Privacy Policy

December 2020

In this Privacy Policy, ‘William Buck’, ‘we’, ‘us’ and ‘our’ mean William Buck (NZ) Limited.

We respect your privacy

William Buck respects your privacy and is committed to treating the personal information we collect in accordance with the Information Privacy Principles (Privacy Principles) in the Privacy Act 2020 (Privacy Act) and the NZ Code of Ethics (Code of Ethics).

This Privacy Policy outlines the obligations William Buck has in managing the personal information we hold about our clients, potential clients, contractors and others. Personal information is any information that can identify an individual, either directly or indirectly.

This Privacy Policy does not apply to acts or practices that are directly related to employee records of current or former employees.

If you would like further information on this Privacy Policy, you may contact us at the email address at the bottom of this page.

References to the Privacy Act includes any subordinate legislation, by-law, regulation, order, statutory instrument or determination made under it, any re-enactment of, or amendment to, the Privacy Act and all legislation passed in substitution for that legislation.

Personal information we collect

As a provider of accounting, advisory, audit, business recovery and wealth advisory services we are subject to certain legislative and regulatory requirements which necessitate us obtaining and holding detailed personal information.

In general, the main types of personal information we collect and hold includes (but is not limited to):

— Names

— Contact details

— Gender

— Dates of Birth

— Employment details and employment history

— IRD Numbers

— Details of your financial circumstances, including bank account details, your assets and liabilities (both actual and potential), income, expenditure, insurance cover and superannuation

— Health information (for some types of insurance cover)

We will not collect any personal information about you except when you have knowingly provided that information to us or authorised a third party to provide that information to us.

How we use your personal information

William Buck will use personal information only for the following lawful purposes in connection with our products and services:

a. Provide you with products and services during the usual course of our business activities;

b. Administer our business activities;

c. Manage, research and develop our products and services;

d. Provide you with information about our products and services, invite you to events or distribute articles or publications;

e. Communicate with you by a variety of measures including, but not limited to, by telephone, email, SMS or mail;

f. Investigate any complaints;

g. Carry out credit checks;

h. Enforce any legal rights that we have against you; and

i. Any other uses to which you consent.

You have a right not to provide personal information requested by us. If, however, you withhold your personal information, it may not be possible for us to provide you with our products and services or alternatively may affect the adequacy or appropriateness of advice or services provided.

How we collect your personal information

William Buck collects personal information from when you interact with us remotely (including electronically) and in person. This includes, but is not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference(s), respond to surveys and/or promotions, provide financial or credit card information, or communicate with your advisor.

We may also gather personal information through the use of our websites (See Website and Cookies, below).

We may also receive personal information from third parties. If we do, we will protect it as set out in this Privacy Policy. You have a right to refuse us authorisation to collect information from a third party.

Sometimes you may provide us with someone else’s personal information, e.g. other members of your family group. You must not do this unless you have their consent to do so. You should also take reasonable steps to inform them of the matters set out in this Privacy Policy.

Unsolicited personal information

There may be times when we receive personal information that we do not solicit. If this occurs, we will determine if we are entitled to receive this information under this Privacy Policy and the Privacy Act.

If it is determined that we should not have obtained this information, we will destroy or de-identify the information as soon as practicable, provided it is lawful and reasonable to do so.

Disclosure of personal information

In providing our services we may need to disclose personal information to a third party. This will be done to the extent that it is permitted by law and set out in this Privacy Policy.

Examples of the types of third parties we may disclose personal information to include:

— Member organisations of William Buck and their related bodies corporate and other associated entities.

— Companies or individuals contracted to assist us in providing services or who perform functions on our behalf (such as mailing houses, specialist consultants, barristers and solicitors, contractors or temporary employees to handle peak period workloads, information technology service providers, superannuation fund trustees, insurance providers, fund managers, market research organisations and other product providers)

— Courts, tribunals, law enforcement and regulatory authorities, as required or authorised by law and in accordance with the Code of Ethics.

— Auditors or compliance officers, as required or authorised by law or Professional Associations

— To third parties (such as debt collectors) where we are seeking to enforce any rights against you.

