Privacy Policy

We care about your privacy, and we’ve designed our services with your privacy in mind.

This policy covers the services that are offered by Kernel Wealth Limited when we interact with you through our website or otherwise in connection with your account with us.

We want you to understand what personal information we collect and store about you, what we will do with that information, and who we might share that information with. That’s what this privacy policy covers. Please read this privacy policy alongside our Terms & Conditions.

We are Kernel Wealth Limited (Kernel), a company incorporated in New Zealand. Our company number is 7050334 and our registered office is at Level 4, Canterbury Arcade, 166-174 Queen Street, Auckland Central, Auckland.

If you have any questions about this privacy policy, please contact us at privacy@kernelwealth.co.nz.

In this policy, when we say 'we', 'us', and 'our', we mean Kernel.

We care about the privacy of our users of www.kernelwealth.co.nz (our ‘website’) and our services.

• what information we might collect about you – from you and others;

• how we might use that information;

• where we store that information; and

• who we might share your information with.

When we say ‘New Zealand privacy law’, we mean the law in New Zealand that covers personal information that’s in force at the time that you use our services. This includes codes of conduct issued by the Privacy Commissioner.

When you use our services, you acknowledge that we may collect, use, store, and share your information as we’ve described in this policy.

We may collect the following information from you when you use our website or when you use our services.

You don’t have to give us your information. But if you do not provide us with information, we may not be able to provide you with our services.

Where you have a financial adviser that has portal access agreement with us, we may also collect any of the personal information above from your financial adviser, for example when they register you to use our services or otherwise during interactions between us and your financial adviser.

We might receive your personal information from third-party websites or services, for example service providers that help us verify your identity and digital services such as Google Analytics, which you have authorised to disclose your personal information to us. The collection and disclosure of that personal information by those third parties will be governed by terms you have agreed with them, and New Zealand privacy law.

We might also combine data or information that we have collected about you ourselves, with the information we collect from others for the purposes described in this policy. This data, once aggregated, will in no way identify you or any other individual.

We may collect information about someone else from you, if you provide that information to us. If you do provide us with someone’s personal information, you must make sure you have that person’s authority to do so and you must make sure that person knows that their information may be used by us in the circumstances set out in this policy.

We may gather more extensive information about your interactions with our website and services, such as details of your investing behaviour, or with us generally.

We collect your bank account details so that you can use your ‘Wallet’ for our services. If we don’t have your bank account details, we can’t offer our services to you.

Cookies are pieces of information that are automatically downloaded to your computer or mobile device when you use a website.

We use cookies for a few different reasons. Cookies make it easier for you to use our website in future visits (by remembering who you are). Cookies also help us to monitor traffic and personalise the content on our website for you.

We can’t use cookies to view any data on your device – only data stored in the cookie.

Some parts of our website can’t work without these cookies so we’ve automatically turned them on. You can switch off cookies and other tracking services using your browser settings (but it might mean you can’t use our website in the same way).

Specifically, we may use the following kinds of cookies:

• strictly necessary cookies (which let you use our services);

• performance cookies (which gives lets us know if our services are working and helps us to fix errors);

• functionality cookies (which helps us to personalise your visit);

• persistent cookies (which stay on your device after you’ve left our website so that we can remember you for next time);

• session cookies (which last only for the duration of your visit); and

• advertising cookies (which allow us to show you specially targeted ads).

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

We use your information in the way described in this policy, or if New Zealand law says it’s fine to do so. We’ve outlined the specific ways we’ll use your information above (see "What information we collect").

When we say 'identity information', we mean information like your New Zealand passport or driver licence and address information. We are required to collect this information to meet our obligations under New Zealand’s anti-money laundering laws.

Specifically, we have to make sure that you are who you say you are. This helps prevent people from using our services in harmful ways. The ways that we can verify your identity are also covered by legislation, so we need to undertake specific checks.

To do so, we may use third-party identity verification service providers. This means that we’lldisclose your identifying information to those service providers, for verification purposes. To comply with our AML obligations, this may involve the use of biometric methods for identity verification, which could involve analysing a photo or video (e.g., a selfie or scan of your ID) to ensure it's really you.

We use your personal information to respond to your enquiries and support you in using our services. This includes providing you with important notices and information about our services via email, phone, text and online chat.

