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Privacy Policy

Link Market Services Limited understands that privacy is important to you, and has developed this policy ("Privacy Policy") to govern, among other things, how we handle your personal information.

Our Privacy Policy is designed to answer the following questions:

1. What personal information does Link collect?

Personal information means information or an opinion from which an individual's identity may be ascertained.

Link, a provider of registry and registry related services to listed and unlisted organisations (‘Issuers’) and the holders of their securities (‘you’), may obtain personal information, including your name, email address, phone number, contact address(es) and CSN/ FIN details, from you in order to administer your security holding or to provide you with other services. If part or all of the information is not provided, then Link may not be able to supply its services to the Issuers and you.

You may also be asked to provide contact information (including telephone and facsimile numbers and email address), your tax details and information concerning your nominated financial institution.

Link’s, or Link’s agents or contractor's, server may also log the following information, which is provided by your browser:

  • Your server's IP address (a number which is unique to the machine through which you are connected to the Internet) or your personal IP address
  • The type of browser and operating system you are using
  • The domain name of the referring site (i.e. the previous website that you visited). 

The server may also log:

  • The date and time of your visit
  • The URL address of the pages accessed and the documents downloaded.

This information does not personally identify you, however Link or its agents or contracts may analyse this non-personal information to identify certain trends and statistics, such as which parts of the Investor Centre users are visiting and how long they spend there, among other possible uses.

Link will not try to identify you or your browsing activities except, in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect the service provider's logs or if your usage is causing technical issues for the Investor Centre Link website which may need to be resolved. Link may, in these circumstances, identify your IP address to enable Link to contact you.

Companies Act 1993

As agent for Issuers, Link collects personal information about you (including your name, address and details of the securities you hold/ held) on behalf of Issuers in which you hold securities in accordance with the requirements of the Companies Act 1993 ("Companies Act"). This information is included in the public register of the Issuer in which you hold securities for a period of 10 years after you cease to be a security holder and may be required to be publicly disclosed by Link pursuant to the requirements of the Companies Act and the Financial Market Conduct Act 2013 ("FMCA"). 

Anti Money Laundering and Countering Finance of Terrorism Act 2009

Link may also collect personal information about you including, but not limited to, your legal name, other names you may be known by, your residential street address and your date of birth, for the purpose of identifying you to meet Link's obligations under the the Money Laundering and Countering Finance of Terrorism Act 2009 ("AML/CFT Act").

This information may be collected on behalf of Issuers, and on behalf of Link/LMS Custodians Limited for our 'Share Sale Centre'. The AML/CFT Act requires a designated reporting entity to collect this information where a ‘customer’ (investor) is conducting a transaction covered by the AML/CFT Act.

This information will not generally be included in the public register. Access to information collected under the AML/CFT Act is restricted to authorised Link employees, the Issuer for which we collected the information, the AML/CFT Regulator and law enforcement agencies.

2. How is personal information collected and stored?

This will depend on how you interact with us or the services you require. We may collect personal information about you from an application or a registration form or verbally if you call our call centre or speak directly with our staff.

In addition, if you access your information on-line through our Internet site [www.linkmarketservices.com] we may collect personal information relating to your holding during your visit to the website. The personal information is maintained on our servers, and a reference to this information is sent to the application you are using to access the Internet, in the form of a non-persistent "cookie". A "cookie" is a method employed to maintain a link between the application you are using and the website you are visiting. It is also used for security purposes. Non-persistent cookies exist only in the application's memory and are destroyed when the application is shut down. This behaviour is different to persistent cookies, which are stored on your computer and which may remain there for an extended period of time. Link specifically and exclusively uses a non-persistent (or session) cookie, which means once you exit your application the cookie and the reference to the data it contains is destroyed.

For on-line access to information about your security holding, you will be required to authenticate your identity through a ‘knowledge’ process. This means that you must identify all of the following three fields adequately to gain and protect your access on-line:

  • Holder Identifier (i.e. your Common Shareholder Number (CSN) or Holder Number)
  • Faster Identification Number (FIN)
  • Surname/Company Name

Link takes reasonable steps to ensure the security of personal information held by it from risks such as loss or unauthorised access, destruction, use, modification or disclosure.

3. How is personal information used?

Link only uses personal information obtained from you for the purpose for which it was collected and to offer and provide related services that are connected to that initial purpose. For example, the personal information collected from you by Link may be used to:

  • Provide the relevant Issuers and you with registry and related services, or with other information you have requested; and/or
  • Notify you about other Issuer or Link services relating to the purpose for which your personal information was collected. If at any time you no longer wish to be notified about other Issuer or Link services, please let us know.

Please note that the personal information collected about you may be disclosed to related companies of the Issuer or Link, but only if this relates to the purpose for which your personal information was collected.

