Kinly Privacy Policy

1. Introduction

The New Zealand Guardian Trust Company Limited, trading as Perpetual Guardian (referred to in this Privacy Policy as "Perpetual Guardian", "we", "us", "our") respects the privacy of the personal information you may provide to us when we deal with you. The way we manage your personal information is governed by the Privacy Act 1993 (Privacy Act) and the New Zealand Information Privacy Principles established under the Privacy Act.

For the purposes of this Privacy Policy, "personal information" has the meaning given to it in the Privacy Act, which is information about an identifiable individual. Examples of personal information include an individual's name, address, telephone number and date of birth.

This Privacy Policy explains how we handle any personal information we hold about you. Please note that this Privacy Policy is to be read subject to any overriding provisions of law or contract.

2. Collecting personal information

2.1 What kinds of personal information do we collect?

The kinds of personal information we may collect include but are not limited to:

  • information collected when you register, create or update your account, including your name, address, date of birth, contact details and other personal details;
  • financial information that you may submit through the mobile application software (App) or our website;
  • content of electronic applications and images that you submit through the App, requesting us to take action, or to provide services or information;
  • personal information provided when you commence a business relationship with us;
  • personal information provided if you seek employment with us;
  • contact and identification details of any third party whom you have authorised to negotiate or provide your personal information on your behalf (including any agents or attorneys appointed by you under a power of attorney);
  • any correspondence between you and us; and
  • any other personal information provided to us when you make an inquiry, request information, correspond with us or lodge a complaint.

2.2 How do we collect personal information?

Where possible, we always try to collect personal information directly from you, for example when you:

  • request information or contact us through our App or website or we contact each other by other means such as by telephone, in writing or emails;
  • purchase our App; or
  • meet with us in person.

2.3 Dealing with us anonymously

It is generally not possible for us to enter into a business relationship or carry out commercial transactions with you without your personal information.

3. Why do we collect, hold, use and disclose your personal information?

We collect, use and disclose your personal information to carry out our commercial activities, operations and to provide the services, products and information you request.

In particular, we may collect, use and disclose your personal information so that we can:

  • accept your purchase;
  • respond to your requests or inquiries and provide you with any publications, information or other services requested by you;
  • assess your application for employment;
  • maintain and administer your business or other relationship with us (for example, updating and maintaining our records);
  • communicate with you during the course of your business or other relationship with us;
  • administer, support, improve and develop our business activities and services;
  • notify you about important changes or developments to our functions, activities, services, website or our App;
  • carry out any other activities which relate to or arise out of any investments or requests made by you;
  • process and respond to you if you make a complaint;
  • do anything which you authorise or consent to us doing; or
  • take any action we are required or authorised by law to take.

If you do not provide us with your personal information, it may not be possible for us to carry out these functions and activities.

4. Disclosing your personal information

4.1 Who we may disclose your personal information to

We may disclose your personal information to:

  • our related bodies corporate;
  • our shareholders;
  • our business partners and service providers (such as contractors who provide website, IT, marketing, administration and other services to support us);
  • suppliers we engage for data processing and other administrative and support functions;
  • our professional advisers (for example, our insurers, auditors, lawyers, accountants and consultants);
  • your authorised agents or attorneys;
  • financial institutions (for payment processing);
  • any entity to whom we are required or authorised by law to disclose your personal information (for example, law enforcement agencies and government and regulatory authorities); and
  • with your consent (express or implied) - other entities.

The above entities may in turn disclose your personal information to other entities as described in their respective privacy policies or notices.

5. Dealing with Kinly online

This Privacy Policy applies to your use of our website ( and any personal information that you may provide to us via our website.

