This is the Privacy Policy of Silver Harbour Capital Limited trading as Safe Harbour Investment (“we”, “us”, “our”). Your privacy is important to us. This Privacy Policy governs our collection, use, storage and disclosure of your personal information (as defined in the Privacy Act 2020 (“Act”)) and has been prepared in accordance with our obligations and your rights set out in the Act.

We may update this Privacy Policy from time-to-time.  The updated policy will apply from the date we provide an updated copy to you or we upload an updated copy on our websites. 

How we collect your personal information?

We collect personal information about you from:

• you, when you provide that personal information to us, including via our websites and any related service, through any registration or subscription process, through any contact with us (e.g. telephone calls, emails), or when you acquire or use our products or services;

• third parties, where you have authorised this or the information is publicly available.

What personal information do we collect?

We only collect personal information that we need for the purposes of providing information, products and services to you (including via our websites). The personal information we collect may include:

• your name, date of birth and contact information (including residential address, email address and telephone numbers);

• your IRD number and tax status;

• documents which verify your identity and other personal details (such as your passport, driver's licence, visa or work permit);

• where you are a potential borrower or guarantor, information about your employment, income, assets, liabilities and financial and personal circumstances (including, in some circumstances, a statement of position);

• where you are a potential borrower or guarantor, details about your credit history, credit accounts, credit that may have been extended to you and your repayment history;

• where you are a potential borrower or guarantor, details of any security offered (including property valuations);

• where you are a company, information about your business, its directors and shareholders, its structure and financial position;

• any other information provided by you or specifically related to your communications with us or your use of our websites.

How do we use your personal information?

We need to collect personal information so that we can provide information, products and services to you and related persons. The personal information collected is used:

• to confirm and verify your identity and other personal information to satisfy our obligations under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009;

• to respond to communications from you;

• to market our products and services to you, including contacting you electronically (e.g. by text message or email);

• to conduct research and statistical analysis (on an anonymised basis);

• to improve our products and services;

• to bill you and to collect money that you owe us, including authorising and processing credit card transactions;

• in the credit application decision making process;

• to undertake credit checks on borrowers or guarantors;

• to prepare and issue loan documents;

• to comply with our obligations at law;

• to carry out any activity in connection with any legal, governmental or regulatory requirement, or in connection with legal proceedings, crime or fraud prevention, detection or prosecution

• to defend, protect and/or enforce our legal rights and interests including defending a complaint, claim or other action;

• to provide investment opportunities, to process investment applications and to issue & manage investments and related property

• for general administrative and business purposes; and

• for any other purpose authorised or permitted by you or the Act.

Disclosure of personal information

We may disclose your personal information to:

• any person engaged by us to provide such information as is necessary for the purposes described above;

• any business that supports our products and services, including any person that hosts or maintains any underlying IT system or data centre that we use to provide our websites, or products and services;

• our related companies and Public Trust (and its related companies);

• persons who may wish to invest in our products or use our services;

• the purchaser of all (or a significant part of) our business (where we are satisfied they will use and protect your information to at least the same standards as us);

• debt collection agencies;

• any person as required by any applicable laws or regulations, or in the course of legal proceedings or investigations;

• lawyers and other professionals, and our insurers (and their advisers), in connection with defending, protecting and/or enforcing our legal rights & interests;

• third parties in relation to identity verification, financial credit checks, Companies Office checks, online checks and background and legal checks as deemed appropriate; or

• any other person you authorise us to disclose your personal information to.

You don’t have to share your personal information with us.  However, withholding it may affect the quality of the products and services you receive or our ability to provide products and services.   Please talk to us if you have any concerns.

A business that supports provision of our services may be located outside New Zealand.  This may mean that personal information is held and processed outside New Zealand.

Security and accuracy

We take reasonable steps to ensure personal information is:

• protected against loss, damage, misuse and unauthorised access. We restrict access to personal information to those individuals who need access to this information in order to assist us in performing our duties and obligations; and

• accurate, up to date, complete, relevant and not misleading.

Access to personal information

You may request:

• confirmation of whether or not we hold any personal information about you; and

• access to any personal information that we hold.

To do so please contact the Privacy Officer at the contact details set out below.

Accuracy of information

Subject to certain grounds for refusal in the Act, you have the right to ask us to correct your personal information when it is inaccurate, incomplete or out of date. To do so please contact the Privacy Officer at the contact details set out below.

Internet Use

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.

When a person visits our websites we may collect information including details of visits to our websites such as traffic data, location data, and website analytics. 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 our websites. 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 websites.

Privacy Officer – Contact Us

If you would like to contact us about any matter relating to privacy, our details are:

Roger Su
Level 2, 81 New North Road Eden Terrace
Auckland 1021
Email: roger.su@srrs.co.nz