Privacy Policy

Last updated: 1/1/2025

1. Information We Collect

1.1 Information You Provide to Us

We collect information you provide directly to us, including:

• Account Information: Name, email address, phone number, residential address
• Investor Qualification: Information to verify wholesale investor status, income details, net asset information
• Investment Preferences: Asset classes of interest, investment goals, risk tolerance, investment amount ranges
• Communications: Any information you provide when contacting us or participating in surveys
• Profile Information: Investment experience, professional background, areas of interest

1.2 Information Collected Automatically

When you access our platform, we automatically collect:

• Usage Data: Pages visited, time spent, offers viewed, search queries, click patterns
• Device Information: IP address, browser type, operating system, device identifiers
• Location Data: General geographic location based on IP address
• Cookies and Tracking: Information collected through cookies, web beacons, and similar technologies

1.3 Information from Third Parties

We may receive information about you from:

• Investment providers and fund managers featured on our platform
• Analytics and marketing partners
• Public databases and records
• Referral partners

2. How We Use Your Information

We use the information we collect to:

• Provide Services: Operate and maintain our platform, match you with suitable investment opportunities
• Verify Eligibility: Confirm wholesale investor status and eligibility for investment opportunities
• Facilitate Connections: Connect you with investment providers and fund managers
• Communications: Send you updates, newsletters, investment opportunities, and marketing materials
• Improve Platform: Analyze usage patterns, improve user experience, develop new features
• Personalization: Customize content and recommendations based on your preferences
• Security: Detect, prevent, and address fraud, security risks, and technical issues
• Legal Compliance: Comply with legal obligations and enforce our terms

3. Information Sharing and Disclosure

3.1 Sharing with Partners

By using our platform, you consent to us sharing your information with our partners, including:

• Investment Providers: When you express interest in an opportunity, we share your contact details and relevant investor information with the fund manager or investment provider
• Platform Partners: Investment platforms and aggregators featured on our site may receive your information when you inquire about their offerings
• Referral Partners: Licensed financial advisors and investment consultants who may assist you
• Service Providers: Third-party vendors who help us operate our platform (email services, analytics, hosting)

3.2 Business Transfers

If we are involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you via email and/or prominent notice on our platform of any such change in ownership or control of your personal information.

3.3 Legal Requirements

We may disclose your information if required to do so by law or in response to:

• Legal proceedings, court orders, or government requests
• Compliance with regulatory requirements (FMA, AML/CFT obligations)
• Protection of our rights, property, or safety, or that of others
• Detection and prevention of fraud or security issues

3.4 Aggregate Data

We may share aggregated or de-identified information that cannot reasonably be used to identify you, including statistics about investment trends, platform usage, and market insights.

4. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:

• Remember your preferences and settings
• Analyze platform usage and performance
• Provide personalized content and recommendations
• Measure advertising effectiveness

You can control cookies through your browser settings. However, disabling cookies may limit your ability to use certain features of our platform.

5. Data Security

We implement industry-standard security measures to protect your personal information, including:

• Encryption of data in transit and at rest (HTTPS/SSL)
• Secure database storage with access controls
• Regular security audits and monitoring
• Employee training on data protection
• Secure authentication and authorization systems

However, no method of transmission over the Internet is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

6. Data Retention

We retain your personal information for as long as necessary to provide our services and comply with legal obligations. Specifically:

• Account information: Retained while your account is active and for 7 years after closure (regulatory requirement)
• Communication records: Retained for 7 years (regulatory requirement)
• Usage data: Typically retained for 2 years
• Marketing data: Until you unsubscribe or request deletion

7. Your Rights and Choices

Under New Zealand privacy law, you have the right to:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information (subject to legal obligations)
• Opt-Out: Unsubscribe from marketing communications at any time
• Restriction: Request restriction of processing in certain circumstances
• Data Portability: Receive your data in a structured, machine-readable format
• Object: Object to processing of your information for certain purposes

To exercise these rights, contact us at privacy@wholesaleinvestor.co.nz. We will respond to your request within 20 working days as required by the Privacy Act 2020.

8. Marketing Communications

We may send you marketing emails about investment opportunities, platform updates, and related content. You can opt out at any time by:

• Clicking the "unsubscribe" link in any marketing email
• Updating your communication preferences in your account settings
• Contacting us at privacy@wholesaleinvestor.co.nz

Note: Even if you opt out of marketing communications, we may still send you transactional emails related to your account or services you've requested.

9. International Data Transfers

Your information may be transferred to and processed in countries other than New Zealand, including:

• United States (hosting and cloud services)
• Australia (data processing and analytics)
• European Union (service providers)

We ensure appropriate safeguards are in place to protect your information in accordance with New Zealand privacy laws.

10. Third-Party Links

Our platform may contain links to third-party websites, including investment provider websites. We are not responsible for the privacy practices of these sites. We encourage you to review the privacy policies of any third-party sites you visit.

11. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes by:

• Posting the updated policy on our website with a new "Last Updated" date
• Sending an email to your registered email address
• Displaying a prominent notice on our platform

Your continued use of our platform after such changes constitutes acceptance of the updated Privacy Policy.

13. Governing Law

This Privacy Policy is governed by the Privacy Act 2020 (New Zealand) and other applicable New Zealand laws and regulations.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Email: privacy@wholesaleinvestor.co.nz
• Subject Line: "Privacy Inquiry"

If you are not satisfied with our response, you have the right to lodge a complaint with the Office of the Privacy Commissioner: www.privacy.org.nz

15. Consent

By using our platform and services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein, including the sharing of your information with investment providers, platforms, and partners.