Castle Point Privacy Statement and Complaints Policy (website)

Privacy Policy

At PG Funds Limited (trading as Castle Point), we believe an individual’s right to keep their personal information private is highly important. We are committed to protecting and maintaining the privacy, accuracy and security of your personal information.

What information we collect

We will only collect information relevant to our business relationship with you. The information we collect will include (but isn’t limited to):

• Identifying information such as your name, date of birth, mailing address, telephone number and email address.
• If you opt to use electronic identity verification, we will collect a digital record of your face.
• If you contact us, we may keep a copy of the correspondence.
• Details of transactions you carry out with our team or using our technology including the fulfilment of these transactions. This may include bank account information you have provided us.
• Details of your visits to our websites including, but not limited to, traffic data, location data, your IP address, weblogs and other communication data, whether this is required for our own billing purposes or otherwise, and the resources you access.

How we collect your information

We will collect your information directly from you, or through your business relationship and interactions with us. If we use other sources, we will tell you what they are.

How we use your information

We will limit the use of your personal information to:

• Providing you services,
• The carrying out of our business,
• Fulfilling our legal requirements (for example, compliance with anti-money laundering legislation and disclosure to law enforcement agencies or the courts).

Sharing your information

In order to provide our services to you we may share your information with related companies within the Perpetual Guardian Group:

• New Zealand Trustee Services Limited - Level 23, 191 Queen Street, Auckland
• Perpetual Guardian Investments Limited - Level 23, 191 Queen Street, Auckland
• Perpetual Trust Limited - Level 23, 191 Queen Street, Auckland

Or with our partners:

• New Zealand Guardian Trust Limited – Level 6, 191 Queen Street, Auckland
• Apex Investment Administration (NZ) Limited - Level 25, 125 Queen Street, Auckland, 1010
• Verifi Identity Services Limited – Level 2, 22 Queen Street, Auckland CBD

We may be required to share your information with third parties. The situations in which we share this information are detailed below:

• Regulatory bodies and Supervisors to comply with our legal obligations.
• Fraud prevention agencies, and other organisations in order to detect and prevent financial and other crime.
• Suppliers, where necessary for the performance of our products or services.

We may also share your personal information with certain suppliers when we have a legitimate interest to do so, or your explicit consent, as detailed below:

• Data, service and software providers to help improve, develop and maintain our products and website (which may include, for example, customer data modelling or statistical and trend analysis).
• Data, service and software providers to provide you with an interest-based web journey.

We will endeavour to anonymise your data and minimise the amount of your data we share with third parties, where possible. Prior to sharing any of your personal information with these suppliers we will ensure the appropriate contractual, technical and organisational measures are in place to safeguard your personal information. All of our suppliers and partners who we may share your data with are compliant with the New Zealand Privacy Act, or an equivalent international standard. We will not sell or lease your personal information to third parties.

Biometric Information

Some services we provide require identity verification in accordance with the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 and related regulations, codes and guidance. We use Verifi Identity Services Limited to complete electronic identity verification – who uses biometric processing to verify your identity.

If you opt to complete electronic identity verification, we will hold biometric information in the form of a photo of your face (selfie) in accordance with our legal and regulatory requirements. Verifi Identity Services Limited will hold your biometric and personal information for seven days from the completion of your identity verification. Verifi Identity Services Limited may hold some non-identifiable information longer in accordance with their policies.

You do not have to complete electronic identity verification – you may provide us with identity documents in person at any of our branch offices, however we may not be able to provide our services until identity verification has been completed.

You may request a copy of our Proportionality Assessment by writing to us at info@castlepointfunds.com

CCTV

We have CCTV cameras at some of our branch offices in New Zealand. Signage is installed at any branch office where CCTV is in operation, notifying employees and visitors of its operation. The CCTV collects visual images only.

These images may be used by us or the Perpetual Guardian Group in connection with the security of our branches, staff and visitors. CCTV footage may be provided on request (but only in accordance with the Privacy Act 2020) to law enforcement and government bodies, insurers and third parties who may provide us with services from time to time.

CCTV footage is held securely and will generally only be kept for up to 90 days. Access is restricted to a limited number of authorised employees for the purposes set out above.

How long we hold your information

We will not hold your information for longer than is reasonably necessary to provide our services to you, and to ensure we are able to comply with legal, regulatory and accounting requirements.

Some legal and regulatory requirements require your information to be held after our relationship with you has ended.

Your information is secure

Confidentiality is a cornerstone of our service, and safeguarding the privacy of all client information is of paramount importance to us. We will use all reasonable endeavours to ensure that your personal information is kept secure and confidential.

All our staff are contractually bound not to disclose any information regarding the identity or other details of our clients.

You have access to your information

You can access the personal information we hold about you, and you can request corrections. You may not request information that does not relate to you.

You can request access to, or correction of, your information by writing to us at contact@pginvestements.nz or Perpetual Guardian, PO Box 1934, Auckland 1140.

PG Funds Limited adopts the Privacy Principles set out in the Privacy Act 2020. If you are not satisfied with the resolution to a complaint regarding your information or privacy, you have the right to make a formal complaint to the Privacy Commissioner.

More information is available on the Privacy Commissioner’s website www.privacy.org.nz.

Complaints

If something has gone wrong, we would like to work with you to resolve it. Please email us at infor@castpointfunds.comif you have a complaint, along with any documents or correspondence that will help us understand what’s happened. When we receive your complaint, we will:

• Acknowledge your complaint within 1-2 working days
• Gather and evaluate information about your complaint
• Respond to you within 20 working days

External Dispute Resolution If you are not happy with our response, you can contact Financial Services Complaints Limited (FSCL) for independent assistance. FSCL is an independent, not-for-profit, dispute resolution scheme approved by the Minister of Consumer Affairs. FSCL’s service is free, and they will help resolve the complaint. Please note that before the FSCL can review your complaint, it must have gone through the full complaint process and we have given our response.

Phone: 0800 347 257

Email: complaints@fscl.org.nz

Website: www.fscl.org.nz

Mailing address: PO Box 5967, WELLINGTON 6140