Privacy Policy.
At Elevation Capital Funds Management Limited (Elevation Capital) we take our obligations under the Privacy Act 2020 seriously. This is why we have this Privacy Policy. It explains how we collect, use, disclose and protect your personal information, and your rights in relation to that information.
In this policy, the terms “we”, “us” and “our” refer to Elevation Capital and its related companies, and the terms “you” and “your” refer to our customers, beneficiaries of estates or trusts that we administer, and “associated people” (such as shareholders and company directors) of our customers.
This policy is reviewed regularly and may change from time to time. We provide the current version of this policy on our website. This policy was last updated on 10 March 2021.
What personal information do we collect?
Personal information is information about an identifiable individual. The personal information that we collect will depend on which of our products and services we provide, or may provide, to you. Without limiting the foregoing, we may collect:
your contact details, being your name, telephone number, postal and email address;
your date of birth;
information about your personal, family and financial circumstances, including the assets you own; and
other personal information necessary to provide our products and services to you.
Where do we collect your personal information from?
In most cases, we will collect your personal information from you. This occurs when you provide that personal information to us directly, such as when registering with us, applying for a product or service, completing a form, or making an appointment to visit us.
We may also collect personal information from third parties. This occurs when you have authorised someone else to supply your personal information to us. For example, you may have appointed an agent or attorney to act on your behalf.
How do we store your personal information?
We may store your personal information both physically and electronically. Physical storage will occur at our premises, whereas electronic storage occurs on devices and may include storing personal information on the cloud, including using third party service providers. We take reasonable steps and security safeguards to protect personal information against loss, unauthorised use and other misuse.
Where personal information is no longer required by us, we will delete the personal information or permanently de-identify it in accordance with the applicable laws and our records management policy.
We may store your personal information on servers and services both within New Zealand and offshore (including third party cloud-based services and storage). We may access and use that personal information in and outside New Zealand. You acknowledge that some of the third party storage providers, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to New Zealand.
How do we use your personal information?
We collect, use, and store your personal information primarily to provide you with the products, services and information that you have asked for. We may use your personal information to:
verify your identity;
administer, monitor and manage our products and services;
process your requests for information;
provide you with information about our products and services;
develop new products and services;
to market events, other products and services that be of interest to you, including those offered by other organisations in conjunction with us;
perform data matching activities, where we compare your personal information with information that is publicly available and/or held by someone else;
to meet our legal obligations under applicable laws;
to meet the obligations imposed by any relevant governmental or regulatory entities; and
for any other purpose directly related to the above, any other purpose you authorise, or any other use that is permitted or required by the law.
Who do we provide your personal information to?
We may disclose your personal information for the purpose for which it was collected, with your authorisation, or to otherwise meet our legal obligations. This may include disclosing your personal information to:
your agent, attorney, or authorised signatory;
other entities or companies within our group;
people or organisations who undertake services for us;
persons who require your personal information for legal or regulatory purposes;
any person who is authorised by law (e.g. a law enforcement agency); and
any person authorised by you.
How do you request access to or correction of personal information?
You may request access to, and correction of, any of your personal information that we hold by contacting us using the contact details below. If we choose not to make correction to your personal information, you can ask us to attach a statement of correction to that information.
Do we collect other information when you use our website?
We may use cookies to monitor and enhance your use of our website and services online. A cookie is a piece of data that is stored on a device. Cookies collect IP, browser information, and other information relating to your device. You can disable cookies and still use our website, although this may affect our website’s full functionality.
How can you contact us?
If you would have any questions, would like further information, or would like to provide feedback on this policy, we would like to hear from you. You can reach us by:
Email: admin@elevationcapital.co.nz
Phone: +64 9 379 6493
Post: The Privacy Officer
Elevation Capital Funds Management Limited
PO Box 28053
Remuera
Auckland 1541
New Zealand
If you would like to make a privacy complaint, please contact us using one of the above methods. If you are not satisfied with this, you can contact the Privacy Commissioner on 0800 803 909 or visit www.privacy.org.nz (http://www.privacy.org.nz/).