1. Our commitment to protect your privacy

We understand how important it is to protect your personal information. This document sets out our privacy commitment in respect of personal information we access and hold about you and what we do with that information.

It is important t o us that you are confident that any personal information we access or hold about you will be treated in a way which ensures protection of your personal information.

Our commitment in respect of personal i nformation is t o abide by the Privacy Principles set out in the Privacy Act 2020 (or any successor legislation) (the Privacy Act) and all other applicable laws. This Privacy Policy applies in addition to, and does not limit, our rights and obligations under the Privacy Act and other applicable laws.

2. Who are we

References in t his Privacy Policy to “we", “us” and “o ur” means NZ Financial Services Group Limited (NZFSG). NZFSG is a financial services group and holds a Financial Advice Provider license issued by the Financial Markets Authority (F AP Licence). Businesses who are members of NZFSG (NZFSG Members) are Financial Advice Providers. NZFSG Members provide, or engage Financial Advisers to provide, financial advice to clients.

3. What personal information do we collect?

When we refer to personal information we mean information that identifies, or is capable of identifying, you.

• This includes, for example, your name, date of birth, address, contact details, account details and occupation.

• If you are a client of a NZFSG Member, it also includes personal information about your financial situation or goals that has been collected by the NZFSG Member in order to recommend to you mortgage and/or insurance products.

4. How do we access and collect your personal information?

If you are a client of a NZFSG Member, generally we will access and collect your personal information directly from a NZFSG Member:

• This may be done by us directly accessing the NZFSG Member’s client management system, or by requesting the NZFSG Member to provide your personal information to us.

• As a client of a NZFSG Member, you sign a Declaration Form that authorises the NZFSG Member to share your personal information with us (see “Why do we access and collect your personal information” below).

NZFSG may also access and collect your personal information from:

• Product Providers, such as a Lender or Insurer.

• You, where you make a general enquiry through this website or otherwise provide us with your information.

• Any other person authorised by you or the Privacy Act.

5. Why do we access and collect your personal information?

We access and collect your personal information so that:

If you are an NZFSG Member (or a Financial Adviser engaged by a NZFSG Member), we can provide services to you.

• If you are a client, we can provide services to t the NZFSG Members and carry out our monitoring and oversight obligations, which includes carrying out assurance checks on the advice provided to clients. This is to ensure that the advice provided to clients meets all regulatory obligations and prioritises client interests.

• We can respond to you (in relation to website enquiries).

6. Updating your personal information

If you are a client of a NZFSG Member and any of your details change, please contact your NZFSG Member. If you are a NZFSG Member, please contact us promptly to update your details.

7. Who do we disclose your personal information to?

We may disclose your personal information to the following people if we consider it necessary to

do so for the purposes described in section 5 above:

• Product Providers, such as Lenders or Insurers in relation to existing loans or insurance that relate to you as a client or a NZFSG Member.

• Contractors or service providers that we may use.

• Investors, or any entity that has an interest in our business or any entity to whom we consider assigning or transferring any of our rights or obligations or selling all or part of our business.

• Anyone who we are legally required or authorised to share your information with, including regulators and government agencies.

• External auditors to ensure we are meeting our monitoring and oversight obligations.

• Any other person or entity authorised by you or the Privacy Act.

Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that the person or organisation has a commitment to protecting your personal information at least equal to our commitment.

8. Do we disclose your personal information to anyone outside New Zealand?

We may use cloud storage to store any personal information we hold about you. The cloud storage and the IT servers may be located outside New Zealand.

We may also disclose personal information to contractors and service providers located overseas for some of the purposes listed above.

9. Our Website

Cookies and IP addresses

When you access our website, we may send a “cookie” (which is a small summary file containing a unique I D number) to your computer. This enables us to recognise your computer each time you visit our website. We also use cookies to measure traffic patterns, to determine which areas of our website have been visited, to measure transaction patterns, to analyse trends, administer the website, track users’ movements and gather broad demographic information. We use this to research our users’ habits so that we can improve our website and our service offering. Our cookies may record information such as your Internet Protocol (IP) address (that is, the electronic addresses of computers connected to the internet), your device and browser type, operating system, the pages or features of our site to which you have browsed and the time spent on those pages or features, the frequency with which the site is used by you, the search terms that you have used, the links on our site that a you have clicked on or used, and other usage statistics.

While our cookies do not collect personal information, if you submit your name and email address as part of your usage, then we will link that personal information with the cookies information that we have previously collected from you.

If you do not wish to receive cookies, you can set your browser so that your computer does not accept them.

Security

As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being t ransmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

Links and third party advertisements

Our website may contain links to other websites operated by third parties. Our website may also display advertisements, which are hosted by third parties.

We make no representations or warranties in relation to the privacy practices of any third party website or advertisement providers and we are not responsible for other privacy policies or the content of any third party website or advertisements. Third party websites are responsible for informing you about their own privacy practices.

Our online advertising network partner may use cookies, web beacons or other web tracking techniques to collect non-personally identifiable information about your activities on the website and other websites that you may visit to provide you targeted advertising based upon your interests.

10. Are you required to provide personal information to us?

You are not required to provide any personal information to us. However:

• If you are a NZFSG Member, or a Financial Adviser engaged by a NZFSG Member, this may limit our ability to provide services to you.

• If you make an enquiry through our website, we will require your name and contact details to respond to you.

• If you are a client of a NZFSG Member, and you don’t provide authorisation to the NZFSG Member to share your personal information with us, this may impact their ability to provide services to you (as our oversight is required to meet our regulatory obligations under our FAP Licence and our contractual obligations to Product Providers).

11. Access and correction to your personal information

You may access and request correction of any of the personal information that we hold about you at any time by contacting us. We may charge a fee for our reasonable costs of retrieving and supplying the information to you.

12. Changes to our Privacy Policy

We may change our Privacy Policy from time to time, by publishing an updated version on this page, to reflect changes in the law and also our business needs so long as the changes do not disadvantage you.

13. Further information

If you have any questions on our Privacy Policy or your personal information please contact us.