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Collection of Personal Information
Centuria Funds Management (NZ) Limited (“Centuria NZ”) collects ‘Personal Information’ for the purposes of improving and personalising its services to investors, for the purposes of complying with its Reporting Entity obligations under the Anti-Money Laundering and Countering of Financial Terrorism Act 2009, and other regulatory or compliance obligations.
“Personal Information” refers to all and any information relating to an investor, including, but not limited to an investor’s name, date of birth, contact numbers, email address, mailing address, copies of identity documents, bank statements, bank deposit slips etc.
In some instances, Centuria NZ may collect personal information about individuals from third parties. In such circumstances, Centuria NZ or the third party will obtain the individual’s consent.
Consent to Use of Personal Information
Centuria NZ obtains the consent of all investors as part of its application process.
Your personal information is held in our registry systems for our investors. These are either third party specialist registry service providers or through our in-house systems. Generally personal information is stored electronically with hard copy records retained and archived with an archival service provider where necessary.
All internal systems are subject to the security measures detailed in this policy. All external service providers are contractually required to hold personal information in accordance with the Privacy Act.
Use of Information
Centuria NZ will used the personal information about you primarily:
Centuria NZ does not sell, rent or lease Personal Information to any other person, business, organisation or other entity except to Centuria NZ’s related companies or third party contractors, bound by confidentiality undertakings (“Related Entities”). The Related Entities will only use such Personal Information for the same legitimate purpose as Centuria NZ.
Disclosure to third parties
Centuria NZ will not provide Personal Information held to any third parties except:
(a) where required to do so in compliance with any law, regulation, or court order;
(b) where required by a governmental authority, regulatory body, or where Centuria NZ is under a legal obligation to do so;
(c) where third parties engaged by Centuria NZ to provide services in connection with the uses of Personal Information who authorised to do so and where there is an appropriate confidentiality undertaking;
(d) to Related Entities;
(e) to financial intermediaries such as financial planners and taxation or accounting advisers where you have consented to disclosing the Personal Information;
(d) where it is otherwise required by law.
For statistical purposes Centuria NZ may collect information on its website activity (such as number of users who visit our website, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have sued to access the site, and when entering our website from another website, the address of that website) through the use of ‘cookies’. This information on its own does not identify an individual but it does identify a user’s browser type and their Internet Service Provider. Cookies also provide Centuria NZ with statistics that can be used to analyse and improve our website.
A ‘cookie’ is a packet of information that allows the server (the computer that houses the website) to identify an interact more effectively with the user’s computer. When a user visits Centuria NZ’s website, we send a temporary cookie that gives the user a unique identification number. A different identification number is sent each time our website is viewed. To evaluate the effectiveness of our website, we may use third parties to collect statistical data. No personal data is collected on these occasions.
Security – Storage of Information
The security of Centuria NZ’s investors’ Personal Information is important to us. Centuria NZ uses all reasonable steps to ensure that all personal information is securely protected against loss, unauthorised access and other misuse. In summary, Centuria NZ protects Personal Information by: limiting physical access to investor files by anyone other than employees, requiring any third-party providers to have acceptable security measure in place; requiring any third parties to sign confidentiality undertakings before providing Personal Information; putting in place cyber security (as described below); and destroying Personal Information in accordance with section 50 of the AML/CFT Act (as discussed below).
Centuria NZ has a range of physical and technology policies in place to provide a robust security environment. We ensure the on-going adequacy of these measures by regularly reviewing them.
Employees and contractors of the Centuria are bound by confidentiality obligations.
Passwords, firewalls and virus protection are used by Centuria with a view to ensuring the security and integrity of the information technology systems that hold your information.
All premises housing our systems and other copies of your information are monitored and protected by security alarms and access card or key lock entry. Service providers who hold personal information are contractually required to hold information in accordance with the Privacy Act and Centuria obtains periodic confirmation of adequate information security management.
Access to and Correction of Personal Information
You are entitled to obtain access to your personal information subject to some exceptions allowed by law.
Centuria NZ will take all reasonable steps to ensure that all personal information we hold is as accurate as is possible. You have the right to contact Centuria NZ at any time and ask for its correction you believe that the personal information held by Centuria NZ is inaccurate or incomplete. In normal circumstances, Centuria NZ will correct that information. If we do not, the party is entitled to request that we attach to that information a statement of the correction requested but not made.
Storage and Deletion of Investor Data
Centuria NZ does not keep Personal Information for longer than is necessary for those purposes which the information was collected. Centuria NZ will take all practical steps to ensure that Personal Information held about investors who have not had a business relationship with Centuria NZ for more than 5 years or such longer period of time if required by law will be deleted/destroyed.
In Centuria NZ’s opinion, it is not practicable to ensure that all Personal Information of such investors be deleted from any back-up tapes held by Centuria NZ. Instead, such investor’s hard copy files will be destroyed or returned to the investor. Further, as an employee becomes aware of Personal Information that should have been destroyed in accordance with sections 50 and 54 of the AML Act, Centuria NZ will take steps to do so.
Anti-Money Laundering and Countering of Terrorism Act 2009 (AML/CFT Act)
Section 50 of the AML/CFT Act requires Centuria NZ to keep the following records for the purposes of meeting its obligations under the AML Act for a period of at least 5 years after the end of that business relationship:
(a) Customer identity and verification;
(b) Relevant to the establishment of the business relationship;
(c) Relating to risk assessments, AML/CFT programmes, and audits; and
(d) any other records (for example, account files, business correspondence, and written findings) relating to, and obtained during the course of, a business relationship that are reasonably necessary to establish the nature and purpose of, and activities relating to, the business relationship.
Subject to the above, in accordance with section 54 of the AML Act, Centuria NZ must take all practicable steps to ensure that every record retained by Centuria NZ under the AML Act, and every copy of that record, is destroyed as soon as practicable after the expiry of the period for which Centuria NZ is required to retain that record – except where there is a lawful reason for retain the record.
There is a lawful reason for retaining a record, if the retention of that record is necessary:
(a) in order to comply with the requirements of any other enactment; or
(b) to enable Centuria NZ to carry on its business; or
(c) for the purposes of detection, investigation, or prosecution of any offence.
Centuria NZ will maintain a record of customer contact information for marketing purposes as this does not fall within ‘customer identity and verification’ information.
Centuria NZ takes any concerns regarding the maintenance and protection of our investors’ privacy serious. Any complaint by an investor will be dealt with in accordance with Centuria NZ’s complaints handling policy.
Phone: +64 (9) 300 6161