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Irvine-Wenborn Investment Partners Limited, trading as Irvine Wenborn (“Irvine Wenborn”, “we”, “us” or “our”), respects your privacy and is committed to protecting the personal information entrusted to us.

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This Privacy Statement explains how we collect, hold, use and disclose personal information when you engage with us, use our website, receive financial advice or planning services from us, or otherwise interact with our business.

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We handle personal information in accordance with the Privacy Act 2020, including the Information Privacy Principles, and other legal and regulatory requirements that apply to our financial advice business.

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Our office is located at:

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Irvine-Wenborn Investment Partners Limited
575 Springs Road
Prebbleton 7604
New Zealand

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Why we collect personal information

Providing personalised financial advice requires us to understand you, your financial circumstances and what you are trying to achieve.

We collect and use personal information where it is reasonably necessary to:

  • understand your personal circumstances, financial position, needs, objectives and preferences;

  • provide financial planning, investment, retirement planning, wealth management and other financial advice services;

  • provide specialist financial planning services, including advice relating to US expatriates, property divestment and significant life or financial changes;

  • assess the suitability of financial strategies, investments and financial products;

  • implement financial advice and facilitate authorised transactions or instructions;

  • establish, administer and review your relationship with investment platforms, custodians, fund managers, KiwiSaver providers and other relevant financial service providers;

  • communicate with you about your financial plan, investments, services and our ongoing relationship;

  • verify your identity and comply with anti-money laundering, countering financing of terrorism, sanctions, fraud-prevention and other regulatory requirements;

  • maintain records of the financial advice and services we provide;

  • manage complaints, disputes, audits and compliance reviews;

  • operate, administer, protect and improve our business, systems and services;

  • maintain the security and integrity of our information systems;

  • comply with our legal, regulatory and professional obligations; and

  • send newsletters, educational material and other communications where you have requested or agreed to receive them.

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If you choose not to provide information that we reasonably require, we may not be able to provide you with advice or services, implement recommendations, meet our regulatory obligations, or continue providing services to you.

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How we collect personal information directly from you

Where practicable, we collect personal information directly from you.

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This may occur when you:

  • meet or speak with one of our financial advisers or staff;

  • complete a fact find, questionnaire, application, authority or other document;

  • provide financial statements, investment information, tax records or supporting documents;

  • communicate with us by telephone, email, video conference or in person;

  • give us instructions relating to your financial affairs or investments;

  • use our website or online services;

  • complete a website form;

  • subscribe to newsletters or other communications;

  • attend an event, seminar or meeting; or

  • otherwise interact with Irvine Wenborn.

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When we ask you for personal information, we will take reasonable steps to ensure you understand why it is being collected, how it may be used, who may receive it, whether providing it is mandatory or voluntary where relevant, and your rights to access and correct it.

 

 

Information we collect from other people or organisations

Sometimes we need to collect personal information about you from someone other than you. This is known as indirect collection.

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Depending on the services we provide and your circumstances, information may be obtained from sources such as:

  • your accountant, lawyer, tax adviser, trustee or other professional adviser;

  • your spouse, partner, family member, attorney, trustee or authorised representative;

  • a previous or existing financial adviser;

  • investment platforms, custodians, brokers, fund managers and investment providers;

  • KiwiSaver and other retirement savings providers;

  • banks, lenders and other financial institutions;

  • employers, where relevant to the advice or service being provided;

  • identity-verification, AML/CFT, sanctions and politically exposed person screening services;

  • Companies Office and other government or public registers;

  • government departments, regulators or statutory bodies where collection is permitted or required by law;

  • publicly available sources; and

  • other people or organisations where you have authorised the collection or where the Privacy Act or another law permits it.

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We will only collect personal information indirectly where we have a lawful basis for doing so. Click the PDF icon here to view our Indirect Collection Source Schedule.

 

 

What we tell you when we collect information indirectly

Where the Privacy Act requires us to do so, we will take reasonable steps to make sure you are aware:

  • that we have collected personal information about you;

  • why we collected it;

  • the people or organisations that are intended to receive it;

  • that Irvine-Wenborn Investment Partners Limited collected and holds the information, together with our contact details;

  • the particular law that authorises or requires the collection, where applicable; and

  • your rights to access and request correction of your personal information.

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Where we routinely collect particular information from another organisation as part of providing services to you, we may give you this information in advance through this Privacy Statement, our engagement documents, authorities, application forms or other privacy notices.

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If you have already been properly informed of the relevant collection and the circumstances have not materially changed, we may not need to provide the same notification every time information is collected.

