PRIVACY POLICY

Eliteinsure Limited (“Eliteinsure”, “we”, “us” or “our”) is committed to protecting personal information and handling it in accordance with the Privacy Act 2020 and other applicable legal and regulatory requirements.

This Privacy Policy explains how we collect, hold, use, disclose, protect and otherwise handle personal information, and how individuals may request access to and correction of their personal information.

This policy applies to personal information collected by us in connection with our business and operations, including when we provide insurance advice and services, KiwiSaver advice and services, managed investment product-related services, mortgage and home loan advice and services, commercial lending services, and business lending services, respond to enquiries, assess applications, support claims, carry out compliance and identity verification checks, manage our website, recruit staff and contractors, and otherwise conduct our business activities.

In this policy, personal information means information about an identifiable individual.

Depending on the nature of our relationship with you and the services we provide, this may include:

• your name and contact details;
• date of birth and identity information;
• demographic and personal circumstances information;
• employment and professional information;
• income, assets, liabilities and other financial information;
• banking and lending information;
• insurance, underwriting and claims information;
• KiwiSaver and investment-related information;
• mortgage, property and home loan-related information;
• health or medical information where relevant to insurance, claims or related advice;
• government-issued identifiers and records where lawfully required;
• communications with us; and
• any other information reasonably required for the purposes described in this policy.

We only collect personal information that is reasonably necessary for lawful business purposes.

We may collect personal information in a number of ways, including:

1. Directly from you

   We may collect personal information directly from you when you:

   1. contact us or make an enquiry;
   2. book an appointment;
   3. complete forms or provide documents;
   4. engage our services;
   5. provide information for applications, renewals, alterations, claims, lending assessments, KiwiSaver-related transactions, investment-related matters, or other service requests;
   6. lodge a complaint;
   7. apply for employment or contracting opportunities; or
   8. communicate with us by phone, email, online, in person, or through our website.

2. Indirectly from other sources

   Where permitted by law, we may collect personal information from third parties and other sources, including:

   1. insurers and product providers;
   2. KiwiSaver providers and managed investment product providers;
   3. banks, lenders, mortgage aggregators and other credit providers;
   4. referral partners, affiliates and introducers;
   5. your employer, accountant, solicitor, valuer, real estate agent or other professional adviser;
   6. your authorised representatives;
   7. identity verification providers;
   8. credit reporting agencies;
   9. AML/CFT service providers;
   10. public registers and publicly available sources;
   11. government agencies, regulators or official bodies;
   12. medical professionals or other third parties involved in applications or claims; and
   13. any other person or entity authorised by you or otherwise permitted or required by law.

Where we collect personal information about you indirectly, we will do so only where we have a lawful basis to collect that information.

Where required, we will take reasonable steps to ensure that you are made aware of:

• the fact that the information has been collected;
• the purpose of the collection;
• the intended recipients of the information;
• the name and address of the agency collecting and holding the information;
• the law under which the collection is authorised or required, where applicable; and
• your rights to access and request correction of your information,

unless an exception applies under the Privacy Act 2020.

Information collected indirectly may be used and disclosed for the purposes described in this policy, including to relevant insurers, KiwiSaver providers, managed investment product providers, banks, lenders, mortgage aggregators, regulators, auditors, compliance service providers, and other persons authorised by you or permitted or required by law.

Where notice has not already been given in advance, we will provide that notice as soon as reasonably practicable after the information is collected.

We may collect, hold, use and disclose personal information for the following purposes:

• to provide insurance, KiwiSaver, managed investment product, mortgage, home loan, commercial lending, business lending and other related financial advice and services to you;
• to assess your needs, objectives, eligibility and suitability for products and services;
• to prepare, submit and manage insurance applications, policy renewals, alterations and claims;
• to prepare, submit and manage KiwiSaver applications, transfers, changes and related service requests;
• to prepare, submit and manage mortgage, home loan, commercial lending and business lending applications, pre-approvals, approvals, variations, refinancing and related service requests;
• to communicate with you about your enquiries, policies, claims, lending matters, KiwiSaver matters, investment matters and services;
• to verify your identity and undertake due diligence, screening and compliance checks;
• to obtain credit, financial, employment, property, medical or other information reasonably required to assess applications or provide services;
• to comply with our obligations under privacy, financial services, anti-money laundering, and other applicable laws and regulations;
• to manage complaints, disputes and quality assurance processes;
• to maintain client records and support internal administration;
• to train staff and improve service delivery, systems and processes;
• to undertake audit, risk management, legal and compliance reviews;
• to protect our lawful interests, including fraud prevention, investigation and business continuity;
• to send you information about products or services that may be relevant to you, where permitted by law; and
• for any other purpose authorised by you or permitted or required by law.

