Full Privacy Policy

Purpose

We know that how we collect, use, disclose and protect your information is important to you, and we value your trust. That’s why protecting your information and being clear about what we do with it is a vital part of our relationship with you.

The purpose of this Privacy Policy is to inform our clients and any users of our digital platforms i.e. our social media pages and groups about how we comply with the requirements of the New Zealand Privacy Act 2020 (“the Privacy Act”) in managing personal information.

Consent to Privacy Policy

Please note that when you contact us through our social media pages and groupsyou are agreeing to this Privacy Policy. If you do not agree with this Privacy Policy, please do not contact us through any of our social media pages and groupsbut call us on 027 227 5237.

Collection of personal information

Personal Information is defined in the Privacy Act as information about an identifiable individual (a natural person as opposed to a company or other legal entity).  

Types of personal information we collect

The types of personal information we collect will vary depending on the nature of your dealings with us. We only collect personal information that is necessary. Where reasonable and practicable, we will collect your personal information directly from you and inform you that we are collecting it. 

We mainly collect personal information directly from you, for example:

  • Over the telephone or a video call (such as over Microsoft Teams, Zoom or Skype) e.g. when you contact our staff;

  • Through one of our digital platforms like our social media pages and groups including through any online chat

  • When you email or write to us; or

  • When you participate in a marketing campaign, competition or promotion (or a similar event) administered by us or our representatives.

If it is not obvious that we are collecting personal information from you, we will do our best to make it clear to you so that you are always aware when information is being collected.

 

Generally, the types of personal information we collect and hold include your:

  • Name

  • Date of birth

  • Contact details (such as your email address, postal address, phone number)

  • Details relating to your use of any product and/or service offered by us

  • Details of your enquiry

  • Details of any preferences you tell us about (such as subscription preferences).

 

We may also collect personal information about you from:

  • Publicly available sources e.g. via the internet;

  • Your professional advisers e.g. your accountant, solicitor, other financial advisers and real estate agents

We collect your personal information from the above parties (other than publicly available sources) where we have received your express consent to do so. We are not responsible for the privacy or security practices of the above parties and the parties described above are not covered by this Privacy Policy. 

Online device information and cookies

If you are visiting us through social media pages and groups  then we collect information about your use and experience on these by using cookies. Cookies are small pieces of information stored on your hard drive or on your mobile browser. They can record information about your visit to the site, allowing it to remember you the next time you visit and provide a more meaningful experience.

The cookies we send to your computer, mobile phone or other device cannot read your hard drive, obtain any information from your browser or command your device to perform any action. They are designed so that they cannot be sent to another site or be retrieved by any non ASA Investments Limited social media pages or groups.

When you interact with us through our social media pages or groups the information collected through the cookies may include:

  • The date and time of visits;

  • Information about your location;

  • Information about the device used to visit our digital platform; and

  • IP address (or addresses), and the type of web browser used.

 

We will not ask you to supply personal information publicly over Facebook, Twitter, Instagram or any other social media platform that we use. Sometimes we may invite you to send your details to us through a private message, for example, to answer a question. You may also be invited to share your personal information through secure channels to participate in other activities, such as competitions, but we would require your express consent prior to us including you in such activities.

Purpose of collection and use of personal information

Any personal information you provide to us may be used to:

  • Check whether you are eligible for the product or services offered by us;

  • Facilitate those services;

  • To contact you about and managing and administering the products and services we provide you with;

  • Provide information that you request; and / or

  • Provide you with further information about our other products and services.

If you do not wish to receive marketing correspondence from us, please let us know. You will be able to opt-out of any marketing messages we send you by email or text message by following the unsubscribe link in those messages.

You can also opt out of any future marketing information by contacting us by phone on 027 227 5237, email:andre@lookahead.co.nz or by post : The Director, ASA Investments Limited, 3B Torrington Crescent, Glen Innes, Auckland 1072

 

We also have an obligation to maintain personal information to disclose to regulatory and similar bodies – see Disclosure of your personal information below.  These bodies have a legal right to such information.

Storage and protection of your personal information

We may electronically record and store personal information which we collect from you. When we do so, we will take all reasonable steps to keep it secure and prevent unauthorised disclosure.

However, we cannot promise that your personal information will not be accessed by an unauthorised person (e.g. a hacker) or that unauthorised disclosures will not occur. If we provide you with any passwords or other security devices, it is important that you keep these confidential and do not allow them to be used by any other person. You should notify us immediately if the security of your password or security device is breached, this will help prevent the unauthorised disclosure of your personal information.

Most of your information will be stored electronically on the cloud, by cloud service providers – Cloud Based Service Providers below.

We use a range of physical and electronic security measures to protect the security of the personal information we hold, including:

  • Access to information systems is controlled through identity and access management;

  • Advisers are bound by internal information security policies and are required to keep information secure;

  • When we send information overseas or use service providers to process or store information, we put arrangements in place to protect your information;

  • We regularly monitor and review our compliance (and our service providers’ compliance) with internal policies and industry best practice.

  • We only keep information for as long as we need it, or as long as the law requires us to.

Cloud-based service providers

We use Microsoft 365 cloud servers located in Sydney Australia. We also use Datto Backupify and Datto File Protection cloud servers located in Sydney Australia. We ensure that our cloud-based service providers are subject to appropriate security and information handling arrangements and that the information stored or processed by them remains subject to confidentiality obligations.

Timeframes for keeping personal information

We take reasonable steps to destroy or permanently de-identify any personal information as soon as practicable after the date of which it has no legal or regulatory purpose, or we have no legitimate business purpose with it.

In the case of information that relates to our advice services or products or services we have provided, we are required by law to hold this information for seven years. After this time, provided that the personal information is no longer relevant to any service we are providing you, we will take reasonable steps to safely destroy or de-identify any personal information.

