Privacy Statement

Generate Investment Management Limited (or Generate group companies), Public Trust, any of their authorised agents, and any distributor (each an "Authorised Person") collects personal information in the course of carrying out our business.  Any personal information that we collect about you will be handled in accordance with the Privacy Act 2020 and this Privacy Statement.  This Privacy Statement applies in addition to any applicable terms and conditions relating to our website, promotions, products or services (collectively, Services). 

By applying for and using our Services or otherwise providing us with your personal information, you consent to the collection, use, disclosure, storage and retention of your personal information as described in this Privacy Statement.

We may amend and update this Privacy Statement from time to time by posting a revised version on our website, so we encourage you to check it regularly to see what changes have
been made.  By continuing to use our Services you are deemed to have accepted any updates to this Privacy Statement. This Privacy Statement was last updated in July 2024.

What personal information do we collect? 

Your personal information will be collected and held by Generate Investment Management Limited and/or a Generate group company, at Floor 9, 21 Queen Street, Auckland Central, Auckland 1010, New Zealand. 

The type of information that we collect about you will depend on the purpose for which it is collected, but may include: 

• name and contact details
• date of birth
• identity verification documents, such as passport and driver licence numbers
• financial information such as the nature and purpose of your investment and your source of funds 
• employment records and payslips
• IRD number 
• records of our communications with you

We generally collect this information directly from you, however sometimes we may collect information from other people (such as credit agencies or third party identify verification providers) or other publicly available sources. 

If you do not provide the required information, we may not be able to onboard you. 

Where you have provided personal information about another individual, you confirm that you have the authority and consent of that individual to provide us with their personal information.

How do we protect your information?

Generate will (or through Apex Investment Administration (NZ) Limited will) hold the information securely taking reasonable steps to ensure personal information is protected against loss, misuse, or unauthorised access, use or disclosure.  

Your information will be used by Generate and Authorised Persons to manage your relationship with Generate and Authorised Persons, to provide products and services to you including the provision of financial advice, to administer the Generate KiwiSaver Scheme and Generate Unit Trust Scheme (Managed Funds) that we operate, to comply with any applicable laws, to facilitate and run events and competitions, for marketing purposes including offering you further products and services that may be of interest to you, to improve and develop our Services, and for any other use for which you have given authorisation or is otherwise permitted by the Privacy Act 2020. 

We may use your personal information for marketing and promotional communications, however you can opt out at any time by notifying us at info@generatekiwisaver.co.nz or by clicking the unsubscribe function included in our marketing communications.  

We may disclose your personal information in connection with these purposes to Generate group companies, Authorised Persons, their staff members, our third-party service providers (including distributors) and to the Financial Markets Authority or other applicable regulators or government entities.

Disclosure to and use of your information by third party advisors 

Where you have given your consent, we may also disclose your personal information to our trusted third-party advisors, who may use the information for the purposes of contacting you about our Services and other financial products and services that they consider may be of interest to you.  While we take reasonable steps to ensure that these third parties protect your personal information in accordance with the requirements of the Privacy Act, any retention, use or disclosure of your personal information by a third-party advisor will be subject to their own privacy policy and practices and we accept no responsibility or liability for their actions.

Use of your personal information for identity verification purposes 

Generate may further use your information to electronically and/or biometrically verify your identity, including where we are required to do so to comply with our legal obligations under AML/CFT legislation. We may pass your information to and check it with the document issuer, official record holder and authorised third parties that Generate has contracted to carry out
the verification process. Generate may share your information and the results of the verification process with appropriate third parties (such as a distributor or adviser that will or has been providing services to you) to enable that third party to comply with any applicable laws. 

Where we collect or process biometric information for the purposes set out in this Privacy Statement, we will obtain your prior consent and comply with all applicable laws and codes of practice in relation to such processing.

Use of cookies 

Like many other websites on the internet, we may use cookies to store and track information about you when you are on our website for the purposes of:

• providing more customised content and material to you on our website; and
• conducting business and marketing analysis.

All information collected via cookies will be held by Generate. This information will not be made available to any third party in a manner that enables you to be identified. If you do not wish to allow cookies you may change your browser settings to disable cookies. However, if you disable cookies some parts of our website may not function properly.   

Records of your engagement with us 

If you contact us or we contact you, we may keep a record of that contact. We may also monitor and record calls you make to us and we make to you for training and security purposes, to enable us to better understand your needs and personalise our services, and to undertake analysis and insights into our clients and business. 

Your rights to access and correct your information 

You may request access to the information held about you, and if any of the information is incorrect, ask for it to be corrected. You can do this by contacting us by email at info@generatekiwisaver.co.nz or call us on 0800 855 322. If we are not willing to correct errors that you have identified in your personal information, you may request that we take reasonable steps to attach a statement to the personal information noting the correction sought.

How to contact us 

If you have any questions or concerns regarding your personal information or this Privacy Statement, please contact us by email at info@generatekiwisaver.co.nz or call us on 0800 855 322.

How we may contact you

Where you have consented, we may contact you by telephone, email, mail or SMS. If you consent to SMS and reply to an SMS, standard rates will apply.