Privacy Policy 2020

Our commitment to your privacy

Your privacy is important to us. We respect your right to privacy and your right to view and update the personal information which we hold about you. We are committed to protecting your privacy when you visit our website, use our services or deal with us in any other way.

We will only collect your personal information in accordance with the Privacy Act 2020 and this Privacy Policy.  As an existing or prospective client or as a website user, you are consenting to this Privacy Policy.

If you do not want us to collect or use your information as outlined in this Privacy Policy, you should please stop using our website or services.

Collecting information from you

Substantial Equities Ltd trading as The Brokers provides financial advice in relation to insurance, kiwi-saver, investments, and mortgages.  To offer you financial advice we collect personal information from you, including information about your:

  • Name
  • Contact information (such as address, telephone number and email)
  • Date of birth
  • Computer or network (if online)
  • Financial and health details
  • Interactions with us

We gather information in a number of ways but most of this personal information is collected directly from you.  In some circumstances we may be legally required to collect personal information for example to verify your identity and in other instances providing some information is optional.  We may be unable to assist you if you choose not to provide the personal information requested.

We collect your personal information in order for us to take action requested by you (such as providing Financial Advice) or in order to provide information (such as policy information) or to assist a financial adviser to contact you.

Security and Disposal of your personal information

We are committed to protecting your personal information.  We store personal information electronically and physically in New Zealand.  We store electronic information in New Zealand and elsewhere in our client relationship management system which is provided by a third party and some of which is cloud based.

To protect the personal information that we gather from you, we have put in place physical, electronic, and managerial procedures to assist in safeguarding and securing the information we collect.

The Brokers is required to retain personal information in relation to clients by several New Zealand laws for example the Financial Markets Conduct Act 2013.  We usually hold personal information for at least 7 years although we may keep certain information for longer even if you’re no longer a client.

Disclosing your personal information

You allow The Brokers to provide your information to third parties that work with us to deliver financial products, services, or communications to you.  The Brokers will require those third parties to keep your information confidential and secure.  They may use it only for the purpose that we give it to them for or as permitted by law and in accordance with the Privacy Act 2020, and this Privacy Policy.

The Brokers may also disclose information to

  • the Financial Markets Authority and any other applicable regulatory or government agencies or independent compliance personnel as part of our obligations to meet regulatory and industry standards.
  • any person or organisation assisting us to investigate any concerns or complaints or manage any legal action; and
  • any other person or organisation as allowed by applicable law, including the Privacy Act 2020.

Newsletters and other notices

It is our policy to send communications to all The Brokers clients to keep you updated with information that we believe is relevant to you. In addition, we may send promotional material to you regarding new or amended material where we think it may be relevant to you.

You can choose not to receive information about our services.  Click unsubscribe at the bottom of the email or you can call us on 09 927 4300, email or or tell your adviser if you don’t want information about other services we offer.

Accessing and correcting your personal information

The Privacy Act 2020 gives you certain rights to access and correct your personal information.  The Brokers will try to ensure that the personal information collected about you is up to date. Please help us by telling us as soon as possible if your information, such as your contact details, changes.

The Brokers clients can do this by contacting their adviser, call us on 020 408 73640 or email or

Updates to Privacy Policy

We may change this Privacy Policy at any time and without notice so please review it frequently.  We will take reasonable steps to tell you about changes.  By continuing to use the website, use our services or deal with us in any other way, you agree to the Privacy Policy current at that time.

Breach of Privacy

If we believe that there has been a privacy breach, we will identify the issue and take steps to minimise harm to you.

If we believe the breach has caused, or is likely to cause serious harm, we will contact the Office of the Privacy Commissioner. We will also contact clients who may be affected by the breach.

Questions or concerns

If you have any questions about our Privacy Policy, you are concerned your privacy may have been breached or that we may have breached the Privacy Act 2020, please contact The Brokers immediately by calling us on 020 408 73640, emailing or





Privacy Commissioner

If you are not satisfied with our response to any privacy related matter you may have, you can contact the Privacy Commissioner at

Office of the Privacy Commissioner
PO Box 10-094
Wellington, New Zealand
Phone: 04 474 7590

For more information on privacy see the Privacy Commissioner website.

Links to other websites

Our website may contain links to enable you to easily visit other websites of interest. Clicking these links may mean that you give information to us or to third parties through cookies or in other ways.

The Brokers is not responsible for content on other websites.  Please review the privacy policies and privacy practices of third-party sites before you use the sites or disclose any personal information.  We do not endorse any third-party websites, or their content, and we have no control over the conduct of the companies or organisations operating those sites.

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