We may disclose personal information, where reasonably necessary for the purposes described in this policy, to:

• insurers and product providers;
• KiwiSaver providers, scheme administrators and managed investment product providers;
• banks, lenders, mortgage aggregators, finance providers and other credit providers;
• referral partners, affiliates and introducers;
• service providers, contractors and professional advisers who assist us to operate our business;
• auditors, compliance reviewers and legal advisers;
• identity verification providers, credit reporting agencies and AML/CFT providers;
• regulators, government agencies, dispute resolution bodies and law enforcement agencies;
• your employer, authorised representatives, referees, accountants, solicitors, valuers, real estate agents or other advisers, where relevant and lawful;
• third-party technology, hosting, storage, communications and software providers;
• any actual or prospective purchaser, investor, successor or assignee in connection with a proposed business transaction, subject to appropriate confidentiality protections; and
• any other person or entity authorised by you or permitted or required by law.

Some of the service providers, contractors or technology platforms we use may store or process personal information outside New Zealand.

Where personal information is disclosed or made available overseas, we will take reasonable steps to ensure that the information is protected by safeguards comparable to those required under New Zealand law, or otherwise ensure that the disclosure is permitted by law.

We may use third-party platforms and systems to support our operations, including customer relationship management systems, website and email hosting services, secure storage solutions, document management tools, note-taking systems, and approved artificial intelligence or digital productivity tools.

Where we use such providers, we do so for legitimate business purposes and subject to contractual, operational and access controls intended to protect personal information and maintain confidentiality.

When you visit our website, we may collect technical and usage information through cookies and similar technologies. This may include information such as your IP address, browser type, pages visited, device information, and website interaction data.

We may use that information to:

• operate and secure our website;
• understand website usage and improve functionality;
• support analytics and administration; and
• improve user experience.

You can usually manage cookie settings through your browser. Disabling cookies may affect website functionality.

We take reasonable steps to protect personal information against loss, unauthorised access, use, modification, disclosure or other misuse.

These steps may include:

• limiting access to authorised personnel;
• staff training and confidentiality obligations;
• due diligence on service providers and contractors;
• user access controls and authentication measures;
• secure systems and storage arrangements;
• retention and deletion controls; and
• incident response and breach management processes.

While we take reasonable safeguards, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

We retain personal information only for as long as it is reasonably required for the purposes for which it was collected, to comply with legal and regulatory obligations, to resolve disputes, or to enforce our rights and obligations.

When personal information is no longer required, we will take reasonable steps to destroy it or de-identify it.

You may request access to the personal information we hold about you, and you may request correction of that information.

If you make a request, we may need to verify your identity before responding. We will respond in accordance with the Privacy Act 2020.

If we do not agree to make a requested correction, you may ask us to attach a statement of correction to the information.

You are not required to provide personal information to us. However, if you do not provide information that we reasonably require, we may be unable to provide some or all of our services, assess applications, progress claims, verify identity, assess KiwiSaver or investment matters, assess lending matters, or otherwise deal with you effectively

If we become aware of a privacy breach, we will assess and respond to it in accordance with our legal obligations. Where required, this may include containing the breach, investigating what occurred, assessing the likelihood of serious harm, and notifying affected individuals and relevant authorities.

Where permitted by law, we may send you information about products, services or updates that we consider may be relevant to you. You may opt out of receiving marketing communications from us at any time by contacting us directly or using any unsubscribe facility provided.

We may update this Privacy Policy from time to time to reflect changes in our business practices, legal obligations, technology, or regulatory expectations. The updated version will take effect from the date stated in the policy.

If you have any questions about this Privacy Policy, wish to request access to or correction of your personal information, or wish to make a privacy complaint, please contact us:

Eliteinsure Limited
Email: admin@eliteinsure.co.nz
Phone: 0508 123 467
Address: 27C Mauranui Avenue, Epsom, Auckland 1051, New Zealand