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Privacy Policy

Falcon Financial Services Limited t/a Falcon Mortgages must comply with the Privacy Act
2020 (the Act) when dealing with personal information. Personal information is information
about an identifiable individual (a natural person).
 
A person is not required to provide the personal information that we request but, if that
person chooses not to do so, in many cases we will not be able to provide our services.
 
Falcon Mortgages has a privacy policy to ensure it is meeting its regulatory requirements
and customer best practice commitments regarding managing privacy obligations.
 
Falcon Mortgages operates the Privacy policy to:
 
» Ensure a robust framework around Privacy requirements.
» Identify what Falcon Mortgages considers to be private information.
» Set out how privacy complaints to Falcon Mortgages will be recorded, responded to
    and reported
 
This Policy is in accordance with the Privacy Act 2020.

What is Personal Information

Personal information is information about an identifiable individual. It includes (but is not
limited to) name, address, contact details, date of birth, occupations, payment details,
employment history and/or details, education and qualifications, financial information,
testimonials and feedback, evidence of source of funds or source of wealth (in some cases)
and other information.

How We Collect Personal Information

We collect personal information about an individual from that individual, through contact with
us (for example, in a meeting, or via an email, or website), or when we provide services to
the individual.
 
We also collect information from third parties including clients’ related businesses,
accountants, current providers of financial products (including insurers and lenders), medical
service providers and employers.
 
We may also collect personal information from the Accident Compensation Corporation and
credit reporting agencies. Any information we collect from third parties is at the knowledge
and approval of the client.
 
When a person visits Falcon Mortgages, website we may collect information including details
of visits to our website such as traffic data, location data, cookies and website analytics.

Third Party Collection of Information

Where we collect your personal information from someone other than you, we will take
reasonable steps to notify you that we have collected your personal information, the purpose
of the collection, the intended recipients of the information, the name and address of the
agency collecting and holding the information, whether the collection is authorised or
required by law and, if so, the law that authorises or requires the collection, and your right to
access and request correction of that information, unless an exception applies under the
Privacy Act 2020.

How We Use Personal Information

We collect personal information for the following purposes:

» To verify your identity
» To provide and market our services (and to assist in improving our services)
» To respond to communications from a client
     to market our services and products to you, including contacting you electronically
     (e.g. by call, text, or email for this purpose)
»  In connection with defending, protecting and/or enforcing our legal rights and
    interests including defending a complaint, claim or other action
»  To conduct research and statistical analysis (on an anonymised basis)
     to undertake credit checks on clients (if necessary)
» To comply with our obligations at law and to support us to engage with the relevant
     regulator
»  For any other purpose authorised by our client or the Act

Who We Disclose Personal Information To

We may disclose a client’s personal information to: 

» Kiwi Advisor Network (KAN) and its affiliated entities
» Any business that supports the provision of our services (including related
   companies, information technology service providers, lawyers, accountants)
» Financial product providers in connection with assisting clients to apply for financial
   products and services, administer financial  products and services, make claims
   under financial products, renew, vary, replace or exit/end financial products or
   services
» Third parties noted above in order to obtain relevant required information
» Individuals or organizations with whom we are legally required or authorized to share
   information, including regulators and government agencies
» Lawyers and other professionals, and our insurers (and their advisers), in connection
   with defending, protecting and/or enforcing our legal rights & interests
» Debt collection agencies
» Any other person or entity authorised by you or as permitted by the Privacy Act or
   another law.
» Auditors (such as KAN) to ensure compliance with regulations and that the services
   provided to you are in your best interests
 
A business that supports the provision of our services may be located outside New Zealand.
This may mean that personal information is held and processed outside New Zealand.

How We Protect Personal Information

We will:

»  Take steps that are reasonable in the circumstances to keep personal information
    safe from loss and from unauthorized access, use, modification or disclosure.
»  Employees are not allowed to access or share client information unless it is in the
    course of standard business processes.
»  We will identify and delete all files seven years after the end of the customer’s
    relationship.

 
Accessing And Correcting Personal Information

You have the right to access and request correction of any personal information we hold
about you at any time. To do so, please contact us.

Website

Cookies and IP Addresses:
Upon accessing our website, we may send a “cookie” (a small summary file containing a
unique ID number) to your computer. This enables us to identify your computer each time
you visit our website. Cookies are also used to analyse traffic patterns, identify visited areas
of our website, measure transaction patterns, analyse trends, administer the website, track
user movements, and gather broad demographic information. This helps us research user
habits to improve our website and service offerings. Our cookies may record information
such as your Internet Protocol (IP) address, device and browser type, operating system,
pages or features browsed, time spent on those pages or features, site usage frequency,
search terms used, links clicked or used, and other usage statistics. While our cookies do
not collect personal information, if you submit your name and email address during usage,
we will link that personal information with the cookie information previously collected from
you. If you prefer not to receive cookies, you can configure your browser to reject them.

Security:

As our website is connected to the internet, which is inherently insecure, we cannot
guarantee the security of information transmitted to us online. There is a risk that the
information you provide may be intercepted during transmission over the internet. Therefore,
any personal or other information you transmit to us online is done so at your own risk.

Links and Third-Party Advertisements:

Our website may include links to other websites operated by third parties, as well as display
advertisements hosted by third parties.
We do not make any representations or warranties regarding the privacy practices of these
third-party websites or advertisement providers.

Additionally, we are not responsible for their privacy policies or the content of their websites
or advertisements. It is the responsibility of third-party websites to inform you about their own
privacy practices.
Our online advertising network partner may utilize cookies, web beacons, or other web
tracking techniques to gather non-personally identifiable information about your activities on
our website and other websites you visit. This information may be used to deliver targeted
advertising based on your interests.

Privacy Breach

A privacy breach occurs when an organization or individual either intentionally or
accidentally:

»  Provides unauthorised or accidental access to someone’s personal information.
»  Discloses, alters, loses or destroys someone’s personal information
»  A privacy breach also occurs when someone is unable to access their personal
    information due to, for example, their account being hacked.

Falcon Mortgages is obligated to notify the Privacy Commissioner, and any affected people
as soon as is practically possible for any privacy breach that either has caused or is likely to
cause anyone serious harm.

Reporting Of Privacy Breaches

Falcon Mortgages will undertake an analysis of a privacy complaint to identify if it is serious
and systemic in nature. Where a privacy breach of this nature occurs Falcon Mortgages will,
in accordance with their obligations under the Privacy Act notify the privacy commissioner
and the individuals impacted by the breach.

Responding to Client Information Requests

When a client requests their information, we are obligated to provide that information to
them. When a request is received, we will notify the Director of Falcon Mortgages. We will
provide the information to the client within 20 working days, we will also notify the client if we
do not have any related information for the client.

The information could be held in:

»  Physical files
»  Digital or electronic files
»  File notes
»  Applications
»  Data held on the client CRM; and/or
»  Communication records

Falcon Mortgages will ensure staff and Advisers are trained on privacy obligations, including
using tools provided by the Privacy Commissioner.