Last updated on 8th August 2022
Vincent Capital Limited (Vincent Capital, we or us) attaches great importance to protecting our customers’ privacy. We are committed to meeting our obligations under the Privacy Act 2020.
This Privacy Policy sets out how we collect and use your personal information when you use our products and services.
Please read this Privacy Policy carefully before using our products and services. In using our products and services, and providing us with personal information, you agree to this Privacy Policy.
Changes to this Privacy Policy
We encourage you to review this Privacy Policy regularly as we may update it from time to time. When we update it we will notify you by changing the date at the top of this policy and including an updated copy on our website at www.vincentcapital.co.nz/privacy
Personal information we collect
We may collect personal information about you, including:
name, date and place of birth, country of residence, tax status, address and contact details
financial position (including, income, wealth, assets, and net worth, and the source of your wealth)
credit record and banking transaction history
employment details
information about background and involvement in other projects
information about trusts, including trust deeds and deeds of variation, if the borrower is a trustee on behalf of a trust
information about companies, including details about shareholding (potentially personal shareholding) if the borrowing entity is a company
copies of your passports and identity documents, photos and videos of your face and your signature
any information you provide us when you contact us.
You may be provided with some options as to what personal information can be provided, but if you do not provide certain required types of personal information to us (for example, identification, proof of address and source of wealth), we may be unable to provide you with products and services (for example, your loan may not be approved), and/or certain features of our products and services may not be available to you.
We will normally collect personal information about you from you directly. However, we may collect personal information about you from third parties where you have authorised such collection, or such collection is permitted or required by the Privacy Act 2020 or any other applicable law.
We will also collect personal information about you from third parties including:
where that information has been made publicly available (which we may access through a Google search to check old and recent news stories about the borrower) and public information service providers such as public registers like the New Zealand Companies Office Register; and
commercial information service providers such as credit reporting agencies, data when we perform credit checks and providers who perform politically exposed person checks.
Your personal information will be collected and held by us. Our address is: Level 3, 246 Queen Street, Auckland CBD.
What we use your personal information for
We collect and use your personal information for a range of purposes including for the provision of products and services and to conduct and develop our business, including in order for us to assess a borrower’s credit risk before a loan is approved.
Some of the personal information we collect is required by law in order for us to comply with our customer due diligence requirements under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (the AML Act).
We may also use your personal information to contact you, as a borrower, to seek your written approval to use a project that we have funded for marketing purposes, where we will focus our marketing on the project only.
Who we may share your personal information with
We may provide your personal information to our employees, companies within our group, persons who provide services to us (including companies that may assist us with complying with our customer due diligence requirements under the AML Act), regulatory authorities, government agencies, law enforcement and courts. We will disclose your personal information to these parties only:
for the purposes set out in this privacy policy;
if you have otherwise authorised us to do so;
if we are required or permitted by law to disclose such information; or
otherwise in accordance with the Privacy Act 2020.
These recipients may be located in New Zealand or overseas, including in Australia.
Retention, storage and security
We will delete your personal information when it is no longer required for the purpose it was collected it for.
We will retain your personal information (including after you have fully paid back any lending) only where we are required to by law. For example, the AML Act requires us to retain certain personal information for a minimum of five years.
Your personal information will be stored physically or electronically (including via cloud storage) by us, or the persons to whom we disclose it to, in New Zealand and overseas (including Australia).
We will protect your personal information using such security safeguards as it is reasonable in the circumstances to take against loss, unauthorised access, use, modification or disclosure, and other misuse.
Our employees are assigned access rights to our electronic folders stored on cloud servers on an as needs basis. For example, our lending manager have access only to the personal information of borrowers under their management.
Your rights to access and correction
The Privacy Act 2020 gives you rights to request access to, and correction of, your personal information held by us. If you wish to exercise these rights, please contact us at: Vincent Capital, privacy@vincentcapital.co.nz, +64 (0) 9 303 0368, Lvl3, 246 Queen Street, Auckland 1010