Privacy Policy

1. Introduction

Black Whole Solutions Limited (trading as "Ledger Black"; "we", "our", "us") is committed to protecting the privacy of our users and their clients. This privacy policy explains how we collect, use, store, and protect personal information in accordance with the New Zealand Privacy Act 2020 and the Information Privacy Principles.

2. Data Sovereignty

All personal data you enter into Ledger Black, records, documents, recordings, and backups, is stored and replicated exclusively on New Zealand-owned infrastructure, to meet the data residency expectations of New Zealand financial services regulations and the Privacy Act 2020.

Our AI features (for example, drafting documents and meeting summaries) are currently powered by specialist AI providers that may process data overseas. We only engage these providers under contractual data-protection terms that prohibit them from selling your data or using it to train their models, consistent with Information Privacy Principle 12. Particularly sensitive information (such as medical and tax details) is handled with additional safeguards. We continue to strengthen on-shore processing of client data.

3. Information We Collect

We collect information that financial advisers provide when using our platform, including account information, client data entered for practice management purposes, and usage data to improve our service. Financial advisers are the data controllers for their client information; Ledger Black acts as a data processor on their behalf.

4. Security

We employ enterprise-grade encryption, encrypted communications, role-based access controls, comprehensive audit logging, and regular security assessments. Our security practices meet the standards expected for financial services data protection.

5. Retention

Where we act as a data processor for a Financial Advice Provider, records of advice and the information used to give that advice are retained for at least 7 years from the date the advice was given, in accordance with FAP Standard Condition 4 under the Financial Markets Conduct Act 2013. Account and platform usage data is retained for as long as is reasonably necessary to operate the service. After the retention period, the Financial Advice Provider remains responsible for ongoing retention or deletion of client records in line with their regulatory obligations.

6. Your Rights

Under the New Zealand Privacy Act 2020, you have the right to access and request correction of your personal information, and to request deletion of your personal information (subject to lawful retention obligations, such as the 7-year financial advice record-keeping requirement). We may require evidence of your identity before actioning a request.

To make a privacy or data deletion request, email hello@ledgerblack.co.nz. Every request we receive is logged, tracked and responded to within 20 working days, as required by the Privacy Act 2020.

7. Contact

Black Whole Solutions Limited
Auckland, New Zealand
hello@ledgerblack.co.nz