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Privacy Policy

Last updated: June 2026

1. Introduction

Smart Brokers Limited trading as SMART (‘we’, ‘us’, ‘our’) is a licensed Financial Advice Provider (FAP) under the Financial Markets Authority (FMA). We are committed to protecting your privacy and handling your personal information in compliance with the Privacy Act 2020 (including the Privacy Amendment Act 2025), the Financial Markets Conduct Act 2013, and the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act).

This Privacy Policy explains how we collect, use, store, and disclose your personal information in connection with our financial advice services, including mortgage broking, life and health insurance, KiwiSaver advice.

By engaging our services or using our website (www.smartbrokers.co.nz), you acknowledge that you have read and understood this policy.

2. What Personal Information We Collect

We may collect personal information including, but not limited to:

  • Full name, date of birth, and contact details
  • Financial information (income, expenses, assets, liabilities)
  • Employment details
  • Identification documents (for identity verification under the AML/CFT Act)
  • Insurance and mortgage-related information
  • Credit history and credit reports
  • Health information, where required for insurance advice — collected only with your explicit consent
  • Any other information required to provide financial advice and services

3. How We Collect Your Information

3a. Directly from you

Including when you:

  • Complete forms on our website
  • Engage with us via phone, email, SMS, or social media
  • Use our services or coaching programmes
  • Respond to lead generation or advertising (including via Meta/Facebook or YouTube)

3b. Indirectly from third parties

Including:

  • Referral partners, advisers, or introducers
  • Lenders, insurers, and financial service providers
  • Credit reporting agencies
  • Publicly available sources
  • CRM systems and technology platforms

4. Purpose of Collecting Your Information

We collect your personal information to:

  • Provide mortgage, insurance, and KiwiSaver advice
  • Arrange financial products and services
  • Assess your eligibility for lending, insurance, or KiwiSaver
  • Verify your identity as required under the AML/CFT Act
  • Communicate with you and manage our relationship with you
  • Comply with legal and regulatory obligations as a licensed FAP
  • Improve our services and systems

5. Use of Your Information

We use your personal information only for the purposes outlined above, including information collected both directly and indirectly.

6. Disclosure of Personal Information

We may disclose your personal information to:

  • Lenders and financial institutions
  • Insurance providers
  • KiwiSaver providers
  • Credit reporting agencies
  • Referral partners and introducers
  • Our aggregators — Newpark Home Loans (mortgage) and mySolutions (insurance)
  • Service providers (including CRM, messaging, AI-assisted tools, and IT platforms)
  • Regulatory bodies and government agencies where required by law

In some cases, we may receive your information from third parties and also share your information with third parties as part of providing our services. Where required, we will comply with our obligations under the Privacy Act, including Information Privacy Principle 3A (IPP3A).

We do not sell, rent, or trade your personal information.

6a. Indirect Collection of Personal Information (IPP3A Compliance)

We may collect personal information about you from third parties rather than directly from you. Where we do so, we will take reasonable steps to ensure you are aware of:

  • The fact that we have collected your personal information
  • The purpose for which the information has been collected
  • The intended recipients of the information
  • Our name and contact details
  • The name of any organisation holding your information (if different from us)
  • Whether the collection is authorised or required by law (and the relevant law, if applicable)
  • Your right to request access to and correction of your personal information

We will provide this information either before the information is collected, or as soon as reasonably practicable after collection, unless an exception applies under the Privacy Act 2020.

We may notify you of indirect collection via email, SMS, phone call, disclosure from a referral partner, or during onboarding or initial engagement.

7. Use of Artificial Intelligence and Automated Tools

To improve the efficiency and accuracy of our advice process, SMART may use AI-assisted tools and technology platforms to help process and analyse client information. These tools assist with tasks such as preparing loan applications, generating client summaries, and streamlining administrative tasks.

Where such tools are used, we ensure that:

  • Your data is not used to train third-party AI models
  • All data shared with technology providers is encrypted in transit and at rest
  • Providers hold appropriate data processing agreements and privacy commitments
  • A qualified financial adviser reviews all AI-assisted outputs before any action is taken on your behalf
  • Data shared with technology tools is limited to what is strictly necessary for the task
  • Your personal information is deleted by those platforms promptly after processing, unless you have specifically authorised longer retention

Important

AI tools are used as a drafting and efficiency aid only. All financial advice decisions remain the responsibility of your SMART financial adviser.

8. Storage and Security

We take reasonable steps to protect your personal information from loss, unauthorised access, misuse, or disclosure. Safeguards include:

  • Encrypted communications (HTTPS) between your device and our systems
  • Secure, access-controlled storage of client files and records
  • Use of reputable third-party cloud storage providers with strong security practices
  • Staff awareness and training on privacy obligations

Where personal information is transferred to servers located outside New Zealand (for example, through cloud-based tools), we take appropriate steps to ensure it receives protections comparable to those under the Privacy Act 2020, consistent with Information Privacy Principle 12.

9. Notifiable Privacy Breaches

Under the Privacy Act 2020, if a privacy breach occurs that is likely to cause serious harm to any affected individual, we are required to notify both the affected individual(s) and the Office of the Privacy Commissioner as soon as practicable. We have internal processes to identify, assess, and respond to privacy breaches promptly.

10. Retention of Information

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, and to meet our legal and regulatory obligations, including:

  • A minimum of 7 years following the provision of financial advice, as required by the FMA
  • A minimum of 5 years after the end of a client relationship for AML/CFT compliance records

When personal information is no longer required, we will destroy or de-identify it securely.

11. Access and Correction

You have the right to:

  • Request access to the personal information we hold about you
  • Request correction of any inaccurate information we hold

To make a request, please contact us at info@smartbrokers.co.nz. We will respond within 20 working days as required by the Privacy Act 2020. We may charge a reasonable fee for retrieval of information in some circumstances.

12. Cookies and Website Analytics

Our website may use cookies and analytics tools to improve user experience, track website performance, understand visitor behaviour, and support our advertising activities (including Meta/Facebook and YouTube). Cookies are small text files stored on your device.

You can disable cookies through your browser settings, though this may affect some website functionality. By continuing to use our website, you consent to our use of cookies as described in this policy.

13. Marketing and Anti-Spam

We comply with the Unsolicited Electronic Messages Act 2007. We will only send you commercial electronic messages (including email and SMS) where we have your consent, or where the law otherwise permits. Every marketing message we send will include an unsubscribe option.

If you do not wish to receive marketing information, you may opt out at any time by contacting us at info@smartbrokers.co.nz.

14. Identity Verification (AML/CFT)

As a reporting entity under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009, we are required by law to verify the identity of our clients before providing certain financial services. This includes collecting and retaining copies of government-issued identification and conducting ongoing monitoring where required. This information is held securely and used only for AML/CFT compliance purposes.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in legislation, our business practices, or the services we provide. The current version will always be available at www.smartbrokers.co.nz/privacy-policy. By continuing to engage our services after any update, you accept the revised policy.

16. Contact Us

If you have any questions or concerns about this Privacy Policy or your personal information, please contact:

  • Email: info@smartbrokers.co.nz
  • Phone: 0800 405 801
  • Post: PO Box 424, Whitianga 3542

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner at www.privacy.org.nz or on 0800 803 909.