Privacy Policy
Aurellan Asset Management Limited (“Aurellan”, “we”, “us”, “our”)
Effective date: 15 May 2026
Last updated: 2 September 2025
1. About Aurellan
Aurellan Asset Management Limited is a New Zealand-based asset management business providing investment management and related financial services to retail and wholesale clients. We are registered on the Financial Service Providers Register and (where applicable) hold the relevant FMA licences. We are a reporting entity under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (“AML/CFT Act”).
2. The personal information we collect
The types of personal information we collect depend on your relationship with us, but may include:
•Identity information – full name, date of birth, country of birth, photograph from identification documents, signature, IRD number, tax residency, and politically exposed person (PEP) status.
•Contact information – residential and postal addresses, email addresses, and phone numbers.
•Verification information – copies of passports, driver licences, proof of address, and source of funds / source of wealth information required under the AML/CFT Act.
•Financial information – bank account details, investment objectives, risk tolerance, investment experience, financial position, assets and liabilities, and employment and income information.
•Account and transaction information – portfolio holdings, contributions, withdrawals, instructions, and correspondence relating to your account.
•Beneficial ownership and related party information – details of directors, shareholders, trustees, settlors, beneficiaries, authorised signatories and other related parties of entity clients.•Website and digital information – IP address, device information, browser type, pages visited, and cookies (see section 9).
•Marketing preferences and feedback.
3. How we collect personal information
We collect personal information directly from you where practicable – for example through onboarding forms, identification documents, and communications with us.We also collect personal information about you from third parties, including:
•Your authorised representatives (lawyer, accountant, adviser, attorney, trustee).
•Other related parties to your account.•Our custodian, Adminis NZ Limited (“Adminis”), and other custodians or administrators.
•Identity verification, sanctions, PEP and credit reference providers.
•Public registers, Inland Revenue, and other government agencies.
•Brokers, counterparties and other financial institutions involved in transactions.
•Our professional advisers and publicly available sources, where reasonably necessary.
Where we collect personal information about you indirectly, we take reasonable steps to make you aware of that collection in accordance with the Privacy Act 2020.
4. Why we collect personal information
We collect and use personal information for purposes connected with our business, including to:
•Assess whether to provide services to you and onboard you as a client.
•Meet customer due diligence, enhanced due diligence, ongoing monitoring and reporting obligations under the AML/CFT Act, FATCA, CRS, sanctions and other applicable laws.
•Provide, administer and manage our investment management and related services, including instructing our custodian Adminis and other service providers.
•Communicate with you about your account, our services, market commentary, and changes that affect you.
•Assess suitability of products and services for retail clients in accordance with the Code of Professional Conduct for Financial Advice Services and the Financial Markets Conduct Act 2013.
•Manage complaints, disputes, claims and legal proceedings.
•Maintain records as required by law, including FMA, IRD and AML/CFT recordkeeping obligations.
•Manage risk, prevent fraud, conduct internal audit, and protect information security.
•Improve our website, services and client experience.
•Provide direct marketing of our services, where permitted (you can opt out at any time).
If you do not provide the personal information we request, we may be unable to open an account for you, provide our services, or continue to act for you.
5. Who we share information with
We treat your personal information as confidential. We only share it where reasonably necessary for the purposes described above, including with:
•Adminis NZ Limited, our custodian, who holds client assets and provides custody, settlement, reporting and related administration services. Adminis will hold and use your personal information in accordance with its own privacy obligations under the Privacy Act 2020.
•Our external auditors and accountants, for audit, assurance and tax purposes.
•Our professional advisers, including lawyers and compliance consultants.
•Identity verification, sanctions, PEP and credit reference providers used for AML/CFT and onboarding checks.
•Regulators and government agencies, including the Financial Markets Authority, Department of Internal Affairs, Reserve Bank of New Zealand, Inland Revenue, the New Zealand Police Financial Intelligence Unit, and the Office of the Privacy Commissioner, where required or permitted by law.
•IT, cloud, email and software providers that support our business systems, under appropriate confidentiality and security obligations.
•A purchaser or potential purchaser of our business, or a successor entity, on appropriate confidentiality terms.
We do not sell your personal information.
6. Sending information overseas
Some of the recipients above (for example, certain cloud-based service providers or screening providers) may store or process your information outside New Zealand. Where personal information is disclosed to an overseas agency, we comply with Information Privacy Principle 12, including by ensuring the recipient is subject to comparable privacy safeguards, or by obtaining your authorisation, where required.
7. How we store and protect your information
We hold personal information in a combination of secure electronic systems and, where relevant, secure paper records. We take reasonable technical, physical and organisational steps to protect personal information against loss, misuse, unauthorised access, modification or disclosure. These include access controls, staff training, encryption in transit, secure data hosting, and ongoing security monitoring. If a notifiable privacy breach occurs, we will comply with our obligations under Part 6 of the Privacy Act 2020, including notifying the Office of the Privacy Commissioner and affected individuals where required.
8. How long we keep your information
We keep personal information only for as long as required for the purposes for which it was collected, or as required by law. Some records, including AML/CFT customer due diligence records and transaction records, must be kept for at least seven years after the end of the business relationship or the date of the transaction. After the applicable retention period, we securely destroy, delete or de-identify the information.
9. Cookies and our website
Our website uses cookies and similar technologies to help the site function, remember your preferences, measure use, and improve performance. Some cookies are strictly necessary; others are optional and used for analytics. You can control cookies through your browser settings, but disabling them may affect website functionality. Where required, we will seek your consent for non-essential cookies via our cookie banner.
10. Your rights
Under the Privacy Act 2020 you have the right to:
•Request access to the personal information we hold about you.
•Request correction of personal information that is inaccurate, incomplete, irrelevant, misleading or out of date.
•Withdraw any consent you have given (for example, to direct marketing).
•Make a complaint about how we have handled your personal information.
To make a request, please contact us at contact@aurellan.com. We may need to verify your identity before responding. We will respond within the timeframes required by the Privacy Act 2020 (generally 20 working days).
11. Complaints
If you are concerned about how we have handled your personal information, please contact us at contact@aurellan.com so we can try to resolve the matter. If you are not satisfied with our response, you can complain to the Office of the Privacy Commissioner:
Website: www.privacy.org.nz
Phone: 0800 803 909
Email: enquiries@privacy.org.nz
12. Contact us
If you have any questions about this Policy or our handling of your personal information, please contact us:
Email: contact@aurellan.com
Aurellan Asset Management Limited,
Level 6, 1 Willis St,
Wellington 6011