A. We are responsible for, and may collect and hold, all personal information you provide to us and will deal with that information in accordance with the following Privacy Principles.
B. We have in place strict procedures to ensure the implementation of our Privacy Principles and to deal with complaints and enquiries. Our Compliance Manager has overall responsibility for ensuring that our employees, agents and subsidiaries comply with our Privacy Principles. Our Compliance Manager may be contacted in relation to any enquiry or complaint at firstname.lastname@example.org or on TEL: 0800 161 868.
C. We will not disclose any of your personal information to a third party, or a foreign country, unless the recipient is subject to legislation, or a contract, that safeguards your personal information in a manner that is substantially similar to our Privacy Principles.
Purpose and Intended Recipients
1 We will collect personal information only for the purpose of providing our services to you or for any purpose that is directly incidental to the provision of those services. In the event that we wish to use your personal information for any other purpose, we will identify such purpose and obtain your consent before doing so, unless the new purpose is required by law. For the avoidance of doubt, purposes that we would regard as being directly incidental to the provision of our service include credit assessment and debt recovery purposes as well as information about our services.
2 We are always willing to explain to you the purposes for which your information is being collected. Failure to provide necessary personal information when requested may result in certain services not being available to you or other consequences as notified at the time of request.
3 We may disclose information about you, including your personal information, to our affiliates, employees, officers and agents for the purposes set out in paragraph 1 above and to our contractors and suppliers to enable them to assist in the provision of the services to you. If We wish to provide your personal information to any other recipient, we will identify that recipient and obtain your consent before doing so, unless the provision of that information to that recipient is permitted by law.
4 We will seek your consent to the use of your personal information either expressly or impliedly, depending on the circumstances and the type of information collected. For example, we will rely on your implied consent when you give us your name, address, telephone number and other details necessary for us to verify your identity in accordance with the provisions of the client agreement you enter into. We will seek your express consent if the information is of a financial nature or concerns your personal credit.
5 Your consent may also be given by an authorised representative or a person having your power of attorney.
6 You may withdraw your consent at any time, subject to any legal restrictions and subject to any contractual restrictions you have already entered into with us, and provided that you give us reasonable notice in writing. We will explain to you the implications of such withdrawal.
8 There may be circumstances in which we are obliged to collect, use, or disclose certain personal information without your consent as provided for by applicable laws. Collecting information relating to the identity of parties transferring money is a mandatory requirement in New Zealand under the Financial Transactions Reporting Act 1996 and the Anti-Money Laundering and Countering Financing of Terrorism Act 2009.
Limiting Collection and Retention of Information
9 The amount and type of information collected by us will be limited to that which is necessary to provide our services.
10 We will make reasonable efforts to inform you if we have collected personal information about you from someone else.
11 Any personal information that you provide to us will, unless otherwise notified, be collected and held by us in an electronic form on our web server in Sydney Australia. Personal information shall be retained only for as long as may be necessary for the fulfilment of the purpose for which the information is collected. However, you should be aware that we are obliged under relevant anti-money laundering and counter-terrorism legislation to retain information relating to personal identity for 7 years.
12 Subject to any legislative requirements, we will destroy, erase, or make anonymous your personal information when it is no longer required to fulfil the purpose for which it has been collected.
13 We will make reasonable efforts to ensure that your personal information is sufficiently accurate, complete, and up-to-date to minimise the possibility that inappropriate information may be used to make a decision about you.
14 We will not routinely update your personal information, unless such a process is necessary to fulfil the purposes for which the information was collected. In accordance with the Client Agreement, you must notify us as soon as possible if any of the information you have provided to us has changed.
15 We have in place a range of security safeguards to protect your personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification, regardless of the format in which it is held.
16 The methods of protection may depend on the sensitivity of the information and the format in which it is contained. Security measures employed by us include:
(i) technological measures including SSL 128 bit encryption for all data transfers over the Internet;
(ii) physical measures such as locked filing cabinets and restricted access to offices; and
(iii) strategic measures such as security clearances and limiting access to a "need-to-know" basis.
17 We ensure that our staff are aware of the importance of maintaining the confidentiality of personal information.
18 Under the Privacy Act 1993, you have rights of access to and correction of personal information that we hold. This can be done by contacting our Compliance Manager at the address given above. Without limiting this right, we will upon request and within 10 days of any such request allow you access to your personal information. The requested information shall be provided or made available in a form that is generally understandable.
19 In circumstances where you point out to us that any information held by us is inaccurate or incomplete, we will take appropriate action to amend the information as required and, if necessary, notify any third party of the correction.
20 There may be circumstances which preclude us from providing access to some or all of your personal information as provided for by applicable laws.
21 We may be prohibited by law from providing you with access to your personal information as provided for by applicable laws.
22 We have procedures in place, to receive and respond to, complaints or inquiries about our policies and practices relating to the handling of personal information. For more information, please see our Complaints Policy on our website.
23 We take all complaints seriously and will investigate all complaints.
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