Privacy Policy

(as at September 2020)

1. INTRODUCTION
   1.1 Ora Partners (“we” or “us”) is an international network of affiliated firms with each firm providing separate categories of specialised client services. Ora Partners Limited operates, or has the right to operate, the website www.ora-partners.com, and itself does not provide any client services.
   1.2 We are committed to protecting and respecting your privacy.
   1.3 This policy applies to the collection of personal information when you engage with us, access our website or otherwise interact with us. We respect the privacy rights of users and recognise the importance of protecting information collected about you.
   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.
2. CHANGES TO THIS NOTICE
   2.1 We may change this policy from time to time. If we make any changes, we will notify you by revising 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 review our policies whenever you access our website to stay informed about our information practices and to see any changes or updates.
3. INFORMATION COLLECTED
   3.1 This policy applies to the collection of certain personal information. We may collect, record, disclose or use information about you in physical and electronic form and will hold, use and otherwise process the data in accordance with this Privacy Policy and the Privacy Act 1993 (New Zealand).
   3.2 Information we may handle, collect and process of yours 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 and marital status;
   (e) financial information including relating to your investment portfolios as recorded in the online portfolio management system, 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, and non-identifiable information relating to your use of the Services such as device-related information (i.e. browser type) and server log information (date and time of day of your visit and pages you accessed;
   (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;
   (h) information to assess as to whether you are a wholesale investor or a professional investor for the purpose of financial services legislation; and
   (i) 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 us;
   (b) the use of our online portfolio management system and details of the transactions carried out through the online portfolio management system;
   (c) information gained from AML/KYC checks that we are required to conduct;
   (d) your or your authorised representative’s interactions with us, discussions, correspondence, instructions provided to us, transactions and your use of our website;
   (e) your or your authorised representative’s dealings with us, including via email, telephone, video conferencing, or otherwise as stated in contracts with you; and
   (f) any recording and monitoring tools that may be used for compliance or security purposes (e.g. recording of telephone calls, monitoring emails, online portfolio management system and website use 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. 3.6 If you do not provide all personal information requested you may not be able to proceed with your business relationship with us.
4. CONSENT
   4.1 Your personal information is processed by us with your written or oral consent. By continuing to use our website, you hereby authorise us to process your personal information. Consent can be withdrawn at any time by notifying us in writing. Consent can only be withdrawn going forward and does not affect consent given until that time. However, is consent is withdrawn we may not be able to proceed with your business relationship with us.
   4.2 For clarity, you consent for all entities within Ora Partners to process your personal information.
5.  COOKIES
   5.1 We set and access cookies and similar technology on your computer to obtain information about how you access and use our website. Unless you have adjusted your settings so that you can refuse cookies or you have not accepted the use of cookies, our system will set cookies when you load and navigate around our website.
   5.2 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.
6. USE OF INFORMATION
   6.1 We may use the information collected to perform a variety of purposes, including:
   (a) to facilitate or administer the various services operated by Ora Partners and any related administration on an on-going basis;
   (b) to provide, operate, maintain and improve the online portfolio management system, including (without limitation) for the processing of applications, redemptions, transfers, deposits, payments, generating reports and record keeping of investment portfolios;
   (c) to provide you with alerts, newsletters, education materials or information that you requested or signed up;
   (d) to provide updates and reports in relation to the services provided by Ora Partners;
   (e) to disclose information to other third parties such as our service providers, including auditors, custodians, regulatory authorities and technology providers;
   (f) for identifying and dealing with any conflicts that may arise;
   (g) undertaking “know your client” checks and obligations in accordance with know-your-client (KYC), anti-money laundering and countering financing of terrorism (AML/CFT) laws;
   (h) to comply with our legal obligations including any Inland Revenue (IRD) regulation;
   (i) carrying out fee calculations;
   (j) to monitor and record calls and electronic communications;
   (k) to report regulatory and tax related information to regulatory and tax authorities in order to comply with a legal obligation;
   (l) for prudential and risk management purposes;
   (m) to provide, operate, maintain and improve the website;
   (n) for statistical analysis purposes and to improve the provision of services provided by Ora Partners;
   (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 any other purpose we may notify you about from time to time.
   6.2 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 servers are located in New Zealand, Cook Islands and other such international jurisdictions as our service providers may use.
   6.3 By accessing our website or otherwise providing information to us, you consent to the processing and transfer of information between countries and territories globally, which may have different privacy laws from your country of residence.
   6.4 Your information will be processed by staff who work for us and by our Custodian service provider to enable the provision of the online portfolio management service. This includes, among other things, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
   6.5 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our sites and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7. SHARING AND DISCLOSURE OF INFORMATION
   7.1 We will not share personal information about you otherwise than as set out in this Privacy Policy. For example, we may share 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.
   (iv) to enforce our agreements and policies; and
   (v) to perform our obligations in accordance with our engagement.
   7.2 We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
8. OTHER
   8.1 This Privacy Policy is for your information and should not be used as the basis for any decision to use any services provided by Ora Partners. The views and information expressed in this policy do not constitute and may not be relied upon as constituting any form of investment advice or inducement to invest, and prospective investors must obtain appropriate independent professional advice before making investment decisions.
9. SECURITY
   9.1 While no service is completely secure, we will endeavour to protect information about you from loss, theft, misuse, unauthorised access, disclosure, alteration and destruction.
   9.2 If you have any questions about the security of your personal information, you can contact us at info@ora-partners.com.
10. YOUR RIGHTS
    10.1 This Privacy Policy shall be governed by the laws of New Zealand. You agree to submit to the non-exclusive jurisdiction of the New Zealand courts.
    10.2 Pursuant to the Privacy Act 1993, you have the right to access the personal information we hold about you, where it is stored, and if it is held in such a way that it can be readily retrieved. If the personal information we hold about you is not accurate or complete, then you may ask us to correct it.
    10.3 You may update, correct or delete information about you at any time by emailing us at info@ora-partners.com, but note that we may retain certain information as required by law or for legitimate business purposes.
11. 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 Privacy Commission.