Privacy Policy

Introduction

This Privacy Policy explains how Policywise Ltd (“Policywise”, “we”, “us”, “our”) collects, uses, discloses, stores, and protects personal information.

We comply with the Privacy Act 2020 when dealing with personal information. In this policy,“personal information” means information about an identifiable individual.

You are not required to provide the personal information we request. However, if you choose not to provide it, we may not be able to provide some or all of our services.

Privacy Officer

Policywise has appointed Berne Villacastin as its Privacy Officer.

The Privacy Officer is responsible for:

• helping ensure Policywise complies with the Privacy Act 2020

• handling privacy-related enquiries and complaints

• dealing with requests for access to, or correction of, personal information

• acting as Policywise’s contact point with the Office of the Privacy Commissioner

If you have any questions, concerns, or complaints about privacy, or if you would like to access or correct your personal information, please contact our Privacy Officer at:

Privacy Officer
Berne Villacastin
Policywise Ltd
Email: berne@policywise.co.nz
Phone: +64 9 886 4848

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner.

PERSONAL INFORMATION WE COLLECT

Depending on the services we provide to you, we may collect and hold personal information such as:

• identification and contact details, such as your name, date of birth, address, email address, and phone number
• financial and employment information relevant to the advice we provide
• insurance and financial product information, including existing cover, policy history, claims information, and underwriting information
• health and medical information where relevant to underwriting or claims
• communications with you, including emails, forms, file notes, and call recordings
• website and digital usage information, including cookies and analytics data

We take reasonable steps to ensure that the personal information we use or disclose is accurate, up to date, complete, relevant, and not misleading. We may ask you to confirm or update your information from time to time.

HOW WE COLLECT PERSONAL INFORMATION

1. Information collected directly from you

We generally collect personal information directly from you during our dealings with you, including in meetings, over the phone, by email, through our website, and through any forms or other communications you complete.

2. Information collected from third parties

In some circumstances, we may collect personal information from third parties where you have authorised us to do so, and it is reasonably necessary to provide our services, or where otherwise permitted or required by law.

These third parties may include:

• insurers and other financial product providers
• medical providers
• ACC
• employers
• accountants or other professional advisers
• related businesses or authorised representatives

3. Acting for family members

In some family engagements, one adult may act as the primary contact on behalf of other family members.

Where the primary contact provides personal information about another adult, we rely on that person confirming that they are authorised to act on the other person’s behalf and that the individual has been informed of the collection and has consented to it.

Where we collect personal information about children or young people, we generally do so through a parent or legal guardian, unless the child or young person is sufficiently mature to engage directly.

If we collect a family member’s personal information indirectly, we will take reasonable steps to notify that person as soon as reasonably practicable, unless an exception under the Privacy Act 2020 applies.

4. Website and digital information

When you visit our website, we may collect information about your visit, including traffic data, location data, and analytics information. This may include the use of cookies and similar technologies.

Cookies are small data files stored on your device that help websites function and help us understand how visitors use our site. We may use cookies to:

• remember information you enter into forms
• improve website functionality and user experience
• understand how users interact with our website
• identify and resolve website issues

You can disable cookies through your browser settings, although doing so may affect website functionality.

5. Collection notice

When we collect personal information from you, we will take reasonable steps to make sure you understand:

• what information we are collecting and why
• whether providing the information is required and the consequences of not providing it
• who we may disclose it to
• whether information may be disclosed outside New Zealand and how it will be protected
• how long we may keep it
• your rights to access and correct your personal information
• how to make a privacy complaint
• how to contact our Privacy Officer

6. Fairness of collection

We will not collect personal information by unlawful, unfair, misleading, or unreasonably intrusive means. Where practicable, we will collect personal information directly from you.

7. Record keeping

We store and retain personal information in accordance with our internal record-keeping and information security policies.

HOW WE USE PERSONAL INFORMATION

We collect and use personal information only to the extent reasonably necessary to:

• provide financial advice and insurance services
• assist with underwriting and claims
• arrange, administer, review, vary, replace, or cancel financial products and services
• communicate with you about your cover and our services
• meet our legal and regulatory obligations
• maintain client records and provide ongoing client service

We will not use your personal information for unrelated purposes unless you have authorised us to do so or the law otherwise permits it.

