Information collected

Information collected may include personal information (e.g. name, email, contact address, financial information, etc). The personal information we collect may include information:

• communicated via post, email or telephone (including to our helpline)
• provided by a member's employer
• provided through completing one of our forms such as the membership application form for the scheme
• provided when registering an online account on the website, submitting an online form, requesting information, filling out a survey or application through the website or otherwise submitting information to us through the website
• provided when members use certain parts of the website (such as managing your online account and investments) or otherwise relating to your interactions and transactions on or through the website (including via your online account)
• provided through any other method (including in-person or virtual meetings, correspondence and discussions)
• collected through tracking your use of the website, including the content you access and any services you utilise, and information collected through automated technologies as further detailed below.

Automatic data collection

As members navigate through and interact with the website, automatic data collection technologies such as trackers and cookies may be used to collect certain information about a member's device, browsing actions and patterns. Some of this information may be linked to the member personally. This information is used to ensure the website functions correctly, assists in understanding the needs of members and may be used for the other purposes set out in this privacy policy. Examples of this information include:

• website traffic data, logs and other communication data
• data related to members' use of the website, pages visited, the resources and services accessed and downloaded, the time spent on each page, the date and time of a member's visit, pages members came from or go to and statistical and other aggregated data derived from members' use of the website
• information about a member's device, computer and network connection, including IP address, operating system, hardware version and browser type.

The technologies used for this automatic data collection may include trackers, log files, usage monitoring software and cookies. Members can choose to refuse cookies by turning them off in the browser and/or deleting them from their hard drive. Members do not need to have cookies turned on to use the website, but their experience may be affected.

Our administration manager Mercer (N.Z.) Limited (Mercer) may monitor and record phone calls on the helpline for quality control or staff training purposes and other purposes related to the purpose for a member's call. Members will be advised at the time if a call is to be recorded.

More extensive information may be gathered about members' interactions with the website or the scheme generally if directors are concerned about abnormal website usage patterns or security breaches.

Non-provision

Members may elect not to provide personal information. However, in such cases:

• directors may not be able to consider or process a member's application in relation to the scheme
• a member may not be able to participate in the scheme and/or manage their investments in the scheme and directors may not be able to pay members their investments
• directors may not be able to provide you with the services requested or access to certain parts of the website or members may not be able to fully utilise all of the scheme's products and services.

Information others give us

The directors may receive a member's personal information from third parties if they have authorised this disclosure or from publicly available sources.

The collection and disclosure of that personal information by those third parties will be governed by the terms the member has agreed with them.

Keeping us updated

It is important to us that the personal information held about a member is accurate and complete. Directors will regularly request through generic communication that members advise as soon as possible if they think that changes to that information need to be made.

Using your information

Directors (and Mercer and other third-party providers of services to UniSaver) may use members' personal information to:

• process and assess any application to participate in the scheme and any applications, requests or queries in relation to the management of a member's investments under the scheme
• make a decision on a member's application(s)
• provide a member with the services and/or information request
• manage and administer the scheme
• carry out a member's instructions and action their choices for their investments in the scheme
• verify a member's information and identity (including for their use of the website), carry out any checks through third parties (e.g. a member's employer and government agencies such as Inland Revenue) for UniSaver to comply with its obligations under applicable law (including the Anti-Money Laundering and Countering Financing of Terrorism Act 2009) and to assist a member if they forget their username or password for any of the services provided via the website
• assist in providing better services to members by tailoring them to meet their needs
• carry out member research and member surveys
• keep our website relevant and of interest to users
• customise the website to members' preferences and to show information that is most relevant to them based on the information provided by them or that has otherwise been collected
• contact members via electronic message regarding use of the website, their online account, the scheme or other potential aspects of the website or the scheme
• assist the directors in performing their functions and activities
• communicate with members
• comply with the scheme's or directors' legal obligations

Personal information may be used for any other purpose stated to a member at the time of collection or that they otherwise authorise. Member data or information may be aggregated for the purposes described in this privacy policy.

Sharing your information

Members' personal information may be disclosed:

• within UniSaver for the purposes set out above
• to Mercer and other third-party providers of services to UniSaver
• to the scheme's investment consultant and/or investment managers
• to government agencies such as Inland Revenue
• to third parties (e.g. to a member's financial advisor(s) or your employer if they are applying to participate in the scheme) in accordance with the uses set out above and/or if a member has requested or authorised this
• to UniSaver's contractors, suppliers and other third parties to enable them to provide services and products to the scheme and members, including in relation to the website and the scheme
• when the directors believe it is appropriate to comply with the law, to facilitate court proceedings or protect their rights
• where directors are authorised or required to do so by law.

Storage and security of your personal information

Providers of services to UniSaver may store members information on its behalf (for instance, the service providers described above).

Members' personal information may be held by UniSaver (e.g. on servers or in physical files located at the premises of service providers).

UniSaver places a high priority on the security of the personal information held. It maintains the website and all associated data with reasonable technical, administrative and physical safeguards to protect against loss, unauthorised access, destruction, misuse, modifications and improper disclosure.

The information members enter on the website, including scheme membership number and personal identification numbers, is stored securely by UniSaver and its service providers on their data servers.

While no computer system or information can ever be fully protected against every possible threat, UniSaver is committed to providing reasonable and appropriate security controls to protect the website and the personal information we hold.

Members are responsible for ensuring their devices and internet browsers are secure and can support any security measures UniSaver uses to protect their personal information. Members are also responsible for maintaining the confidentiality of their membership number and personal identification number.

Data access and correction

Under the Privacy Act 2020, members have certain rights to request access to and correction of the personal information held about them. Members should contact UniSaver using the details below.

Changes to this privacy policy

The directors of UniSaver may make changes to this privacy policy from time to time.

When such changes are made, this privacy policy will be updated on the website. The date of the latest update to this privacy policy will be noted.

Contacting us

Any questions about this privacy policy or any other matter should be communicated to:

Contact             Jenny Taylor, Privacy Officer

Phone               04 819 2657

Email                jenny.taylor@mercer.com

Mail                  UniSaver New Zealand, PO Box 2897, Wellington 6140