(as at 20 November 2021)
1.1 Matū Group Limited (“Matū”, “we” or “us”) provides management services for a number of Matū entities including Matū Karihi LP (via Matū Karihi (GP) Limited) and Matū Iramoe Limited. We are committed to protecting and respecting your privacy, and comply with the New Zealand Privacy Act 2020.
1.2 This policy applies to the collection of personal information when you engage with us, invest with us, access our website, when you attend a Matū event, or otherwise interact with us. We respect the privacy rights of users and recognise the importance of protecting information collected about you.
1.3 This policy does not limit or exclude any of your rights under applicable legislation such as the Privacy Act 2020.
1.4 Please read the following carefully to understand how we will collect, use and maintain your personal information. It also describes your choices regarding use, access and correction of your personal information.
- CHANGES TO THIS NOTICE
2.1 We may change this policy from time to time. If we make any changes, we will revise the “Last Updated” date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our home page, a notification popping up, or sending you an email notification). We advise you to review our policies regularly to stay informed about our information practices and to see any changes or updates.
- INFORMATION COLLECTED
3.2 Information we may collect may include:
(a) information obtained from identification documentation (including your name, contact details, nationality and national identity numbers (where applicable));
(b) bank account details;
(c) your professional title and occupation;
(d) your age;
(e) financial information, tax status, account details and evidence of ownership of financial assets;
(f) personal identifiers such as your tax identification number, IP address or our internal electronic identifiers;
(g) information which we or our service providers need to conduct ‘know your client’ checks such as details relating to your passport or other identification documentation and credit history; and
(h) other information you provide in the course of your dealings with us.
3.3 In certain circumstances, we also collect and process information that may be sensitive and may relate to money laundering, sanctions, financial crime and fraud prevention checks.
3.4 Information we collect can come from:
(a) application forms, agreements, deeds or other materials you or your authorised representative submits to them during the course of your relationship with Matū;
(b) information gained from AML/KYC checks that Matū is required to conduct;
(c) your or your authorised representative’s interactions with us, discussions, due diligence, transactions and your use of our website;
(d) your or your authorised representative’s dealings with Matū, including via email, telephone, video conferencing or as stated in contracts with you; and
(e) any recording and monitoring tools that may be used for compliance or security purposes (e.g. recording of telephone calls, monitoring emails, etc.).
3.5 When you visit our website, we may collect general user information such as users internet protocol addresses, browser type, internet service provider information and other technical information. Some of this information may include personal information. We may use this information to provide, operate, maintain and improve the website. Our website uses Google Analytics, Google Tag Manager, and LinkedIn Insights.
3.7 You may refuse to accept cookies by activating the setting on your browser which allows you to reuse the setting of cookies. Please be aware that if you select to refuse or restrict cookies you may be unable to access certain parts of our website.
3.8 If you do not provide all personal information requested you may not be able to proceed with your business relationship with Matū.
- USE OF INFORMATION
4.1 We may use the information collected to perform a variety of purposes, including:
(a) to run Matū, facilitate or administer the holding of partnership units or shares in Matū and any related administration on an on-going basis;
(b) for receiving and administering your (or an affiliated entity of yours) investment (or potential investment) in Matū;
(c) to disclose information to other third parties such as our service providers, including auditors, regulatory authorities, and technology providers;
(d) for identifying and dealing with any conflicts that may arise;
(e) undertaking “know your client” checks and obligations;
(f) to comply with our legal and tax obligations;
(g) to provide updates and reports in relation to Matū and its investment companies, opportunities for co-investment and information about the investment ecosystem;
(h) for the application of grants or licenses that help support Matū;
(i) to update and maintain records, including any register of directors and limited partners;
(j) carrying out fee calculations;
(k) to monitor calls and electronic communications;
(l) to report regulatory and tax related information to regulatory and tax authorities in order to comply with a legal obligation;
(m) for prudential and risk management purposes;
(n) to provide, operate, maintain and improve the website;
(o) combine third party information, the information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive); and
(p) for other reasonable purposes we may notify you about from time to time.
4.2 Matū does not undertake marketing activities for third parties, nor does it provide personal information to third parties for their marketing purposes.
5.1 Your personal information is processed by us with your written or oral authorisation. Authorisation can be withdrawn at any time by notifying us in writing. Authorisation can only be withdrawn going forward and does not affect authorisation given until that time. However, if authorisation is withdrawn, we may not be able to proceed with your business relationship with Matū.
- ACCESSING AND CORRECTING INFORMATION
6.1 Subject to certain grounds for refusal in the relevant legislation, you have the right to:
(a) request confirmation from us as to whether we hold your personal information;
(b) access your readily retrievable personal information that we hold; and
(c) request a correction to your personal information.
6.2 Before you exercise these rights, we may request evidence to confirm that you are the individual to whom the personal information relates.
6.3 If you request for information to be corrected, we will take reasonable steps to make the correction, but where that is not possible, we will inform you and make a note that you have requested such correction going forward.
6.4 To request access or correction of your personal information, please contact [email protected].
7.2 We regularly review our files to check that information is accurate, up-to-date, and still required.
8.1 The personal information we collect may be stored or held in any format, at our office or premises or outside of our offices including data storage facilities provided by our server provider or online storage. Our Google Workspace servers are located in the United States of America and other international jurisdictions as our service providers may use.
8.2 By accessing our website or otherwise providing information to us, you authorise us to disclose your personal information to entities overseas, where that is necessary for one of the purposes for which we collected your information. You also acknowledge that the overseas entities may not be required to protect your personal information in a way that, overall, provides comparable safeguards to the Privacy Act.
- SHARING AND DISCLOSURE OF INFORMATION
9.1 We may disclose personal information about you including as follows:
(a) with third-party vendors, consultants and other service providers who are working on our behalf and require access to your information to carry out that work such as hosting and data storage providers, including in the course of representing or advising you or the client if you acting on the client’s behalf;
(b) where you have chosen to use collaboration features that by their nature support sharing with third parties of your choice. Your name, email address, and other information you choose to share may be shared with such third parties, and such third parties may communicate with you (such as by emailing you); and
(c) we may disclose your information to a third party, if:
(i) it is required or authorised by you or an affiliated entity of yours;
(ii) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request (including in any foreign jurisdiction); or
(iii) it is required or authorised by law or our obligations as Financial Service Provider;
(iv) to enforce our agreements and policies; and
(v) to perform our obligations in accordance with our engagement.
9.2 You authorise us to share information held by one Matū entity with another (e.g. AML records between different Matū funds) as members of a Designated Business Group where that is necessary for one of the purposes for which we collected your personal information.
10.1 While no service is completely secure, Matū will apply appropriate technical, physical, electronic, and administrative safeguards to protect information about you from loss, theft, misuse, unauthorised access, disclosure, alteration and destruction.
10.2 If you have any questions about the security of your personal information, you can contact us at [email protected].
- EU GENERAL DATA PROTECTION REGULATION
11.1 You may also have rights under the EU General Data Protection Regulation, to the following: erasure of personal information, restriction of processing information, restrictions of the transfer of information outside of New Zealand and data portability, the ability to object to processing and the right to lodge a complaint with a supervisory authority other than the New Zealand Office of the Privacy Commissioner.