1. Introduction

1.1 Craigmore is committed to protecting and respecting your privacy and complying with applicable privacy laws.

1.2 This is the New Zealand Privacy Policy of Craigmore (Policy). This Policy, together with any other policies which cover personal information, sets out how and what personal information is collected, used, stored, and disclosed in relation to a third party’s relationship with Craigmore.

1.3 This Policy has been designed to enable Craigmore to explain how it deals with personal information and how this information is stored or accessed. The procedure is based on a system of holding information that is required by applicable New Zealand law.

1.4 The business group headed by Craigmore Sustainables Group LP includes a United Kingdom registered limited liability partnership, Craigmore Sustainables LLP (CSLLP). CSLLP maintains its own privacy policy consistent with the regulatory regime applicable to that country and the business environment in which it operates.

1.5 This Policy may change from time to time. References to ‘we’, ‘us’, and ‘our’ in this Policy mean Craigmore and are deemed to include references to our employees, contractors, officers, directors, agents or delegates, where applicable.

2. Definitions

2.1 In this Policy, the following terms have the following meanings:

    1. Craigmore means Craigmore Sustainables Group LP and all New Zealand entities majority owned, managed or controlled by it.
    2. Personal Information means information about an identifiable individual, as defined in the Privacy Act.
    3. Privacy Act means the New Zealand Privacy Act 2020.

3. What Personal Information do we collect?

3.1 We may collect and process Personal Information such as an individual’s:

    1. full legal name,
    2. date of birth,
    3. driver’s licence number,
    4. passport number,
    5. relationship status,
    6. postal or residential address,
    7. email address,
    8. telephone number,
    9. nationality,
    10. income,
    11. bank account details,
    12. taxation details;
    13. accounting and financial information relating to a person’s involvement in a Craigmore investment;
    14. accounting and financial information relating to a Craigmore investment; and
    15. employment history.

3.2 We collect Personal Information for the purposes set out in clause 5 (Purposes of collection)

4. How we collect the Personal Information

4.1 The Personal Information that we collect may be collected through various means, including through forms that are completed by individuals or in other communication with Craigmore such as by phone, email or post.

4.2 Personal Information is collected in several circumstances including:

    1. Prospective employment or contract for services; and
    2. Investment due diligence.

4.3 Through your use of a Craigmore website and or forms, we may collect information from one individual about another individual. If you provide Craigmore with Personal Information about someone else, you must make sure that you are authorised to disclose that information to Craigmore and that, without Craigmore taking any further steps required by applicable data protection or privacy laws, we may collect, use, store and disclose such information for the purposes described in this Policy.

4.4 With reference to the above clause 4.3, you must take reasonable steps to ensure the individual concerned is aware of and/or consents to the various matters detailed in this Policy, including the fact that their Personal Information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual’s right to obtain access to that information, our identity, and how to contact us.

4.5 Where requested to do so by us, you agree to assist Craigmore with any requests by the individual to access or update the Personal Information you have collected from them and provided to us.

5. Purposes of collection

5.1 The purposes for which Personal Information may be used by Craigmore inside and outside New Zealand include:

    1. as required by law, such as in connection with our obligations under know-your-client (KYC), anti-money laundering and countering financing of terrorism (AML/CFT) and Inland Revenue (IRD) regulation;
    2. in connection with the operation of our business, including processing of applications, redemptions, transfers, deposits, payments, generating reports, buying and selling assets and agricultural produce and commodities and record keeping of investment portfolios;
    3. carrying out our obligations arising from any contracts entered into between you and us;
    4. for statistical and research purposes (on an anonymised basis);
    5. providing you with alerts, newsletters or information that you requested or signed up to;
    6. complying with laws and regulations applicable to Craigmore or any of our related entities in or outside New Zealand;
    7. legal proceedings, including collecting overdue amounts and seeking professional advice;
    8. researching, designing and launching services or products including seminars/events/forums;
    9. promoting and marketing services and products (subject to your exercise of the opt-out right in relation to receiving commercial electronic messages);
    10. purposes directly related or incidental to the above; or
    11. for any other purpose authorised by you or permitted by law.

