LAST UPDATED: 31 AUGUST 2023

Introduction

Your privacy is important to us, and we are committed to ensuring that your personal information is protected.

This Privacy Policy explains how we collect, use and disclose the personal information that we collect from you or which we have obtained about you from a third party. It sets out various rights that you have in relation to that personal information. Please take a moment to read and understand it.

This Privacy Policy explains:

• how we collect personal information;
• the kind of personal information we collect;
• how we use, and may share your personal information;
• how you can access/amend your personal information;
• how long we hold personal information;
• who you can contact for further information; and
• additional terms that apply to some residents of the European Economic

In this Privacy Policy:

• “we” means Beca & Co;
• “you” means you, the person purchasing or using our products or services, providing us with personal information or visiting our website;
• “products and services” means all products and services we provide and anything else we do for you; and
• “website” means our website accessible at becaco.co.nz, or associated websites or pages.

We may modify or amend this Privacy Policy at any time and for any reason.  You can view our most current Privacy Policy on our website.

How we collect personal information

We collect personal information in the following ways:

• directly from you or from third parties acting on your authority or who you authorise us to make contact with about you:
• when you contact us seeking information about us, our products or services or anything on our website;
• in the course of conducting customer due diligence;
• in the course of providing our products and services to you; or
• when you apply to work at Beca & Co;
• publicly available information searched as part of carrying out customer due diligence or as part of the provision of our products or services to you;
• the agents and service providers that we may engage to assist us with fulfilling any of the purposes recorded in this policy; and
• third parties connected with the substance of the matter(s) / purpose(s) for which you have engaged us.

The kind of personal information we collect

We collect only the personal information (including for example your name, date of birth, address, email address and contact telephone numbers) you give us, and as acquired through the other sources or means mentioned above.  We may also keep a record of any information that you acquire from us.

If you are providing us with personal information about someone else, it may be necessary to make sure that person is aware that our acting for you may involve collecting, using and disclosing their personal information.  Please ensure you comply with your privacy obligations relating to the personal information of others that you provide to us.  We can discuss this with you if the matter arises.

How we use, and may share, your personal information

We use your personal information for the following purposes:

• to verify your identity, perform customer due diligence and for other administrative purposes;
• to reply to your queries;
• to carry out your instructions, deliver our products and services to you and otherwise fulfil our professional duties;
• to improve, develop, market and provide information about us and our products and services (subject to any confidentiality requirements), including:
• working with you to develop ways in which we can improve our products and services and the way we deliver them, for you specifically and generally; and
• addressing any particular matters you raise with us in connection with our products and services;
• for recruitment purposes, including assessing a candidates suitability for a position with us;
• to enforce our agreements with you (including to supply, and invoice for, products and services ordered by you, and to collect payment);
• to protect our rights, property or safety or those of third parties, including our employees, contractors, other clients, and users of our website or our products or services;
• any specific purpose which we notify you of at the time personal information is collected; and
• to comply with any legal requirement, including any applicable law, court order, other judicial process, or the requirements of a regulator, and as otherwise required or permitted by law.

In providing our products and services to you, or in carrying out any of the other functions mentioned above, we may also disclose your personal information to our contractors or agents, and other organisations, including:

• other parties involved in the matter(s) / purpose(s) for which you have engaged us;
• identification verification and screening agencies including credit reporting agencies (who may retain the personal information we share with them on their databases for use in the provision of their credit reporting services);
• third party service providers such as:
• IT systems or services providers;
• data management, processing and storage service providers;
• auditors;
• banks and other financial service providers;
• third parties engaged in the course of providing our services (such as barristers, mediators, arbitrators, witnesses and subject-matter experts); and
• service providers that assist us with client insight analytics;
• a court or tribunal;
• regulatory and enforcement agencies; and
• government agencies.

We do not sell information that identifies you personally.

How you can access/amend your personal information

You may request access to any of your personal information we hold by emailing us at tj@becaco.co.nz.

Subject to any lawful grounds for withholding, we will provide you with a copy of the personal information we keep about you.

You may request that the personal information we hold about you be corrected by emailing us at tj@becaco.co.nz.  If we agree that your personal information is to be corrected, we will do so. If we do not correct your personal information, your correction request will be kept with the personal information held.

How long we hold personal information

We will keep your personal information only for as long as necessary to achieve the purpose for which it was collected.

If your personal information is no longer required by us, we will either destroy the information or de-identify it so it cannot be attributed to you personally.

Who you can contact for further information

If you have any queries about this Privacy Policy or personal information we have collected please contact:

Additional terms that apply to some residents of the European Economic Area (EEA)

In addition to the rights already recorded above, if you are based in the EEA, you may have the following additional rights in relation to the personal information we hold about you:

• Right to erasure

You can ask us to delete or remove your personal information in some circumstances, such as where we no longer need it or, if we are relying on your consent to process the information, you withdraw your consent.  If you are entitled to erasure we will comply with your request.  If we have shared your personal information with others, we will let them know about your request where reasonably possible.  If you ask us, where it is reasonably possible and lawful for us to do so, we will also tell you who we have .shared your personal information with so that you can contact them directly.

• Right to restrict processing

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you do not want us to erase your information but require restriction of processing instead.  If you are entitled to restriction of processing of your personal information, and we have shared your personal information with others, we will let them know about the restriction where it is reasonably possible for us to do so.  If you ask us, where it is reasonably possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.

• Right to data portability

You have the right, in certain circumstances, to obtain personal information you have provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

• Right to object

You can ask us to stop processing your personal information, and we will do so, if we are:

• relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
• processing your personal information for direct marketing purposes.

• Right to withdraw consent

If we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

• Right to lodge a complaint with the supervisory authority

If you have a concern about any aspect of our privacy practices, including the way we have handled your personal information, you can report it to the relevant Supervisory Authority in the EEA.

Please be aware that some of these rights may be limited or unavailable where we have an overriding interest or legal obligation to continue to process the data, or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.

Your personal information may be processed by our third party providers in Australia and Hong Kong.  The European Commission has not recognised either Australia or Hong Kong as providing adequate protection.  We have enforceable contractual arrangements with these third party providers to ensure appropriate safeguards are in place to protect your personal information. Please email us at tj@becaco.co.nz if you would like to obtain a copy of the safeguards in place with our third party providers.