Privacy Policy

SM Advisory Privacy policy

Introduction

This policy sets out how SM Advisory Limited (we) collects, uses and discloses personal information. Personal information is information about an identifiable individual (i.e. a natural person) (you). We comply with the applicable privacy laws, including the New Zealand Privacy Act 2020 (replacing the Privacy Act 1993) (Act).

You can find out further information about the Act at www.privacy.org.nz.

Personal information we collect

We collect personal information about you, which may include:

• your name

• your date of birth and/or age

• your gender

• your location (e.g. address, GPS location)

• your contact details (e.g. postal address, email address, phone number, twitter handles)

• about your interactions with us

• your billing information (e.g. credit card, purchase history)

How we collect your personal information

We may collect your personal information from you, when you provide that personal information tous, including via:

• our website

• an electronic form or application

• a registration or subscription process

• our contact with you (e.g., in person or by phone, zoom, email or mail)

• any other means authorised or requested by you

We may also collect your personal information from:

• publicly available information

• third parties, where you have authorised or requested us to do so

Why we collect your personal information

We collect your personal information when it is necessary for a purpose connected with a function or activity that we carry out, including to:

• verify your identity

• provide products and services

• market our products and services

• improve our products and services

• improve the way we provide our products and services

• bill and get paid by you (e.g. authorising and processing credit card transactions)

• communicate with you

• protect and/or enforce our rights and interests

• when you apply to be employed or contracted by us, for recruitment, employment and

contracting purposes

• fulfil any other purpose authorised or requested by you

Disclosing your personal information

We may disclose your personal information to:

• a person who can require us to supply your personal information (e.g., a regulatory or

government authority)

• any other person authorised by the Act or another law (e.g., a law enforcement agency)

• any other person authorised or requested by you

We may store personal information within services provided by cloud service providers based inNew Zealand or overseas.

Protecting your personal information

We will take reasonable steps to ensure your personal information is securely stored and safe from loss, unauthorised activity or misuse. However, please be aware that the internet is not a secure environment. If you send us any information over the internet (in whatever way or format), you send it at your own risk.

If information is not provided

If you do not provide all or any part of the personal information we request,

r we may be unable to provide (or continue to provide) products and services to you.

Accessing and correcting your personal information

You can ask for the personal information we hold about you (if it is readily retrievably by us). Before we provide any information to you, we will need evidence that you are the individual to whom the personal information relates. If your personal information is wrong, you can ask for it to be corrected. If we consider that the correction is reasonable (and we are reasonably able to make the correction), we will make the

correction. If we do not make the correction, we will take reasonable steps to note on the personal information that you requested the correction.

Cookies

We use ‘cookies’ on our websites. Cookies are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. They are small text files that are placed on your computer by the websites that you visit. If you do not agree to the use of cookies, you can manage and control them through your browser, including removing cookies by deleting them from your ‘browser history’ (cache) when you leave the site.

Your consent

By providing information to us (in whatever way or format), you consent to us collecting, using and disclosing that information in accordance with this policy and the Act.

Changes to this policy

We may change this policy by uploading a revised policy to our website. The revised policy will apply from the date it is available on our website.

Contacting us

To submit a request, or otherwise contact us in connection with this policy, please contact us by email (smadvisory@xtra.co.nz). Our address is PO Box 308050, Manly, Auckland 0932, New Zealand