Privacy Statement
Rutherford Rede Limited is committed to protecting your privacy. This privacy statement outlines how we collect, store, use and share your personal information. For more information read our full privacy policy here.
Introduction
Rutherford Rede Limited (“we”, “us”, “our”) is committed to protecting your privacy and complies with the Privacy Act 2020 and, if applicable, the European Union’s General Data Protection Regulations when dealing with personal information.
Personal information is information about an identifiable individual.
This statement sets out how we collect, use, disclose and protect your personal information. It does not limit or exclude any of your rights under the Privacy Act 2020. Further information is available from the Office of the Privacy Commissioner at www.privacy.org.nz.
What information we collect
We may collect personal information about you directly from you, from third parties, or generate information about you in the course of providing our services.
The types of personal information we collect may include:
Contact information – such as your name, phone number, email address, and physical or postal address;
Identity information – such as your passport or driver licence details;
Compliance information – such as information required for Anti-Money Laundering and Countering Financing of Terrorism requirements, sanctions, politically exposed persons, fraud prevention, and other compliance checks;
Financial information – such as your financial position, needs, goals, circumstances, risk profile, investment preferences, or other information relevant to financial advice or services we provide;
Information about your relationship with entities, trusts, companies, partnerships, estates, or other clients – such as where you are a director, trustee, shareholder, beneficial owner, authorised person, attorney, beneficiary, settlor, protector, or person acting on behalf of another person;
Preferences and subscriptions – including your preferences for receiving communications; and
Other information relevant to the services we provide to you
We may also collect information from third parties where you have authorised this or where the information is publicly available.
How we collect your personal information
We collect personal information directly from you, including through your communications and interactions with us, forms you complete, documents you provide, and information generated in the course of providing services to you.
We may also collect personal information about you from other sources where this is permitted by the Privacy Act 2020, where you have authorised us to do so, where the information is publicly available, where collection from another source is necessary for us to provide our services, or where collection is required or authorised by law.
These other sources may include:
Identity verification providers, including Aply Limited, trading as APLYiD;
Your representatives, advisers, attorneys, trustees, directors, officers, authorised persons, or persons acting on your behalf;
Product providers, platform providers, fund managers, KiwiSaver or investment providers, and other financial service providers;
Government agencies or regulators;
Fraud prevention, sanctions screening, politically exposed person screening, electronic identity verification, and other compliance databases or service providers;
Public registers and publicly available sources; and
Other third parties where this is necessary for the purposes described in this privacy statement.
Where we collect personal information about you from someone else, we will take reasonable steps to make sure you are aware of the collection and the matters required by the Privacy Act 2020, unless an exception applies. This privacy statement is one way we do that.
How we use your personal information
We collect and use your personal information to:
Provide our services and products to you;
Communicate with you, including responding to enquiries or service issues;
Verify your identity and authority to act;
Comply with our legal and regulatory obligations, including Anti-Money Laundering and Countering Financing of Terrorism Act 2009 requirements;
Conduct client due diligence, enhanced due diligence, sanctions screening, politically exposed person checks, fraud prevention checks, and other compliance checks;
Assess your needs, objectives, financial situation, risk profile, and suitability for products or services;
Administer, manage, review, and maintain your relationship with us;
Keep records required for legal, regulatory, professional, audit, dispute resolution, and compliance purposes;
Improve our services and website; and
Protect and enforce our legal rights.
We may also contact you with information about services, updates, or events that may be of interest to you. You can unsubscribe from these communications at any time.
We may use tools, including generative artificial intelligence (AI), to assist with administrative tasks such as drafting and summarising documents. Where we do so, we take steps to minimise the use of personal information, use providers with appropriate safeguards, and ensure outputs are reviewed by our staff.
Sharing your personal information
In order to provide our services to you, administer your relationship with us, comply with our legal and regulatory obligations, operate our business, improve our products and services, and protect our legal rights and interests, we may share your personal information with our employees, contractors, advisers and agents.
We may share your personal information with the following intended recipients where this is necessary for the purposes described in this privacy statement:
APLYiD Aply Limited – 99 Khyber Pass Road, Grafton, Auckland
Adminis NZ Limited – Level 1, 125 Featherston Street, Wellington
Marloo Limited – Lot 3, 130 Ponsonby Road, Grey Lynn, Auckland
Zoho Limited – Suite 2.04, Level 2, 30 Currie Street, Adelaide, Australia
Microsoft New Zealand Limited – Level 5, 22 Viaduct Harbour Avenue, Auckland
FUJIFILM CodeBlue Limited – 12 Normanby Road, Mt Eden, Auckland
We may also share your personal information with third parties in the following circumstances:
Regulatory bodies and supervisors, to comply with our legal obligations
Fraud prevention agencies and other organisations, to detect and prevent financial and other crime
Suppliers and service providers, where necessary for the performance, delivery, maintenance and improvement of our products, services and website
Technology, cloud storage, data hosting, software, document management, communications, analytics and administrative service providers.
