• how we collect personal information;
• the kind of personal information we collect;
• how we use and may share, your personal information;
• how we store personal information;
• responsibility for personal information collected through linked third-party websites;
• how you can access/amend your personal information;
• how long we hold personal information;
• who you can contact for further information.
2.How we collect personal information
We collect personal information in the following ways:
- directly from you, including when you complete an application form for our products or services;
- from third parties acting on your authority or who you authorise us to make contact with about you (eg authorised representatives to your account);
- indirectly through your use of our website and the services and functionality offered through it;
- when you contact us seeking information about us, our products or services or anything on our website;
- publically available information searched as part of the provision of our products and services to you; or
- in the course of providing our products and services to you and/or other people.
3.The kind of personal information we collect
The information we collect may include:
- your first and last name;
- your date of birth;
- your contact phone number and email address;
- your mailing address;
- fax number;
- IRD number;
- financial information;
- bank account details;
- nominated beneficiaries;
- IP address;
- copies of your verified identification; and
- any other information you give us, or that we acquire through the other sources or means mentioned above.
If you are providing us with personal information about someone else, it may be necessary to make sure that person is aware that your engagement with us may involve collecting, using, and disclosing their personal information. Please ensure you comply with your privacy obligations relating to the personal information of others that you provide to us. We can discuss this with you if the matter arises.
If you do not provide us with the information we require, we may not be able to provide you with the products, services or information you have requested from us.
4. How we use and may share, your personal information
We may use your personal information for any of the following purposes:
- establishing, administering, facilitating and managing your investment in our fund(s) (PMG Funds) (including monitoring, auditing and evaluating PMG Funds);
- communicating with you about our products, services and website, including contacting you in relation to your investment in any PMG Fund;
- processing payments from and transferring money to you;
- providing you with newsletters and other marketing and promotional information about our products and services;
- assisting us in providing you with the products and services offered in New Zealand;
- conducting research to improve our products and services; and
- complying with our legal obligations, including under the following legislation:
- Companies Act 1993;
- Financial Markets Conduct Act 2013 and Financial Markets Conduct Regulations 2014;
- Income Tax Act 2007;
- Tax Administration Act 1994; and
- Anti-Money Laundering and Countering the Financing of Terrorism Act 2009 and Anti-Money Laundering and Countering the Financing of Terrorism Regulations 2011;
- verifying your identity and address;
- processing payments in relation to our products and services;
- facilitating any acquisition, merger, or sale of all or any portion of our business, with, or to, another company;
- for administrative and record-keeping purposes; and
- any specific purpose which we notify you of at the time your personal information is collected or any other purpose which you may subsequently authorise.
You will have the choice to elect to receive some of the above communications either on our website at www.pmgfunds.co.nz or, if investing in a PMG Fund, via the application form accompanying the relevant fund PDS or other offer documents. Should you elect to receive newsletters and other marketing and promotional information about our products and services, 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 us at firstname.lastname@example.org.
We may disclose your personal information (including your identity):
- to our unit registry provider, custodian, fund supervisor and fund accountant;
- our related companies;
- our agents and contractors that provide services to us 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;
- any party proposing to acquire an interest in us;
- anyone else to whom you authorise us to disclose your personal information;
- anyone else required or authorised by law; and
- anyone else we notify you of at the time your personal information is collected or any other person to whom you may subsequently authorise disclosure.
We may also use your personal information in aggregate or anonymised form in which your identity is not disclosed.
Except as provided above, we will not share your personal information with any other third parties and will not sell, license or rent your personal information to third parties.
5.How we store personal information
Your information will be stored by us or on our behalf by third party storage providers. We have entered into appropriate arrangements requiring our third-party storage providers to keep the hosted information secure and confidential, and we will do everything reasonably within our power to prevent unauthorised use or disclosure of the information.
Where we store personal information ourselves, we ensure that your information is protected by security safeguards (as is reasonable in the circumstances to take) against loss, other misuse and unauthorised access, use, modification or disclosure. This includes us taking the following precautions:
- restricting access to personal information stored on our servers;
- imposing confidentiality requirements on our employees;
- requiring that our agents and third party contractors take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure;
- implementing electronic security systems, such as firewalls;
- ensuring that servers containing investor account information have security measures such as password protection; and
- controlling access to our offices.
- for session authentication purposes; and
- to collect information about how you use the website.
A cookie is a small data file that the website sends to your browser (as the case may be), which may then store it for later retrieval by the website.
Some cookies we use last only for the duration of your website session and expire when you close your browser. Other cookies are used to remember you when you return to the website and will last for longer.
If you reject cookies, you may still use our website, but your ability to use some of their features or functionality may be limited.
We may use non-personalised statistics about the use of our website to monitor site traffic, to analyse trends, to gather demographic information about our user base as a whole, to improve our website and improve the web user experience. We may share this anonymised information with our advertising agencies. These anonymised and/or amalgamated statistics do not comprise personal information.
Use of Google Analytics
7. Responsibility for personal information collected through linked third party websites
Our website may contain links to third party websites. Unless expressly stated otherwise, these websites have not been developed by and are not controlled by us. They are provided for your convenience only and do not imply that we check, endorse, approve or agree with the privacy practices of the third party websites linked to.
8. How you can access/amend your personal information
You may access your personal information that we hold by contacting us using the contact details below. We will provide you with a copy of the personal information we keep about you. However, we reserve the right to charge you a reasonable amount for providing copies of any personal information you request, to take into account the time, cost and effort involved.
If you have completed an application form to invest in a PMG Fund you may also be able to access your personal information online via secure access if you so elect.
You may request that the personal information we hold about you be corrected by contacting us using the contact details below. If we do not agree to your request for a correction, you may then request that we take reasonable steps to attach to the information a statement of the correction sought but not made.
9. How long we hold personal information
We will keep your personal information only for as long as necessary to achieve the purpose for which it was collected.
If your personal information is no longer required by us, we will either erase or destroy the information or de‑identify it so it cannot be attributed to you personally.
10. Who you can contact for further information
Privacy Contact Person:
+64 9 578 3494
PMG Property Funds Management Limited
PO Box 2034
If you are not satisfied with the manner in which we have handled your complaint, you can lodge a complaint with the Office of the Privacy Commissioner at www.privacy.org.nz.