Your privacy is important to us. This Privacy Policy outlines how PPS Mutual Limited (we / us / our) collects, uses, stores, discloses and processes your personal information in accordance with the Privacy Act 2020.
Below is a summary of our approach to managing your personal information:
- We collect personal information directly from you, and from third parties, where permitted by law or with your consent.
- We generally only collect personal information that we require to manage our relationship with you and we retain that personal information for as long as necessary, or as required by law. From time to time, we may share your personal information with third parties with your consent, or if required by law.
- We store your personal information securely in New Zealand and overseas with our cloud-based data storage providers, subject to appropriate safeguards. We take all reasonable steps to ensure that it is safe.
- We use cookies and other tracking technologies to improve our services, to provide targeted marketing, and to enhance your experience with us.
- You can contact us about the personal information that we hold about you, request a copy or correction of that personal information or make a privacy-related complaint by emailing us at [email protected].
As we interact with you, we may tell you more about how we handle your personal information. Please review any additional privacy information we give you carefully.
The information we collect
To manage our relationship with you, we need to collect personal information about you. Initially, for prospective customers and expressions of interest from advisers, we only collect your name and email address. When onboarding advisers, the personal information we collect about you may include:
- Additional contact details – e.g. your phone number or postal address.
- Information about your identity – e.g. your date of birth.
- Business information – e.g. your nominated bank account for payments.
- Background information – e.g. information about your professional history.
- Your feedback.
We may collect this information directly from you when you interact with us and, when onboarding advisers, from the adviser company that holds the market services licence under which you are authorised to provide financial advice. We may also collect personal information from third parties, where permitted by law.
There might also be times when we need to collect personal information about another person (e.g. your support staff). You should only provide us with this personal information when you’re authorised to do so. It is your right not to provide us with your personal information, but this may affect the business relationship that we can maintain with you.
Using your information
Depending on your relationship with us, we may use your personal information in some of the following ways:
- To confirm your identity.
- To give you information about our products, services and distribution opportunities, including where you submit an expression of interest over our website.
- To provide you with a Distribution Agreement and assess and process your onboarding request.
- To respond to your questions, requests, instructions, feedback, and complaints.
- To manage our relationship with you.
- To manage or assess your insurance claims.
- To calculate and process commission payments.
- To perform business activities – e.g. to perform statistical or actuarial investigations, risk management activities, etc.
- To improve our products and services.
- To comply with regulatory and legal obligations (including any obligations we may have under laws outside New Zealand), e.g. responding to requests from regulators and complying with applicable financial crime and taxation laws.
- To prevent, detect and investigate fraud and financial crimes, which may involve us disclosing your personal information to a government agency, regulator, or law enforcement to assist with investigating suspected illegal activity.
Disclosing your information
We may share your personal information with third parties who provide services that help us to operate our business to perform certain business functions or where required by law. We will not disclose your personal information except where authorised by you, or where disclosure is made:
- To our related entities where required for reporting or governance purposes.
- To regulators and other public authorities such as courts, law enforcement and tax authorities where required by law.
- In connection with services performed for us by our suppliers and service providers, including service providers that help us gather and analyse your feedback – for example, to conduct adviser experience surveys.
- To reinsurers, other insurance companies, banks and financial institutions that are involved in providing our services to you.
- To any third party where necessary to prevent a threat to health, security or safety.
Storing and protecting your information
Most of the personal information that we keep or provide to third parties to keep, is securely store by third party cloud-based data storage providers based in New Zealand and overseas – such as Microsoft Azure or Amazon Web Services.
We choose our providers carefully and only work with companies that have appropriate information retention and security policies and that we believe will keep your personal information safe. Communications over the internet are not secure unless they have been encrypted. When it is necessary to send personal information over the internet, we use secure methods to do so. We may also use third parties to monitor our technology for security and information assurance purposes.
We take reasonable steps to protect the security of your personal information from unauthorised access, disclosure or loss. However, in the current cyber-risk environment, we do not warrant its security.
Use of Artificial intelligence (AI)
All decisions made in connection with our business are made by a person – either directly or through process automation using business logic defined by a person. We may use generative AI tools, such as predictive learning models, to support our staff to perform such activities.
We may use data that you disclose through our AI tools, ensuring that no personal information is incorporated into the AI training data set. These tools may not be used by the AI developer or any other third party to access your personal information or to incorporate your personal information into its AI model training set data. We may use data that you disclose to train our own AI models provided that such data does not contain any personal information about you.
Accessing your personal information
You have the right to request access to, and correction of, the personal information we hold about you. In your request, please make clear what information you would like to access or have corrected. The law contains exceptions to some requests and if we decide not to grant your request under one of these exemptions, we will let you know why.
It is not usually our policy to charge for these requests. However, while most questions and issues can be handled quickly, complex or difficult requests may take more time. In such cases, you will be contacted and provided with an explanation of the likely charges for processing your request.
Cookies and tracking
A cookie is a small text file placed on your device by a website to capture information about your visit to the website. We use cookies and other tracking technologies to improve our services, to provide targeted marketing, and to enhance your experience with us.
The information collected by cookies may or may not identify you personally. The cookies we use collect information about how you have used our website and the pages you have visited. Cookies can also let you set preferences. Where cookies or other tracking technology we use collects or generates personal information, that personal information will be handled in accordance with this Privacy Policy.
We also use tracking cookies and technology which can identify if your device has visited our website before and which pages or areas of the website you have visited and how often. This technology may also be used for targeted advertising.
You can adjust the settings on your browser to notify you of when a cookie is offered, and to disable or block cookies. If you disable or block cookies some sections of our website may not work or may not work as intended. Some tracking technology may still work even if the cookies are blocked or disabled.
The personal information captured by cookies and other tracking technology we use will be processed by the provider of the technology, in accordance with their own privacy policies. You are responsible for reviewing any third-party website policies for personal information collected via that technology.
Complaints
If you have a privacy-related complaint regarding our use, disclosure and storage of your information in accordance with the Privacy Act 2020 and/or our Privacy Policy, you should first contact us. We will investigate and attempt to resolve your complaint regarding use and disclosure of your information. If you’re not satisfied with the resolution of your complaint, you can contact the Office of the Privacy Commissioner.
Contact Us
If you no longer want us to provide you with information about our products and services, or you want to make a privacy-related request, you can let us know by contacting us at [email protected].
Changes to this Privacy Policy
We may update this Privacy Policy by posting changes to our website. These changes take effect from the date that they are posted.