Privacy Policy


Link Market Services Limited and/or its wholly owned subsidiary Pacific Custodians (New Zealand) Limited (collectively referred to as “Link”) understands that privacy is important to you, and has developed this policy (“Privacy Policy”) to govern, among other things, how we handle your personal information. In this Privacy Policy the Privacy Act refers to the Privacy Act 2020.

Our Privacy Policy is designed to answer the following questions:

  • What personal information does Link collect?
  • How is personal information collected and stored?
  • How is personal information used?
  • Will personal information be given to anyone else?
  • What security precautions are taken to safeguard my personal information?
  • What if I live outside of New Zealand?
  • How can you access and correct your personal information?

1. What personal information does Link collect?

Personal information as defined in the Privacy Act means information about an identifiable individual. It therefore refers to any information or an opinion from which an individual's identity may be ascertained.

Link, a provider of registry and registry related services, to listed and unlisted organisations (‘Issuers’) and the holders of their securities (‘you’), Share Sale Centre and the ShareMeUp platform, may obtain personal information, including your name, email address, phone number, contact address(es) and CSN/ FIN details, from you in order to administer your security holding or to provide you with other services. If part or all of the information is not provided, then Link may not be able to supply its services to the Issuers and you.

You may also be asked to provide contact information (including telephone and email address), your tax details and information concerning your nominated financial institution.

Link’s or it’s agents or contractor's, server may also log the following information, which is provided by your browser:

  • your server's IP address (a number which is unique to the machine through which you are connected to the Internet) or your personal IP address
  • the type of browser and operating system you are using
  • the domain name of the referring site (e.g. the previous website that you visited).

The server may also log:

  • the date and time of your visit
  • the URL address of the pages accessed and the documents downloaded.

This information does not personally identify you, however Link or its agents or contractors may analyse this non-personal information to identify certain trends and statistics, such as which parts of the Investor Centre users are visiting and how long they spend there, among other possible uses.

Link will not try to identify you or your browsing activities except, in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect the service provider's logs or if your usage is causing technical issues for the Link website or Investor Centre which may need to be resolved. Link may, in these circumstances, identify your IP address to enable Link to contact you.

Companies Act 1993

As agent for Issuers, Link collects personal information about you (including your name, address and details of the securities you hold/ held) on behalf of Issuers in which you hold securities in accordance with the requirements of the Companies Act 1993 (“Companies Act”). This information is included in the public register of the Issuer in which you hold securities for a period of 10 years after you cease to be a security holder and may be required to be publicly disclosed by Link pursuant to the requirements of the Companies Act and the Financial Markets Conduct Act 2013 (“FMCA”).

Anti- Money Laundering and Countering Finance of Terrorism Act 2009

Link may also collect personal information about you including. but not limited to, your legal name, other names you may be known by, your residential street address and your date of birth, for the purpose of identifying you for the purpose of meeting under the Money Laundering and Countering Finance of Terrorism Act 2009 (“AML/CFT Act”),

This information may be collected on behalf of Issuers, and, by Link for its ‘Share Sale Centre’ and ShareMeUp. The AML/CFT Act requires a reporting entity to collect this information where a ‘customer’ (the investor) is conducting a transaction covered by the AML/CFT Act.

This information will not generally be included in the public register. Access to information collected under the AML/CFT Act is restricted to authorised Link employees, the Issuer for which we collected the information, the AML/CFT Regulator and law enforcement agencies.

Pacific Custodians(New Zealand) Limited (“PCNZ”) has a Ministerial Exemption from collecting AML/CFT information in relation to individual security holders using the Share Sale Centre subject to the following conditions:

a. Securities sold via the Share Sale Centre must be listed on either the NZX Main Board (or any other equity market operated by NZX) or the Australian Stock Exchange, and Link must be the registrar for those securities;

b. Transactions must involve the sale of an individual’s entire holding of the relevant security, and the sale must occur on-market;

c. The exemption does not apply to transactions exceeding NZD 30,000;

d. The listed security holding must be in the customer’s name and with a registered New Zealand address. The security holding cannot be held in a deceased estate, a trust (beneficially or as trustee) or be a joint or company holding;

e. PCNZ must only transfer proceeds of a sale of a security holding to a bank account which PCNZ has taken reasonable steps to verify is held by the relevant security holder; and

f. PCNZ must inform the Ministry of Justice of any changes that may affect the exemption within 10 working days from which the change affecting the exemption occurs.


2. How is personal information collected and stored?

This will depend on how you interact with us or the services you require.

We may collect personal information about you from an application form or a registration form or verbally if you call our call centre or speak directly with our staff. We may monitor and retain recordings of any telephone calls with you, including for quality assurance, training purposes, to make sure we comply with our regulatory obligations and to help detect or prevent fraud or other crimes.

In addition, if you access your information on-line through our Internet site [www.linkmarketservices.co.nz] (‘our website’) we may collect personal information relating to your holding during your visit to the website. The personal information is maintained on our servers, and a reference to this information is sent to the application you are using to access the Internet, in the form of a non-persistent "cookie". A "cookie" is a method employed to maintain a link between the application you are using and the website you are visiting. It is also used for security purposes.

Non-persistent cookies exist only in the application's memory and are destroyed when the application is shut down. This behaviour is different to persistent cookies, which are stored on your computer and which may remain there for an extended period of time. Link specifically and exclusively uses a non-persistent (or session) cookie, which means once you exit your application the cookie and the reference to the data it contains is destroyed.

