Privacy Policy

In short

• We follow the NZ Privacy Act 2020
• We never sell your information
• People, not AI, give you advice
• See and correct your information free of charge

Contents

1. Who we are
2. Our Privacy Officer
3. What personal information we collect
4. How we collect it
5. Why we use your information
6. Who we share it with
7. Storing information overseas
8. How we use AI (artificial intelligence)
9. Keeping your information safe
10. How long we keep it
11. Your right to see and correct your information
12. If there is a privacy breach
13. Our website and cookies
14. Questions or complaints
15. Changes to this policy

Who we are

This policy explains how Clearwater Accountants Limited (“we”, “us”, “our”) collects, uses, shares and protects your personal information. We are an accounting, tax and business advisory firm based at 1 Station Road, Manurewa, Auckland. We are a member of the Accountants and Tax Agents Institute of New Zealand (ATAINZ) and act as a tax agent for our clients with Inland Revenue.

We follow the Privacy Act 2020 and its 13 Information Privacy Principles. This policy applies to our clients, people who contact us or visit our website, and anyone whose information we hold while doing our work. It applies to all our offices.

Our Privacy Officer

Our Privacy Officer is responsible for making sure we look after your information properly. If you have any questions about this policy or your information, please get in touch:

• NameAmardeep Singh, Director
• Emailamardeep@cwat.co.nz
• Phone / WhatsApp022 096 2760
• Post1 Station Road, Manurewa, Auckland 2102

We are happy to talk about this policy in English or Punjabi.

What personal information we collect

We only collect information we need to provide our services and meet our legal obligations. Depending on the work we do for you, this may include:

• Identity details – name, date of birth, and identity documents such as a passport or driver licence (for example, for anti-money laundering checks)
• Contact details – address, phone number and email
• Tax details – IRD numbers, tax returns and correspondence with Inland Revenue
• Financial records – bank statements, income, expenses, assets, loans and investments
• Business information – company, trust and partnership details, shareholders, directors, employees and payroll
• Family details – where needed, for example for Working for Families or family trusts
• Website information – what you send us through our online forms, and basic technical information from cookies

Some information about your business may include personal information about other people, such as your employees or family members. Please let them know you are sharing it with us.

How we collect it

Most information comes directly from you – in meetings, by phone, email or WhatsApp, through our website forms, or in documents you give us.

With your authority, we may also collect information from:

• Inland Revenue (for example, through our tax agent access)
• Your bank and other financial institutions, including bank feeds into accounting systems
• The Companies Office and other public registers
• Your previous accountant, lawyer, mortgage adviser or other people you ask us to deal with

If you choose not to give us some information, we may not be able to complete the work or give you complete advice. We will tell you if that is the case.

Why we use your information

We use your personal information to:

• Prepare your accounts, tax returns, GST, payroll and other filings
• Act for you as your tax agent with Inland Revenue
• Give you tax, accounting and business advice
• Confirm your identity and meet our legal obligations, including anti-money laundering law and professional standards
• Reply to your enquiries and manage appointments
• Send invoices and run our practice
• Send you useful updates such as key tax dates (you can opt out at any time)

We will not use your information for any other purpose unless you agree, or the law allows or requires it.

Who we share it with

We only share your information when it is needed to do our work for you, when you agree, or when the law requires it. This may include:

• Inland Revenue, to file returns and deal with your tax affairs
• The Companies Office and other government agencies, for filings and registrations
• Banks and lenders, with your consent (for example, when you apply for a loan)
• Other professional advisers such as lawyers, valuers or financial advisers, when you ask us to
• Trusted service providers who help us run our practice, including cloud accounting, payroll, document storage and other software providers. They may only use your information to provide their service to us and must keep it confidential.
• Our professional body, regulators or auditors, if we are required to (for example, a quality review)

Storing information overseas

Some of our trusted service providers, such as cloud accounting and storage providers, may store or process information on secure servers outside New Zealand.

When this happens, we take reasonable steps to make sure your information is protected in a way that is comparable to the New Zealand Privacy Act, as required by Information Privacy Principle 12. For example, we choose providers that are subject to comparable privacy laws or that agree in their terms to protect information to a similar standard.

How we use AI (artificial intelligence)

Like many modern firms, we may use AI-assisted tools to help us work faster and more accurately. For example, AI may help with:

• Data entry
• Bank transaction coding
• Drafting letters and documents
• Summarising information
• Administrative work

Our promises to you:

• People stay in charge. A qualified team member always reviews AI output. Professional judgement and advice always come from people, not AI.
• Secure tools only. We only use tools that have appropriate security and confidentiality commitments.
• Your information is not used to train public AI. Where we can control it, we choose settings so your information is not used to train public AI models.
• No decisions by AI alone. We do not use AI to make decisions that have legal or other significant effects on you without human review.
• Your choice. You can ask us how AI was used on your work, or tell us you would prefer that it is not used. We will respect your preference wherever we reasonably can.

Keeping your information safe

We take reasonable steps to protect your information from loss, misuse, unauthorised access, changes or disclosure. These include:

• Password-protected systems and secure sign-in
• Access limited to team members who need it for their work
• Confidentiality obligations for our team and service providers
• Secure storage and safe disposal of paper and electronic records

No system is ever completely secure, but we work hard to keep your information safe. Please take care when sending us information too, for example by not sending passwords by email.

How long we keep it

We keep your information only for as long as we need it for our work or as the law requires. Tax law generally requires business and tax records to be kept for at least 7 years, and some records may need to be kept for longer.

When information is no longer needed, we securely destroy or delete it.

Your right to see and correct your information

Under Information Privacy Principles 6 and 7, you have the right to:

• Ask for a copy of the personal information we hold about you
• Ask us to correct it if you think it is wrong, incomplete or out of date

Just contact our Privacy Officer. This is free of charge. We will respond as soon as we can, and no later than 20 working days after we receive your request. We may need to confirm your identity first. In a few cases the law allows us to refuse a request; if so, we will explain why.

If we do not agree to change your information, you can ask us to attach a statement of the correction you asked for.

If there is a privacy breach

If a privacy breach happens, we will act quickly to contain it and reduce any harm. If the breach has caused, or is likely to cause, serious harm (a “notifiable privacy breach”), we will notify the Office of the Privacy Commissioner and the affected people as soon as practicable, as the Privacy Act requires.

Our website and cookies

When you use the forms on our website, such as our contact or appointment request forms, we collect the details you enter and use them to reply to you.

Our website uses cookies (small files saved by your browser) to help it work properly. We do not use cookies to identify you personally or for advertising. You can block or delete cookies in your browser settings, although some parts of the site may not work as well.

Our website may link to, or show content from, other websites such as maps or social media. Those websites have their own privacy policies, and we are not responsible for them.

Questions or complaints

If you have a concern about how we have handled your personal information, please contact our Privacy Officer first. We take every concern seriously and will try to resolve it quickly and fairly.

If you are not satisfied with our response, you can make a complaint to the Office of the Privacy Commissioner:

• Websitewww.privacy.org.nz
• Phone0800 803 909

Changes to this policy

We may update this policy from time to time, for example when the law or the way we work changes. The latest version will always be on this page, with the date it took effect.

This policy is effective from 25 October 2026.