Scope of this Privacy Policy
This Privacy Policy (“Policy”) outlines the obligations Lane Neave has in managing the personal information it holds about its clients, potential clients and others. Lane Neave is bound by the Privacy Act 2020 (“Privacy Act”) and the privacy principles set out in the Privacy Act.
In this Policy, “you” and “your” means the individual providing personal information to Lane Neave or whose personal information has been collected by Lane Neave; and ‘personal information’ has the meaning given to it in the Privacy Act. Essentially, it is information relating to an individual or which can be used to identify that individual.
This Policy covers the basis on which Lane Neave collects, stores, uses and discloses your personal information. It sets out general information relating to these situations. It also sets out specific information that applies in relation to our marketing communications and cookies and references where you can find specific information on our anti-money laundering processes. The specific information should be read in conjunction with the general information.
Situations in which this Privacy Policy applies
This Policy applies to your use of Lane Neave’s websites www.laneneave.co.nz and www.laneneaveimmigration.co.nz and where Lane Neave tells you or you are otherwise made aware that this Policy applies. This Policy also applies to personal information provided to Lane Neave in the course of Lane Neave’s relationship with its clients.
However, this Policy does not apply to personal information that is provided to Lane Neave by or on behalf of a client solely for processing on behalf of that client. All such personal information is governed by the agreement between Lane Neave and that client.
By accessing Lane Neave’s websites or obtaining its services you agree to the terms of this Policy.
Full Policy details
For detailed information related to each element of the policy, please click on the relevant headings below to expand.
Who does Lane Neave collect personal Information about?
The type of information Lane Neave may collect and hold includes (but is not limited to) personal information about:
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- clients and potential clients that are individuals, and where clients and potential clients are not individuals their directors, trustees, board members, owners and personnel;
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- third party individuals and individuals at third party organisations that Lane Neave engages with in connection with a client;
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- business associates that are individuals, and where business associates are not individuals their directors and personnel;
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- prospective employees; and
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- users of the Lane Neave websites.
What kind of personal Information does Lane Neave collect?
In general, the type of personal information Lane Neave collects and holds includes (but is not limited to): names, addresses, contact details, occupations, organisation details, and other information which assist it in conducting its business, providing and marketing its services and meeting its legal obligations. Lane Neave also collects personal information contained in the content of your communications with Lane Neave or provided to Lane Neave in the course of a meeting. Bank account details are collected if you provide them to us so we can pay money we hold to you or if you pay your bill by direct credit. If you pay your bill via Lane Neave’s website bill payment function Lane Neave will collect certain invoice related information (but not credit card details).
Lane Neave also collects a range of other information from its clients where required as part of the services that it is providing, and this may include identity information (e.g. driver’s licence and passport details) and financial information (e.g. bank account details). The information required is advised to you at the time it is required. For some transactions, Lane Neave is required by the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 and associated regulations (“AML/CFT”) and the procedures for electronic registration of land transactions to take a copy of documents verifying your identity, including in the case of an organisation, as to its ownership and control. If these documents are not provided Lane Neave will not be able to undertake the transaction for you. In addition, if information we require to meet our obligations under the AML/CFT regime is not provided we will not be able to act for you or your organisation.
If you are applying for employment with Lane Neave, then Lane Neave collects information concerning your previous employment, your qualifications and other information to enable Lane Neave to assess your suitability for the position for which you have applied.
This Policy also sets out in other types of information collected in relation to specific purposes.
In most cases, if personal information that Lane Neave requests is not provided, or it is incorrect, Lane Neave may not be able to provide its services, respond to an enquiry, engage with you, or contact you.
How does Lane Neave collect personal information?
Lane Neave will generally collect personal information directly from you. However, in some cases your personal information will be collected from third parties. Set out below are the typical ways in which Lane Neave collects your personal information.
This Policy and Lane Neave’s websites may also state other ways in which Lane Neave collects your personal information.
Collection from you
Lane Neave collects personal information from you by way of electronic or paper forms which you complete, your use of website query forms, subscription applications and event registrations on the Lane Neave websites, face-to-face meetings, interviews, business cards, telephone conversations, email communications, and when you interact with the marketing communications Lane Neave sends you.