We may also share your personal information with data, service and software providers to help improve, develop and maintain our products and website, including customer data modelling or statistical and trend analysis, and to provide you with a more tailored and relevant online experience.
We will only share personal information where it is necessary to provide our services, comply with legal obligations, operate and improve our business, protect our legal rights and interests, or where you have authorised us to do so.
We will endeavour to anonymise your data and minimise the amount of personal information shared with third parties, where possible. Prior to sharing any personal information, we take reasonable steps to ensure appropriate contractual, technical and organisational safeguards are in place.
Some of our suppliers and service providers may be located outside New Zealand, or may store personal information on servers located overseas. As a result, your personal information may be transferred to and processed in countries outside New Zealand. Overseas privacy laws may not provide the same level of protection as New Zealand law.
We will only disclose personal information overseas in accordance with the Privacy Act 2020, including where we are satisfied that the recipient is subject to privacy safeguards that are comparable to those in New Zealand, or where you have authorised the disclosure.
We take reasonable steps to ensure that suppliers and partners we engage have appropriate privacy and security safeguards in place. We do not sell or lease your personal information to third parties.
Biometric information and identity verification
To comply with our obligations under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009, we are required to verify your identity.
Where you choose to complete electronic identity verification, we use Aply Limited, trading as APLYiD, to complete the verification process. APLYiD uses biometric processing to verify your identity. This may involve capturing a photograph of your face, known as a selfie, and matching it against your identity document.
If biometric verification is used:
Biometric information will be collected and used solely for identity verification purposes
We will retain information in accordance with our legal obligations
APLYiD will temporarily process and store your biometric and personal information in accordance with its privacy policy; and
APLYiD advises that biometric data is automatically deleted after seven days, although some non-identifiable information may be retained for longer in accordance with its policies.
You are not required to complete electronic identity verification. You may instead provide identification documents in person. However, we may not be able to provide services until identity verification has been completed.
Proportionality assessment
Where biometric identity verification is used, we undertake a proportionality assessment to ensure that the use of biometric information is reasonable, necessary, effective, and proportionate to the risks being managed, including fraud, impersonation, identity-related risks, and AML/CFT compliance risks.
You may request a copy of our proportionality assessment by contacting us at enquiries@rutherfordrede.co.nz.
Your rights
You are not required to provide personal information to us. However, if you choose not to provide information that is necessary, we may not be able to provide certain services to you.
You have the right to:
Request access to the personal information we hold about you
Request correction of that information
If you would like to make a request, please contact us at enquiries@rutherfordrede.co.nz. Please provide sufficient information to enable us to verify your identity and process your request.
You may also contact us if you have a privacy concern or complaint. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner.
Storage and security
We take reasonable steps to protect personal information from loss, unauthorised access, use, modification or disclosure. This includes the use of secure systems, controlled access to information, and appropriate policies and procedures.
While we take reasonable measures to protect your information, no method of transmission over the internet or electronic storage is completely secure.
We will not hold your information for longer than is reasonably necessary to provide our services to you, and to ensure we are able to comply with legal, regulatory and accounting requirements.
Some legal and regulatory requirements require your information to be held after our relationship with you has ended.
Website information and use
The purpose of this website is to provide general information only about our services and industry insights. The information provided does not constitute financial or professional advice.
We may update or remove website content at any time.
Cookies
We may make changes to this statement by uploading a revised version to the website. Any change/s will apply from the date that we upload the revised statement to the website. This statement was last reviewed by us in August 2024.
Warranties and liability
While we make reasonable efforts to ensure that information on this website is accurate and up to date, we do not guarantee its accuracy, completeness or suitability for any particular purpose.
To the maximum extent permitted by law, we disclaim liability for any loss or damage arising from reliance on information contained on this website or from its use.
We do not guarantee that this website or any linked website is free from errors, viruses or other harmful components, or that access will be uninterrupted.
Intellectual property
All content, material, layout and design on this website is owned by or licensed to Rutherford Rede Limited and is protected by intellectual property laws.
Changes to this privacy statement
We may update this privacy statement from time to time by publishing a revised version on our website. Changes will apply from the date of publication.
Contact us
If you have any questions or concerns about this privacy statement or how we handle your personal information, please contact us at:
Email: enquiries@rutherfordrede.co.nz