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Where you have not previously been made aware of an indirect collection and no exception under the Privacy Act applies, we will take reasonable steps to notify you as soon as reasonably practicable after the information has been collected.

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AML/CFT and identity information

As a financial services business, Irvine Wenborn is subject to legal and regulatory obligations relating to the prevention of money laundering and financing of terrorism.

We may therefore collect or verify personal information using identity-verification services, public registers, government information, sanctions databases, politically exposed person screening services and other lawful sources.

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Where collection is undertaken because of obligations imposed by the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 or other legislation, we will identify the relevant legal requirement where required.

 

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Types of personal information we may collect

The information we need will depend on the nature and scope of the services we provide.

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It may include:

  • Identity and contact information - Your name, date of birth, address, telephone number, email address and other contact information.

  • Identity-verification information - Copies or details of identification documents, proof of address, citizenship or residency information and information required to verify your identity.

  • Tax and residency information - IRD numbers, tax residency, overseas tax residency, tax identification numbers and, where relevant to our services, information relating to US citizenship, residency or other cross-border tax considerations.

  • Family and personal circumstances - Relationship and marital status, dependants, family circumstances, estate-planning information, trusts, powers of attorney and other information relevant to your financial plan.

  • Financial information - Income, expenditure, assets, liabilities, bank accounts, mortgages, loans, property, businesses, trusts, investments, KiwiSaver, retirement savings, pensions, insurance arrangements and other financial interests.

  • Investment information - Existing portfolios and holdings, investment experience, investment objectives, risk preferences, capacity for loss, liquidity requirements, investment time horizon and investment preferences.

  • Financial planning information - Your personal and financial goals, retirement plans, intended expenditure, estate-planning objectives, lifestyle goals and other matters relevant to the advice you seek.

  • Business and employment information - Employment details, remuneration, company interests, business ownership, partnership interests, directorships and other relevant commercial information.

  • Communications and instructions - Emails, correspondence, meeting notes, records of advice, instructions, authorities, complaints and other interactions with us.

  • Website and technical information - Information such as your IP address, browser, device information, website activity, cookies and similar technical information generated when you use our website or digital services.

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We aim to collect only information that is reasonably necessary for a lawful purpose connected with our functions and services.

 

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How we use personal information

We only use personal information for the purpose for which it was collected, or for another purpose permitted by the Privacy Act.

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This includes using your information to prepare and provide financial advice, communicate with you, implement agreed recommendations, administer your relationship with financial service providers, meet our regulatory obligations and maintain appropriate records.

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Before using personal information, we take reasonable steps to ensure that it is accurate, up to date, complete, relevant and not misleading having regard to the purpose for which it will be used.

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Please let us know if your circumstances change or if information we hold about you is no longer accurate.

 

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Sharing and disclosing personal information

We treat personal information as confidential.

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Where necessary to provide agreed services, carry out your instructions or meet our legal obligations, we may disclose information to appropriate third parties.

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These may include:

  • investment platforms, brokers and custodians;

  • fund managers and financial product providers;

  • KiwiSaver and retirement savings providers;

  • banks and other financial institutions;

  • accountants, lawyers, tax advisers, trustees and other professional advisers;

  • identity-verification and AML/CFT service providers;

  • technology, software, data-storage and other outsourced service providers;

  • auditors and independent compliance providers;

  • our professional advisers;

  • regulators and supervisory authorities, including the Financial Markets Authority or other agencies with lawful authority;

  • law-enforcement agencies, courts or government bodies where disclosure is required or permitted by law; and

  • another person or organisation where you have authorised us to disclose your information.

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We do not sell personal information.

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We only disclose information where there is an appropriate legal basis for doing so and we limit disclosure to the information reasonably necessary for the relevant purpose.

 

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Service providers acting on our behalf

We use specialist providers to assist us with functions such as technology, data storage, client management, identity verification, compliance, administration, communications and other business operations.

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Where another provider holds or processes information on our behalf rather than using it for its own purposes, we remain responsible for ensuring appropriate privacy and security arrangements are in place.

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We take reasonable steps when selecting and working with service providers to ensure that personal information is handled securely and consistently with our obligations under the Privacy Act.

 

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Overseas storage and disclosure

Some services, financial institutions, investment platforms, technology providers or other organisations we interact with operate outside New Zealand.

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This is particularly relevant where clients hold overseas investments or require cross-border financial planning services.

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Where we disclose personal information to a person or organisation outside New Zealand, we will comply with the requirements applying to overseas disclosure under the Privacy Act.

