Privacy Policy

We may collect personal information directly from you or indirectly through another party.  Information collected indirectly such as:

Your employer (for quotation or benefit purposes, including group schemes)

Employers who provide employee information for quotation or group scheme purposes are responsible for informing employees that their information is being shared

A partner, spouse, or other related person who provides information on your behalf

If one person provides information about another person (for example, completing an insurance application on their behalf) this is treated as indirect collection of personal information.

A third-party system like Trail (our client management system)

Recordings/transcriptions like Contented and Trail.

In cases of indirect collection, we will notify the affected individual of specific matters including:

• That information has been collected
• The purpose of collection
• Intended recipients
• The agency collecting and holding the data
• Any overseas storage
• Their access and correction rights

This notification will occur before collection, or as soon as reasonably practicable after collection, unless an exception under the Privacy Act applies.

Please note that where you are providing information about another person, you confirm that:

• You have their authority to do so
• They are aware that their information is being shared and why
• They have been provided with, or have access to, the Privacy Policy.

Personal information collected will be used only for purposes such as:

• Providing financial advice and recommendations
• Arranging, administering, managing, or reviewing insurance or financial services
• Meeting our legal, regulatory, or contractual obligations

The information we collect may include identity details, financial information, health information (for insurance), credit information.

We may share your information with:

• Specific product providers (e.g. Insurer – Asteron, Bank – BNZ)
• Credit reporting agencies (e.g. Centrix, Equifax)
• Our Financial Advice Provider CIC Financial Ltd.
• Compliance, audit, and IT service providers from time to time as required to meet our regulatory and licencing obligations

Use of AI tools and recording: We may use AI-powered tools to record, transcribe, and summarise meetings (including phone/video/in-person).  This may involve audio recordings and transcripts of discussions about your financial situation.

Its purpose:

• To improve accuracy of advice records
• To ensure compliance with regulatory requirements
• To reduce administrative errors

Third-party providers: We use third-party service providers called Contented and/or Trail (which is our database system as well) to process recordings and generate notes. They are contractually bound to protect your information.  Data may be stored overseas, such as Australia.

Retention and Security: Recordings and/or transcripts will be kept for a minimum of 7 years (as that is our regulatory requirement), or longer if deemed necessary. All client records, including these recordings and transcripts are protected in the same way that all other electronic files are safeguarded within our system.

You may withdraw your consent to specific uses (such as meeting recording) at any time by notifying us, although this may affect our ability to provide services.

All staff employed by CIC Financial Ltd have access to all client files.  In addition to CIC Financial Ltd staff other parties may access this information as required by law or for the purposes of providing specific advice to you in accordance with your instructions or our agreed Scope of Service.

Records are stored in secure premises and on secured computer systems at our place of business.

We take reasonable steps to ensure that all personal information we hold is accurate, up to date, complete, and relevant.

Legal basis Some information is required to be collected under New Zealand law, including obligations under the Financial Markets Conduct Act 2013 and Anti-Money Laundering and Countering Financing of Terrorism Act 2009.

You have rights to request access to and correct your personal information in accordance with the provisions of the Privacy Act 2020. Should you require a copy of any information we hold we shall be happy to provide it at our cost but will always retain original records for legal and compliance requirements.

Specific Notification On those occasions when we obtain private or confidential information from a third party, we will:

• Explicitly name the source of information
• Describe types of data or information received
• Clearly advise what our specific purpose is
• Identify other potential recipients
• Obtain your acknowledgement and consent

If you have a complaint about how we handle your personal information, contact:

Office of the Privacy Commissioner
Email: enquiries@privacy.org.nz
Website: www.privacy.org.nz
Freephone:  0800 803 909
Postal: P O Box 10 094, The Terrace Wellington 6143, New Zealand

This option is available as an additional pathway alongside CIC Financial Ltd.’s Internal Complaints process.