WHO WE DISCLOSE PERSONAL INFORMATION TO

We may disclose personal information where necessary for the purposes set out in this Privacy Policy, or where required or permitted by law. We do not sell personal information to third parties.

We may disclose personal information to:

• our staff, contractors, related companies, and service providers who assist us to provide our services
• insurers and other financial product providers
• medical providers, employers, accountants, lawyers, and other professional advisers where relevant
• regulatory bodies, including the Financial Markets Authority
• our own insurers and professional advisers where necessary to protect or enforce our legal rights
• any other person where authorised by you or permitted or required by law

Some of our service providers, such as cloud, CRM, email, call-recording, transcription, or analytics providers, may store or process personal information outside New Zealand.

Before disclosing personal information overseas, we will take reasonable steps to ensure the overseas recipient is subject to privacy safeguards that are comparable to those in New Zealand, or otherwise ensure that the disclosure complies with the Privacy Act 2020.

HOW WE PROTECT PERSONAL INFORMATION

We take reasonable steps in the circumstances to protect personal information from loss, unauthorised access, use, modification, disclosure, and other misuse.

Our safeguards include:

• secure systems and cloud-based storage
• multi-factor authentication on key systems where supported
• role-based access controls
• staff confidentiality obligations
• secure disposal and deletion processes
• regular privacy and security training
• incident response procedures and breach reporting processes

Where calls are recorded, recordings are stored securely, access is restricted, and they are used only for compliance, audit, quality assurance, and training purposes. Where third-party recording or transcription providers are used, we require them to protect information to standards comparable with those in New Zealand.

ACCESSING AND CORRECTING PERSONAL INFORMATION

You have the right to request access to the personal information we hold about you, and to request correction of that information, subject to any grounds for refusal permitted under the Privacy Act 2020.

If you would like to request access to or correction of your personal information, please contact our Privacy Officer.

We may require proof of identity before releasing or correcting information. We aim to respond as soon as reasonably practicable and, in any event, within the timeframes required by the Privacy Act 2020.

RETENTION AND DISPOSAL

We retain personal information only for as long as necessary for the purposes set out in this Privacy Policy and to meet our legal and regulatory obligations.

As a licensed Financial Advice Provider, we generally retain advice and client records for at least seven years in line with regulatory record-keeping requirements.

When personal information is no longer required, we take reasonable steps to securely delete, destroy, or anonymise it.

INTERNET USE

While we take reasonable steps to maintain secure systems and communications, the transmission of information over the internet is not completely risk-free.

If you follow a link from our website to another website, that third party will have its own privacy practices and policy. We recommend reviewing their privacy policy before providing them with personal information.

DIRECT MARKETING AND OPT-OUT

We may send you service-related and transactional communications relating to the financial products and services you have arranged through us. These communications may include information about policy servicing, renewals, claims, compliance matters, and other important updates. Because these communications are necessary for us to provide our services and meet legal or regulatory obligations, you may not be able to opt out of them while you remain a client.

Where permitted by law, we may also send you marketing or promotional communications about products, services, or updates that may be relevant to you.

You can opt out of marketing communications at any time by:

• using the unsubscribe link in our emails
• replying “STOP” to SMS messages where applicable
• contacting our Privacy Officer

Opting out of marketing communications will not affect our ability to send you important service-related communications.

TRAINING

We ensure that relevant staff, including the Privacy Officer, receive regular privacy training, including training on the Privacy Act 2020 and their privacy-related responsibilities.

PRIVACY BREACHES

If we become aware of a privacy breach, we will assess it promptly and take appropriate steps to contain, investigate, and respond to it.

Where a breach is a notifiable privacy breach under the Privacy Act 2020, including where it has caused or is likely to cause serious harm, we will notify the Office of the Privacy Commissioner and any affected individuals as required by law.

We will also keep appropriate internal records of privacy incidents and complaints and manage them in accordance with our internal policies and legal obligations.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time by publishing a revised version on our website. The updated version will apply from the date it is published.