Rayt NZ Limited (referred to as ‘Rayt’, ‘We’, ‘Our’, or ‘Us’) is committed to safeguarding your personal information in adherence with the New Zealand Privacy Act 2020 and the Privacy Principles. We have developed this Privacy Policy to explain:
This Privacy Policy covers all of our interactions with you, including, but not limited to, phone calls, email, our website, and in person communication. While only your information as an individual is protected under the Privacy Act 2020, we also extend our Privacy Policy to your business as well. We treat information about you and information about your company with the exact same privacy and security standards.
For reference:
We collect only the information that we need for the purposes of providing you with honest service, real savings, and a relationship you can count on. The information we collect includes:
When you use our website, you may provide your information via a contact form, which will collect your name, business name, and contact information. The form may also ask for information, such as your transaction and foreign exchange needs, which helps us determine if our products and services are suitable for you. We use this information to communicate with you and to gauge the suitability of our products to your needs.
Our website also collects information via cookies and your IP address. We collect this information to provide you a better experience on our website and to help us understand how to improve our website. For more information on Cookies, and our Cookies Policy, please see Section 4.
You may decide to interact with us via social media, such as through LinkedIn, WhatsApp, or other platforms. When you do so, any information that you provide on these social media platforms is governed by the privacy policy of that platform. We do not own or have any control over the information that you have shared on these platforms.
When interacting with us via social media, we may collect your name, business name and contact details to contact you outside of the social media platform, for example by email or phone. We will only do so when you have already contacted us on the social media platform or are part of our social network on that platform.
We will collect your name, business name, and contact information when you reach out to us to inquire about our products and services. We do this either when you send us an email, or when you reach out to us by phone. We use this information to continue our conversation with you about how we can best meet your needs.
When we communicate with you, we may ask further information about your foreign exchange currency requirements, such as the amounts that you normally send, the types of currency and the locations you send to. We use this information to inform ourselves about how best to serve you and to understand if our products are right for you.
The information that we initially collect is your business contact information. If, however, you provide us with your personal contact information, we understand that you have provided us with the information only for the purposes of contacting you, and we will use it only for this purpose. If at any time, you change your mind and no longer want to hear about our products and services, you can ask us to remove your information from our contact list. You can find more information on this in section 5.
When our clients are happy with us, they often refer other individuals and businesses to us. Sometimes this means that our clients provide your name and contact information to us. When that happens, we will only use this information to reach out to you to describe our products and services to see how we may be able to serve you.
Rayt is a foreign currency exchange and payment broker whose services are provided by Ebury Partners Australia Pty Limited. When you wish to use us for currency exchange and payments, we require information from you to satisfy the requirements under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act). We are required to collect information from you, including, but not limited to, your name, date of birth, home address, and copies of identification documents. We need to be able to prove that we know who you are and can verify your identity. For businesses, we will also collect information on your business, the owners of your business, the directors, and the nature of your business.
The information we collect about you will mainly be from you, when you provide us this information via an onboarding form. However, we may use online sources such as information from your business’ website or from government registries to help you complete your application.
We will use this information for recordkeeping purposes and to fulfil our legal requirements under the AML/CFT Act. We will also use this information to contact you about your account, to send you confirmations of your transactions, to notify you if there are concerns on your account, to resolve disputes, and to give you general information about your account.
We will also collect information from you regarding your payments, such as details on the individuals or businesses you will be making payments to, or information about the bank accounts that you will be paying us from. This information will include the name, address, and bank details of the owner of the bank account. In some cases, we will also require invoices or other documents. This information is used to process your payments and to better understand your payments to ensure they get to your beneficiary safely and on time.
Certain products that we offer may require information that proves your creditworthiness. A forward contract, for example, allows you to lock in a foreign exchange rate now, and pay in the future. If you fail to pay the forward contract amount at the later date, this could damage Us and our ability to provide services to our clients. To ensure that we can offer you these types of contracts, we may need to ask for information on your business to show that you are able to honour the contracts that you are requesting.
When you send us an email or contact us via phone, we record and store records of the email and phone recordings. As a financial services broker, we have an obligation to meet regulatory requirements and the obligations of our business partners. Recording our interactions with you allows us to audit the practices of our employees so that we can verify that they are providing our products and services in a fair and honorable manner. These recordings are also used as records of you providing us with transaction confirmations and other information that we require for legal and contractual reasons.
When you interact with us, you may provide your contact information to us. We may use this information for marketing purposes, for example by sending you a newsletter or providing you with information on our products and services. You can manage your marketing preferences through the links in the marketing email at any time.