Collection from your organisation and other third parties
Your personal information may also be collected from your organisation or other third parties, where it is authorised by you to provide it or your organisation or that other third party reasonably believes it is able to provide it to Lane Neave, or as otherwise permitted by the Privacy Act. By way of example, this includes where Lane Neave is provided with a report by a medical professional, an interview summary from a recruitment agency or a reference from another person.
If you provide Lane Neave with personal information relating to someone else you warrant that you are authorised to do so. If that personal information is held by an organisation that is subject to the Privacy Act and the individual concerned is not already aware of this Policy, you must ensure that the individual is aware of the information in this Policy at the time you provide that personal information to Lane Neave.
If you provide Lane Neave with personal information about others, or if others give Lane Neave your personal information, Lane Neave will only use that personal information for the specific reason for which it was provided to Lane Neave, or as otherwise permitted by the Privacy Act.
Collection from webinar and event providers and social media services
From time to time Lane Neave provides webinars and seminars on legal topics of interest. Lane Neave uses third party services, such as GoToWebinar and EventBrite, to provide/support its webinars and seminars. Some third party webinar providers may also require you to register with them to participate in a Lane Neave webinar, even though you have already registered with Lane Neave to attend it.
Lane Neave also uses third party social media services including Linkedin and Facebook. The platforms that these third party social media providers use often allow you to send messages to other users, such as Lane Neave.
Your use of these third party services is entirely optional. Lane Neave may make use of, for the purposes of Lane Neave’s business, any information that you make available to Lane Neave through your use of such third party services (including messages sent to Lane Neave using the third party’s platform and information which is visible to Lane Neave during a webinar), or which you make public when you use any such third party services.
All third party services are governed by the privacy policies and/or practices of the relevant third party, for which Lane Neave is not responsible. If you do not want to provide personal information to any of those third parties, or make information available to Lane Neave and others, you should not use their particular service.
Collection automatically by Lane Neave websites
Lane Neave’s websites also automatically collect log information about your access to those websites, including time of access, IP address, browser type, device identifiers and error messages. This information may be collected through third party tools. For more information please refer to the section on cookies below.
How might Lane Neave use and disclose your personal information?
Lane Neave may use and disclose your personal information for the primary purpose for which it is collected, for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorised by the Privacy Act or in any other manner with your consent.
In general, Lane Neave uses and discloses your personal information for the following purposes:
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- to verify your identity where you or your organisation are a client or a prospective client;
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- to conduct its business, which may include managing, reviewing, analysing and improving its services and processes;
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- to provide its services, including events, seminars and webinars;
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- to maintain Lane Neave’s relationship with you or your organisation;
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- to optimise your experience as a user of Lane Neave’s websites;
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- to meet its obligations in, exercise its rights under, or enforce, its terms and conditions or the contract with you or your organisation;
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- to send you and your organisation newsletters, alerts and invitations to seminars, webinars and events, to keep you and your organisation updated on Lane Neave services, and to provide Lane Neave marketing material to you and your organisation (where you have signed up or otherwise agreed to receive that particular marketing communication);
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- to perform a credit reference or to undertake credit management processes or otherwise assess your ability to pay for Lane Neave’s services;
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- to take any action in order to recover any amount you owe Lane Neave;
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- to consider your application for a role at Lane Neave (where you are applying for employment with Lane Neave) and if you are accepted for a role your personal information will be subject to Lane Neave’s staff privacy policy;
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- to communicate with you, which includes responding to any message or enquiry you send to Lane Neave and identifying you when you want to communicate with Lane Neave;
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- to investigate any incident on Lane Neave premises or at a Lane Neave event or seminar;
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- to take any action in any case of dispute, or legal proceeding of any kind between you and Lane Neave, or between you and any other person with respect to Lane Neave’s business;
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- to otherwise protect Lane Neave’s interests in its property, its legal rights, or those of others, including to detect, investigate, prevent or address fraud, security or technical issues, or if Lane Neave have good reason to believe there is an imminent threat of death or injury or a serious threat to health and safety;
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- to comply with its legal obligations, and
any other purpose made known to you when collecting the personal information.
Lane Neave may also merge your personal information with other people’s personal information to create an overview for the firm or for analysis purposes, but will first remove all details that could identify you.
Other sections of this Policy also set out or reference other specific situations in which your information is used and disclosed, such as in relation to our anti-money laundering processes and the use of cookies.
To avoid doubt, all disclosure of client information is subject to Lane Neave’s obligations under the Lawyers and Conveyancers Act 2006 and the Lawyers and Conveyancers Act (Lawyers: Conduct and Client Care) Rules 2008.
