1.1 Fortland Capital Limited (the Company, we, us and our) is committed to protecting the personal information of all its Website users and customers (Users) in accordance with the Privacy Act 2020 (Privacy Act) and the Information Privacy Principles as set out in the Privacy Act.
1.4 For further information, please see www.privacy.org.nz.
3. Changes to this Policy
4. Collection of Personal Information
4.1 The Company will collect the following personal information:
(a) Any communication with the Company either directly, via phone or email.
(b) Information obtained by or submitted to the Company from the User.
4.2 The Company may supplement the information provided to it with information it receives from third parties.
4.3 We do not collect any other personal information about Users, including details about any User’s race, ethnicity, religious beliefs, sexual orientation, political information or any other genetic or biometric data.
5. Personal Information that may be Collected
5.1 The Company may, in addition to other information, collect the following information about a User:
(a) The User’s name, phone number, residential address and email address.
(c) The User’s gender and date of birth.
(d) Information regarding the User’s investment background, and whether they qualify as a “wholesale investor” as that term is defined in the Financial Markets Conduct Act 2013 (Wholesale Investor).
5.2 If any User chooses not to provide information when we ask for it, they may not be able to engage with the Company further.
6. Use of Personal Information
6.1 The information that Users provide to the Company may be used (without limitation):
(a) to verify the identity of the User;
(e) to assess whether or not the User qualifies as a Wholesale Investor;
(f) to communicate with Users (including by electronic means);
(g) to undertake credit checks of any User (if necessary);
(h) to respond to communications from a User;
(i) to co-operate with any government, industry or regulatory authorities;
(j) to protect and/or enforce our legal rights and interests, including defending any claim; or
(k) for any other purpose authorised by a User, the Privacy Act and/or GDPR.
6.2 The Company reserves the right to use data (on a strictly anonymous basis) for marketing and accounting purposes.
6.3 Users may request the Company to stop sending marketing messages at any time, by contacting the Company on [email protected].
7. Privacy Officer
7.1 The Company shall at all times have a person appointed as the “Privacy Officer” of the Company (the Privacy Officer).
7.3 The Privacy Officer may be contacted at [email protected].
9. Disclosure of Personal Information
10. Protection and Retention of Personal Information
11. Legal Rights and Access to Personal Information
11.1 Users have the following rights in relation to their personal information:
(a) To request access to their personal information.
(l) To request a correction to their personal information.
(m) To request the deletion or removal of their personal information.
(n) To object to the processing of their personal information.
(o) To request a restriction on the processing of their personal information.
(p) To request a transfer or their personal information to you or a third party.
(q) To withdraw consent to the use of their personal information.
11.2 If at any time a User wishes
12. Data Processing Agreement