Privacy Policy

Bespoke Wealth Limited (FSP1011643) is a licensed Financial Advice Provider (FAP) regulated by the Financial Markets Authority (FMA). We provide personalised investment and financial advice services to individuals, families, trusts, and entities.

We are bound by the Privacy Act 2020 (the Act) and the thirteen Information Privacy Principles (IPPs) it contains. These principles govern how we collect, use, store, and disclose your personal information. This policy explains how we give effect to those principles in practice.

To provide you with financial advice and manage your investments, we need to collect personal and financial information about you. The information we collect may include:

Personal identification information

• Full legal name and date of birth
• Contact details including address, phone number, and email address
• Identification documents such as passport or driver's licence
• Tax identification number (IRD number) and tax residency status
• Immigration status where relevant (for example, Active Investor Plus visa clients)

Financial information

• Details of your assets, liabilities, income, and expenditure
• Investment portfolios, KiwiSaver accounts, and other financial holdings
• Banking and account details required to facilitate transactions
• Risk profile, investment objectives, and time horizon

Other information

• Information about your family circumstances where relevant to your financial planning
• Preferences or requirements relating to religious, ethical, or other personal beliefs that affect how your assets are managed
• Records of our communications with you, including meeting notes and correspondence

We collect only the information that is necessary to provide you with quality financial advice. We will not collect personal information that we do not need.

We collect your personal information directly from you in most cases. This may occur when you:

• Complete our client discovery or fact-find documentation
• Communicate with us by email, phone, or in person
• Provide instructions regarding your investment portfolio
• Submit identification documentation as required under Anti-Money Laundering (AML) obligations

In some circumstances we may collect information from third parties, for example from your accountant, solicitor, or other professional advisers acting on your behalf, or from publicly available sources where relevant to the advice we are providing. We will always handle such information in accordance with this Privacy Policy.

We use your personal information only for the purposes for which it was collected, or for directly related purposes you would reasonably expect. These purposes include:

• Providing you with personalised financial advice and investment management services
• Constructing and managing your investment portfolio in accordance with your goals and risk profile
• Communicating with you about your portfolio, our services, and relevant market developments
• Meeting our legal and regulatory obligations, including AML/CFT requirements and FMA reporting
• Maintaining our internal records and compliance documentation
• Improving the quality of our services

We will not use your information for direct marketing purposes without your consent, and we will not sell your information to any third party under any circumstances.

We will only share your personal information where it is necessary to deliver our services, meet our legal obligations, or where you have given us your consent. The parties we may share your information with include:

Adminis Nominees and FNZ (Custodians)

Your assets are held in custody by Adminis Nominees and FNZ. These custodians require certain personal and account information to administer your account and process transactions on your behalf.

Fund Managers and Investment Providers

Where we invest in managed funds or other investment products on your behalf, the relevant fund managers or investment providers may require certain information to establish and maintain your investment.

Professional Advisers

We may share information with legal counsel, accountants, or other professional advisers engaged in connection with your financial affairs, where you have authorised us to do so or where it is necessary to deliver our services.

Regulatory Authorities

We may be required to share information with the Financial Markets Authority (FMA) as our regulator, the Department of Internal Affairs (for AML/CFT compliance), Inland Revenue (IRD), or other government agencies as required by law.

External Compliance Advisers

We engage external compliance advisers for quality assurance purposes. These advisers are subject to strict confidentiality obligations and may access client records only to the extent necessary for compliance review purposes.

We do not share your information with any other third parties without your consent, except where required by law.

Where your information is shared with parties located outside New Zealand, we take reasonable steps to ensure it receives an equivalent level of protection to that required under the Privacy Act 2020.

We take the security of your personal information seriously. The steps we take to protect your information include:

• Storing electronic records on secure, access-controlled systems with appropriate encryption
• Limiting access to your information to those within our business who need it to perform their role
• Requiring third parties who handle your information on our behalf to maintain appropriate security standards
• Maintaining policies and procedures for identifying and responding to any data breaches promptly

In the event of a privacy breach that poses a risk of harm to you, we will notify you and the Privacy Commissioner as required under the Privacy Act 2020.

We retain your personal information for as long as it is needed for the purposes for which it was collected, and to meet our legal and regulatory obligations. Under FMA licensing requirements and AML/CFT legislation, we are required to retain certain records for a minimum of seven years.

When information is no longer required, it will be destroyed or deleted securely in a manner appropriate to the sensitivity of the information.

You have the right under the Privacy Act 2020 to request access to the personal information we hold about you, and to request that any inaccurate information be corrected.

In some circumstances we may be unable to provide access to certain information (for example, where doing so would prejudice an investigation or reveal information about another individual), and we will explain the reasons if this applies.

To make an access or correction request, please contact us using the details below. We will respond to your request within 20 working days. There is no charge for making an access or correction request. Where a request involves significant time or effort, we may charge a reasonable fee and will advise you in advance.

The quality of the advice we provide depends on the accuracy and completeness of the information we hold about you. We rely on you to keep us informed of any material changes to your circumstances — such as changes to your income, assets, tax residency, or personal situation — that may affect your financial advice or the suitability of your investment strategy.

If you believe any information we hold about you is inaccurate or out of date, please contact us so we can update our records.

Our website at bespokewealth.nz uses cookies and similar technologies to understand how visitors find and use the site, to measure the effectiveness of our advertising, and to connect an enquiry to the person who made it.

What we use

Website analytics — we measure page visits, traffic sources and general site usage to understand what is useful to visitors and to improve the site.

Advertising technologies — where we advertise online, we use tags provided by advertising platforms to measure how those campaigns perform and, in some cases, to show our advertising to people who have previously visited our website.

Customer relationship management (CRM) tracking — we use a CRM system that records activity on our website. If you submit an enquiry form, request a call, or book an appointment, the CRM links your earlier browsing on our website to your contact record. This can include the pages you viewed, when you visited, and the source or advertising campaign that first brought you to the site.

What this means for you

Before you identify yourself, this information is not linked to you by name. If you submit a form, request a call, or book an appointment, information collected during your earlier visits becomes associated with your contact record, and from that point is treated as personal information under this policy. We use this to understand where our enquiries come from, to respond to you properly, and to improve our services. We do not use it to make decisions about the financial advice we give you, and it forms no part of your risk profile or investment strategy.

Third parties

These technologies involve service providers who process information on our behalf, including our website analytics provider, our CRM provider, and the advertising platforms we use. Some of these providers are located outside New Zealand; where that is the case we take reasonable steps to ensure your information receives an equivalent level of protection to that required under the Privacy Act 2020.

Your choices

Most browsers allow you to block or delete cookies through their settings, and to signal that you do not wish to be tracked. Blocking cookies may affect how parts of our website work. You can also ask us at any time what information we hold about you, and request that it be corrected or deleted, using the contact details in section 12.

If you have concerns about how we have handled your personal information, we encourage you to contact us first so we can work to resolve your concern directly.

We will acknowledge your complaint promptly and aim to resolve it within 20 working days. If we are unable to resolve your concern to your satisfaction, you may lodge a complaint with the Office of the Privacy Commissioner:

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. The current version of this policy is always available on our website at bespokewealth.nz. We will notify existing clients of any material changes.

This policy was last reviewed in September 2026.