Privacy Policy

Calibre Partners (‘Calibre Partners’, ‘we’, ‘us’ or ‘our’) is committed to protecting and respecting your
privacy and will seek to comply with the privacy legislation in New Zealand. This policy does not apply to
personal information that is exempted under the Act.

This privacy policy sets out how Calibre Partners collects and uses personal information and how Calibre
Partners aims to protect the privacy of your personal information.

This policy applies to Calibre Partners, Calibre Partners Limited and any related entity and the services
operated by us.

Calibre Partners may update this policy from time to time.

1. Privacy Act and personal information

The Privacy Act 2020 (‘Privacy Act’) and the relevant privacy principles under the Privacy Act regulate how
private sector organisations collect and use personal information.

For the purposes of the Privacy Act, personal information is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

2. Reasons for collecting personal information

Calibre Partners collects personal information primarily for the purpose of providing our services and
conducting our business. This may involve collecting personal information from you to comply with our
obligations under the Companies Act 1993, Receiverships Act 1993, Insolvency Practitioners Regulations
Act 2019, Companies (Reporting by Insolvency Practitioners) Regulations 2020, [Takeovers Act 1993]:

  • when appointed as external administrators to a company or individual respectively
  • provide advice to you, an associated entity or a third party
  • consider an employment application from you
  • consider procurement of services from you
  • provide you with information on our website and other online services
  • provide our publications to you
  • respond to queries you submit to us
  • provide you with information about our services that may be of interest to you
  • administer accounting, billing and other internal administrative services
  • comply with our legal requirements under any applicable laws, including Anti-Money Laundering and Countering Financing of Terrorism legislation and any other legal requirements we must comply with.

You are not required to provide your personal information to us. However if you choose not to provide
personal information to us where requested (or provide inaccurate or incomplete information), we may
not be able to provide services to you or in the case of an external administration we might not be able to
deal with your claim and make payment of entitlements to you (for example, voluntary administration,
receivership or liquidation appointments).

3. Personal Information collected by Calibre Partners

Calibre Partners collects personal information such as an individual’s name, date of birth, address,
telephone number, email address, personal identification details, IRD number, bank account details,
investment information and employment information.

In circumstances limited to prospective employees or employees of companies subject to external
administrations, Calibre Partners will collect sensitive information such as membership of a profession or
trade association, membership of a trade union or seek information regarding a criminal record or credit
check. In the case of prospective employees, your photo may be taken.

4. How Calibre Partners collects personal information

Generally, Calibre Partners will collect this personal information directly from you, for example by
requesting that you provide the information when you:

  • fill out an application form
  • submit a form to us
  • enter into an agreement with us
  • engage in social media with us
  • correspond with us
  • subscribe to a distribution list.

In the case of externally administered companies, this information may come into our possession when
appointed as external administrators to a company or an individual in accordance with the Companies Act
or Receiverships Act or by other lawful appointment.

There may be other occasions when we collect personal information about you or from other sources, such as from a publicly maintained record or from an information services provider, for example where we are required to verify your (a) identity and/or (b) bank account information (if a payment is due to you) under Anti-Money Laundering and Countering Financing of Terrorism Act legislation.

5. Disclosure of your personal information by Calibre Partners

We may disclose personal information for the purposes for which it was collected and also:

  • As required by law and permitted under the privacy principles;
  • To third parties, including external service providers whom we ask to perform services for us or to whom information must be disclosed to in the course of our provision of services;
  • To our professional advisers; and
  • To government, regulatory or other agencies.

The types of third parties to which we may disclose personal information include:

  • your financial, legal or other professional advisers or other persons you have authorised to act on your behalf
  • service providers we engage to provide administration, technology, auditing, mailing, printing or other services
  • regulatory or government authorities (where required by law)
  • our professional advisers (including legal and accounting firms, auditors, consultants and other advisers)
  • our related companies.

Some of the recipients to whom Calibre Partners may disclose your personal information may be based
overseas.

6. Security of your personal information

Calibre Partners takes all reasonable steps to protect the personal information we hold about you from
misuse and loss and from unauthorised access, modification or disclosure.

Personal information may be held in physical form. Our security measures to protect this information
include access-controlled premises.

Personal information may also be stored in electronic form in our information technology systems. The
security measures that we employ include restriction on access, firewalls, passwords and privacy and data
protection training for staff and partners.

Calibre Partners has in place a number of data security, information security and other similar security
policies and procedures. These policies and procedures are regularly reviewed to ensure they remain
current and appropriate.

We will retain personal information for as long as we need it to fulfil the purpose for which it was collected
and as required by law.

7. Disclosure of personal information outside New Zealand

An agency disclosing personal information to foreign persons or entities may only make that disclosure if it reasonably believes the foreign person or entity meets at least one of the following criteria:

  • is carrying on business in New Zealand and is subject to the Privacy Act
  • is subject to privacy laws that overall, provide comparable safeguards to those in the Privacy Act, or
  • is required to protect the information in a way that, overall, provides comparable safeguards to those in the Privacy Act (for example, by agreement between the agencies)
  • is subject to the privacy laws of a country, province or State, or is a participant in a binding scheme for international disclosures of personal information that has been prescribed in regulations by the New Zealand Government as providing comparable safeguards to the Privacy Act.

8. Accessing or changing personal information

Under the Privacy Act, you have a right to access or change your personal information that is collected and held by Calibre Partners.

If you would like to access or change the personal information Calibre Partners holds about you, you can
contact Calibre Partners and request the relevant change or access. In the first instance, you should
contact your Calibre Partners contact if you have one. Otherwise, please contact us as outlined below. To
change your details, complete this form and provide it, along with the required supporting information, to
your Calibre Partners contact or via one of the other options.

To action any change or access request, we will need to verify your identity and comply with our other
procedures which are in place to prevent unauthorised access to personal information.

Calibre Partners will not normally charge you any fees or costs for access to your personal information.
Fees or costs may apply if providing you with access would require us to incur retrieval or other out of
pocket costs. We will notify you if any such fees or costs would be payable.

9. Privacy complaints

If you believe that Calibre Partners has contravened the Privacy Act or have any other privacy complaint
regarding Calibre Partners, you can make a complaint by contacting our Privacy Officer as below.

Calibre Partners will seek to resolve any privacy complaints and will deal with privacy complaints as quickly as possible and in a respectful and confidential manner.

Calibre Partners will investigate any privacy complaint you make and will inform you of the outcome of
your complaint following the completion of the investigation.

In the event you are dissatisfied with the outcome of your complaint, you may refer the complaint to the
Office of the Privacy Commissioner.

10. Contact us

For further information or enquiries regarding your personal information, please contact the Privacy
Officer at privacy@calibrepartners.co.nz, on +64 (0)9 307 7865 or by mail c/- Calibre Partners, PO Box 982,
Shortland Street, Auckland 1140.