Milford is bound by and adheres to the New Zealand Privacy Act 2020 for personal information to which that Act relates and the Australian Privacy Act 1988 for personal information to which that Act relates (each, the Privacy Act) and the Privacy Principles of each Privacy Act. These Principles govern how we collect, use, hold and disclose your personal information.
We can change this policy from time to time. The updated policy will be available on our website and client portal (each, a platform). It’s up to you to check for any changes. By continuing to use the platform you are considered to have accepted any updated policy.
Why do we collect personal information?
The personal information you provide to us (whether on our platform or in an application form for a Milford Fund or elsewhere) will be collected and held by Milford Asset Management Limited and its subsidiaries, including Milford Funds Limited, Milford Private Wealth Limited, Milford Australia Pty Ltd and Milford Private Equity Limited, for the following purposes:
- processing and responding to your web enquiry
- administration, marketing, operation, security and management of the Funds
- the provision of our financial products and services to you
- the provision of financial advice
- compliance with any laws, rules and regulations whether in New Zealand, Australia or in any other country
- to understand our users preferences and interests
- for internal research, development, and optimisation of our platforms and the services we provide
- targeting our advertising, and letting you know about new features and services we offer
- evaluating and improving our client service
Who do we disclose your personal information to?
Your personal information may be disclosed to, and held and used by, the following persons:
− Milford Asset Management Limited or any of its subsidiaries or related entities (together, the Milford Group), and any of the Milford Group’s employees, contractors, advisers, and agents.
− Any third party, whether in New Zealand, Australia or elsewhere, that provides services to the Milford Group (note that if you are a New Zealand investor and have opted for electronic identity verification in connection with an application for any Milford Fund, your information will be shared with external agencies who may use a credit file header database to verify your address (note, however, this is not a credit check)). The Milford Group takes reasonable steps to ensure the third party does not breach the Privacy Principles.
− Other bodies such as government agencies (including the FMA and ASIC), regulators, and legal and professional advisers (whether or not we are legally obliged to disclose).
− Any other person or entity where it is relevant to do so for the purposes set out above.
We can also disclose personal information to third parties as instructed and/or authorised by you and in other ways permitted by the Privacy Act and Principles.
Your personal information may also be used by, and you consent to the use of your personal information by, any Milford Group member to keep you informed about other financial opportunities, products and services of any Milford Group member, including by email, by text message, by Milford Group’s online portal or by any other electronic means. Any electronic communication offering other financial opportunities, products or services will include an unsubscribe facility.
How do we collect personal information?
We collect most personal information directly from you. Sometimes we may (and you authorise us to) collect personal information about you from other people. We may also collect information about you from publicly available sources of information.
When you are dealing with Milford by telephone or live web or video chat service, your conversation may be recorded for training or verification purposes.
Cookies and similar technologies
We may share information collected through cookies (or similar technologies) with third parties (who may also use that information for ad targeting and the other purposes described above).
Opting out of cookies
You can prevent new cookies from being installed and delete existing cookies. The procedure depends on which browser you are using. For information on how to remove cookies, check your internet browser. You may be unable to make full use of our platform or its integration with Facebook unless you accept cookies.
How do we hold personal information?
The personal information we hold will be stored securely by us or our service providers, whether electronically or otherwise. We use a range of security measures to protect the personal information we hold.
What do we do if there has been a breach of your personal information?
If there has been an eligible breach of your personal information, we will respond to actual or potential data breaches quickly through our notification processes. Eligible breaches include (i) unauthorised access or disclosure of personal information, and (ii) information that is lost in circumstances where unauthorised access or disclosure of personal information has occurred, in each case where the breach has or is likely to result in serious harm to one or more individuals and Milford has not been able to prevent the likely risk of serious harm with remedial actions.
If we believe there has been an eligible breach, then affected individuals and the regulator will be notified to ensure that your personal information is protected.
How can you access and correct your personal information?
You have rights under the relevant Privacy Act and Principles to find out what personal information we hold about you, get a copy of and to request correction to the personal information you have supplied, by contacting Milford on the Contact Details below. Any update to your personal information may be used to update other information held about you by any member of the Milford Group.
What happens if personal information is not provided?
If you do not provide the personal information we request, we may not be able to respond to your enquiry or provide you with the full range of products and services we offer.
What do you need to do if you have a complaint?
We will refer your complaint to our Head of Risk & Compliance & General Counsel who will investigate the issue and determine the steps (if any) that we will undertake to resolve your complaint. We will contact you if we require any additional information from you and will notify you in writing of the outcome of the investigation. We will aim to respond to and notify you of the outcome of our investigation regarding the privacy complaint within 30 days of receiving the complaint.
If you are not satisfied with our determination, you can contact us to discuss your concerns or make a complaint to the New Zealand Privacy Office via www.privacy.org.nz or the Australian Privacy Commissioner via www.oaic.qov.au .
If calling from New Zealand: 0800 662 345
If calling from Australia: +1800 161 310
By emailing us at [email protected]