We can use your personal information to assist our software to function and help us debug or fix software problems and improve the functionality of our services, including research or development.

We can use your personal information to personalise our marketing communications and advertising you receive (including promotional material, news, and event information).

When it comes to marketing communications, you can ask us not to send you these at any time. Just follow the unsubscribe instructions in the marketing communication or make your request using the details in the ‘Contact us’ section on our website.

The personal information that we collect about you may be securely stored and hosted on our behalf by dedicated third-party services, such as hosted customer relationship management (CRM) systems or registry systems.

Additionally, your information may be securely hosted by third parties on behalf of the platform administrator who operates the platform through which our services are provided.

We may share your information with third parties, such as:

• Scheme supervisors;

• Custodians and sub-custodians;

• Scheme administrators;

• Registry services;

• Third parties that help us carry out our services (for example, verifying your identity);

• Payment system operators and service providers, such as merchants handling card payments or funds transfers, to ensure secure and efficient processing of your deposits, withdrawals, or subscriptions.

• Broker-dealer partners, NZ registered banks and foreign exchange providers to facilitate the deposit, custody, and management of investments.

• Software providers that we use to carry out customer service and communications (such as Intercom);

• Marketing partners and third-party providers (such as Google and Meta) who assist us to promote our services to you;

• Research and data analytics partners;

• Cloud-storage providers;

• Third-parties that help us enhance safety and security;

• Your financial adviser, if we have been told that you have engaged a financial adviser to provide you with financial advice on your investments with us, and your financial adviser has a portal access agreement with us;

• Our professional advisors, contractors, service providers, business associates, related companies, and others who have agreed to treat your personal information in accordance with this privacy policy.

Some of these service providers, subsidiaries and business partners are located outside of New Zealand and may not be subject to New Zealand privacy laws. However, we take such steps as are reasonable in the circumstances to confirm that those organisations are required to protect the information in a way that, overall, provides comparable safeguards to those under the Privacy Act. By using our services and otherwise providing us with your information, you authorise such disclosure.

We will never sell your personal information to others.

We will not otherwise use or disclose your personal information except:

• for any purpose set out in this privacy policy, or a purpose that is closely related to it;

• where New Zealand law requires or permits us to do so;

• where you have otherwise authorised us to do so; or

• where we believe that we need or should disclose your information to other organisations under New Zealand law, or if we need to protect you or other people from harm.

It is important to us that the personal information we hold about you is accurate, complete and up to date. To help us ensure that’s the case, you can:

• ask us what personal information we hold about you; and

• ask us to correct your personal information.

We may need to obtain personal information from you to identify you and verify that it is in fact you who is seeking access to your personal information.

If you’d like to do so, please contact our privacy manager (see their contact details below). We might ask you to put your request in writing. Depending on the circumstances, we can also ask you to pay a reasonable fee.

Sometimes, we might not be able to help (like if we can’t under the law or doing so would prejudice our commercial interests) but only if we are permitted to not give you access, or correct your information, under New Zealand law. And we’ll always tell you why we’ve made that decision and what your options are.

You can contact our privacy manager by emailing privacy@kernelwealth.co.nz.

We need to make sure that the contact, payment, and tax information we hold about you is accurate and current. There may be negative consequences for you if you fail to do so – for example, you may be liable for additional tax if you have not provided us with updated tax information. So please advise us of all necessary changes to such information as soon as possible.

We care about handling your information responsibly, so we'll only keep it for as long as needed to provide our services and meet our obligations. Here's how we approach retention:

We'll hold onto your information while you have an active account with us, to ensure everything runs smoothly for you.

After your account is closed, we'llretain the information for at least seven years to comply with regulatory, tax, insurance, and other legal requirements under New Zealand law.

We'll keep it for as long as we reasonably believeit's necessary to fulfil the purposes outlined in this privacy policy, always with your privacy in mind.

You can send requests to our privacy manager by using our contact details set out above.

This privacy policy doesn’t cover your use of others’ services. And we can’t control what information third parties collect and how they use your information. When you follow a link on our website, you should read the privacy policy for that website as well.

What information we collect and how we use that information can change. We might need to update this privacy policy from time to time to reflect those changes.

You should check back here for any changes. We’ll tell you when we last updated the policy at the top of the page.