— Anyone else to whom you consent or to whom disclosure is directly related to the purposes in connection with which the information was obtained, such as banks, accountants and other financial institutions.

— If there is a change of control in our business or a sale or transfer of business assets, we may transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases

Where you engage us to attend to your tax affairs we will assume (unless you advise otherwise) that you have specifically authorised us to deal directly with the Inland Revenue Department, the Australian Tax Office and any other overseas tax authority regarding day to day type matters. If, in the course of our dealings with these bodies, they request information regarding you that we believe is outside of such matters, e.g. tax office audit, we will request your specific authority before complying with their request.

Hosting and International Data Transfers

Depending on the nature of the engagement or circumstances of personal information collection, we may disclose your personal information to entities overseas (where we are authorised to disclose your personal information – see Disclosure of Personal Information, above).

William Buck has offices and/or facilities in countries including Australia, New Zealand, the Philippines and India. Our suppliers and contractors are situated in countries including Australia, New Zealand, the EU, the UK, USA, the Philippines and India. The hosting facilities for our website are situated in Australia. We may also store, process or back up your personal information on servers that are located overseas (including through third party service providers). These servers are commonly located in (but are not limited to) USA, the UK, The Netherlands, Ireland & Singapore.

Data Transfers to each of these countries will be protected by appropriate safeguards.

Publication of Personal Data

You acknowledge that personal information that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal information by others.

There may be circumstances in which the disclosure of the information is required or authorised by law or a court/tribunal order, the Code of Ethics, or where you have given your direct consent to disclose it.

Security of your personal information

William Buck is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

Our employees are required to respect the confidentiality of personal information and the privacy of individuals, and privacy and data protection training is undertaken. As part of that training, all employees are required to read this Privacy Policy and understand their obligations in respect to personal information.

Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the Privacy Act (or where data processors are located outside New Zealand that provide comparable safeguards to the Privacy Act) and that have adequate measures in place to protect personal information against unauthorised use, loss and theft.

The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us or receive from us. Although we take measures to

safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

We will retain your personal information only as long as necessary to fulfil the purpose for which it was collected, as required by law and the Privacy Principles or in accordance with our documentation retention policies.

Access to your personal information

You may request details of, update and correct personal information that we hold about you in accordance with the provisions of the Privacy Act. If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at nz.privacy@williambuck.co.nz.

We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act or any other applicable law.

Website and Cookies

When you visit our websites

When you visit our websites (www.williambuck.com and www.williambuck.com/nz), we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

We may also collect personal information through subscription applications, event registration and emails. You are not required to provide personal information via our websites, however you may choose to do so in order to receive communications on our services, apply for an employment position or receive invitations to events. Information collected via our digital marketing activities is treated in accordance with this Privacy Policy.

Cookies

We may from time to time use cookies on our websites. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site.

Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies, but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our websites. Our websites may from time to time use cookies to analyse website traffic and help us provide a better visitor experience.

In addition, cookies may be used to serve relevant advertisements to website visitors through third party services such as Google AdWords. These advertisements may appear on our websites or other websites you visit.

Third party sites

Our websites may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that William Buck is not responsible for the privacy practices of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.

Social media platforms

You may wish to participate in the various social media platforms hosted by us and which we make available to you. These platforms are designed to facilitate and share content. We cannot be held responsible if you publicly share personal information on these sites that is subsequently used, misused or otherwise appropriated by another party/entity.

Changes to this Privacy Policy

Please be aware that this Privacy Policy may be updated as and when required in our sole discretion, for example, to take into account new laws, changes to our operations and practices, changes in the business environment and technology. All modifications will be effective immediately upon our posting of the modifications on our websites. Please check back from time to time to review our Privacy Policy.

Contacting Us

If you have any complaints about our privacy practices, please feel free to send in details of your complaints to nz.privacy@williambuck.co.nz. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

If you would like to exercise any of your rights under this Privacy Policy or the Privacy Act or have any other questions about privacy-related issues, you should use the relevant email address below.