We are committed to providing you with high quality financial services in a secure and confidential manner in compliance with the Privacy Act 2020.
This policy sets out details on:
- Collecting your personal information
- Using your personal information
- Sharing your personal information
- Protecting your personal information
- Accessing and updating your personal information
- How you can contact us
Personal information includes any information that could identify you, such as your name and address, tax details, transaction records and any unique identifiers assigned to you.
Collecting your personal information
We collect your personal information if it is necessary to help us deliver the services that you have engaged, or are seeking to engage, us to provide. This may include collecting your information to satisfy the legal and regulatory obligations that we have as a financial services provider.
We may collect your personal information directly from you or from third parties (such as service providers we have engaged to help us provide services to you or that you have engaged and authorised to share your information with us) and publicly available sources, including government registers.
We will not collect your personal information if you refuse to provide consent, however this may restrict the services that we are able to provide to you or cause us to suspend or terminate your account.
Using your personal information
We will only use your personal information:
- when you apply (this includes verifying your identity and other due diligence tasks associated with setting up an account);
- to deliver the services you have asked us to provide, such as administering your account and carrying out your instructions;
- to meet our obligations to regulators, other authorities, and to comply with any laws (including monitoring accounts for fraud, money laundering and any other illegal activities); and
- for our own marketing purposes (you may opt out at any time).
Your information will not be used for any other purpose without your consent.
Sharing your personal information
We share your personal information with:
- our related companies (as defined in section 2(3) of the Companies Act 2020, read as if the expression ‘company’ in the subsection included a body corporate of any jurisdiction);
- third party providers we use to help us provide services to you, deliver technology solutions and assist us with regulatory obligations (including but not limited to sub-custodians, brokers, banks and other deposit-taking institutions and our advisers such as lawyers, auditors, accountants and other consultants);
- any third parties you authorise disclosure to (such as your lawyer or accountant);
- government agencies, regulatory authorities and law enforcement; and
- credit reporting and collection agencies.
As above, we may share your personal information with government agencies, regulatory authorities and law enforcement, as necessary in order to comply with our legal obligations. In those circumstances, they may not have to keep your information confidential.
We will not share your personal information to third parties based in countries with privacy laws weaker than NZ unless they are required to protect your personal information to a comparable standard (for example, under the terms of our contract with them) or with your consent.
Protecting your personal information
Your personal information is protected by various security measures and protocols and can only be accessed by authorised personnel. It is stored both physically and electronically, mainly in New Zealand and Australia. We remain responsible for ensuring the security of your personal information.
All personal information collected from our website and subsequently transmitted over the internet will be encrypted.
If there has been a breach of your personal information, we will identify the cause of the breach, make attempts to rectify, and limit any harm. If we are unable to prevent the breach causing or being likely to cause you serious harm, we will notify you and report the breach to the Office of the Privacy Commissioner (https://www.privacy.org.nz).
If you close your account with us, we’ll continue to retain your personal information for 7 years to comply with our legal obligations, after which your information will be securely disposed of to the fullest extent possible.
Accessing and updating your personal information
We will always endeavour to ensure the personal information we store about you is accurate, complete and up to date.
You, or someone you authorise, can view, and request updates/corrections to, the record of all the personal information we store about you. Please contact your adviser in the first instance or alternatively contact the JBWere Privacy Officer (see ‘How you can contact us’ below).
We will generally not charge any fee for servicing these requests, although if the request is complex in nature, we reserve the right to apply a reasonable fee - we will provide you with advance notice if this is the case.
Once you make a request, we will respond to you as soon as possible and within 20 working days. Please let us know if your request is urgent and if so, the reasons why so we can take this into account when responding.
If you are not satisfied with our response you have the right to lodge a complaint with the Office of the Privacy Commissioner.
Depending on the nature of the changes, we may notify you by way of:
- Notice on our website; and/or
- Contacting you by email or post.
How you can contact us