This may involve satisfying ourselves that the recipient is subject to the Privacy Act, is subject to comparable privacy protections, or is contractually required to protect the information to a comparable standard.

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Where those safeguards are not available and the law permits us to rely on your authorisation, we will expressly inform you that the overseas recipient may not be required to protect your information in a way that provides safeguards comparable with New Zealand law before obtaining that authorisation.

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Use of an overseas technology or cloud provider solely to store or process information on our behalf may be treated differently under the Privacy Act. Regardless, we take reasonable steps to protect information held or processed for us.

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Protecting your information

We take reasonable safeguards to protect personal information against loss, misuse, unauthorised access, disclosure, alteration and destruction.

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Our safeguards may include physical, technical and administrative security measures such as access controls, authentication, secure systems, data backups, staff confidentiality requirements and controls over third-party service providers.

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Access to personal information is restricted to people who require it for legitimate business purposes.

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While we take reasonable measures to protect information, no method of transmitting or storing information electronically can be guaranteed to be completely secure.

 

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How long we retain personal information

We retain personal information only for as long as we have a lawful purpose for holding it, subject to legal and regulatory record-keeping requirements.

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As a Financial Advice Provider, we are required to retain adequate records relating to our financial advice service for at least seven years.

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Certain records may also be subject to retention requirements under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 and other laws.

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Where information is no longer required for a lawful purpose and is not subject to a continuing retention requirement, we will take reasonable steps to securely destroy, delete or de-identify it.

 

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Website, cookies and analytics

Our website and associated digital services may use cookies and similar technologies.

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Cookies are small files or pieces of information stored on your device that can help websites operate effectively and provide information about how a website is being used.

We may use cookies and analytics information to:

  • operate and secure our website;

  • understand website traffic and usage;

  • identify technical issues;

  • improve the content and usability of our website; and

  • understand which information and services are useful to visitors.

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You can control cookies through your browser settings. Disabling certain cookies may affect the functionality of some parts of the website.

 

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Newsletters and other communications

If you subscribe to our Money Mail newsletter or other marketing or educational communications, we may use your name, email address and relevant communication preferences to send those communications to you.

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You can unsubscribe from marketing emails at any time by using the unsubscribe function included in the message or by contacting us.

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Unsubscribing from marketing communications will not prevent us from sending communications that are reasonably necessary in connection with financial advice or services we provide to you.

 

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Links to other websites

Our website may contain links to websites or services operated by other organisations.

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Once you leave our website, the privacy practices of the other organisation apply. Irvine Wenborn is not responsible for the privacy practices or content of external websites, and we recommend reviewing the privacy statement of the relevant organisation.

 

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Privacy breaches

We have procedures for responding to suspected loss, unauthorised access, disclosure or other breaches involving personal information.

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If a privacy breach has caused, or is likely to cause, serious harm, we will notify the Office of the Privacy Commissioner and affected individuals as soon as practicable where required by the Privacy Act.

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We will also take reasonable steps to contain the breach, minimise potential harm, investigate what occurred and reduce the likelihood of a similar event happening again.

 

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Your right to access your personal information

You have the right to ask whether we hold personal information about you and to request access to that information, subject to the grounds on which information may lawfully be withheld under the Privacy Act.

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If you would like to request access to personal information we hold about you, please contact our Privacy Officer using the details below.

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We may need to confirm your identity before releasing personal information.

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Your right to request correction

You can ask us to correct personal information you believe is inaccurate, incomplete or misleading.

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If we agree that the information should be corrected, we will take reasonable steps to make the correction.

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If we do not agree to make the requested correction, you may ask us to attach a statement of the correction sought to the information so that it is read with the original information where required by the Privacy Act.

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Privacy Officer and enquiries

Irvine Wenborn has a Privacy Officer responsible for overseeing our compliance with the Privacy Act and our handling of personal information.

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For access or correction requests, questions about this Privacy Statement, concerns about how your information has been handled, or other privacy matters, please contact:

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Privacy Officer
Irvine-Wenborn Investment Partners Limited
575 Springs Road
Prebbleton 7604
New Zealand

Email: service@irvinewenborn.co.nz
Phone: 021 670 770

If you are not satisfied with our response to a privacy concern, you may also contact the Office of the Privacy Commissioner of New Zealand.

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Changes to this Privacy Statement

We may update this Privacy Statement from time to time to reflect changes to our services, business practices, technology or legal and regulatory obligations.

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The most current version will be published on our website together with the date it was last updated.

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Where a change materially affects how we collect, use or disclose personal information, we will take reasonable steps to communicate the change where appropriate.

Privacy Policy

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