) handles your personal information in accordance with the Information Privacy Principles of the Privacy Act 1993 (Privacy Act
Vinta collects personal information directly from the potential and existing investors concerned and their authorised representatives. The personal information Vinta collects depends on your relationship with us, but could include your name, mailing address, email address, phone number, fax number, date of birth, IRD number, financial information, bank account details, gender, nominated beneficiaries and IP address. How is personal information collected?
Vinta will only collect personal information by lawful and fair means and not in a way that may be unreasonably intrusive. Vinta collects your personal information from you directly when you provide your information to us (such as when you complete an application form or request certain information from the Vinta website). Vinta may also collect your personal information from third parties where you have authorised the relevant collection such as any authorised representatives to your account. Vinta may also collect your personal information from publicly available sources.
Vinta may collect, hold, use and disclose your personal information for the purposes of:
(a) establishing, administering and facilitating your investment in a Vinta fund (including monitoring, auditing and evaluating the fund);
(b) communicating with you;
(c) processing payments from and transferring money to you;
(d) promoting goods and services to you and facilitating related companies of Vinta promoting goods and services to you;
(e) assisting Vinta in providing you with the products and services offered in New Zealand; and
(f) conducting research to improve its services and complying with its legal obligations.
You will have the choice to elect to receive some of the above communications either on the Vinta website at www.vinta.co.nz
or, if investing in a Vinta fund, via the application form accompanying the relevant fund PDS or other offer document. Should you elect to receive any of the above communications, you will also have the option to 'opt out' of receiving them at any time in the future by unsubscribing from communications received electronically or by contacting Vinta at email@example.com.
Vinta is also required to collect certain personal information in order to comply with its legal obligations, including under the following legislation:
(a) Companies Act 1993
(b) Financial Markets Conduct Act 2013 and Financial Markets Conduct Regulations 2014;
(c) Income Tax Act 2007
(d) Tax Administration Act 1994; and
(e) Anti-Money Laundering and Countering the Financing of Terrorism Act 2009 and Anti-Money Laundering and Countering the Financing of Terrorism Regulations 2011 Who is your personal information disclosed to?
Vinta may disclose your personal information, in a manner consistent with the purposes for which it was collected, to:
(a) Vinta's related companies;
(b) agents and contractors that provide services to Vinta or perform functions on our behalf, including custodians, fund supervisor, legal advisers, accountants, actuaries, insurers, website managers, and providers of internet, data storage and data access services;
(c) anyone else to whom you authorise Vinta to disclose your personal information; and
(d) anyone else required or authorised by law.
Any person included in subparagraph (a) and (b) will be contractually bound to use the personal information that is shared with them only to perform the services they have been hired to provide. Is your personal information disclosed overseas?
Vinta may disclose your information, for the purposes for which the information was obtained, overseas to our head office, located in Australia. Australia’s Privacy Principles and protection laws are comprehensive and comply with the principles as outlined in this policy. Where these principles may differ, Vinta will take appropriate steps to ensure your personal information is handled as described in this policy. How is your personal information protected?
Vinta uses reasonable steps to protect your information from misuse, interference and loss, and from unauthorised access, modification or disclosure. Vinta takes precautions including:
(a) restricting access to personal information stored on Vinta's servers;
(b) imposing confidentiality requirements on its employees;
(c) requiring that its contractors and agents take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure;
(d) implementing electronic security systems, such as firewalls;
(e) ensuring that servers containing investor account information have security measures such as password protection; and
(f) controlling access to Vinta's offices. Accuracy of your personal information
Vinta aims to ensure that the personal information we keep about you is accurate, up to date and complete. How can you access and correct personal information?
Subject to the exceptions set out in the Privacy Act, you have a right to access and seek correction of personal information that Vinta holds about you.
Where your information is held in such a way that it can be readily retrieved by us, Vinta will, on request, provide your information to you.
If you have completed an application form to invest in a Vinta Fund you may also be able to access your personal information online via secure access if you so elect.
Vinta may recover from you reasonable costs of supplying you with access to your personal information. However, we will not charge you for the making of the request or to correct or update your personal information.
If you would like to access or correct your personal information, please contact Vinta's Privacy Officer via the contact details listed below. Your request will be dealt with as soon as reasonably practicable. If Vinta refuses to provide you with the requested correction for the information it will generally notify you of the reasons for refusal to the extent required and at your request take reasonable steps to attach a statement setting out that you have requested the information be corrected. Retention of information
Vinta will not keep your information for longer than it is required for the purposes for which the information may be lawfully used.
If your personal information is no longer required, it will be destroyed. Privacy Complaints
If you believe Vinta has breached the Privacy Act or a registered code that binds us, please contact Vinta's Privacy Officer via the contact details listed below. Vinta may request that you put your complaint in writing. Vinta will endeavour to resolve your complaint in a reasonable time frame (usually within 30 days) and may contact you in order to obtain further details in order to provide you with a full and complete response. If you are not satisfied with the manner in which Vinta has handled your complaint, you can lodge a complaint with the Office of the Privacy Commissioner at www.privacy.org.nz. Privacy Officer Contact Details
To access or correct your personal information, to notify Vinta of a breach of the Privacy Act or a registered code or if you have any privacy related inquiries, please contact:
Vinta Funds Management Limited
PO Box 596
Telephone No: +64 9 3772626
Email: firstname.lastname@example.org Links to other websites
This policy is amended from time to time, and was last updated on 24th June 2015.