We will not ask for information about minors, and we ask that you do not supply information about minors to us. Individuals must be over the age of 18 to do business with Rayt.
We will not request personal information that is otherwise unnecessary for you to do business with us, such as information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic data, health information or sexual orientation.
While we do not seek to collect the information described above, we may inadvertently capture this information through our interactions with you. For example, you may advise us that you are sending money to your home country in an email where you provide transaction instructions to us. Because we capture the email for recordkeeping purposes as it includes transaction details, we will have also inadvertently captured information about your racial and ethnic origin through the understanding of your home country.
By agreeing to our privacy policy, you agree that any incidental collection of this information is allowed. We will not use this information for any purpose other than to store the information as part of our records.
If we make a general request for information, we ask that you advise us that your answer could include personal information or information on a minor. We will then assess if we can satisfy our contractual or legal requirements in a different way, or if the information is necessary to facilitate your transaction request with us. If the information is necessary, we will inform you. You can then make a choice to either provide us with the consent to process your information specifically for that transaction request, or you may choose to modify your transaction request with us.
We will not share your information with any third party, other than what is necessary to provide a service that you have requested or for our own internal business needs. We will share your information in the following circumstances:
When we reach out to you to provide newsletters, information on our products and services, or send similar content, we may use a third-party provider (software or other service) to facilitate that service. The third parties that we use are under contract so that they do not use your information for their own purposes and do not share your information further.
Rayt’s payment and foreign currency exchange services are provided by Ebury Partners Australia Pty Ltd (‘Ebury’). We share your information with Ebury to facilitate transactions on your behalf. This includes your account information as well as the information you provide to us about your requested transactions. You may review Ebury’s privacy notice through the following link (Ebury Privacy Notice).
When we receive and process your information, we will use third party software programs to do so, such as an email provider, phone provider, customer relationship management (CRM) software, and storage facilities. We review each vendor to ensure that we are only using those with high IT security standards. Contracts with these vendors ensure that any data that they store or process via their services is not shared with any other party.
We must provide information to law enforcement or regulatory authorities where we are required to do so. Before providing any information, we validate that the agency has the legal authority to make such request, such as by providing a subpoena. We may also share your information with our own lawyers if it is necessary to solve a dispute.
We may share your information with a third-party service provider as part of a consulting agreement to gain insights into how we grow as a company. We may do this to understand what kind of clients appreciate our services, to see what new products may be useful to you, and to determine if we are serving you in the way we intend to. When we do this, we will anonymise the data, meaning that while the data may show your transaction details or industry, it will not also show the name or address of you or your business. We will also ensure that the service provider is under contract and that they are not allowed to use this information for other purposes.
It is possible that Rayt could buy, merge with, or be bought by another company. Prior to a merger or acquisition, we may need to share your information with the interested party and their advisors. This is done to determine the value of our assets prior to the merger or acquisition.
If the merger or acquisition is successful, your information could be transferred to the new owner/company. Your information will continue to be bound by this privacy agreement until it is updated or amended.
We protect your information from any accidental or unauthorised access, modification, or loss. This protection includes both physical and IT security measures, including the following:
Our employees go through vigorous security checks to work for us. We validate that our people are trustworthy and do not have a criminal history. This goes for the people we work with as well. When selecting our vendors or outside contractors, we review to make sure that they too have standards in place to ensure the trustworthiness of their employees before they have access to your data.
Rayt employees have been through cybersecurity training and know that basic protections like password protected applications and phishing awareness are necessary. We ensure that your information is only stored in applications that require passwords and two-factor authentication. This guarantees that only we and our trusted partners have access to your information.
We also protect your information by not oversharing your personal data. Our employees and partners will only be given access to the information that they need to perform their job. For example, if we have a vendor that assists us in sending out newsletters, we will only provide your name and contact information for this purpose – and not your date or birth or other unnecessary information.
When choosing who we work with, we review how they manage and store information. We look at the security of their systems and any history they may have of data or security breaches. Rayt only chooses the most reliable vendors to work with, who conform with the New Zealand Privacy Act 2020 or similar legislation in their home jurisdiction. If they cannot protect your information to the standards we expect in New Zealand, we won’t use them.
If you are our client, we are legally required by the AML/CFT Act to retain your information for 5 years from the date of your last transaction with us. If you set up an account but did not conduct a transaction, we keep your information for 5 years from the date your account was set up.
