This website is administered by Smart future funds Company. When you visit this website or otherwise interact with us we may collect personal information about you, either directly (where you are asked to provide the data, such as part of an online sign up process for certain products) or indirectly through tracking your use of the website or otherwise. We will use this personal information in accordance with the purposes set out in this Privacy Statement or contained in the applicable online form and the Privacy Act. We recognize the importance of safeguarding the personal information collected.

You may decide not to provide your personal information to us. However, if you do not provide it, we may not be able to provide you with access to the website or certain parts of the website or you may not be able to fully utilise all of our products and services.

Holding of Information

When you provide personal information it will be held by us and may be stored or accessed on our behalf (in New Zealand or overseas) by our service providers (such as those that provide data hosting services for us). We will store and keep your personal information secure in accordance with the Privacy Act and any service providers will be subject to our information security and privacy requirements.

Disclosure of Information

We will generally not share personal information that is provided or collected through this website or other interactions with you (outside of Smart future funds Company and our service providers) unless it is necessary to do so for the purpose for which you gave us the information (e.g. to process an application and tax processes), or where you consent or as required or permitted by law.

Cookies and Web Analytics

We may gather and analyse information regarding usage of this web site, including domain name, the number of hits, the pages visited, previous/subsequent sites visited and length of user session. This information may be gathered by using a cookie. A cookie is a small text file placed on your hard drive by our web page server. You can choose whether or not to use a cookie by altering the settings of your browser. The cookies are used to recognise you online and to gather information about your online activity and browsing habits (including the pages you have visited and the links you have followed). These cookies, assist us to make our websites and the advertising displayed on the websites more relevant to you (i.e. by helping us specify our content, investment portfolios and advertisements to your interests.)

These cookies may be placed on our websites by carefully selected third parties on our behalf (with our permission) in order to help us (i) track the effectiveness of advertising and online marketing campaigns, (ii) measure referrals from third party sites to our website, (iii) conduct market research. We also use other tools in order to understand and optimise user experiences, including but not limited to Google & X’s(formally Twitter) Remarketing features. We may share the information we learn through advertising/targeting cookies with carefully selected third parties for these purposes, unless you disable or block cookies. Please note this does not opt you out of being served advertising as you will continue to receive generic ads.

Purposes of Collection and Processing

• - We collect and process information about investors and visitors to our website to conduct our business, administer your accounts, to comply with certain New Zealand and global laws and regulations and to inform and make available our related company's products and services that may be of interest to you and for the development of web statistics. The information you provide may be viewable by our personnel (as appropriate), contractors and our service providers. The information will be used by us, our related companies or our service providers to contact you when necessary, e.g. to notify you about functional changes to the website and to offer or carry out services that you may find helpful (provided you have not opted out of receiving such services).
• When you subscribe to one of our newsletters or register for an information pack, the details you provide may be stored by us and in a secure third-party database by our service providers. You will be asked to provide your name, email address and other information so we can contact you and send you electronic information or future electronic newsletters.
• When you unsubscribe to our newsletter, your details will be removed from the database. When you apply for a financial service on our website your personal information will be collected and used in accordance with the terms and conditions applying to that service and this privacy statement.
• When you partner with us to provide you with services your personal information will be collected and used in accordance with our application form, investor declaration and this Privacy Statement.
• We may also use your personal information for other reasons permitted under the Privacy Act e.g. with your consent, for a directly related purpose, or where the law permits or requires it.

Amendments

We reserve the right to modify sections of this Privacy Statement at any time without notice. Please check this statement from time to time for any changes as you indicate agreement on the updated terms and conditions immediately after publishing.

Commercial Electronic Messages

If you provide us with electronic contact details, you agree that we may send you commercial electronic messages (e.g. texts and emails) for any of the purposes set out in this Privacy Statement.

CCTV Cameras In Our Offices

We may also use CCTV cameras to record footage at our offices for security and safety purposes. Recorded footage may constitute personal information under the Privacy Act 2020. The footage will be used to detect and deter criminal behaviour in our workplace. Signage advising of such equipment will give notice of the areas covered.

If you are recorded by our cameras, you have the right to access that footage so long as it relates to you and is reasonably accessible. CCTV footage will usually be retained for a period of 30 days, after which time it will usually be deleted.

Physical Address

Smart future funds Company
Unit N/G/6b, Nortex Business Centre, 105 Chorley Old Rd, Bolton BL1 3AS, United Kingdom.

Changes to our privacy statement

Smart future funds Company may modify or update this Privacy Statement from time to time as a result of changes to legislation, industry standards and/or customer feedback.

This Privacy Statement was last updated on 09 August 2023.