Privacy Policy

Harness Financial (we, us, our) complies with the New Zealand Privacy Act 2020 and the Health Information Privacy Code 2020 (together, “the Act”) when dealing with personal information. Personal information is information about an identifiable individual (a natural person). This policy sets out how we will collect, use, disclose, and protect your personal information. Where we collect health information, the Health Information Privacy Code 2020 applies in addition to the Privacy Act 2020.

This policy does not limit or exclude any of your rights under the Act. If you wish to seek further information on the Act, you can contact our Privacy Officer by email at hello@harnessfinancial.co.nz. Or visit www.privacy.org.nz for further information.

We may change this policy by uploading a revised policy onto the website. The change will apply from the date that we upload the revised policy.

Personal information is information about an identifiable individual. It includes (but is not limited to) name, address, contact details, date of birth, occupations, payment details, employment history and/or details, education and qualifications, financial information, testimonials and feedback, evidence of source of funds or source of wealth (in some cases), medical information including medical history and reports or opinions of health professionals, details of claims history including assessments and prior approvals, other insurer and ACC information, voice recordings and transcripts of telephone calls or meetings, and other information.

Where we collect your personal information from someone other than you, we will take reasonable steps to notify you that we have collected your personal information, the purpose of the collection, the intended recipients of the information, the name and address of the agency collecting and holding the information, whether the collection is authorised or required by law and, if so, the law that authorises or requires the collection, and your right to access and request correction of that information, unless an exception applies under the Privacy Act 2020.

● to verify your identity

● to provide services and products to you

● to market our services and products to you, including contacting you electronically (e.g. by call, text, or email for this purpose)

● to improve the services and products that we provide to you

● to respond to communications from you, including a complaint

● to protect and/or enforce our legal rights and interests, including defending any claim

● for any other purpose authorised by you or the Act.

• to comply with legislative or regulatory requirements imposed on us, including requirements under the Financial Markets Conduct Act 2013, the Anti-Money Laundering and Countering Financing of Terrorism Act 2009, and the United States Foreign Account Tax Compliance Act (FATCA), where applicable.

We typically collect your personal information directly from you, for example when you engage with us for financial advice, complete forms, or communicate with us by phone, email, or in person.

We may also collect your personal information indirectly where you have authorised this, or where we are permitted or required to do so by law. This includes collection via our technology platforms (such as HubSpot, Fireflies, Planolitix, and Microsoft 365), through cookies on our website, and via authorised third parties, including:

● product providers, insurers, and KiwiSaver providers;

● medical, health, or rehabilitation providers;

● persons authorised by you such as lawyers, accountants, or other advisers;

● credit information and reporting providers;

● publicly available sources, including the Department of Internal Affairs and New Zealand Transport Agency; and

● social media platforms and internet sources where relevant.

If you are providing us with information about anyone else, please ensure it is accurate and, where practicable, inform them that we are collecting their information.

We may use AI-enabled tools and automated processing to assist in delivering our services and improving our operations. For example, we use Fireflies for AI-assisted meeting and call transcription. Our AI tools may process personal information to support client communications, record-keeping, and service delivery. We ensure that all personal information processed by AI tools is handled securely and in compliance with the Act. If you would prefer that a particular interaction not be recorded or transcribed, please let us know at the start of that interaction.

We may disclose your personal information to:

● Other companies or individuals who assist us in providing services or who perform functions on our behalf (such as mailing houses, hosting and data storage providers, specialist consultants, and legal advisers);

• Technology and planning platforms, including the following, but not limited to:
• Google Business
• Microsoft Office 365
• Front
• Planolitix.com
• HubSpot
• Trail
• Monday.com
• Docusign
• Fireflies
• Mailchimp

● Product providers we work with (such as, but not limited to, investment, KiwiSaver and insurance companies);

● Financial advisers and financial advice providers who may use our services;

● Any third party to whom you have given your consent, such as lawyers, accountants, mortgage brokers, or insurance brokers, is required to provide holistic financial advice;

● Other companies or individuals who perform checks (such as, but not limited to, compliance reviews and audits) that are necessary or desirable under the law on our behalf;

● Other companies, agencies, or individuals that maintain databases against which your identity may be verified, which may include (but are not limited to) the New Zealand Department of Internal Affairs and the New Zealand Transport Agency;

● Social media sites on which we may have a presence;

● Courts, tribunals, and regulatory authorities (such as the Financial Markets Authority and the Ministry of Justice in New Zealand);

● Office of the Ombudsman, where a complaint relates to official information;

● Any person or agency we believe could assist in responding to a serious privacy breach.