If you are not our client, you will have provided us with your information for contact and marketing purposes. You may remove your consent at any time, and we will remove your information from our systems. Please understand that if we remove your information, we will also remove any record of us contacting you in the past, and all phone numbers or email addresses associated with you. Because we will have no record of the phone number and email address to prevent contacting you, we may unintentionally contact you again in the future. Instead of asking us to remove your contact details, we recommend instead requesting us to add your contact information to a ‘do not contact’ list instead.
In rare circumstances, for example due to a dispute, law enforcement request, or to protect our interests, we may hold your information for longer than 5 years. Otherwise, we will not retain your information longer than we have the legal requirement to do so.
Our website, www.raytfx.com, uses cookies. Cookies are small bytes of information that are placed on your computer or mobile device as you visit websites. This is how your browser understands your search history, knows which language to present on websites, and how to customise a website for you.
Our website uses cookies to provide you with a better user experience on our website. We will also collect information from cookies to better understand how our website is performing. For example, by using cookies we can see how long people are spending on various parts of our website. Cookies won’t tell us who is visiting our website, but it will tell us how long someone has viewed certain pages – giving us an insight into what you may find more interesting or useful. Cookies also help us understand how much traffic we are getting to our website, so we can try to improve our website over time.
Having up to date information is beneficial to both of us. If you see that we have incorrect or incomplete information, we encourage you to reach out to us and let us know. We will go through the process of correcting your information to make sure everything is up to date.
We may ask for additional documents to verify the information you are supplying. Part of our obligations under the AML/CFT Act is to verify the information that you provide to us. If you are unable to provide the documents we request, we may need to delay the update of your information until you are able to provide us with them.
You may wish to request a copy of the information that we have about you. If you require this, please contact us, and let us know about the information you require and why. When we ask why you need the information, we just want to understand if we can present the information in a format that would be more suitable for your purposes. We want to make things easy for you and provide you with the best service available.
We will let you know if we have any of your information and we will provide you with a copy of that information. You can request all of your information, or you can request specific elements.
If you are someone that we do not immediately recognise, we may need to first verify that the person making the request for your information is you, or someone with a power of attorney over your information. We don’t want to provide your information to someone that is not authorised or is not you. To verify that it is you, we may ask for a copy of your ID or by asking a series of question that only you would know.
Depending on the size of your request, it may take some time to provide all of the information that you are requesting. Rayt reserves the right to take up to 30 days to process your request. If we are having difficulties in processing your request and need more time, we will let you know. The maximum time that we will take from your initial request is 60 days.
We have no problem with providing you with your information on request, however we reserve the right to charge a reasonable fee to provide your information for repeated or excessive requests. For example, if you request Rayt to provide your information to you monthly, even though most of your information will not have changed, we will calculate the cost of providing you the information for subsequent requests and request that you provide a payment for this service.
You may withdraw your consent for us to use your information at any time. This means that you do not want your information used by us for any purpose. Other than what is legally required by the AML/CTF Act for recordkeeping, we will cease using your information.
Instead of withdrawing consent, you may choose to opt out instead. Opting out means that you are removing consent for specific uses as opposed to all uses. An example of this is opting out of marketing material. This means that we will not use your information to send newsletters or marketing information, however you allow us to use your information to provide you with other services, such as providing foreign exchange and money transfer services.
Withdrawing consent or opting out will mean that we may not be able to provide you with our products and services. When you make a request to withdraw or opt out, we will let you know what specific services you will not have access to, so that you can make an informed decision to withdraw, opt out, or allow us to continue to use your information. Most of the information that we collect about you is required by the AML/CFT Act for us to provide transaction and foreign currency exchange services to you. If you choose to withdraw your consent to use your information, we will not be able to provide these services to you.
Privacy law adherence in New Zealand is regulated by the Privacy Commissioner. We ask that if you are dissatisfied with how we have managed your personal information, you first reach out to us via our information in Section 7. If you are still dissatisfied, you may report a concern with the Privacy Commissioner via the information on their website www.privacy.org.nz.
We reserve the right to make updates to this policy as our business changes and adapts to our client’s needs. An updated Privacy Policy will always be available on our website. Please check back to our website to keep updated on how we protect your personal information.
If we make substantive changes to the Privacy Policy, we will provide a copy of our new Privacy Policy to our clients via the email address we have on file for them.
If you have any questions, would like to contact us, or make a request about your information, we ask that you reach out to your main contact with Rayt. Otherwise, you can contact us via the information below:
Email: info@raytfx.com
Address: Rayt NZ Limited, Level 10, 19 Como Street, Takapuna, Auckland 0622
