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PRIVACY POLICY – Privacy Act 1993

Geneva Capital Limited (referred to as GCL) is bound by the Privacy Act 1993 (‘Privacy Act’) and recognises the importance of ensuring the confidentiality and security of your personal information. All third parties (including customers, suppliers, sub-contractors, or agents) that have access to or use personal information collected and held by us must abide by this Policy. Copies of this Policy are available free of charge by contacting our Privacy Officer or can be downloaded from our website www.genevacapital.co.nz

In this Policy:

  • “Disclosing” information means providing information to persons outside of GCL;
  • “Personal information” means information or an opinion relating to an individual, which can be used to identify that individual;
  • “Privacy Officer” means the contact person for questions or complaints regarding GCL’s handling of personal information;
  • “Sensitive information” is personal information that includes information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, and also includes health information; and
  • “Use” of information means GCL’s use of information.

WHAT KINDS OF PERSONAL INFORMATION DOES GCL COLLECT AND HOLD?
GCL may collect and hold a range of information about you that is reasonably necessary for, or directly related to, one or more of GCL’s functions or activities, including:

  • non-public, personal information you knowingly choose to disclose, which is collected on an individual basis via internet, fax, phone, or mail;
  • website use information collected on an aggregate basis as you and other users on our website. If you choose to correspond through e-mail, GCL may retain the content of your e-mail messages together with your e-mail address and all responses sent through the GCL website;
  • information from credit bureaus;
  • details about your activity on selected online webpages;
  • information GCL obtains to verify representations made by you, such as your passport, bank account details, as well as organisation details (such as name, NZBN, address), and other identity documents required under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009;
  • information about you and your organisation from public sources and other third party affiliated and non-affiliated sources; and
  • details about specific transactions conducted in the course of your business.

HOW DOES GCL COLLECT PERSONAL INFORMATION?
GCL generally collects personal information directly from you. For example, personal information will be collected through the GCL application processes, forms and other interactions with you in the course of providing you with GCLs’ products and services, including when you visit the GCL website, call GCL or send GCL correspondence.

GCL may also collect personal information about you from a third party, including, but not limited to, banks and non-bank financial institutions, credit agencies, governmental agencies, marketing agencies. If so, GCL will take reasonable steps to ensure that you are made aware of this Policy. GCL may also use third parties to analyse traffic at the GCL website, which may involve the use of cookies. Information collected through such analysis is anonymous.

GCL will not collect sensitive information about you without your consent unless an exemption in the Privacy Act applies. These exceptions include if the collection is required or authorised by law or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.

If you do not provide us with the personal information that GCL requests, GCL may not be able to provide you with any GCL products or services, or meet your needs appropriately or GCL may decide to provide products and/or services on terms that are less favourable to you.

GCL does not give you the option of dealing with GCL anonymously, or using a pseudonym. This is because, due to anti-money-laundering provisions, it is illegal for GCL to deal with individuals who are not identified.

UNSOLICITED PERSONAL INFORMATION
GCL may receive unsolicited personal information about you. GCL destroy or de-identify all unsolicited personal information that GCL receive, unless it is relevant to GCLs’ purposes for collecting personal information. GCL may retain additional information that GCL receives about you if it is combined with other information that GCL are required or entitled to collect. If GCL do this, GCL will retain the information in the same ways that GCL hold your other personal information.

WHO DO GCL COLLECT PERSONAL INFORMATION ABOUT?
The personal information GCL may collect and hold includes (but is not limited to) personal information about the following individuals:

  • customers;
  • potential customers;
  • visitors to our website; and
  • service providers or suppliers.

WHY DOES GCL COLLECT PERSONAL INFORMATION?
GCL collects and holds personal information about you so that GCL may:

  • provide you with the GCL products and services;
  • review and meet your ongoing needs;
  • provide you with information that GCL believes may be relevant or of interest to you;
  • let you know about other products or services that GCL offers, send you information about special offers or invite you to events;
  • consider any concerns or complaints you may have;
  • comply with relevant laws, regulations and other legal obligations; and
  • help GCL improve the products and services offered to our customers and enhance the overall GCL business.

GCL may use and disclose your personal information for any of these purposes. GCL may also use and disclose your personal information for secondary purposes which are related to the primary purposes set out above, or in other circumstances authorised by the Privacy Act.

Sensitive information will be used and disclosed only for the purpose for which it was provided (or a directly related secondary purpose), unless you agree otherwise or an exemption in the Privacy Act applies.

WHO DOES GCL DISCLOSE PERSONAL INFORMATION TO?
Unless expressly specified with regard to specific information that we collect from your, GCL may disclose personal information to:

  • a related entity of GCL;
  • a potential novatee, assignee or other transferee;
  • an agent, professional advisor or service provider GCL engages to carry out the GCL functions and activities such as, but not limited to, lawyers, accountants, IT contractors, marketing companies;
  • organisations involved in a transfer or sale of the GCL assets or business;
  • financial institutions involved in managing the GCL payments and collections, such as banks;
  • regulatory bodies, government agencies, law enforcement bodies and courts; and
  • anyone whom you authorise GCL to disclose it.

If GCL discloses your personal information to service providers that perform business activities for GCL, they may only use your personal information for the specific purpose for which GCL has supplied it. GCL will ensure that all contractual arrangements with third parties adequately address privacy issues and will make third parties aware of this Policy.