Please note that under the Companies Act and the FMCA, certain information regarding you as a securityholder (including your name, address and details of the securities you hold) must be included in the public register of the entity in which you hold securities and, therefore this information will be disclosed and is in the public domain.

Link will not use or disclose your personal information for any other purpose without first obtaining your express or implied consent.

4. Will personal information be given to anyone else?

Link will seek to maintain the confidentiality of all personal information provided and will take all reasonable steps in order to protect your personal information from misuse and loss, and from unauthorised access, modification or disclosure.

Link does not sell, rent or trade personal information to, or with, third parties. In some circumstances however, personal information may be disclosed by Link, for example:

  • Disclosures may be required or authorised by or under law (for example, in accordance with the Companies Act, where a person requests a copy of an Issuer's register of security holders).
  • Personal information collected by Link may be disclosed to third parties to which Link contracts out specialised functions (including mailing houses and printing companies). If so, we take reasonable steps to ensure that those contractors comply with the Privacy Act, and are authorised only to use personal information in order to perform the functions required by Link.
  • Personal information may be disclosed to third parties in accordance with the Issuer’s direction where this is related to the Issuer’s administration of security holdings.

5 What security precautions are taken to safeguard my personal information?

Link employs appropriate technical security measures to protect your personal information and to ensure that it is not accessed by unauthorised persons. Information is held on secure servers and is encrypted wherever this is possible. This is the same encryption used to transmit credit card details over the Internet when buying merchandise online.

Our security procedures also provide that, in addition to any password, which you may require to gain access to the service, you may have to provide proof of identification before we will release personal information to you. Multiple incorrect attempts or invalidation, result in a lockout from the information.

We undergo periodic reviews of our security policies and procedures to ensure that our systems are secure and protected. You should never divulge your identification numbers, username or password to anyone else. You should also never write your password down or store it on your computer and you should make sure you change it regularly.

6. How can you access and correct your personal information?

Under the Privacy Act, you have a right to seek access to certain information that we hold about you. You also have the right to ask us to correct information about you which is inaccurate, incomplete or out of date. Link will consider any requests for access or correction in a timely way and take reasonable steps to correct the information so that it is accurate, complete and up-to-date.

To provide you with access to your personal information, Link would ordinarily provide you with a print-out of the relevant personal information from our current databases, or with photocopies of records which are held only on paper files.

To provide you with access to personal information we collected under the AML/CFT Act, the Issuer and Link/LMS Custodians Limited will only provide you with a copy of, or confirmation of the relevant personal information that we collected from you. The AML/CFT Act prevents the issuer and Link/LMS Custodians Limited from revealing certain information.

To access and/or correct such information, you may write to or call Link on the following:

Telephone: Auckland (09) 375 5998
Facsimile: Auckland (09) 375 5990
In writing: PO Box 91976

Auckland 1142

If you wish to correct current information about you which is inaccurate, incomplete or out-of-date then, for security purposes, you will need to prove your identity by confirming/providing the following information to us:

  • Quote your CSN/Holder Number that appears on the latest documentation sent to you in relation to your security holding; or
  • Provide proof of your registered name (Note: supporting documentation e.g. birth certificate, marriage certificate may also be required), and
  • Provide proof of your registered address that matches the details appearing on the register.

A form signed by you will also need to comply with the signing requirements below:

Individual holder: Must be signed by the securityholder or his/her attorney or a parent/guardian (if under 18) or a trustee such as a bankruptcy trustee or an Executor of a deceased estate.
Joint holders: Must be signed by all joint securityholders or their attorney(s) as stated above.
Companies: Must be signed by either; two or more directors; or if there is only 1 director, by that director whose signature must be witnessed;or if the constitution of the company so provides, a director, or other person or class of persons whose signature or signatures must be witnessed; or if the constitution of the company so provides, a director, or other person or class of persons whose signature or signatures must be witnessed; or a person acting under the company's express or implied authority.

For legal and administrative reasons, Link may also store records containing personal information in its archives. You may seek [access or copies] to the records held by Link which are not current records, but if you do so, you may be charged for the reasonable cost of providing access.

If you have any questions or comments about this Privacy Policy, or if you wish to complain about how we have handled personal information about you, please contact Link’s Privacy Officer:

Telephone: (09) 375 5998
Facsimile: (09) 375 5990
Email: operations@linkmarketservices.com
In writing: The Privacy Officer, Link Market Services Limited, PO Box 91976 Auckland 1142

If you have a privacy complaint, Link’s Privacy Officer will try to resolve the issue. Where the matter cannot be resolved to your satisfaction, you may refer it to The Privacy Commissioner who may be contacted on 0800 803 909 or by post to PO Box 10094, The Terrace, Wellington 6143.

This Privacy Policy may change from time to time and we recommend that you review it periodically, including prior to the provision of any further information to Link which is covered by this policy.