Who might Lane Neave disclose your personal information to?
There are some specific situations in which Lane Neave may disclose your personal information to other parties.
Other parties to whom Lane Neave may disclose your personal information
Lane Neave may disclose your personal information to:
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- Lane Neave trustee companies, where they act as a trustee for any of your assets (and those trustee companies will comply with this Policy in relation to the personal information provided to them);
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- a client or a third party in connection with the services Lane Neave is providing to that client, where Lane Neave is dealing with you or your organisation in connection with the services being provided to that client;
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- credit monitoring and debt collection agencies;
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- referees that you provide to Lane Neave to contact;
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- third party providers to Lane Neave as stated in other sections of this Policy; and
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- anyone else to whom you authorise Lane Neave to disclose it.
If the services that Lane Neave is providing to you or your organisation involve dealing with third parties (e.g. courts, tribunals, regulatory authorities, specialist consultants, barristers, trustees, financial institutions, insurers, brokers, real estate agents, translation agencies and other members of a group of companies to which your organisation is a member), Lane Neave may disclose your personal information to those third parties on your behalf where you instruct Lane Neave to do so, or otherwise where it is required as a part of the process of providing Lane Neave’s services to you or your organisation. The personal information provided would only be what is required by those third parties or what you have instructed Lane Neave to provide to them.
Lane Neave also collects personal information from these third parties and deals with that information in accordance with this Policy.
Disclosures in relation to seminars or events
Where you attend a Lane Neave seminar or event, Lane Neave usually makes available at the door name tags of all persons attending the seminar or event. Name tags display your name and may also display the name of your organisation. These name tags are visible to all attendees of the seminar or event.
Your privacy in connection with anti-money laundering processes
Please refer to the Client onboarding requirements page which deals with anti-money laundering (AML) personal information, obtained to enable Lane Neave to check and confirm your identity and to enable it to undertake other identity related checks.
Your privacy in connection with marketing communications
Lane Neave uses third parties to assist it to send you its marketing communications, including newsletters, alerts, and invitations to seminars, webinars and events. Lane Neave provides those third parties with your name and relevant contact information. Such third parties may be offshore, and may not be subject to privacy laws as comprehensive as New Zealand.
Where marketing communications Lane Neave initiates are sent by electronic means the relevant third party (where applicable) will collect information about your interaction with the communication. The information collected includes whether you opened the email, the links you clicked on, the webpages viewed and the dates and times of such access and activity. Information about the device used to access the marketing communication may also be collected. The third party provides or makes available this information to Lane Neave for the various purposes outlined in this Policy. They may also hold this information on Lane Neave’s behalf.
While these third parties are primarily collecting this information on Lane Neave’s behalf, some of these third parties also use the information that Lane Neave provides them and which is collected from your interaction with the marketing communications for their legitimate business interests, such as to provide, support and improve the services they provide and to undertake data analytics projects. However, Lane Neave does not use third parties that would use your personal information to market their or any other person’s services to you.
The third party that Lane Neave currently uses for these purposes is MailChimp. MailChimp is located in the United States. To understand the ways MailChimp collect, hold, use and disclose such personal information, please read its privacy policy, which is available here.
If you do not agree with how MailChimp will handle your personal information then you will need to unsubscribe from receiving marketing communications from Lane Neave. You may unsubscribe from receiving marketing communications from Lane Neave in accordance with the unsubscribe facility in any email sending you marketing communications or by contacting Lane Neave in accordance with the contact details set out below.
Lane Neave will not be able to provide marketing communications to you if you unsubscribe or do not agree to Lane Neave’s use of third parties to assist it with marketing communications.
Your privacy in connection with the use of cookies
Lane Neave’s websites use cookies. A cookie is a small piece of data contained in a file, and cookies are stored on a device with a web browser such as a personal computer, tablet and a smart phone. A cookie can contain information about your IP address, your device, or the online activity of a person who uses that device.
Necessary Cookies
Lane Neave uses cookies to provide the functionality of its websites. These cookies are necessary to enable certain features of its websites to operate. If these cookies are blocked, disabled or rejected, some functions will not be available to you. Generally these are session cookies that expire when you close your browser.
Performance Cookies
Lane Neave may also use third party analytic and optimisation tools, such as Google Analytics, to help it analyse data from its websites so Lane Neave can optimise its websites. Lane Neave uses these cookies to compile reports and to help it better understand your use of its websites.
