Privacy policy

Welcome to Pathfinder Asset Management Limited. In this policy, references to “Pathfinder”, “we”, “us”, and “our” are to Pathfinder Asset Management Limited.

At Pathfinder we care about the privacy of our investors and website visitors and we are always seeking to protect personal information and use it in compliance with applicable privacy laws. This policy describes how we may collect and use personal information provided to us in the course of our business and the rights and choices available to you regarding such information. This could include information collected as part of our Kiwisaver and fund investment services.

References to “you” includes our clients and any other person accessing our services (including our website).

"Personal information” means information about an identifiable individual, as defined in the Privacy Act 2020 (New Zealand) (Privacy Act). This could include your first and last names, email address and other information used to identify you.

We may update this policy from time to time. By continuing to use our services, you agree to be bound by the amended policy. We strongly urge you to read this policy and make sure you fully understand it before you access or use any of our services. You should also check from time to time to see if the policy has changed.

Information collection

We will generally collect personal information directly from you. This could include collecting information from:

  • forms and documents provided by you in relation to our services, including any application forms you provide;
  • your voluntary use of the Pathfinder website (including use of cookies) or any of the online platforms or communications we provide to you; and
  • communications you have with us (including by email or using our online chat, or by phone or in person).

Purpose of collecting information

We may use your personal information:

  • to conduct our normal business (including opening and managing your account) and provide services to you;
  • to verify your identity;
  • to comply with all applicable laws including our anti-money laundering and foreign tax disclosure requirements;
  • to help us manage and enhance our services;
  • to communicate with you, including responding to complaints and distributing our newsletter updates to you;
  • to protect and/or enforce our legal rights and interests, including defending a claim;
  • to market and advertise our services to you, including promoting new or updated material on our website that we think might be relevant to you; and
  • for any other purpose authorised by you or the Privacy Act.

The collection of certain personal information in order for us to provide our services may be required by law, in particular the Financial Markets Conduct Act 2013, Anti-Money Laundering and Countering Financing of Terrorism Act 2009, the Tax Administration Act 1994 and related regulations. If you do not provide personal information requested by us, we may not be able to provide you with our services (including that we may be required to terminate any existing arrangement).

We will never sell or rent your personal information to third parties.

Disclosing your personal information

We may disclose your personal information to:

  • another company within our group;
  • any business that assists us with the purposes above or who performs functions on our behalf in relation to those purposes (such as data storage, IT systems, our investment supervisor, trustee, custodian or any investment administrators);
  • other companies, agencies or individuals that maintain databases against which your identity may be verified including, but not limited to, Waka Kotahi, the New Zealand Department of Internal Affairs, the New Zealand Companies Office, Centrix Group Limited, UK and US Government agencies, credit agencies in New Zealand and overseas, including the UK and the Australian Document Verification System;
  • our advisors, auditors and financiers;
  • a person who can require us to supply your personal information to them under law, including, but not limited to, a regulatory authority;
  • any other person we are authorised to disclose your personal information to under the Privacy Act or any other law, including a law enforcement agency;
  • organisations conducting market research, data processing and statistical analysis for us; and
  • you, or any other person we are authorised by you to disclose your personal information to (including a joint account holder).

Information storage

We work to ensure all personal information we are provided with is held securely and protected from loss or unauthorised use. We will notify you and the Privacy Commissioner, as required in accordance with the terms of the Privacy Act, if we are aware a notifiable privacy breach has occurred.

We may store your information physically or electronically ourselves. Our physical address is Level 37, 15 Customs Street West, Auckland 1010, New Zealand.

We may also store your information with other contracted agencies who assist us with the purposes set out above. We will only provide your personal information to agencies which we believe are subject to the Privacy Act or privacy laws that provide comparable safeguards to those in the Privacy Act. As well as New Zealand, your information may be held offshore in certain jurisdictions including, without limitation, the United States and Australia. Which agencies hold your personal information could depend on the services being accessed by you. If you would like the address of any other agencies which may be holding your personal information, we can provide this on request.

Access to, and correction of, information

You have the right to request:

  • confirmation of whether we hold any personal information about you;
  • access to any personal information we hold about you;
  • us to correct any personal information we hold about you. You can provide us with a statement of correction under the Privacy Act for those purposes.; and
  • us to take reasonable steps to ensure that, having regard to the purposes for which your personal information may lawfully be used, your personal information is accurate, up to date, complete and not misleading. You can provide us with a statement of correction under the Privacy Act for those purposes.

There are some exceptions to this right, set out in the Privacy Act. If you make an access request, we will ask you to verify your identity and specify what information you require.

If you are concerned about how your personal information is being handled or if you would like to make a complaint, please contact us on the details listed on our contact page.

Other online information we collect

If you are accessing our website, we may collect and use additional information to carry out research on our users’ demographics, interests, and behaviour, to better understand and serve you and our other users. This information may include the URL that you just came from (whether this URL is on our site or not), which URL you next go to (whether this URL is on our site or not), what browser you are using, and your IP address. We may collect information on our website using cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. Cookies help us to provide you with a better website experience, and declining cookies may prevent you from taking full advantage of our website.

We may also collect information by tracking your clicks on our website or newsletter including the content you download, the content you access, page response times and the length of your visit to certain pages.

If you post on our LinkedIn, Facebook or any other social media site about us or your experience with us, we may collect that information for the purposes of improving our service and the end user experience.

Links to other websites

Our websites may contain external links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.