When you visit our website, we and/or our contractors may collect certain information about your visit. Examples of such information may include:

  • Cookies - Cookies are small amounts of information which we may store on your computer (after you register on our website) to enable our server to collect certain information from your web browser. Cookies in themselves do not identify the individual user, just the computer used. Cookies and other similar technology make it easier for you to log on to and use the website during future visits. It also allows us to monitor website traffic, to identify you when you visit this website, to personalise the content of the website for you and to enable you to both carry out transactions and have access to information about your account. Cookies only record which areas of the site have been visited by the computer in question, and for how long. Allowing us to create a cookie does not give us access to the rest of your computer and we will not use cookies to track your online activity once you leave our site. Cookies are read only by the server that placed them, and are unable to execute any code or virus; and
  • Site visit information - we collect general information about your visit to the Kinly website. The information we collect is not used to personally identify you, but instead may include your server address, the date and time of your visit, the pages you accessed and the type of internet browser you use. This information is aggregated and used for the purposes of system administration, and to prepare statistics on the use of our website. Our App or website may contain links to other websites which do not belong to us and are not covered by this Privacy Policy. If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their privacy policy, which may be different from ours.

6. Data storage, retention, security and location of your personal information

We will take reasonable steps to protect your personal information from loss, misuse, interference, unauthorised access, modification or disclosure. We may store your personal information in different forms, including in hardcopy and electronic form. We have implemented policies, procedures and systems to keep your personal information secure.

We may be required by law to retain certain information for a set period of time. Once this period of time expires, or we no longer need to hold your personal information, we will take reasonable steps to destroy, delete or de-identify your personal information in a secure manner.

7. Overseas disclosure of personal information

Where we disclose your personal information to an entity located overseas, we will take reasonable steps to ensure that the overseas recipient of your personal information handles your personal information in accordance with the Privacy Act.

8. Access and correction

To effectively conduct business with you, it is important that the personal information we hold about you is complete, accurate and current. At any time while we hold your personal information, we may ask you to tell us of changes to your personal information.

Correcting personal information

You can request us to update or correct your personal information if you believe that the personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading or otherwise needs to be corrected or updated. Our contact details are provided below. We will respond to a request to correct your personal information within a reasonable period after the request is made.

Accessing your personal information

You can also request access to the personal information we hold about you by contacting us using our details provided below. We will respond to a request for access within a reasonable period after the request is made, either by giving you access to the personal information requested, or by notifying you of our refusal to give access.

We will not charge you an application fee for making a request to access the personal information we hold about you or for making any corrections to your personal information.

However, we may charge a reasonable fee to cover our costs of providing you with access to your personal information, for example, if you make multiple requests for information, where your request relates to a large volume of information, or we incur third party costs in providing you with access.

We may request to verify your identity before responding to any request.

If we decide not to provide you with access to or correct your personal information, we will give you reasons for our decision.

9. Lodging a complaint

If you have a complaint about how we handle your personal information (including how we dealt with any requests to correct or access your personal information), please contact us at the contact details below. Please note that we may ask you to lodge your complaint in writing.

We will acknowledge receipt of your complaint as soon as possible after receiving your complaint in writing. We will investigate your complaint and provide you with a response within a reasonable timeframe.

If you are not satisfied with how your complaint is handled by us, then you can lodge a formal complaint with the Office of the New Zealand Privacy Commissioner at:


  • +64 4 474 7590 (Wellington)
  • +64 9 302 8680 (Auckland)

PO Box 10-094, The Terrace, Wellington 6143

Fax: +64 4 474 7595

Email: [email protected]



10. Contacting Us

If you wish to contact us regarding our handling of your personal information or any of the matters covered in this Privacy Policy, please contact the Kinly Product Manager

by post at: 

  • Perpetual Guardian
  • PO Box 1934
  • Shortland Street
  • Auckland 1140

by email: through the 'Contact' page on our website

by telephone: +64 9 927 9400

We welcome your questions and any suggestions you may have about our Privacy Policy.

11. Changes to this Policy.

Perpetual Guardian reserves the right to revise or supplement this Privacy Policy from time to time. The updated version of this Privacy Policy will be posted on our website and will be effective from the date of posting.

This Privacy Policy was last updated on 27 July, 2017.