Privacy Policy

1.   Introduction

1.1.    Sage Wealth Management (Sage) is committed to protecting the personal information that it is entrusted with through the course of its business.  This Privacy Policy (Policy) outlines the type of personal information Sage collects, how it is stored, used and disclosed.

1.2.    The Policy and the enclosed Privacy Statement apply to all personal information collected and held by Sage or its agents, including the personal information collected on employees.

1.3.    The Privacy Act 2020, including any succeeding Privacy Act, (Privacy Act) governs the way in which we must manage personal information.

2.   Roles and responsibilities

2.1.    The Chief Operating Officer (COO) of Mint Asset Management, a ‘sister’ company to Sage, is the designated Privacy Officer at Sage.

2.2.    Queries regarding our Policy will be forwarded to the COO as the initial point of contact.

2.3.    The COO is responsible for the reporting and escalation of any privacy complaints or breaches and for the maintenance of a log of any such events.

3.   Privacy Statement

3.1.    The enclosed Privacy Statement is for external use and is to be published on Sage’s website, together with being referenced, linked or included in other external sources as appropriate.

3.2.    Changes to the Privacy Statement must be accompanied by a notice on the website.  If the change is significant, the COO will determine whether an email notifying clients is required.

4.   Employees

4.1.    Sage is required to collect personal information from employees in order to run the business effectively. This includes information such as names, addresses, contact details, bank and tax details.

4.2.    An employee can request details of any personal information held about them and advise Sage if it is inaccurate, incomplete or out of date.

4.3.    The information provided will only be used for the purpose for which it was intended, except where legislation allows it to be used for other purposes, or with the consent of the person concerned.

4.4.    Sage will take all reasonable security measures to protect personal information from loss, unauthorised access, destruction, misuse, modification or disclosure.

5.   Privacy breach

5.1.    Any privacy breach must be notified to the COO immediately.

5.2.    They will be tasked with responding as quickly as possible to minimise the impact. They will also be responsible for escalating the breach to the Board, Supervisor, Regulator and client(s) (as appropriate).

5.3.    The COO will assess the potential harm caused by the breach.  If they consider it poses a risk of serious harm to affected individuals, they will notify the Privacy Commissioner immediately.

5.4.    Information on how to deal with a privacy breach can be found at www.privacy.org.nz.

6.   Policy review

6.1.    This Policy and the contents of the Privacy Statement will be reviewed at least annually.

Privacy Statement

We are committed to protecting and respecting your privacy and your information.

We handle your personal information in accordance with the Privacy Act 2020 and any succeeding Privacy Act (Privacy Act). This Privacy Policy sets out how we collect, use, disclose and store your personal information.

This Privacy Policy may change from time to time.  We will tell you about any changes to this Privacy Policy, by posting a new version on our website.  We encourage you to periodically review this Privacy Policy to stay informed as, by continuing to use our services, you will be agreeing to our changes. If you provide information to us about any other person, then you must have authorisation from that person to do so.

References to 'Sage', 'we', 'us', and 'our' in this Privacy Policy are references to Sage Wealth Management and our related companies, agents or delegates, where applicable. This Privacy Policy applies to all products and services made available by us.

What information do we collect?

Most of your personal information we collect will come directly from you. The type of information we may collect includes:

• your name, date of birth, driver's licence number, passport number, marital status, postal or residential address, email address, telephone number, nationality, income, bank account details, and taxation details;
• accounting and financial information relating to your investment portfolios;
• any information that you provide via our website or online services; and
• all of your correspondence with us. 

When you visit or use our website, we collect information including the IP address and phone number of your machine or device, the operating system and the browser your machine or device uses, your browser's general Wi-Fi location, the date and time you are visiting and the pages you view.

How do we collect your information?

We may collect personal information directly from you when you interact with us over the phone, through email or letter, via our website, when you personally meet with our staff or agents or where you use our services.

When you use our website, we use tools such as cookies and monitoring tools to collect information that helps us improve our website and our online services.  Cookies do not identify you personally, but they may link back to a database record about you.  We collect information about what technologies you use and the browsing habits that you display when you use our website, which helps us to identify how we can improve our website and services to you.