● Office of the New Zealand Privacy Commissioner, where a complaint relates to a breach of the Privacy Act 2020;

● Human Rights Commission, where a complaint relates to discrimination;

● CERT NZ, where appropriate, to assist with the management of a voluntarily notified privacy breach

● Overseas privacy regulator, where a complaint relates to the actions of an overseas agency; and

● External dispute resolution schemes of which we are a member;

● Anyone else to whom you authorise us to disclose it.

Except as described above, we will not disclose your personal information without your written or oral consent, unless we are required to do so by applicable law.

We will take reasonable steps to keep your personal information safe from loss, unauthorised activity, or other misuse. Our software is subject to audits to ensure it continues to meet security requirements. All data handled in our software is encrypted in transit and during storage and can only be accessed over secure network connections.

We will only retain personal information as long as it is required for the purposes for which the information may lawfully be used. All data stored online is backed up and can be retrieved in the event of data loss or corruption.

Data will sometimes be held on-premise at Floor 8, 95 Customhouse Quay, Wellington Central, Wellington if it is provided to us outside of our software.

Some of your personal information may be stored or processed overseas, including in Australia and the United States, by third-party providers such as Microsoft, HubSpot, and Planolitix. We will only disclose personal information to overseas recipients where we are satisfied on reasonable grounds that the recipient is subject to privacy laws that provide comparable safeguards to the Privacy Act 2020, or where the recipient is required to protect the information in a way that, overall, provides comparable safeguards. Links to the privacy policies of our key overseas-based providers are set out in the Disclosing your personal information section above.

Subject to certain grounds for refusal set out in the Act, you have the right to access your readily retrievable personal information that we hold and to request a correction to your personal information. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.

In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the personal information, we will make the correction. If we do not make the correction, we will take reasonable steps to note the personal information that you requested the correction.

If you want to exercise either of the above rights, email us at hello@harnessfinancial.co.nz. Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information or the correction that you are requesting)

Our Privacy Officer has processes and systems in place in the unfortunate event of a data breach. If such an event occurs, we will promptly identify, report and examine a personal data breach.

While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.

If you follow a link on our website to another site, the owner of that site will have its own privacy policy relating to your personal information. We suggest you review that site’s privacy policy before you provide personal information.

We use cookies (an alphanumeric identifier that we transfer to your computer’s hard drive so that we can recognise your browser) to monitor your use of the website. You may disable cookies by changing the settings on your browser, although this may mean that you cannot use all of the features of the website.

We use website analytics tools to collect visitor information when you use our website. Each time you visit our website, we may collect information about your visit, which may include the date and time of visits, pages viewed, how you navigate through the site, general location information, and information about the device used (including device type and identifiers). This information helps us understand how to improve our website and services.

If our website uses a chatbot or live chat service, please be aware that information you enter during those interactions may be monitored, recorded, and used to improve our services. We recommend that you do not share sensitive personal information such as bank account details or medical information via any chatbot or online chat function.

We may use information about your use of our websites and other IT systems to prevent unauthorised access or attacks on our software. We may utilise services from one or more third-party suppliers to monitor the use of our systems. These third-party suppliers will have access to monitoring and logging information, as well as information processed on our websites and other IT systems.

We will only send you marketing communications where we have a legitimate basis to do so, such as where you have given us your express consent or where we have an existing relationship with you. If you no longer wish to receive marketing communications from us, you can opt out at any time by clicking the unsubscribe link in any email we send you, or by contacting us directly at hello@harnessfinancial.co.nz or +64 4 384 7113. We will action your request promptly.

If you would like to contact us about this policy, access or correct your personal information, or make a privacy complaint, please contact our Privacy Officer at:

● Email: service@harnessfinancial.co.nz

Phone: +64 4 384 7113

Post: Level 8, 95 Customhouse Quay, Wellington Central, Wellington 6011

We will acknowledge your complaint promptly and aim to resolve it within 20 working days. If you are not satisfied with our response, or if you believe your privacy rights have been breached, you can also contact the Office of the Privacy Commissioner:

• • Phone: 0800 803 909
  • Website: www.privacy.org.nz

The Office of the Privacy Commissioner provides further information regarding your rights under the New Zealand Privacy Act 2020 and the Health Information Privacy Code 2020.