Privacy policy

PERPETUAL GUARDIAN INVESTMENTS LIMITED (“PERPETUAL GUARDIAN INVESTMENTS”) COMPLIES WITH THE NEW ZEALAND PRIVACY ACT 1993 (THE ACT) WHEN DEALING WITH PERSONAL INFORMATION.  PERSONAL INFORMATION IS INFORMATION ABOUT AN IDENTIFIABLE INDIVIDUAL (A NATURAL PERSON).

Perpetual Guardian Investments recognises the importance of safeguarding clients’ personal information. This policy sets out how we will collect, use, disclose and protect your personal information.

The collection of your personal information is essential to enable us to conduct our business and provide services (“Services”) to you.

What information does Perpetual Guardian Investments collect?

We are committed to our obligations under the Act relating to collecting personal information.  In order to provide our Services, it is essential we collect and process some personal information.

The information we collect can include:

• Information provided by you when using our Services. This includes information provided at the time of registering or utilising any of our Services, interacting with our staff, or posted material.
• If you contact us, we may keep a copy of the correspondence.
• Details of transactions you carry out with our team or using our technology including the fulfilment of these transactions.
• Details of visits to our websites including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources access.

We may also ask you to complete surveys we use for research purposes, although you do not have to respond to these requests.

IP Addresses

We may collect information about your computer, including, where available, IP address, operating system and browser type, for system administration and to report aggregate information for our advertisers.  This is statistical data about our users’ browsing patterns and actions, and does not identify any individual. 

Cookies

In order for us to provide the Services, you may be asked to access websites operated by Perpetual Guardian Investments.  These websites use cookies to improve and personalise your experience.  Cookies are small text files, which are placed on your computer when you access a website or application.  They are a common feature used by many websites and other applications. Cookies do not have the capability to perform actions by themselves.  They can be used for tracking, authentication, marketing and managing user information.   Most browser technology will allow you to prevent the browser or device to accept cookies.  This may result in certain functions of the website being diminished.

How does Perpetual Guardian Investments use your information?

We may use your personal information:

• To establish your requirements and provide the appropriate product or service;
• To set up, administer and manage our products and Services;
• To understand your needs and improve our products and Services, including training and developing our staff and representatives;
• To verify your identity;
• For any other use you authorise;
• To communicate with you;
• To protect our rights;
• To ensure the secure and proper operation of our websites;
• For internal research purposes;
• In any other way set out in this Privacy Policy.

We are required by the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 to collect your personal information to verify your identity. We may be required by the Foreign Account Tax Compliance Act (“FATCA”) and OECD Common Reporting Standard to collect and report certain information about an account holder’s tax residency.

Therefore, the collection of certain personal information will be mandatory for particular Services you require.

Sharing your information

We use and disclose your personal information for the purposes we collected it. 

We may use and disclose personal information for a secondary purpose only if the secondary purpose is directly related to the purpose of collection. 

When necessary and in connection with the purposes listed above, we may disclose personal information to:

• Subsidiaries, related companies or joint venture companies where required or authorised under our relationship.
• Information technology providers, including hardware and software vendors and consultants such as programmers, for the development or delivery of our Services only.
• Customer research organisations, solely for the purpose of service improvements, however, not for direct marketing purposes.
• Intermediaries including your agent, adviser, broker, a representative acting on your behalf, or our authorised representatives and our agents.
• Accounting and financial specialists, trustees associated with funds, government, law enforcement or statutory bodies, professional advisors, administration or business management services. 
• Printers and mail service and delivery providers for the mailing of statements and marketing material.
• Imaging and document management services.

Additionally, if you have not opted out of receiving marketing material from us, we may also provide contact details to carefully selected third parties who we reasonably believe provide products or services that may be of interest to, or who have contracted with us to keep the information confidential, or who are subject to obligations to protect your personal information.

Disclosure overseas 

There are also instances where we may have to send personal information overseas or collect personal information from overseas.

These instances include: 

• When you have asked us to do so.
• When we are authorised or required by law to do so, including in response to any order from any regulator or court in any jurisdiction. 
• When we have outsourced a business activity or function to an overseas provider with whom we have a contractual arrangement.
• Certain electronic transactions.
• When it is necessary in order to facilitate a transaction on your behalf. 

We will only send information overseas or collect personal information about you from overseas for the purposes in this policy document.

Access 

You are entitled to obtain confirmation from us that we hold personal information about you and can request access to that personal information by contacting us. In some circumstances, we are able to deny your request for access to personal information. If we deny your request, we will tell you why.

If accessing your personal information will take an extended period of time, we will inform you of the likely delay. For more detailed requests for access to information, an administration fee may be charged to cover the associated cost of supplying this information.

Correction 

If you believe the information we hold about you is incorrect, you may ask for it to be corrected. If we decline to correct the information, you may request a statement is attached to the information that a correction was sought but not made.

Personal Information Storage 

We will endeavour to store personal information on secure servers and encrypt any passwords and transaction details you provide to us. 

We will use every security precaution reasonably available to us to maintain the security of your personal information. However, there are risks inherent in transmitting and storing data online. As such, we cannot guarantee data sent or stored electronically will be secure, and any information provided to us is at your own risk. 

We will endeavour to contact you if any security breaches compromise the security of your personal information.  

Marketing

We would like to use and disclose your personal information to keep you up to date with the range of products or Services available from us. Generally, we will use and disclose your personal information for our marketing purposes and may use your information in other aspects of our business. 

If  you do not want us to use and disclose your personal information for marketing purposes please advise us of this.

General

Third parties and external links may appear on our website.  They are not governed by this Privacy Policy and we are not responsible for them.   You should check the privacy policies of the relevant third party. 

This Privacy Policy is governed by New Zealand law and the New Zealand courts have jurisdiction.

 You can contact us by:

1. email on [email protected];
2. Telephoning us on 0800 673 659; or,
3. Writing to us at Perpetual Guardian Investments Limited, PO Box 1934, Auckland 1140.

Changes to our Privacy Policy

Changes in legislation, industry codes, the business environment, or the addition of new solutions and Services to this site may result in changes to this Privacy Policy. We encourage you to look at this Privacy Policy on a regular basis to stay informed of any changes. By continuing to use our Services or provide information to us, you agree to any changes made to this Privacy Policy.