For on-line access to information about your security holding, you will be required to authenticate your identity through a process outlined in the Terms and Conditions of Investor Centre.

Link takes reasonable steps to ensure the security of personal information held by it from risks such as loss or unauthorised access, destruction, use, modification or disclosure.


3. How is personal information used?

Link only uses personal information obtained from you for the purpose for which it was collected and to offer and provide related services that are connected to that initial purpose.

For example, the personal information collected from you by Link may be used to:

  • Provide the relevant Issuers and you with registry and registry related services, or with other information you have requested; and/or
  • Notify you about other Issuer or Link services relating to the purpose for which your personal information was collected. If at any time you no longer wish to be notified about other Issuer or Link services, please let us know.

Please note that the personal information collected about you may be disclosed to related companies of the Issuer or Link, but only if this relates to the purpose for which your personal information was collected.

Please note that under the Companies Act and the FMCA, certain information regarding you as a securityholder (including your name, address and details of the securities you hold) must be included in the public register of the entity in which you hold securities and, therefore, this information will be disclosed and is in the public domain.

Link will not use or disclose your personal information for any other purpose without first obtaining your express or implied consent.


4. Will personal information be given to anyone else?

Link will seek to maintain the confidentiality of all personal information provided and will take all reasonable steps in order to protect your personal information from misuse and loss, and from unauthorised access, modification or disclosure.

Link does not sell, rent or trade personal information to, or with, third parties.

In some circumstances however, personal information may be disclosed by Link, for example:

  • Disclosures may be required or authorised by or under law (for example, in accordance with the Companies Act, where a person requests a copy of an Issuer's register of security holders).
  • Personal information collected by Link may be disclosed to third parties to which Link contracts out specialised functions (including mailing houses and printing companies). If so, we take reasonable steps to ensure that those contractors comply with the Privacy Act, and are authorised only to use personal information in order to perform the functions required by Link.
  • Personal information may be disclosed to third parties in accordance with the Issuer’s direction where this is related to the Issuer’s administration of security holdings.

5. What security precautions are taken to safeguard my personal information?

Link employs appropriate technical security measures to protect your personal information and to ensure that it is not accessed by unauthorised persons. Information is held on secure servers and is encrypted wherever this is possible.

We undergo periodic reviews of our security policies and procedures to ensure that our systems are secure and protected. You should never divulge your identification numbers, username, or password to anyone else. You should also never write your password down or store it on your computer and you should make sure you change it regularly.


6. What if I live outside of New Zealand?

If you live outside of New Zealand, the Privacy Act and this Privacy Policy still apply to your personal information. In addition, other international privacy or data protection laws may apply to you, for example, the EU General Data Protection Regulation (GDPR). These international laws may set out additional rights, such as the right to erasure, restriction of processing, data portability or the right to have human intervention in automated decision-making.


7. How can you access and correct your personal information?

Under the Privacy Act, you have a right to seek access to certain information that we hold about you. You also have the right to ask us to correct information about you which is inaccurate, incomplete or out of date. Link will consider any requests for access or correction in a timely way and to take reasonable steps to correct the information so that it is accurate, complete and up-to-date.

To provide you with access to personal information we collected under the AML/CFT Act, the Issuer and Link will only provide you with a copy of, or confirmation of, the relevant personal information that we actually collected from you. The AML/CFT Act prevents the issuer and Link from revealing certain information.

To access and/or correct such information, you may write to or call Link on the following:

Telephone: Auckland (09) 375 5998
In writing: PO Box 91976
Auckland 1142

If you wish to correct current information about you which is inaccurate, incomplete or out-of-date then, for security purposes, you will need to prove your identity by confirming/providing the following information to us:

  • Quote your CSN/Holder Number that appears on the latest documentation sent to you in relation to your security holding; OR
  • Provide proof of your registered name (Note: supporting documentation e.g. birth certificate, marriage certificate may also be required), and
  • Provide proof of your registered address that matches the details appearing on the register.

A form signed by you will also need to comply with the signing requirements below:

Individual holder: Must be signed by the securityholder or his/her attorney or a parent/guardian (if under 18) or a trustee such as a bankruptcy trustee or an Executor of a deceased estate.
Joint holders: Must be signed by all joint securityholders or their attorney(s) as stated above.
Companies: Must be signed by either; two or more directors; or if there is only 1 director, by that director whose signature must be witnessed;or if the constitution of the company so provides, a director, or other person or class of persons whose signature or signatures must be witnessed; or if the constitution of the company so provides, a director, or other person or class of persons whose signature or signatures must be witnessed; or a person acting under the company's express or implied authority.

For legal and administrative reasons, Link may also store records containing personal information in its archives. You may seek access to the records held by Link which are not current records, but if you do so, you may be charged for the reasonable cost of providing access.

If you have any questions or comments about this Privacy Policy, or if you wish to complain about how we have handled personal information about you, please contact Link’s Privacy Officer:

Telephone: (09) 375 5998
Email: privacyofficer@linkmarketservices.co.nz
In writing: The Privacy Officer, Link Market Services Limited, PO Box 91976
Auckland 1142

If you have a privacy complaint, Link’s Privacy Officer will try to resolve the issue. Where the matter cannot be resolved to your satisfaction, you may refer it to The Privacy Commissioner who may be contacted on 0800 803 909 or by post to PO Box 10094, Wellington, 6143.

This Privacy Policy may change from time to time and we recommend that your review it periodically from to time, including prior to the provision of any further information to Link which is covered by this policy.