While these third parties are primarily collecting this data on Lane Neave’s behalf, some of these third parties may also use the data which is collected for their legitimate business interests, including to improve their own services, and to maintain the security of their systems. To understand the ways that Google Analytics may use your data, please read their policy on safeguarding your data, available here.
Disabling Cookies
If you do not agree to the use of cookies, or would like to block some or all of the cookies on Lane Neave’s websites from being downloaded onto your computer or device, you can do this by disabling or rejecting the use of cookies through your internet browser.
If you disable or reject the use of cookies some functionality on Lane Neave’s websites may not be available or it may take longer to use that functionality.
To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org.
How does Lane Neave manage your personal information?
Except as otherwise stated in this Policy, your personal information Lane Neave collects is held by it. Lane Neave’s address is set out below.
Lane Neave currently uses Windcave to facilitate your payments via Lane Neave’s websites. Windcave is based in New Zealand and in other countries around the world. Windcave will provide or make available to Lane Neave the information collected by it as required to enable Lane Neave to confirm payment of your invoice. Any credit card details stored for payments are done so on the Windcave system. No credit card information is stored by Lane Neave when making a payment to Lane Neave using the Windcave system. Please read Windcave’s privacy policy, available here, to understand the ways in which it collects, holds, uses and discloses such personal information. Lane Neave may change its provider at any time.
In addition to the situations in which Lane Neave provides personal information to third parties as expressly stated in this Policy, Lane Neave may transfer personal information to third party providers (including technology providers, payment service providers, providers of business and marketing services and providers of software tools used by Lane Neave in its business) to perform services on Lane Neave’s behalf, to process the information for Lane Neave, or hold it on Lane Neave’s behalf. These third parties may be offshore, but Lane Neave will not authorise them to use such information for their own purposes.
The Privacy Act requires Lane Neave to take reasonable steps to protect the security of personal information it holds. By way of example, Lane Neave protects personal information by use of physical security and restricted access to electronic records. Lane Neave’s personnel are required to respect the confidentiality of personal information and the privacy of individuals.
Lane Neave will retain your information for as long as needed to provide you or your organisation its services, to manage backups of your personal information in accordance with Lane Neave’s security practices, to be able to address any claim that might be made after Lane Neave stops providing services to you or your organisation, or to meet any legal obligations Lane Neave has to retain such information, including managing its obligations to you in respect of these services. Where Lane Neave no longer requires your personal information for a permitted purpose under the Privacy Act, Lane Neave will take reasonable steps to return, delete or destroy it.
How does Lane Neave keep personal information accurate and up-to-date?
Lane Neave endeavours to ensure that the personal information it holds is accurate, complete and up-to-date. Lane Neave encourages you to contact it to update any personal information held about you.
What are your rights?
You have the right to request access to, and seek correction of, your personal information. Subject to the exceptions set out in the Privacy Act, you may exercise these rights by contacting Lane Neave in accordance with the contact details set out below.
Lane Neave will require you to verify your identity and specify what information you require. A reasonable fee may be charged for providing access to your personal information. Lane Neave will advise you of the likely cost in advance.
Updates to this Policy
This Policy will be reviewed from time to time to take account of new laws and technology, changes to Lane Neave’s operations and practices and the changing business environment. Should Lane Neave decide to change this Policy Lane Neave will post all changes on its websites so that you are always kept up to date. The most current version of this Policy can also be obtained by contacting Lane Neave in accordance with the details set out below.
Use and disclosure of personal information collected from you is subject to the Policy in effect at the time such personal information is collected, unless otherwise agreed.
Address details and enquiries
If you have any questions about privacy-related issues please contact Lane Neave’s Privacy Officer, Graeme Crombie.
Lane Neave’s address and contact details are:
141 Cambridge Terrace
Christchurch 8013
PO Box 2331
Christchurch 8140
t: +64 3 379 3720
e: graeme.crombie@laneneave.co.nz
Privacy complaints and disputes
Please contact Lane Neave’s Privacy Officer if you have any concerns about Lane Neave’s handling of your personal information.
If a dispute arises between us in relation to Lane Neave’s handling of your personal information and Lane Neave cannot resolve it with you, then you may wish to contact the Office of the Privacy Commissioner on investigations@privacy.org.nz.