Privacy Policy

1. Changes to this policy

We may update this policy from time to time by publishing a new version on this page. The updated policy applies from the date it is published, so we'd encourage you to check back if you want to stay across any changes.

2. What is personal information

Personal information is any information about an identifiable individual. In our line of work, that usually includes:

• your name, date of birth, address and contact details
• your occupation, employment history and income
• your assets, debts, expenses and overall financial position
• evidence of your source of funds or source of wealth
• identification documents (passport, driver licence, IRD number)
• bank statements and credit history
• details of the property you're buying, refinancing or insuring
• testimonials and feedback you give us
• any other information you share with us during the advice process

We only ever ask for what we genuinely need to give you good advice and to meet our legal obligations as a Financial Advice Provider.

3. How we collect your information

We collect most personal information directly from you. The main ways this happens are:

• when you book a call with us through Calendly on our website
• when you talk to us by phone, email, video call or in person
• when you complete a fact-find or application form we send you
• when you upload supporting documents to our secure document portal

We don't run general contact or enquiry forms on the website. The only way you'll submit personal information to us through this site is when you book a call via Calendly. Calendly's own privacy policy is available at calendly.com/privacy.

Sometimes we'll also collect personal information about you from a third party (for example, a lender, your accountant, your solicitor, or a credit reporting agency). Where we do, we will take reasonable steps to let you know:

• what we have collected
• why we collected it
• who we are likely to share it with
• your right to access and correct it

This is unless an exception under the Privacy Act 2020 applies.

4. How we use your information

We use your personal information to:

• verify your identity (including for AML/CFT purposes)
• understand your financial position and goals
• provide mortgage and insurance advice tailored to you
• approach lenders and insurers on your behalf and arrange products
• contact you about your application or our services, by phone, text, email or post
• improve the advice and services we provide
• respond to your questions, feedback or complaints
• protect or enforce our legal rights, including defending any claim
• meet our obligations under the Financial Markets Conduct Act 2013, the Anti-Money Laundering and Countering Financing of Terrorism Act 2009, the Privacy Act 2020 and any other applicable law
• any other purpose you authorise, or that is permitted by the Act

We don't sell your personal information to anyone, ever.

5. Who we share it with

To do our job, we need to share your information with the right people. We may share your personal information with:

• Lenders, banks and insurance providers we approach on your behalf during your application
• Other companies that help us run our business, including IT providers, hosting and data storage providers, CRM and email platforms, mailing houses, accountants and legal advisers
• Other financial advisers and Financial Advice Providers who work with us on your file
• Compliance reviewers and auditors engaged to check our work as required by law and our FAP licence
• Identity verification agencies and government databases including the Department of Internal Affairs and the New Zealand Transport Agency
• Social media platforms where we have a business presence, where you've engaged with us through them
• Courts, tribunals and regulators including the Financial Markets Authority and the Ministry of Justice
• The Office of the Privacy Commissioner, if a complaint relates to a breach of the Privacy Act 2020
• The Office of the Ombudsman, if a complaint relates to official information
• The Human Rights Commission, if a complaint relates to discrimination
• CERT NZ, where appropriate to help manage a notified privacy breach
• An overseas privacy regulator, if a complaint relates to an overseas agency
• Any person or agency we reasonably believe could help us respond to a serious privacy breach
• Anyone else you authorise us to share your information with

Other than as described above, we will not disclose your personal information without your written or verbal consent, unless we are required to do so by law.

6. Product providers we work with

When we arrange a mortgage or insurance product for you, we share your personal information with the lender or insurer involved. Each of those providers has their own privacy policy that explains how they handle your information.

A current list of the product providers we work with (and links to each of their privacy policies) is published by Kiwi Adviser Network (our Financial Advice Provider group) at kiwiadvisernetwork.co.nz/PrivacyPolicy. We also keep a copy on file and can email it to you on request.

If we recommend a provider that isn't on the standard panel, we will let you know and tell you where to find that provider's privacy policy before you proceed.

7. How we protect your information

We take reasonable steps to keep your personal information safe from loss, unauthorised access or misuse. In practice that means:

• the systems we use are subject to ongoing security reviews
• information held in our software is encrypted in transit and at rest
• access is restricted to authorised team members on secure connections
• documents you send us are stored in secure cloud platforms, not in personal email inboxes
• paper records (if any) are held securely at our office

No system is completely secure, but we work hard to make sure your information is treated with the level of care it deserves.

8. How long we keep it

We only keep personal information for as long as we need it for the purposes it can lawfully be used, including meeting our record-keeping obligations under New Zealand financial services and AML/CFT law (which generally require us to keep client records for at least seven years after our engagement ends).

Data stored online is backed up and can be restored in the event of loss or corruption. Where information is provided to us outside our software (for example, paper documents), it may be held at our office at 843 Old Tai Tapu Road, Tai Tapu 7672, New Zealand.

9. Accessing and correcting your information

Subject to the grounds for refusal in the Privacy Act 2020, you have the right to:

• ask for a copy of the personal information we hold about you, and
• ask us to correct any of that information

Before we act on a request, we'll need evidence to confirm you are who you say you are.

If we agree a correction is reasonable and we're able to make it, we will. If we decide not to make the correction, we'll take reasonable steps to attach a note to the information recording your request.

To make a request, email us at adviser@simpler.co.nz. Please include:

• evidence of who you are
• the information you want to access, or
• the correction you'd like us to make

There's no charge for making a request, though we may charge a reasonable fee for unusually large requests, as permitted by the Act.

10. Data breaches

Our Privacy Officer has processes in place to respond quickly in the unlikely event of a data breach. If a breach occurs, we will identify, contain, assess and report it as required by the Privacy Act 2020, including notifying the Privacy Commissioner and any affected individuals where the breach is likely to cause serious harm.

We may also voluntarily notify CERT NZ where it would help us manage the breach.

11. Cookies and website use

While we take reasonable steps to maintain a secure website, any personal information you send us over the internet is provided at your own risk.

If you follow a link from our website to another site, that site has its own privacy policy. We recommend reviewing it before sharing any personal information.

We use cookies (small identifiers stored on your device) to recognise your browser, understand how our site is used, and improve it. You can disable cookies in your browser settings, but some features of the site may not work as a result.

We may also use information about your use of our website and IT systems to detect and prevent unauthorised access. We sometimes use third-party services (for example, analytics and security monitoring tools) that have access to logging information from our site.

12. Contact us

If you're not happy with how we've handled a privacy issue, you can also contact the Office of the Privacy Commissioner:

• Web: privacy.org.nz
• Phone: 0800 803 909