Privacy Policy

Progressive Financial Planning Ltd is committed to protecting your privacy. We have robust
systems in place to provide you with services and information tailored to your individual
needs while complying with our obligations under the Privacy Act 2020 (Privacy Act).
The Services are intended for use by people located in New Zealand and are not intended
for use by anyone located outside of New Zealand.
References to “PFP Ltd ”, “we” or “us” in this Privacy Policy means Progressive Financial
Planning Ltd.
We may change this Privacy Policy from time to time and we will tell you about a change in
the Privacy Policy by updating the “last updated” date on our website. Unless otherwise
stated, any changes to the Privacy Policy will take effect immediately upon being placed on
the website and your continued use of the Services will represent an agreement by you to be
bound by the Privacy Policy as amended.

Last updated: 05/04/2022
1. APPLICATION OF THIS PRIVACY POLICY
down icon

This Privacy Policy applies to any personal information that we collect when you interact with
us, including when you:
• visit the Progressive Financial Planning Ltd; 
• request our advice regarding any financial product or service irrespective of whether you
accept Progressive Financial Planning Ltd as your adviser in respect to any financial product
or service;
• use any of Progressive Financial Planning Ltd websites and mobile applications; 
• register to receive regular marketing communications; and/or
• any other services we provide now or in the future, 
(together, the Services). 
In the event of any inconsistency between this Privacy Policy and other policies or terms and
conditions that may apply to your use of any of the Services, the terms of this Privacy Policy
will prevail.

2. COLLECTION OF PERSONAL INFORMATION AND YOUR PRIVACY
down icon

From time to time we may collect or request personal information from you in the course of
providing you, or by you accessing and using, the Services.  Personal information is any
information about you that identifies you, or by which your identity can reasonably be
ascertained.

3. WHAT INFORMATION MIGHT WE COLLECT?
down icon

The type of personal information we may collect when you access and use the Services
includes your name, address, email address, phone number, details of assets, investments
and liabilities, age, gender, family members, personal objectives and goals and any other
information that we request.
You may register with PFP Ltd to receive regular marketing communications from us, for
example via email or text message. If you choose to register to receive regular marketing
communications or to use any of the Services, you will need to provide us with certain
personal information to create an account, which may include your name, age, postal
address, email address, phone number and other requested information.

If you do not provide us with some of this information then you may not be able to access
some or all of the Services, including the marketing communications available after
registration.
From time to time we may also collect from you in the course of providing you, or by you
using, the Services, information that is not personal information at the time of collection
(Non-identifiable Information). However, by choosing to register to use any of the
Services, you agree that we may combine the Non-identifiable Information with your
personal information that we collect, or that is otherwise held by PFP Ltd, its partners or
service providers, in a manner that will change the nature of the Non-identifiable Information
such that it becomes personal information. You agree that

4. WHY DO WE COLLECT PERSONAL INFORMATION?
down icon

We collect personal information in order to provide you with, and allow you to access and
use, the Services.
By accessing and using the Services, or by registering to receive marketing
communications, you agree that we may collect, store and use any of your personal
information including to do any of the following:
• To allow you to access and view your account created to receive the Services or marketing
communications;
• To assist in providing the Services that you request, including to contact you about your use
of the Services and process and deliver any additional Services. 
• To take actions required to keep your information secure;
• To enhance your overall experience of the Services;
• To provide or send you targeted marketing (or allow a third party to provide you) via email,
online (including social media) or physical mail, with details of special offers and information
about products or services offered by PFP Ltd, or other third party providers, or other
information that may be of interest to you, your family or household; 
• Identify and determine the benefits, offers or promotions that may be of interest to you,
your family or household based on your use of the Services;
• To undertake data analytics, insights or data mining (including the anonymisation or
aggregation of your personal information with other data to identify patterns and trends, and
use the full benefit of that analysis); 
• To build a view of you as a client by collating all personal information that PFP Ltd, and our
partners and service providers, hold about you, including collected via any PFP Ltd
managed platforms or services, in a single profile, so that we can analyse and improve your
experience and the services provided to you by PFP Ltd; 
• To conduct research related to your use of the Services; 
• Such other purpose we make known to you at the time of collection.
In doing so, your personal information may be combined with other personal information held
by PFP Ltd, our partners and service providers.
Where possible, PFP Ltd will collect your personal information directly from you.

