Legaseed NZ Ltd, trading as Legaseed ("Legaseed", "we", "us" or "our"), is committed to protecting the privacy and security of the personal information we hold.

We collect, use, store and disclose personal information in accordance with the Privacy Act 2020, the Information Privacy Principles and other applicable New Zealand laws and regulatory requirements.

This Privacy Statement explains what information we may collect, why we collect it, how we use and protect it, when it may be shared, and your rights in relation to your personal information.

1. Personal information we may collect

The information we collect will depend on your relationship with us and the services we provide. It may include:

• your name, date of birth and contact details;

• identity verification information and documents;

• information about your family, dependants and personal circumstances;

·         bank account details, bank statements and other relevant banking or transaction information;

• employment and business information;

• income, expenditure, assets, liabilities and other financial information;

• investment, KiwiSaver, insurance and ACC information;

• financial goals, objectives, preferences and risk profile;

• tax residency, tax identification numbers and other information required to meet legal or regulatory obligations;

• health, medical, lifestyle or occupational information where relevant to insurance advice, underwriting or an insurance application;

·         information relating to trusts, companies, partnerships or other entities with which you are associated, including, where relevant, details of trustees, beneficiaries, settlors, directors, shareholders or other relevant persons, together with governing documents such as trust deeds and variations;

• correspondence, meeting notes, advice records, authorities and instructions;

• information received from financial product providers, insurers, investment platforms, custodians and other parties involved in providing services to you; and

• information generated through your use of our website or electronic communications, such as technical information, cookies or website analytics.

We only collect personal information that is reasonably necessary for a lawful purpose connected with our business and the services we provide.

2. How we collect your information

Where practicable, we collect personal information directly from you.

We may also collect information from another person or organisation where you have authorised us to do so, where this is reasonably necessary to provide our services, where the information is publicly available, or where collection is otherwise permitted by law.

These sources may include, for example:

• your spouse, partner or another person involved in your financial affairs;

• accountants, lawyers or other professional advisers;

• insurers and insurance intermediaries;

• KiwiSaver or investment providers;

• investment platforms and custodians;

• financial institutions;

• government agencies or regulatory bodies;

• referral partners; and

• publicly available or authorised information sources.

Where we collect personal information about you from another source, we will comply with any applicable notification obligations under the Privacy Act 2020, including Information Privacy Principle 3A.

3. Why we collect and use personal information

We may collect and use your personal information to:

• understand your circumstances, needs, objectives and preferences;

• provide financial advice and financial planning services;

• provide advice relating to investments, KiwiSaver, personal insurance and ACC;

• prepare, implement and review recommendations;

• apply for and administer financial products or services on your behalf;

• communicate and liaise with financial product providers and other organisations involved in implementing or servicing your arrangements;

• undertake identity verification and meet anti-money laundering, regulatory or other legal requirements where applicable;

• maintain appropriate records of our advice and services;

• administer our ongoing relationship with you;

• respond to enquiries, complaints or requests;

• manage billing, accounting and business administration;

• maintain and improve our systems, processes and services;

• protect our business, systems and clients from fraud, cyber threats or unauthorised activity;

• meet our legal, regulatory, licensing, audit and compliance obligations; and

• provide information or marketing communications where you have agreed to receive them or where otherwise permitted by law.

Where information is requested from you, providing it will generally be voluntary unless it is required by law. However, if we do not receive information reasonably required to understand your circumstances or comply with our obligations, we may be unable to provide some or all of our services.

4. Sharing personal information

We will only disclose personal information where this is reasonably necessary for the purposes for which it was collected, directly related to those purposes, authorised by you, or otherwise permitted or required by law.

Depending on the services we provide, information may be provided to:

• insurers, underwriters and reinsurers;

• KiwiSaver and investment providers;

• investment platforms and custodians;

• fund managers and other financial product providers;

• banks and financial institutions where relevant;

• technology, software, cloud storage, email, document management, electronic signing, CRM and IT service providers acting on our behalf;

• professional advisers including accountants, auditors, legal advisers and compliance consultants;

• regulators, dispute resolution schemes, government agencies or law enforcement bodies where required or permitted by law; and

• other parties where you have authorised us to provide the information.

Where practicable, we limit information provided to third parties to what is reasonably required for the relevant purpose.

5. Artificial intelligence and automated technology

Legaseed may use approved artificial intelligence ("AI"), machine-learning or other automated technology as part of our business operations.

These tools may assist us with activities such as:

• administrative and operational support;

• organising or summarising information;

• preparing preliminary drafts or communications;

• research and analysis;

• improving internal processes;

• record management; and

• compliance or quality-assurance support.

AI tools are support tools only. Legaseed does not rely solely on artificial intelligence to make financial advice recommendations or material decisions about a client.

