At Elevation Capital Management Limited (“Elevation Capital”) we take our obligations under the Privacy Act 1993 seriously.
Who are the people affected by this policy?
This policy applies to the personal information we hold about ‘living individuals’ who are Elevation Capital customers, beneficiaries of estates or trusts that we administer, the ‘associated people’ (such as shareholders and company directors) of Elevation Capital customers.
How do we collect your personal information?
In most cases we will collect your personal information directly from you, such as when you apply for a product or service, for example on an application form, you register with us online, you ask us for information, you make an appointment to visit us. Under the Privacy Act we may also collect information about you from other people. For example, you might have appointed an agent or attorney to act on your behalf, or authorised someone else to supply your information. We may also continue to collect your personal information for as long as you have a relationship with us.
What personal information do we collect?
The personal information that we collect will depend on the Elevation Capital products and services that you use or that interest you. For example, we might collect your name, postal address, telephone number, email address and date of birth, information about your personal, family and financial circumstances, including the assets you own. Note that if we do not receive personal information that we specifically ask for, we might not be able to provide you with a new product or service, or continue with an existing product or service.
How do we use your personal information?
We collect, use and store your personal information mainly to provide you with products, services and information that you have asked for. For example, we may use your personal information to administer, monitor and manage your Elevation Capital products and services, to process your requests for information, to develop new products and services (using feedback and other information that we have received from you), to identify and contact you about events and other products and services that might interest you (these could include events, products and services offered by other organisations in conjunction with Elevation Capital), as part of ‘data matching’ activities, in which we compare your information with information that is public and/or held by someone else (for example, using a service provider to confirm your postal address details), to meet our legal obligations, as well as obligations imposed by governmental, judicial or regulatory entities or authorities in other jurisdictions, and entities that supervise or regulate Elevation Capital. If you have given us an email address, we may use it to communicate with you about your current Elevation Capital products and services, other products or services (including those of other organisations) that we believe may interest you.
Who may we provide your information to?
We may provide to others details about you and the products you hold with us, to help us provide you with information, products and services, or to meet our legal obligations. For example, we may disclose your information to your agent, attorney or authorised signatory, to other entities or companies within the Elevation Capital Management Limited group, to people or organisations that undertake services for us (such as where we ask a market research provider to get your feedback on our products and services or carry out ‘data matching’ for us), when we need legal or other professional advice, to help meet our legal obligations, as well as obligations imposed by governmental, judicial or regulatory entities or authorities in other jurisdictions, and entities that supervise or regulate Elevation Capital. For example, we may disclose some of your personal information to selected third parties to help us comply with the Anti-Money Laundering and Financing of Terrorism Act 2009, and to ensure that we act according to the Terrorism Suppression Act 2002; if we have reasonable grounds to believe that a transaction or proposed transaction may be relevant to an investigation or prosecution of someone for a money laundering offence; and to help us comply with the United States Foreign Account Tax Compliance Act and/or any agreements between the New Zealand Government and other countries’ governments. Where we disclosure your information to a service provider we make sure they are aware of the importance we place on protecting your privacy. They are required to keep your information confidential, and only use it for the purpose for which we have supplied it. In all other cases we will only disclose your personal information if it is permitted under the Privacy Act.
How do we store your personal information?
We will take reasonable care to keep your personal information safe from loss, misuse and unauthorised disclosure. The law requires us to destroy your personal information if we no longer require it for the purpose for which we collected it, or if it is no longer required to meet our legal requirements. If we have to keep it to meet our legal requirements, we will continue holding it for the legally required time frame.
How can you check and correct your personal information?
We will not use or disclose your personal information without taking reasonable steps to check that it is accurate and complete. You are welcome to ask for, have access to, and check the personal information that we hold about you and if you believe that any of it is incorrect, you can ask us to correct it. Note that if we choose not to make the correction, you can ask us to attach to the information a statement of the correction you wanted. We can only refuse you access to your information in very limited circumstances, such as when disclosure would involve an unjustified breach of someone else’s privacy.
How to contact us:
How to give feedback:
If you would like to provide feedback on the way we use your personal information, please email us at [email protected] or write to us at:
The Privacy Officer
Elevation Capital Management Limited
PO Box 911145
If you make a privacy complaint, we will follow it up through our internal complaints process. If you are not satisfied with the outcome, you can contact the Privacy Commissioner on 0800 803 909 or visit www.privacy.org.nz.