5. DO WE DISCLOSE PERSONAL INFORMATION TO ANYONE ELSE?
down icon

In providing you with, or by you accessing and using, the Services, including where you
register for an account to use the Services, we will need to disclose some of your personal

information to others. By using one or all of the Services you agree that we may disclose
your personal information for any of the purposes listed in the above section to:
• a third party outside of PFP Ltd who is partnered with us to provide a particular service to
you e.g. wrap service providers, fund managers, KiwiSaver Managers, mortgage service
providers, insurance service providers; 
• a third party outside of PFP Ltd who is contracted to us to provide a particular service to us;
• third parties when we believe in good faith that we are required to do so by law, eg:
Financial Markets Authority when they are fulfilling their statutory role. 
You consent to the disclosure of your personal information to the parties listed above.

6. COOKIES AND TRACKING
down icon

When you access PFP Ltd, social media pages and/or mobile apps, we may use cookies to
track your use of the Services so that we can provide you with the best possible experience.
A cookie is a small piece of data that a website sends to your browser that may be stored on
your system. Some information/services may be unavailable if you chose to disable your
browser from accepting cookies.
We may use the information generated by cookies to:
• track traffic patterns to and from the relevant website;
• ensure any content (which may include any advertising) is being shown to the most
appropriate person; and
• enable us to serve targeted advertising to you (on our Site and elsewhere).
By using the Services you consent to the storing and accessing of cookies or other
information on your device in connection with your use of the Site.

7. ANALYSIS TOOLS
down icon

We may use various app, web and/or email analytics tools to collect information about your
activity when you use the Services through our website or mobile applications.  The
information we collect through the use of such analytics tools may be information about you
(e.g. products or services that you engage with on the website) or anonymous information
(e.g. the number of visitors per day or the average amount of time spent on the website).  By
accessing and using our website, you consent to our use of such analytics tools to collect
information about your access and use of the Services through that site.

8. DIRECT MARKETING AND CONSENT TO RECEIVING MESSAGES
down icon

When you register to receive marketing communications from us, your name and contact
details will be added to our PFP Ltd database, and you consent to receiving messages from
us by email, text message, or physical mail (depending on what information you provide us
and your stated preferences). 
All commercial electronic messages from us will contain an unsubscribe function if you no
longer want to receive commercial electronic messages from us. You can unsubscribe from
receiving emails from PFP Ltd at any time by clicking the link in any email you receive from
us or by contacting the specified PFP Ltd email address or planning @pfp.co.nz. We will
endeavour to update your account preferences as soon as possible.  If you unsubscribe or
cancel your registration we may not be able to provide you with all or some of the Services.

9. SECURITY OF PERSONAL INFORMATION
down icon

Security of personal information is very important to us and we will take all reasonable steps
to protect your personal information from misuse, loss, unauthorised access, modification or
disclosure.  However, you acknowledge that security of the transmission of data over the
internet can never be guaranteed, and it is your sole responsibility to protect access to any
emails you receive from us that provide access to your account. To the maximum extent
permitted by law, PFP Ltd will not be liable for any direct or indirect damage or loss if any
third party gains unauthorised access to your information.

10. ACCESSING, CORRECTING AND UPDATING PERSONAL INFORMATION
down icon

Your personal information will be held by PFP Ltd, 96 Ravensdale Rise, Westmorland
Christchurch, 8025 and/or by one or more of PFP Ltd’s trusted data service providers. Under
the Privacy Act you have the right to access your personal information that we hold, and to
have that information corrected and/or updated. You may be able to update some of your
personal information online via your account. To otherwise access, correct or update
information we hold about you please contact us on 03 36-888-66 or planning@pfp.co.nz.
We will rely on the information that you have provided us so please ensure that information
is accurate and kept up-to-date.
If you find that information we hold about you is incorrect, please contact us immediately and
we will correct it.  Our contact details are above.