Financial advice provided by Legaseed remains subject to appropriate human review, professional judgement and the responsibilities applying to us as a licensed Financial Advice Provider.

Where personal information is processed using an AI-enabled service, we take reasonable steps appropriate to the nature and sensitivity of the information to:

• minimise the amount of identifiable personal information provided to the tool;

• use appropriate business or approved systems rather than unrestricted public tools where confidential client information is involved;

• assess relevant privacy, confidentiality and security risks;

• understand how third-party providers may store, process or use information;

• apply appropriate security and contractual safeguards where reasonably available; and

• protect personal information from unauthorised use or disclosure.

We do not intentionally use confidential client information for the purpose of training publicly available general-purpose AI models.

Legaseed remains responsible for the appropriate handling of personal information where third-party technology providers process information on our behalf.

6. Third-party and cloud service providers

We use third-party technology and professional service providers to operate our business.

These may include providers of client relationship management systems, financial planning software, email and communications systems, document storage, investment technology, electronic signatures, accounting systems, cybersecurity, data processing and AI-enabled services.

Where a third-party provider stores or processes personal information on our behalf, we take reasonable steps to assess that provider's privacy and security arrangements and require appropriate protection of the information where reasonably practicable.

Our use of a third-party provider does not remove our responsibility for protecting personal information under the Privacy Act 2020.

7. Overseas storage and processing

Some of the technology or service providers used by Legaseed may store or process information using infrastructure located outside New Zealand or allow authorised support personnel outside New Zealand to access that information.

Where personal information is disclosed to an overseas organisation, we will take reasonable steps to ensure the disclosure complies with the Privacy Act 2020, including the requirements applying to overseas disclosures.

Where an overseas provider processes or stores information solely on our behalf, we remain responsible for ensuring appropriate safeguards are in place.

8. Security

We take reasonable safeguards appropriate to the information we hold to protect personal information against:

• loss;

• unauthorised access;

• unauthorised use or disclosure;

• modification;

• misuse; and

• other security risks.

These safeguards may include access controls, authentication measures, secure systems, staff procedures, cybersecurity controls and appropriate controls over third-party providers.

No electronic system can be guaranteed to be completely secure. If we become aware of a privacy breach, we will assess and respond to it in accordance with our obligations under the Privacy Act 2020.

Where a privacy breach has caused, or is likely to cause, serious harm, we will notify the Office of the Privacy Commissioner and affected individuals as required by law.

9. Retention of information

We retain personal information for as long as reasonably necessary to:

• provide and administer our services;

• maintain appropriate records of advice and client instructions;

• meet legal, regulatory, licensing, audit and compliance obligations;

• resolve disputes or complaints; and

• protect our legitimate legal and business interests.

Information that is no longer required will be securely deleted, destroyed or de-identified where reasonably practicable and subject to any legal or regulatory retention requirements.

10. Accuracy of information

We take reasonable steps to ensure personal information is accurate, up to date, complete, relevant and not misleading before we use or disclose it.

We also rely on you to let us know if your circumstances or information change.

11. Accessing and correcting your information

Under the Privacy Act 2020, you have the right to request access to personal information we hold about you and to ask us to correct information you believe is inaccurate.

In some circumstances the Privacy Act permits us to withhold information or decline a request. If this applies, we will explain the basis for our decision where required.

To request access to or correction of your personal information, please contact us using the details below.

12. Website, cookies and analytics

Our website may use cookies and similar technologies to operate effectively and understand how visitors interact with it.

This may include information such as your browser, device, pages visited and general website usage.

You can usually change your browser settings to control or disable cookies. Disabling cookies may affect the functionality of some parts of the website.

Our website may also contain links to third-party websites. Legaseed is not responsible for the privacy practices of those third parties and we encourage you to review their privacy policies.

13. Marketing communications

Where permitted by law, we may use your contact details to send information relating to Legaseed, our services or information we believe may be relevant to you.

You may unsubscribe from marketing communications at any time.

We will continue to send communications that are reasonably necessary to administer our relationship with you even if you have opted out of marketing communications.

14. Changes to this Privacy Statement

Our business, technology and regulatory obligations may change over time.

We may therefore update this Privacy Statement periodically, including when we introduce new technology, systems or ways of processing personal information.

The most recent version will be available on our website together with its effective date.

15. Contact and Privacy Officer

If you have any questions about this Privacy Statement, how your personal information has been handled, or would like to request access to or correction of your information, please contact:

Privacy Officer
Legaseed NZ Ltd
4a Tamamutu Street
Taupō, New Zealand

Email: support@legaseed.co.nz
Phone: 07 213 2270

If you are not satisfied with our response to a privacy concern, you may also make a complaint to the Office of the Privacy Commissioner of New Zealand.