CREDIT REPORTING BODY
GCL collect, hold and use, information related to your commercial and consumer creditworthiness from Veda Advantage (NZ) Limited (w: www.veda.co.nz, t: 0800 698 332), credit reporting bodies, for all purposes permitted by law. GCL may also disclose information to them. This activity is conducted for the purpose of assessing your credit capacity, eligibility or history in connection with an application, collecting payments from you, and managing the GCL credit relationship.

Creditworthiness information includes information that is both positive (like payment information) and negative (like defaults or serious credit infringements that we may disclose to credit reporting bodies if you fail to pay GCL). GCL may obtain personal information from credit reporting bodies, provide personal information to credit reporting bodies as well as use monitoring services to receive updates. Personal information provided by GCL to credit reporting bodies may be further provided to other customers of credit reporting bodies.

SENDING INFORMATION OVERSEAS
GCL will not disclose your personal information to overseas recipients without your consent unless:

  • GCL has taken reasonable steps to ensure that the recipient does not breach the Privacy Act; or
  • the recipient is subject to a privacy regime that has the effect of protecting the information in a way that, overall, is at least substantially similar to the way in which the Privacy Act protect the information.

MANAGEMENT OF PERSONAL INFORMATION
GCL recognises the importance of securing the personal information of all our GCL customers. GCL will take steps to ensure your personal information is protected from misuse, interference or loss, and unauthorised access, modification or disclosure.

Your personal information is generally stored in the GCL computer database. Any paper files are stored in secure areas. In relation to information that is held on the GCL computer database, GCL will apply the following guidelines:

  • passwords are required to access the system and passwords are routinely checked;
  • data ownership is clearly defined;
  • GCL changes employees’ access capabilities when they are assigned to a new position;
  • employees have restricted access to certain sections of the system;
  • the system automatically logs and reviews all unauthorised access attempts;
  • unauthorised employees are barred from updating and editing personal information;
  • all computers which contain personal information are secured both physically and electronically;
  • data is encrypted during transmission over the network; and
  • print reporting of data containing personal information is limited.

DIRECT MARKETING
GCL may only use personal information GCL collects from you for the purposes of direct marketing without your consent if:

  • the personal information does not include sensitive information; and
  • you would reasonably expect GCL to use or disclose the information for the purpose of direct marketing; and
  • GCL provide a simple way of opting out of direct marketing; and
  • you have not requested to opt out of receiving direct marketing from GCL.

If GCL collects personal information about you from a third party, GCL will only use that information for the purposes of direct marketing if you have consented (or it is impracticable to obtain your consent), and GCL will provide a simple means by which you can easily request not to receive direct marketing communications from GCL. GCL will draw your attention to the fact you may make such a request in the GCL direct marketing communications.

You have the right to request GCL not to use or disclose your personal information for the purposes of direct marketing, or for the purposes of facilitating direct marketing by other organisations. GCL must give effect to the request within a reasonable period of time. You may also request that GCL provides you with the source of their information. If such a request is made, GCL must notify you of the source of the information free of charge within a reasonable period of time.

HOW DOES GCL KEEP PERSONAL INFORMATION ACCURATE AND UP-TO-DATE?
GCL is committed to ensuring that the personal information that GCL collects, holds, use and disclose is relevant, accurate, complete and up-to-date.

GCL encourage you to contact GCL if any personal information GCL holds about you needs to be updated. If GCL corrects information that has previously been disclosed to another entity, GCL will notify the other entity of the correction within a reasonable period. Where GCL is satisfied information is inaccurate, GCL will take reasonable steps to correct the information within 30 days, unless you agree otherwise. GCL will not charge you for correcting your personal information.

ACCESSING YOUR PERSONAL INFORMATION
Subject to exceptions in the Privacy Act, you can access the personal information that GCL holds about you by contacting the Privacy Officer. GCL will generally provide access within 30 days of your request. If GCL refuses to provide you with access to the information, GCL will provide reasons for the refusal.

GCL will require identity verification and specification of what information is required. An administrative fee for search and photocopying costs may be charged.

UPDATES TO THIS POLICY
This Policy will be reviewed from time to time to take account of new laws and technology, and changes to our operations and the business environment.

GCLs’ RESPONSIBILITIES
It is the responsibility of management to inform employees and other relevant third parties about this Policy. Management must ensure that employees and other relevant third parties are advised of any changes to this Policy. All new employees are to be provided with timely and appropriate access to this Policy, and all employees are provided with training in relation to appropriate handling of personal information. Employees or other relevant third parties that do not comply with this Policy may be subject to disciplinary action.

COOKIES
Cookies help GCL collect important business and technical statistics which enables GCL to serve you better. The information in the cookies lets GCL track the various paths followed by users of the GCL website as they move from one page to another while on the GCL website. Web server logs allow GCL to assess site visits and site visit capacity. These methods are not used to capture individual e-mail address or any personally identifying information about you.

CHILDREN ONLINE PRIVACY PROTECTION ACT
GCL not knowingly solicit data from, nor knowingly market to, individuals under the age of 18. Concerned parents can use readily available software packages to prevent children from accessing websites they deem as inappropriate.

MAKING A COMPLAINT
If you have any questions about this Policy or wish to make a complaint about how GCL has handled your personal information, you can lodge a complaint with GCL by telephoning or emailing GCL.

If you are not satisfied with GCLs’ response to your complaint, you can also refer your complaint to the Office of the Privacy Commissioner by:

For more information visit https://privacy.org.nz/your-rights/how-to-complain/.

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