Disclosure of your personal information

We may disclose your personal information to others outside ASA Investments Limited where:

  • It is necessary to enable us to achieve the purpose that we collected the information for;

  • We are required or authorised by law or where we have a public duty to do so;

  • You have expressly consented to the disclosure or your consent can be reasonably inferred from the circumstances; or

  • We are permitted to disclose the information under the Privacy Act 2020.

We take reasonable steps to destroy or permanently de-identify any personal information as soon as practicable after the date of which it has no legal or regulatory purpose, or we have no legitimate business purpose with it.

In the case of information that relates to our advice services or products or services we have provided, we are required by law to hold this information for seven years. After this time, provided that the personal information is no longer relevant to any service we are providing you, we will take reasonable steps to safely destroy or de-identify any personal information.

Parties we may disclose your information to

Your personal information may be used by us for the purpose of providing advice and services to you and may also be used by agencies such as, but not limited to:

  • Any out-sourced service provider who assists in the services we are required to carry out such as auditors and external compliance reviewers;

  • Our external dispute resolution service;

  • The Regulator;

  • Credit reporting and debt collecting organisations;

If we don’t need to share your information with a third party in order to provide advice and services to you, we will not pass on your information to them without your consent. Under no circumstances will we sell or receive payment for disclosing your personal information.

Parties we may disclose your information to

Your personal information may be used by us for the purpose of providing advice and services to you and may also be used by agencies such as, but not limited to:

  • Any out-sourced service provider who assists in the services we are required to carry out such as auditors and external compliance reviewers;

  • Our external dispute resolution service;

  • The Regulator;

  • Credit reporting and debt collecting organisations;

If we don’t need to share your information with a third party in order to provide advice and services to you, we will not pass on your information to them without your consent. Under no circumstances will we sell or receive payment for disclosing your personal information.

Sending your information overseas

We may send your personal information outside New Zealand, including to overseas service providers or other third parties who process or store our information, or provide certain services to us.

Where we do this, it does not change any of our commitments to you to safeguard your privacy. We make sure that appropriate security and information handling arrangements are in place and the information remains subject to confidentiality obligations.

All countries have different privacy laws and information protection standards. If we need to send your personal information to a country that has lower standards of information protection than in New Zealand, we will take appropriate measures to protect your personal information. Where it is not possible to ensure that appropriate security and information handling arrangements are in place, we will let you know and gain your consent prior to sending your personal information.

Third party websites

Through our social media pages and groups, you may be able to link to other websites which are not under our control.  We are not responsible for the privacy or security practices of those third-party websites and the sites are not covered by this Privacy Policy. Third party websites should have their own privacy and security policies and we encourage you to read them.

 

In addition, we have no knowledge of (or control over) the nature, content, and availability of those websites. We do not sponsor, recommend, or endorse anything contained on these linked websites. We do not accept any liability of any description for any loss suffered by you by relying on anything contained or not contained on these linked websites.

Right to access, correct and delete personal information

You have the right to request access to, correct and, in some circumstances, delete your personal information. You can do so by contacting us at:

The Director, ASA Investments Limited, 3B Torrington Crescent, Glen Innes, Auckland, 1072

Or via email at andre@lookahead.co.nz

 

When you contact us with such a request, we will take steps to update or delete your personal information, provide you with access to your personal information and/or otherwise address your query within a reasonable period after we receive your request. To protect the security of your personal information, you may be required to provide identification before we update or provide you with access to your personal information.

We are only able to delete your personal information to the extent that it is not required to be held by us to satisfy any legal, regulatory, or similar requirements.

There is no fee for requesting that your personal information is corrected or deleted or for us to make corrections or deletions. In processing your request for access to your personal information, a reasonable cost may be charged. This charge covers such things as locating the information and supplying it to you.

There are some circumstances in which we are not required to give you access to your personal information. If we refuse to give you access or to correct or delete your personal information, we will let you know our reasons, except if the law prevents us from doing so.

If we refuse your request to correct or delete your personal information, you also have the right to request that a statement be associated with your personal information noting that you disagree with its accuracy.

If we refuse your request to access, correct or delete your personal information, we will also provide you with information on how you can complain about the refusal.

What happens if you do not provide us your information?

If you do not provide information we have requested, you may be unable to obtain or access our services for which the information is required. Please ask us if you are unsure what information is important and how this might affect you.

Changes to this Privacy Policy

We review this Privacy Policy periodically to keep it current and available on our website. If the changes are significant, we may advise you directly. You may also obtain a copy of the latest version by calling us on  027 227 5237. 

Privacy Policy queries and concerns

If you are concerned about how your personal information is being handled or if you feel that we have compromised your privacy in some way, please contact us by way of the following:

By Post: The Director, ASA Investments Limited, 3B Torrington Crescent, Glen Innes, Auckland, 1072

By phone: 027 227 5237

By email: andre@lookahead.co.nz

 

We will acknowledge your complaint within three working days of its receipt. We will let you know if we need any further information from you to investigate your complaint.

We aim to resolve complaints as quickly as possible. We strive to resolve complaints within five working days, but some complaints take longer to resolve. If your complaint is taking longer, we will let you know what is happening and a date by which you can reasonably expect a response.

If you are not satisfied with our response to any privacy related concern you may lodge a complaint on the Privacy Office website (www.privacy.org.nz) or send a complaint form to  the Privacy Commissioner at: 

Office of the Privacy Commissioner

P O Box 10-094

Wellington 6143, New Zealand

Fax: 04- 474 7595

Email: enquiries@privacy.org.nz

 

Telephone: 0800 803 909

Website: www.privacy.org.nz