Privacy Policy

Who We Are

This Privacy Policy applies to Trebla Partners Limited (FSP728251), trading as Trebla ("we", "us", "our"). We provide financial advice services including mortgage lending, insurance, investment, and KiwiSaver advice to clients throughout New Zealand.

We are committed to protecting your privacy and handling your personal information responsibly, in accordance with the Privacy Act 2020 (as amended by the Privacy Amendment Act 2025) and the Information Privacy Principles (IPPs) contained within it, including the new IPP 3A that took effect on 1 May 2026.

What Information We Collect

We may collect and hold personal information about you including:

• Full name, date of birth, and contact details (address, phone, email)
• Identity verification documents (passport, driver's licence)
• Financial information including income, assets, liabilities, and credit history
• Employment details and history
• Insurance needs and health information (where relevant to insurance advice)
• KiwiSaver and investment details
• Information about your property or business
• Any other information you provide to us in the course of receiving our services

How We Collect Your Information

We collect personal information in two ways:

• Directly from you — through meetings, phone calls, emails, forms, or our website
• Indirectly from third parties — such as lenders, banks, insurers, credit reporting agencies, or other financial institutions, where you have authorised this or where we are permitted by law to do so

You are not required to provide personal information to us, however if you choose not to, we may be unable to provide our services to you.

Indirect Collection — IPP 3A Notice (effective 1 May 2026)

Under the Privacy Amendment Act 2025, a new Information Privacy Principle — IPP 3A — took effect on 1 May 2026. This requires us to notify you whenever we collect personal information about you from a source other than you directly (indirect collection).

When we collect your personal information indirectly, we will take reasonable steps to make you aware of the following, as soon as reasonably practicable after collection:

• Who is collecting the information — Trebla Partners Limited (FSP728251), Auckland, New Zealand
• Who holds the information — Trebla Partners Limited holds information we collect. In some cases, third-party providers (lenders, insurers, or cloud-based practice management systems) may also hold your information on our behalf
• Why we are collecting it — to provide you with financial advice, arrange financial products, verify your identity, or meet our legal obligations (see "Why We Collect Your Information" below)
• Whether collection is authorised or required by law — some collection is required under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act), the Financial Markets Conduct Act 2013, or other applicable legislation
• Your right to access and correct your information — you have the right under the Privacy Act 2020 to request access to any personal information we hold about you, and to request that inaccurate information be corrected

In most cases, this notice is provided through this Privacy Policy. Where we collect information indirectly in the course of acting on your instructions (for example, when we contact a lender or insurer on your behalf), we consider you to have already been made aware of this collection through your engagement with us and the scope of services agreed. Where we collect information indirectly in other circumstances, we will notify you directly as soon as reasonably practicable.

Common examples of indirect collection at Trebla:

• Obtaining a credit report from a credit reporting agency to support a lending application
• Receiving information about your existing insurance policies from an insurer when reviewing your cover
• Receiving payroll, employment, or financial information from a third party at your instruction
• Receiving KiwiSaver or investment information from a provider during a review

If you have any questions about indirect collection of your personal information, please contact us using the details in the "Contact Us" section below.

Why We Collect Your Information

We collect and use your personal information to:

• Provide you with financial advice and arrange financial products on your behalf
• Verify your identity and meet our Anti-Money Laundering obligations
• Assess your financial situation and recommend suitable products
• Communicate with lenders, insurers, and other providers on your behalf
• Maintain accurate records of the advice we have given
• Comply with our legal and regulatory obligations
• Respond to your enquiries and provide ongoing client support
• Improve our services and client experience

Who We Share Your Information With

We may share your personal information with:

• Lenders and banks — to arrange mortgage or lending products for you
• Insurance companies — to arrange insurance policies on your behalf
• KiwiSaver and investment providers — where relevant to your advice
• Credit reporting agencies — for credit checking purposes, where authorised
• Our professional advisers — including accountants or legal advisers where necessary
• Regulatory bodies — including the Financial Markets Authority (FMA) if required by law

We do not sell, rent, or trade your personal information to third parties for marketing purposes.

Storage and Security

We take reasonable steps to keep your personal information secure from unauthorised access, use, modification, or disclosure. Your information may be stored in electronic systems, some of which are operated by third-party providers (such as cloud-based practice management software). We ensure these providers meet appropriate security standards.

We retain your personal information for as long as is necessary to fulfil the purposes for which it was collected, or as required by law. Financial advice records are typically retained for a minimum of 7 years.

Your Rights

Under the Privacy Act 2020 (as amended), you have the right to:

• Ask whether we hold personal information about you
• Request access to that information
• Request correction of any information that is inaccurate or incomplete
• Be notified when your personal information is collected indirectly from a third party (IPP 3A, effective 1 May 2026)
• Make a complaint about how we have handled your personal information

To exercise any of these rights, please contact us using the details below. We will respond to access and correction requests within 20 working days.

Cookies and Website Analytics

Our website may use cookies and analytics tools (such as Google Analytics) to help us understand how visitors use our site. This information is collected in aggregate and does not identify you personally. You can disable cookies through your browser settings, although this may affect the functionality of our website.

Links to Other Websites

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites and recommend you review their privacy policies before providing any personal information.

Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date. We encourage you to review this policy periodically.

Last updated: 1 May 2026 — updated to incorporate IPP 3A notification requirements under the Privacy Amendment Act 2025.

Contact Us

If you have any questions about this Privacy Policy, or wish to access or correct your personal information, please contact us:

• Email: arapeta@trebla.nz
• Phone: 021 0271 2712
• Post: Trebla Partners Limited, Auckland, New Zealand

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner:

• Website: www.privacy.org.nz
• Phone: 0800 803 909