6. Disclosure of the Personal Information

6.1 We will only disclose your Personal Information in accordance with this Policy and the Privacy Act.

6.2 We may provide Personal Information to third parties where necessary or appropriate to facilitate the purpose for which information was collected pursuant to this Policy.

6.3 We may disclose your Personal Information to Government entities and other external data providers that hold information about you in order to verify that the information provided by you is consistent with the records held by such entities for the purpose of complying with our KYC, AML/CFT and IRD obligations.

6.4 We may disclose Personal Information where we are required to do so by law, court order, subpoena or other legal process, including investigation by tax authorities or law enforcement authority. Where possible and appropriate, we will notify you if we are required by law to disclose your Personal Information.

6.5 We will not otherwise disclose your Personal Information to a third party unless you have provided your consent.

6.6 Personal Information may be disclosed between Craigmore’s related entities and our personnel and those of our agents or delegates. Those related companies, personnel, agents and delegates will treat and handle such Personal Information in a manner consistent with this Policy and applicable laws.

7. Security and protection of the Personal Information

7.1 We store Personal Information that is in electronic form on secure servers or devices.

7.2 We may provide your Personal Information to third parties contracted by us in order to perform data storage and data processing services on our behalf. We will take all reasonable steps to ensure that these third parties comply with our instructions and do not use your Personal Information for any other purpose.

7.3 Unfortunately, the transmission of information via the internet is not completely secure. Once we have received your Personal Information, we will use all reasonable procedures and security features to try to protect your Personal Information from misuse, loss, disclosure, and unauthorised access. However, by providing us with your Personal Information over the internet you acknowledge that the provision of that information is at your own risk, and that we cannot guarantee the security of such Personal Information.

8. Where we store the Personal Information

8.1 The intended recipient of your Personal Information is Craigmore.

8.2 We may store your Personal Information on servers and services both within New Zealand and offshore (including third party cloud-based services and storage).

8.3 We may access and use that Personal Information in and outside New Zealand.

9. Retaining the Personal Information

9.1 We only retain Personal Information for so long as it is necessary for the purposes for which the information can lawfully be used, including if Craigmore is required to obtain such Personal Information by applicable laws such as obligations under KYC, AML/CFT and IRD regulations.

10. Your consent and rights

10.1 By providing Personal Information to Craigmore, you consent to the collection, storage, use, and disclosure of your Personal Information as outlined in this Policy.

10.2 Under the Privacy Act, you have the right:

    1. to check whether Craigmore holds their Personal Information and to request access the Personal Information held by Craigmore; and
    2. to request Craigmore to correct as soon as reasonably practicable any Personal Information relating to them that is inaccurate.

10.3 It is your responsibility to let us know if the Personal Information which we hold about you needs to be corrected or updated.

10.4 In accordance with the Privacy Act, Craigmore has the right to and may charge a reasonable fee for processing or responding to any request to access or correct Personal Information.

11. Role and responsibilities

11.1 The Craigmore Privacy Officer is Craigmore’s nominated Privacy Officer and is responsible for this Policy.

11.2 The Policy will be reviewed annually or more frequently should circumstances require it.

12. Contacting us and complaints process

12.1 If you have any questions about the privacy or security of your Personal Information, would like to request access to or correction of your Personal Information, or if you have a concern about a breach of privacy or a privacy complaint, please contact the Privacy Officer via email privacy.officer@craigmore.com.

12.2 Craigmore will deal with any privacy complaint(s) by investigating the complaint(s) and providing a response to the complainant within 20 working days, provided that we have all necessary information and have completed any investigation required. In cases where further information, assessment or investigation is required, Craigmore will seek to agree alternative time frames with you.