Effective 10 August 2018
This Privacy Notice clarifies confidentiality obligations owed by Redward Associates (hereafter referred to as “RA”) to its current and prospective clients (or “you”). It serves to give information regarding your personal information and describe the basis on which RA processes your personal information, its purposes, your privacy rights, and how RA protects your personal information.
RA is a registered financial services provider under the New Zealand Companies Office to provide wholesale and/or generic financial advisor services, operating from our office in Auckland, New Zealand.
We are primarily regulated by the New Zealand Privacy Act 1993 and our policy is also in accordance with the EU General Data Protection Regulation (GDPR), which was enforceable from 25 May 2018.
In the conduct of our business, we may obtain personal details about you. The personal information includes, without limitation:
Contact details: Information such as your name, postal address, contact numbers, nationality/place of incorporation, email address and other contact details.
Payment data: Information necessary for us to process payments such as account name and number, security code number and other billing details.
Financial details: Information such as source of funds and other financial information.
This information may come from sources such as executed subscription forms, written, electronic or verbal correspondence between you and us and platforms which allows us access to publicly available information.
In addition, when you visit RA’s website or access our digital publications, we collect usage information such as information about your device’s IP address and internet domain, and if you visit a link from another website, the URL of the linking page.
RA collects your personal information to fulfill our contractual obligation, our statutory obligation and other reasons for which we have a lawful basis to: (i) provide research services and manage your account, and (ii) send contract renewal notifications and/or service notifications. If you have provided special categories of personal data to us for us to satisfy our obligation to respond to certain requests, we do so with your explicit consent. We will not process your personal information in order to communicate with you for marketing purposes without your consent.
We may use your personal information for in-house research and analysis to help us create marketing profiles and support strategic/business development. All results of any research and analysis will be anonymous or aggregated and will not reveal personal details of individual customers. We may share this information with third party suppliers in order to assist this process.
Your personally identifiable information may be provided to a third party in the event that RA files for bankruptcy, or there is a transfer of assets and/or ownership of RA. RA may also provide personal information in order to investigate, prevent, and take legal action regarding fraud or misuse of the service, or to comply with the law and respond to a law enforcement agency’s request, or to protect the rights, property, and safety of the service users and others. RA may also provide personally identifiable information in response to a subpoena, court order, or other such request, or otherwise to exercise our rights, or defend against legal claims.
RA is not part of any group of entities and so your information will be accessible by our employees. Our employees are not permitted to share the information we have collected from you with the public and/or unrelated parties, except as described herein or permitted by the privacy laws or other applicable laws.
We do not rent, sell, or trade personal information to any external organization.
We are obligated to retain your personal information for a period of at least seven years from the date on which the business relation commences or a later date on which the last transaction is completed. We will delete your personal data once it is no longer necessary for us to keep them for the purposes set forth above except as required or permitted by applicable law or regulation.
Your rights to your personal information provided to us
You have the right to: (i) access and check the personal data we hold on you, (ii) request for a correction of information about you that is inaccurate, (iii) object or restrict our use of personal data save for when the information is needed for the performance of our legal and compliance obligation, and (iv) have a copy of the personal data we hold about you provided to you or transmitted to another controller where technically feasible.
To do so, please send your request to email@example.com. You are required to ensure that the personal information we hold about you is up-to-date and accurate at all times. For any changes of any information provided to us, we request that you also notify us through the email provided above.
RA’s website may contain links to external websites. RA is not responsible for the privacy policies or content of these sites. If you provide any information to such third parties, different rules regarding the collection and use of your personal information may apply. We recommend that you read the privacy policies on any external site you use.
It is our priority to safeguard your non-public personal information. We continuously ensure sufficient physical, electronic and procedural safeguards to protect against unauthorized access to the information we keep. RA uses all reasonable efforts to protect your privacy and ensure that your personal details are not misused, accidentally destroyed, lost or altered by RA.
We may allow access to our database and/or systems to third parties (e.g. database consultants, IT specialists). These third parties are only permitted to access and/or process your data with explicit permission from RA, to enable them to perform the services required.
In any case that our IT systems are compromised resulting in a personal data breach, we are obligated to notify your supervisory authority within 72 hours when the breach is detected.
We review our policies regularly and may occasionally change or update them. This may occur due to changes in the law, best practice or changes to our services. This Privacy Notice was last reviewed and updated on 10 August 2018.
By taking no action upon receipt of this notice, you accept and agree to the collection and use of your personal data for the purposes set forth in this document.
If you have any queries, comments or other feedback on this Privacy Notice, please contact us at firstname.lastname@example.org and we will promptly respond to your requests. In the event that you are unhappy with our response, you may escalate the matter to the relevant privacy regulator. We can provide you with the details of the relevant regulator upon your request.
Redward Associates Limited is a company registered in New Zealand (no. 354332) with a registered office at: Level 5, 64 Khyber Pass Road, Grafton, Auckland 1023, New Zealand.