We may also collect your personal information from a third party where you have authorised this or from the following:

• a publicly available source;
• a government department, body, or law enforcement agency;
• a service provider, for example your financial adviser;
• credit agency;
• third party providers of cookies and other online tracking systems; or
• third party providers who offer market research.

Our website may contain links to other websites. We are not responsible for the privacy policies and practices of linked websites.

How do we use your information?

We collect your personal information to allow us to carry out our commercial activities and provide the best service to you.  This includes providing you with the services, products and information that you request and expect from us.

We will use your personal information to:

• meet our contractual obligations with you or our legal obligations (such as complying with know-your-client (KYC), anti-money laundering and countering financing of terrorism (AML/CFT) and Inland Revenue (IRD) regulations);
• process your client applications, instructions and provide customer support, including contacting you to offer assistance with online applications (including those you do not complete);
• generate reports and record keeping of investment portfolios;
• communicate with you during the course of your business relationship with us;
• administer, develop and improve our business activities and those of our business partners;
• notify you about changes or developments to our business activities;
• assist us with any legal proceedings;
• respond to any correspondence or requests for information from you; and
• provide you with information about our other products or services which we think you may be interested in, including alerts, newsletters or information that you requested or signed up to. 

By providing your email address and / or mobile phone number, you consent to us sending you information connected with the above collection and use purposes via email or text message.  The messages you receive from us will have instructions for how you can remove yourself from our mailing list.

When we disclose information

We will only disclose your personal information to people other than you when:

• you have authorised such disclosure;
• we are required to provide the information by law;
• disclosure is for the purpose of collecting the information (such as where we disclose information to credit agencies);
• the source of the information was a publicly available source;
• it is necessary to facilitate the sale, disposal, assignment or transfer of Sage or any of its assets or subsidiaries or related companies;
• disclosure is required by our contractors (for the purposes of the services they provide), so that we can complete a transaction on your behalf or provide you with a service that you have requested;
• disclosure is necessary to offer you products and services that may be of interest to you and to optimise the advertisements on our websites;
• disclosure is necessary to market, review or improve our services or facilities;
• it is necessary for a function of Sage, such as for legal or auditing purpose; or
• we are permitted to do so under the Privacy Act.

We will not disclose your personal information to overseas recipients without your consent unless:

• we have taken reasonable steps to ensure that the recipient does not breach the Privacy Act;

or

• the recipient is subject to a privacy regime that has the effect of protecting the information in a way that, overall, is at least substantially similar to the way in which the Privacy Act protects the information.

How do we store and protect your information?

We may store your personal information in different forms, including in hardcopy and electronic form.  All electronic information is stored on secure servers.  We will take all reasonable steps to protect personal information from misuse, loss and unauthorised access, modification or disclosure.  We have implemented policies, procedures and systems to keep your personal information secure.  We ensure the on-going adequacy of these measures by regularly reviewing them.  Communications over the internet, such as emails, are not secure, unless they have been encrypted.

We will not retain your personal information for longer than is necessary.

How can you access your information?

We will take reasonable steps to ensure any personal information held by us is accurate.  Any request by an individual to correct personal information held about that individual will be responded to as soon as we can following receipt of such a request.

You may obtain confirmation as to whether or not personal information is held about you, unless there is good reason (in accordance with our legal obligations, including under the Privacy Act) to not disclose this.  You may also request access to, or a copy of, the information and / or request that corrections or changes are made to it.  In accordance with our obligations under the Privacy Act, within 20 working days of receiving a request we will a) decide whether the request is to be granted and, if so, in what manner and for what charge (if any); and b) give or post a notice of the decision on the request to you.

We will disclose personal information to the relevant individual about whom the information relates where it can be readily retrieved, unless there is good reason (in accordance with the Privacy Act) for not doing so, including where such a disclosure would breach someone else’s rights to privacy and / or the law.

To request your personal information, of if you have any questions please contact our Privacy Officer at info@minteasset.co.nz.

If you feel that we have not respected your privacy or we have conducted ourselves inconsistently with this Privacy Policy, please contact our Privacy Officer us as soon as possible. We will investigate your queries and privacy complaints within a reasonable period of time depending on the complexity of the complaint. 

Nothing in this Privacy Policy shall limit your rights under the Privacy Act. This Privacy Policy is governed by the laws of New Zealand.

This policy is current as at 25 July 2022.