Privacy Statement

Privacy statement
SMX Financial Solutions Ltd (referred to in this privacy statement as “we”, “our” or “us”) takes your privacy and protection of your information very seriously. We are bound by the Privacy Act 2020 when handling personal information. We collect, hold, use, and disclose your personal
information in accordance with this privacy statement.

The purpose of this privacy statement is also to inform you of your rights in relation to your personal information. If you have any questions about this policy, please contact our Privacy Officer by email sm*******************@***il.com or by sending a letter to:

The Privacy Office
SMX Financial Solutions Ltd
516 High Street,
Hutt Central 5010
Lower Hutt

We reserve the right to update this privacy statement at any time and for any reason, so we encourage you to make sure that you are familiar with the current version of our privacy statement. Any change we make applies from the date the updated Privacy Policy is posted on our website.

What is personal information?
Personal information is information about an identifiable individual. It includes (but is not limited to) name, address, contact details, date of birth, occupations, payment details, employment history and/or details, education and qualifications, financial information, testimonials and feedback, evidence of source of funds or source of wealth (in some cases) and other information.

Why do we collect personal information?
We only collect personal information to conduct our business, to provide you (if you are a client) our services, emailing (subject to you giving us your consent) updates, event invitations and publications that we think you may be interested in, and to meet all our legal obligations (including in relation to anti-money laundering and countering financing of terrorism legislation).

You do not have to voluntarily provide your personal information to us. However, if you do not provide us with certain personal information we request, we may not be able to provide our services to you or perform our obligation.

How do we collect your personal information?
Except as otherwise permitted by law, most of the personal information we collect is provided directly by you, or your authorised representative. We collect personal information about you when you visit our website, participate in any of our surveys, request (over telephone, email, social media such as face book) our advice or service, ask us to send you our publications (such as newsletters) , or when you otherwise interact with us. Please be aware that when you send us any information over the internet you send it at your own risk because internet is not a secure environment.

We may also collect personal information from you through registration and attendance at seminars, business cards, and social media channels.
In some instances, we may collect your personal information from third parties – for example:

• we may use third parties to analyse traffic at our websites, or to provide information security related services, and social media channels, which may involve the use of cookies; and
• in some circumstances we might collect personal information about an individual from a third party, such as an employment reference from another person; and We may also collect personal information about you from publicly available websites.

Collection of Information from Third Parties

In some situations, we may collect personal information about you from other people or organisations rather than directly from you. This may include lenders, insurers, credit reporting agencies, identity verification providers, government agencies, professional advisers, employers, trustees, publicly available sources, or other parties authorised by you.

Where we collect your personal information from a third party, we will take reasonable steps to
let you know:

• that we have collected the information;
• why we collected it;
  who we may share it with;
• how you can access and correct your information; and
• any other information required by the Privacy Act 2020.

We may provide this information through our engagement documents, privacy notices, website, or other reasonable means.

In some circumstances, the Privacy Act 2020 does not require us to provide this notification, including where you are already aware of the information, the information is publicly available, the collection is authorised or required by law, or another exception under the Privacy Act 2020
applies.

To whom might we disclose personal information?

We may obtain information about you from lenders, credit reporting agencies, insurers, accountants, solicitors, trustees, employers, government agencies, and other third parties where necessary to assess your eligibility for financial products, verify information you have provided, comply with legal obligations, or provide financial advice and related services.

We may disclose your personal information to:

• other companies or individuals who assist us in providing services or who perform functions on our behalf (such as mailing houses, hosting and data storage providers, specialist consultants and legal advisers);
• Product providers (such as but not limited to lenders and insurance companies);
• Financial advisers and financial advice providers who may use our services;
• other companies or individuals who perform checks (such as but not limited to compliance reviews and audits) that are necessary or desirable under law on our behalf;
• other companies, agencies or individuals that maintain databases against which your identity may be verified, which may include (but is not limited to) the New Zealand Department of Internal Affairs, and New Zealand Transport Agency;
• social media sites on which we may have a presence;
• courts, tribunals and regulatory authorities (such as the Financial Markets Authority, and Ministry of Justice in New Zealand);
• Office of the Ombudsman, where a complaint relates to official information;
• any person or agency we believe could assist in responding to a serious privacy breach.
• Office of the New Zealand Privacy Commissioner, where a complaint relates to breach of the Privacy Act 2020;
• Human Rights Commission, where a complaint relates to discrimination;
• CERT NZ, where appropriate to assist with the management of a voluntarily notified privacy breach
• Overseas privacy regulator, where a complaint relates to the actions of an overseas agency; and
• anyone else to whom you authorise us to disclose it.

Except as described above, we will not disclose your personal information without your written or oral consent, unless we are required to do so by applicable law.

We may obtain information about you from lenders, credit reporting agencies, insurers, accountants, solicitors, trustees, employers, government agencies, and other third parties where necessary to assess your eligibility for financial products, verify information you have provided,
comply with legal obligations, or provide financial advice and related services.

AML/CFT requirements

As part of our obligations under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009, we may collect and verify information about your identity, source of funds, source of wealth, and related matters from third-party verification providers, government agencies, financial institutions, and publicly available sources.

Storage of personal information

We may store personal information we collect in any format we choose at our offices at 516 High Street, Lower Hutt or at premises outside our offices, including data storage facilities or online storage located within or outside New Zealand, which may be operated by independent service
contractors.

Where your personal information is transferred outside New Zealand we will ensure the intended recipient has provided appropriate safeguards and that requisite rights and remedies in relation to the personal information remain available, or we will obtain your explicit consent for the transfer.
Management of personal information We take reasonable steps to protect the security of personal information. All our personnel (including but not limited to third party service providers) are required to hold personal information and the privacy of individuals in confidence.

We take reasonable steps (such as, but not limited to, use of physical security and restricted access to electronic records) to protect personal information we hold from misuse and loss and from unauthorised access, modification, or disclosure.

Where we no longer require your personal information, we will comply with our legal obligations in respect of that information.

Your right to access and correct your personal information we hold You have the right to request access to any personal information we hold about you, and to ask for it to be corrected if you think that it is wrong. If you’d like to exercise that right, or ask us anything else in relation to your privacy, please ask the person you are dealing with, send us an email to sm*******************@***il.com or send a letter to:

The Privacy Officer

SMX Financial Solutions Limited
516 High Street,
Lower Hutt

Last updated: May 2026