1. Policy

This policy applies to Russell Investment Group Limited, a member of the Russell Investments group of companies and referred to as “Russell Investments” or “We” throughout this policy.

This policy sets out what information we collect, how we use, disclose and store it, and what your rights are under the New Zealand Privacy Act of 2020 and the 13 Information Privacy Principles (IPPs), herein referred to as the "Privacy Act". The Privacy Act sets out how agencies should collect, use, disclose and provide access to personal information about their customers.

Russell Investments reserves the right to change this policy at any time.

2. Russell Investments' Commitment

Russell Investments is committed to maintaining the privacy of individuals whose personal information we collect in accordance with the Privacy Act.  This document sets out Russell Investments’ policy on the management of personal information, together with what sort of information we hold, for what purposes, and how we collect, hold, use, disclose and provide access to that information. 

3.  Russell Investments' Activities

Russell Investments provides investment solutions and advisory services to institutional or habitual investors in New Zealand.  Russell Investments also distributes funds managed by its affiliates to the NZ market, including through arrangements with other financial service intermediaries such as banks, platforms and investment advisers.

4. Why Russell Investments Collects Information

Russell Investments collects personal information where Russell Investments is:

• obligated by relevant legislation or regulation; and/or
• collection of the information enables or facilitates the efficient provision of the services provided by Russell Investments and/or its affiliates.

5. How Personal Information is collected

Personal information is primarily collected directly from you or your representative whom you have authorized to provide us with your information. Information is collected in a number of ways including:

• in written form (usually signed by the individual);
• electronically (via email or a website); or
• verbally.

When you visit a website hosted by Russell Investments we may set a 'cookie' on your machine (this is a small piece of system information stored on your hard drive) so when you next visit our site it links to your personal information that is stored on our system. If you do not wish us to use a cookie you can set your browser so it will not accept them.

Our website may contain links to other sites. We are not responsible for the privacy practices or the content of these websites.

We will take steps to ensure that personal information we hold is accurate, complete and up-to-date. If you think that we hold information about you that is incorrect in any way, please contact us. 

6. What Personal Information is collected

Under this policy, "personal information" is any information about an individual (a living natural person) as long as that individual can be identified. We will only collect personal information that is necessary so that we can provide you with a financial service or product, information about a financial service or product or other information that you have requested from us.

If you provide incomplete or inaccurate information, we or our affiliates may not be able to provide the financial service or product or information to you.

7. How Personal Information is used

We or our affiliates use personal information to provide you with financial products and services. We may use personal information for related purposes. We may share personal information with our affiliates, where it will remain confidential. We may use personal information to notify you about products and services that we, or our affiliates, offer.

We or our affiliates use external service providers, for example, for administration, custody or management of our financial products and services. We may provide your personal information to these service providers. The information will only be used for the purpose of providing the service.

We or our affiliates will only disclose personal information to a third party with your consent or as permitted by law or the Privacy Act, this includes for the purposes of direct marketing. We will not sell your personal information to third parties.

If you do not want to receive communications from us and our partners, please contact us.

On websites hosted by Russell Investments the collected data is used to help us determine which pages are most popular, peak usage times and other information to help us make our sites more efficient and easier to use. We use your IP address to help diagnose problems with our server, to administer our websites and to gather broad demographic information.

8. Disclosure of Your Information

Personal information is only disclosed in the course of services provided to you by us or our affiliates. For example, personal information may be accessed by, or disclosed to the trustee or responsible entity of the funds, mailing houses, legal and tax advisers, service providers, insurers, regulators and courts.

Personal information that has been collected will not otherwise be disclosed unless:

• it is public information;
• express consent is given by the individual affected;
• disclosure is authorised or required by law;
• collection would not prejudice the individual; or
• the individual cannot be identified.

Like many businesses, Russell Investments, our affiliates and our outsource partners may use other providers to help maximise the quality and efficiency of our services and our business operations. This means that individuals and organisations outside of Russell Investments, our affiliates and our outsource partners, such as mail houses, will sometimes have access to personal information held by us and may use it on our behalf.  These providers are required to adhere to strict privacy guidelines and not to keep this information or use it for any unauthorised purposes.

9. Overseas Disclosure of Your Information

Per IPP 12, we will only disclose your personal information outside of New Zealand where we believe that the receiving party is subject to equivalent protections and safeguards to those in the Privacy Act or otherwise with your permission.

10. Access to and Correction of Information Collected

Individuals will have access to their personal information collected and are able to notify us of any corrections which need to be made so as to ensure their personal information is accurate. 

We will only grant access by an individual to personal information where the individual has given appropriate identification verification, which may be required in writing.  We reserve the right to impose charges for providing such access to information.

11. Security of Information

Personal information collected by Russell Investments may only be accessed by our affiliates, officers, employees, agents and delegates.

The key personal information collected will be in hard copy and/or electronic format.  The Russell Investments computer system is password protected to prevent unauthorised access.  Personal information in written form is held in appropriately secure locations to minimise the risk of unauthorised access.

Russell Investments also hosts websites. Records are kept of visits to various parts of the site to observe trends and improve the quality of that site.  To the extent to which we have links to other websites, we are not responsible for the policies and practices of those sites. 

