Privacy Policy
Our commitment to your privacy
Midlands Funds Management Limited and its related companies and affiliates (“we”, “us”, “our”) are committed to respecting your right to privacy and your right to view and update the Personal Information which we hold about you.
We will always collect, store, use and disclose your Personal Information in accordance with the Privacy Act 2020 “Privacy Act”.
However, we have also put in place the following Privacy Policy to protect your Personal Information when you submit, or we collect, that information – including via our online services such as (“Online Services“):
- information offered on, and provided by our Website (“Website“);
- social media pages including but not limited to Facebook, Instagram and LinkedIn; and
- email communications and subscription services.
By providing us with Personal Information, you consent to the collection, storage, use and disclose of Personal Information in accordance with this Privacy Policy.
In this policy, “Personal Information” means information about an identifiable individual. By way of example, this type of information includes your name and contact details.
What information do we collect?
Information you provide
You may give us information about yourself, such as your name, address, email address and telephone numbers – for example, when you request information through our Online Services (such as requesting policy information or requesting that an adviser contact you), or provide your Personal Information in order for us to take action on your behalf (such as requesting a change of address). If you do not provide this information, we may not be able to provide our goods or services to you.
Information collected about you
We gather various information about customers and users of our Online Services. This information includes:
- the address of your Internet service provider;
- information collected by us through click-tracking in relation to your use of the Website, including the content you upload and the content you access;
- aggregated data, which tracks traffic to the Website; and
- cookies, which are pieces of information transferred to your computer hard drive for record keeping (such as your preferences on our Website).
Information collected from third parties
Information may be collected about you from third parties (including our third party affiliates or partner companies and from marketing or advertising companies) who may provide us with such information as a part of their relationship with us. We may combine this information with other information that we hold.
Third party service providers may be allowed to use technologies including mobile monitoring and tracking technologies in relation to our Online Services. These third party service providers may collect information sent by your browser or mobile device.
Additional information may be collected about you when you use our Online Services, or when we record your telephone conversation(s) with our operations centre.
How is your Personal Information used?We may (and may authorise third parties to) use your Personal Information to process your transactions and to help us develop, improve, manage, administer and facilitate our services and operations – including to provide the Online Services, to help us to develop our Online Services to be more available and user friendly to our customers, to administer your account, for safety and security issues, for our own internal purposes (such as risk management, staff training and billing), to conduct market research, for employment opportunities within and outside of our organisation, for any purpose permitted by law, and for any other use associated with such purposes or which you may authorise.
In addition, we may use your Personal Information to promote and market our products and services, or the products and services of others. However, we will not do this by email or text (except as part of an email which facilitates, completes or confirms a transaction with you) unless we have your express or deemed consent to do so. These emails and texts will always include an “unsubscribe” facility (see below for more information on email and text communications).
Disclosing your Personal Information
We will not sell, rent or share your Personal Information to any third party. We do however share your information with revenue authorities and the Financial Markets Authority as required by law.
If you are a looking to borrow from us, we will request your specific authority to carry out relevant credit checks.
We may also use other companies and individuals to perform services on our behalf, such as delivering packages, sending mail and emails and processing payments. They will have access to your Personal Information needed to perform these services, but we will not authorise them to use your information for other purposes.
These organisations will only use your Personal Information in accordance with the Privacy Act, and we will not authorise them to share or on-sell any information that they hold on behalf of Midlands Mortgage Trust.
When we disclose your Personal Information to overseas recipients, we ensure that the recipients of your Personal Information are required to protect it in a way that overall provides comparable safeguards to those in the Privacy Act.
We will not otherwise disclose your Personal Information unless we believe on reasonable grounds that you have provided your authorisation. However, you should be aware that we may be required to disclose your Personal Information without your consent in order to comply with any court orders, subpoenas or other legal process or investigation including by tax authorities, if such disclosure is required by law. Where possible and appropriate, we will notify you if we are required by law to disclose your Personal Information.
Email newsletters and other notices
We are committed to full compliance with the Unsolicited Electronic Messages Act 2007.
It is our policy to send emails to all Midlands Funds Management clients to keep them updated with information that we believe is relevant to them. In addition, we may send out promotional material to you regarding new or amended material on our site where we think it may be relevant to you.
