Privacy Policy

Privacy Policy
Crown Financial Services Limited (we, us, our) is an institution offering financial services.  We comply with the New Zealand Privacy Act 1993 and the Australian Privacy Act 1988 and the Privacy Principles of each Privacy Act (collectively, Privacy Laws), when dealing with personal information.

This policy sets out how we collect, use, disclose and protect your personal information and does not limit or exclude any of your rights under Privacy Laws.  Further information on Privacy Laws can also be accessed via www.privacy.org.nz  or www.oaic.qov.au

By using our websites, applications and services, or otherwise providing us with your personal information, you consent to us collecting, holding, using and disclosing your personal information as set out in this Policy.

What does Personal Information mean?
Personal Information is any information about an identifiable individual (a natural person) whose identity can be reasonably determined.  (You and your) refers to the person accessing or using our website.

Updates to this Policy
This Policy may be reviewed from time to time to reflect news laws, changes to our operations and any change in our business environment.  The changes will apply from the date that we upload the revised policy.

Why do we collect personal information?
The personal information you provide to us (whether on our website or in an application form for Crown or elsewhere) will be collected and held by Crown Financial Services Limited or any of its subsidiaries or related entities (together, the Crown Group), and any of the Crown Group’s employees, contractors, advisers, and agents including Crown Private Limited, Make-It Fund Operating Manager L.P., Clearing House Limited and Cybercom Hospitality Solutions Limited, for the following purposes (as applicable):

    • processing and responding to your web queries
    • the provision of our financial products and services to you
    • administration, marketing, operation, security and management of Funds
    • 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 website and the services we provide
    • targeting our advertising or marketing and letting you know about new features and services we offer
    • evaluation and improvement to our client service
    • managing our relationship with you, and exercising and enforcing our rights under the terms of use for our websites.

To whom do we disclose your personal information?
Your personal information may be disclosed to, and held and used by, the following entities:

    • Crown Financial Services Limited or any of its subsidiaries or related entities (together, the Crown Group), and any of the Crown Group’s employees, contractors, advisers, and agents.
    • Any third party, whether in New Zealand, Australia or elsewhere, that provides services to the Crown Group (note that if you are an Australian or New Zealand investor and have opted for Electronic Identity Verification in connection with an application, 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 Crown Group takes reasonable steps to ensure the third party does not breach the Privacy Principles.
    • Other bodies such as government agencies, regulators, and legal and professional advisers.
    • Any other person or entity where it is relevant to do so for the purposes set out above.

We may also release personal information where we believe this is appropriate for legal compliance and law enforcement (including to government agencies with statutory law enforcement responsibilities), or to assist with court proceedings, enforce or apply our terms of use, or protect ourselves, our website users or clients, and others.

We can also disclose personal information to third parties as instructed by you and in other ways permitted by the Privacy Laws and Principles.

Your personal information may also be used by, and you consent to the use of your personal information by, any Crown Group member to keep you informed about other financial opportunities, products and services of any Crown Group member, including by email, by text message, by Crown Group’s online portals (if any) 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.

Linked sites
Our website may contain links to other linked websites.  We are not responsible for the privacy policies of such linked websites.  This privacy policy applies solely to information collected on our website by us.

Cookies and similar technologies
We, and our third party service providers may use cookies, web beacons and other storage technologies when you are on our website. Cookies are small blocks of text stored on your device. They allow us and our third party service providers to recognise your device, and collect and receive information about you from our platform and elsewhere on the internet. Cookies, web beacons and other storage technologies may be used for security to help us identify your browser, to provide you with personalised features, to provide measurement services and target ads, and for tracking traffic on our platform.

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 website or its integration with Facebook unless you accept cookies.

For further information on how to opt out of cookies or similar technologies, see,  http://www.networkadvertising.org and http://www.aboutads.info/choices

How do we hold personal information?
We will take all reasonable steps to keep your personal information safe from loss, unauthorised activity or other misuse.

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:

    • unauthorised access or disclosure of personal information, and
    • information that is lost in circumstances where unauthorised access or disclosure of personal information has occurred, in each case where the breach is likely to result in serious harm to one or more individuals and Crown 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.

Ensuring your personal information is up-to-date and accessing your personal information
We rely on the personal information we hold about you to efficiently conduct our business of providing financial products and services so use all reasonable endeavours to ensure that the personal information is accurate, complete and up-to-date.  So we encourage you to contact us to correct any personal information we hold about you.

You have the right to correct any personal information we hold about you in accordance with Privacy Act laws and Principles.  However, this is subject to exceptions set out in Privacy Act laws and Principles and this can be done by contacting us by email info@crownfinancial.co.nz or phone +64 9 973 5888.

During this process, we will require you to verify your identity and to specify what information you require.  You may be charged a fee for providing access.  If a fee is to be charged, we will inform you of the likely cost in advance.

What happens if personal information is not provided?
If we are not able to collect, handle, use and disclose personal information about you as set out in this Policy, we may not be able to provide you with our services or with access to our websites or applications which may adversely affect our ability to respond to you or supply the relevant service or to perform our obligation to you.

What do you need to do if you have a complaint?
If you have any questions about privacy related issues or wish to complain about the handling of your personal information by us, please contact us using the contact details below.  We may ask you to lodge your complaint.

Your complaint will be investigated by our Managing Partner or General Counsel and you will be notified of the decision relating to your complaint as soon as practicable after it is made, usually within 30 working days.

If you are unable to satisfactorily resolve your concerns about our handling of your personal information, you can either contact us or you can contact the Office of the Privacy Commisioner via www.privacy.org.nz or the Australian Privacy Commissioner via www.oaic.qov.au .

 Contact Details
If calling from Australia or New Zealand: +64 9 973 5888 or by email info@crownfinancial.co.nz

Application of European privacy laws
If you are an individual in a country in the European Economic Area (EEA), we may be required to comply with the EU General Data Protection Regulation 2016/679 (the GDPR) which applies to us when processing the personal information of individuals (Data Subjects) who are in countries in the EEA in relation to offering you our products or services or if we monitor any of your behaviour when in those countries. This includes additional information we are required to tell you about in relation to your privacy, including the basis on which we collect your personal information and your data subject rights under the GDPR.

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