We will take all reasonable measures to protect personal information that we hold from unauthorised access, use, modification or disclosure.  We will, where practicable, destroy or permanently de-identify personal information that is no longer needed.

12. Mandatory breach reporting

If we experience a privacy breach that causes, or is likely to cause, serious harm, we are required to notify the people affected and the NZ Office of the Privacy Commissioner (Commissioner) as soon as practicable.  

Generally, a privacy breach occurs when an organisation or individual either intentionally or accidentally:

• Provides unauthorised or accidental access to someone's personal information
• Discloses, alters, loses or destroys someone's personal information

A privacy breach also occurs when someone is unable to access their personal information due to, for example, their account being hacked.

The unwanted sharing, exposure or loss of access to people’s personal information may cause individuals or groups serious harm. Some information is more sensitive than others and therefore more likely to cause people serious harm.  In the context of our business, serious harm could include:

• Financial fraud including unauthorised credit card transactions or credit fraud 
• Psychological, or emotional harm.

 

13. Russell Investments’ Contact Details

Questions or complaints about this privacy policy and practices should be made in writing to the following contact address:

The Privacy Officer
Russell Investment Group Ltd
Level 15, HSBC Tower
188 Quay Street
Auckland 1010, New Zealand
www.russellinvestments.com/nz

14. Privacy statement for russellinvestments.com

Russell Investments has a firm commitment to privacy. The following discloses our information gathering and dissemination practices for this Web site: russellinvestments.com. The Privacy and Security notice (PDF) of Russell Investments covers these issues in further detail.

We use your IP address to help diagnose problems with our server, and to administer our Web site. Your IP address is used to gather broad demographic information. We use cookies to deliver content specific to your interests, to save your password so you don't have to re-enter it each time you visit our site, and for other purposes.

Our site's registration forms and surveys request users to give us contact information (e.g. their name, phone number, e-mail and mailing address) and limited financial information (e.g. assets under management and investible assets). We use contact information to send the user requested information about our company. The information is also used to contact the visitor when necessary. Users may opt-out of receiving future mailings; see the choice/opt-out section below. The data collected is used to tailor the visitor's experience at our site, showing them content that we think they might be interested in, and displaying the content according to their preferences.

This site contains links to other sites. Russell Investments is not responsible for the privacy practices or the content of such Web sites.

Security

This site has security measures in place to protect the loss, misuse and alteration of the information under our control.

Choice/opt-out

Our site provides users the opportunity to opt-out of receiving communications from us at the point where we request information about the visitor.

This site gives users the following options for removing their information from our database to stop future communications or to no longer receive our service.

You can send e-mail to webmaster@russellinvestments.com.

Correct/update

This site gives users the following options for changing and modifying information previously provided.

You can send e-mail to webmaster@russellinvestments.com.

Cookies

By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set or to reject all cookies. However, you should be aware that if cookies are rejected you will not be able to use some of the online services provided by Russell Investments. For more information on how to configure your browser preferences, please refer to the user guides:

• Microsoft Internet Explorer
• Microsoft Edge
• Firefox
• Google Chrome
• Apple Safari

A full list of all cookies Russell Investments uses can be found here .

Cookies for storing your preferences

We use various cookies to store some details you enter and choices you make so that we do not have to ask you for them every time you visit a page that needs them.

Cookies for improving service by measuring traffic

We use Google Analytics, a web analytics service provided by Google, in order to find out how visitors interact with Russell Investments so we can improve it. Information is collected anonymously and website trends are reported without identifying individual visitors.

DoubleClick (A Google Company) cookies

We also may use DoubleClick cookies for ad serving through Google’s DoubleClick, which places a cookie on your computer when you are browsing the web and visit a site using DoubleClick advertising (including some Google AdSense advertisements). This cookie is used to serve ads specific to you and your interests (”interest based targeting”). The ads served will be targeted based on your previous browsing history. DoubleClick uses “non personally identifiable information”. It does NOT track personal information about you, such as your name, email address, physical address, telephone number, social security numbers, bank account numbers or credit card numbers. You can opt-out of this ad serving on all sites using this advertising by visiting https://adssettings.google.com/authenticated

The LinkedIn Insight Tag

This tag enables the collection of data regarding members’ visits to your website, including the URL, referrer, IP address, device and browser characteristics (User Agent), and timestamp. This data is encrypted, the IP addresses are truncated, and members’ direct identifiers are removed within seven days in order to make the data pseudonymous. This remaining, pseudonymized data is then deleted within 90 days.

LinkedIn does not share the personal data with the website owner, it only provides aggregated reports about the website audience and ad performance. LinkedIn also provides retargeting for website visitors, enabling the website owner to show personalized ads off its website by using this data, but without identifying the member. LinkedIn members can control the use of their personal data for advertising purposes through their account settings.

Contacting the Web site

If you have any questions about this privacy statement, the practices of this site, or your dealings with this Web site, you can contact:

Webmaster

Russell Investments

1301 Second Avenue
18th Floor
Seattle, WA 98101
206-505-7877 (206-505-RUSSELLINVESTMENTS)
1-800-426-7969
webmaster@russellinvestments.com