It is our policy to immediately remove any person from any mailing list upon the person’s request. You can unsubscribe from our email communications and/or text communications at any time by clicking the “Unsubscribe” link in any promotional or marketing email or text received or by emailing us at: investments@midlands.net.nz
Once you have unsubscribed from the email or text communications, you will be removed from the corresponding marketing list as soon as is reasonably practicable.
Cookies
Cookies are small pieces of information that are stored on your computer’s hard drive when you use our Website. Cookies help us provide you with a better Website, by enabling us to monitor which pages you find useful and which you do not. This helps us analyse data about web page traffic and improve our Website to tailor it to our customers’ needs. A cookie does not give us access to your computer or any information about you other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, if you do this it may prevent you from taking full advantage of our Website.
Third party cookies and other technologies: we use third party cookies and other technologies for marketing purposes and to gather Website analytics. This includes:
- Remarketing: we use third party cookies – such as Google Analytics cookies – to keep track of the reports or pages you’re interested in and remarket them to you when you leave our site (as a result, you may see ads from Midlands Funds Management when you visit other websites).
- Impression reporting: we use web beacons to estimate the number of users that have viewed and clicked on our pages or promotions, and as a result we’re able to gauge the success of a campaign.
- Demographics and interest reporting: we use cookies and web beacons to get an overview of our readership broken down by age, gender and interests, and as a result we can provide you with relevant information, services, and features, plus gauge the popularity of our content.
You can opt out of Google Analytics without affecting how you visit our site. For more information on opting out of being tracked by Google Analytics please visit this page.
Other information we collect
We collect and use additional information to carry out internal research on our users’ demographics, interests, and behaviour to better understand and serve you and our community. This information may include the URL that you just came from (whether this URL is on our Website or not), which URL you next go to (whether this URL is on our Website or not), what browser you are using, and your IP address.
If you post on our Website, on Twitter or Facebook or other social media site about us or your experience with us, we may collect that information for the purposes of improving our service and the end user experience.
If we want to use any messages or comments you provide to us in any promotional or campaign material, we will get your permission before copying or quoting your message or comment.
Security / Storage
We are committed to protecting the security of your Personal Information and we take reasonable precautions to prevent loss, unauthorised access, modification, disclosure or other misuse of it.
We have put in place suitable physical, electronic, and managerial procedures to safeguard the security, privacy, confidentiality and integrity of your Personal Information.
We will only keep your Personal Information for as long as we require it for the purpose for which it was required. However, we may also be required to keep some of your Personal Information for specified periods of time, for example under certain laws relating to companies, money laundering and financial reporting legislation.
Privacy Breaches
If a sufficiently serious privacy breach occurs, we may be required to notify you (if you are an affected individual) and the Privacy Commissioner about that breach (where the breach is “notifiable” under the Privacy Act).
If it is not clear whether a suspected data breach is notifiable, we will investigate and assess the breach to determine whether (among other things) we must give notice of the breach.
Changing your Personal Information
You have the right to request access to the information we hold about you, or request that we update or correct any Personal Information we hold about you, at any time. Please do so by emailing your request to us at: investments@midlands.net.nz
We will review your request as soon as reasonably practicable. If we are unable to give you access to the information you have requested, we will give you reasons for this decision when we respond to your request.
Links to other websites
Our Website may contain links to enable you to easily visit other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. We do not endorse any third-party websites, or their content, and we have no control over the conduct of the companies or organisations operating those sites.
Before you disclose any Personal Information to another website, we advise that you check its terms and conditions, including its privacy and security policies.
Updates to our information practices
We reserve the right to modify, amend, change or replace this policy at any time and we will notify such changes by posting an updated version on our Website. It is your responsibility to check our Website from time to time to see if the policy has changed.
Your continued use of our Online Services following notification of any changes to this Privacy Policy constitutes acceptance of those changes. If you do not agree with any aspect of the updated Privacy Policy, you must immediately cease all use of our Online Services.
Complaints
Midlands Funds Management is committed to dealing quickly and appropriately with any complaint you make about your privacy – or any other relevant matter that you are concerned about.
If you are concerned that this privacy policy may have been breached or your privacy has been compromised, please email us immediately via investments@midlands.net.nz or call us on 0800 870 326. For more information on privacy see the Privacy Commissioner’s website.