally required or authorised to share your information with, including regulators and government agencies.
- to auditors to ensure we are providing services to you that are in your best interests, and in accordance with current regulations.
- any other person or entity authorised by you or the Privacy Act.
Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that the person or organisation has a commitment to protecting your personal information at least equal to our commitment.
10. Do we disclose your personal information to anyone outside of New Zealand?
We may use cloud storage to store the personal information we hold about you. The cloud storage and the IT servers may be located outside New Zealand. We may also disclose personal information to relating aggregator groups and its related bodies corporate, and third-party suppliers and service providers located overseas for some of the purposes listed above.
11. Our Website
Our cookies may record information such as your Internet Protocol (IP) address (that is, the electronic addresses of computers connected to the internet), your device and browser type, operating system, the pages or features of our site to which you have browsed and the time spent on those pages or features, the frequency with which
the site is used by you, the search terms that you have used, the links on our site that a you have clicked on or used, and other usage statistics.
While our cookies do not collect personal information, if you submit your name and email address as part of your usage, then we will link that personal information with the cookies information that we have previously collected from you. If you do not wish to receive cookies, you can set your browser so that your computer does not
Security: As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the
internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
Links and third-party advertisements: Our website may contain links to other websites operated by third parties. Our website may also display advertisements, which are hosted by third parties. We make no representations or warranties in relation to the privacy practices of any third-party website or advertisement providers
and we are not responsible for other privacy policies or the content of any third party website or advertisements. Third party websites are responsible for informing you about their own privacy practices.
12. Are you required to provide personal information to us?
You are not required to provide any personal information to us but if you choose not to it might affect our ability to provide services to you and your ability to obtain insurance, implement investments and other products from Product Providers. In most circumstances it will be necessary for us to identify you to successfully do
business with you. However, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information, for example, if you make general inquiries about interest rates or current promotional offers.
You may choose to interact with our website anonymously, but we will not be able to contact you unless you provide your personal information.
13. Access and correction to your personal information
You may access and request correction of any of the personal information that we hold about you at any time by contacting us. We may charge a fee for our reasonable costs of retrieving and supplying the information to you.
14. Further information