Privacy Policy

Acceptance of this Policy

We collect personal information to enable us to make investments, offer services, undertake our business and to meet our legal obligations.

By accessing or using any of our services, contacting us, visiting our websites, logging into our investor portal or otherwise providing personal information, you are accepting the terms of this Policy, including the collection, use, disclosure, storage and retention of your personal information by us as described in this Policy. If you do not accept this Policy you may not be able to use some parts of our services or websites.

Information We Collect

We collect Personal Information from prospective investors, investors, prospective portfolio company individuals, portfolio company individuals, service providers, prospective employees, employees and contractors, and other such individuals that may contact us.

The Personal Information we handle, collect and process may include:

• Identity information, including your name, contact details, nationality and national identify numbers, your professional title and occupation, your age and marital status, ‘know your client’ checks such as details relating to your passport or other identification documentation and credit history;
• Financial information: including bank account details, social security number, IRD number, national insurance number, tax file / identification number, tax status, account details and evidence of ownership of financial assets;
• Usage information: usage data (including but not limited to; IP address, browser type, browser version, the pages of our websites that you visit, the time and day of your visit, the time spent on those pages, unique device identifiers and other diagnostic data, in addition, if you access our websites through a mobile device we may collect additional information relating to that device, we may also collect information that your browser sends to us whenever you visit our websites or visit the site using a mobile device);
• Technical information: personal identifiers such as your IP address, MAC address, or other internal electronic identifiers; and
• other information you provide in the course of your dealings with us or which may be required to provide you with products and services.

In certain circumstances, we also collect and process what are known as ‘sensitive’ or ‘special categories’ of Personal Information. Money laundering, sanctions, financial crime and fraud prevention checks sometimes result in GD1 obtaining information about actual or alleged criminal convictions and offences.

How We Collect Your Information

We collect the Personal Information from:

• you, when you or your authorised representative provide that Personal Information to us, through application information and other information supplied during the course of your relationship with GD1, or through any other interactions with us (e.g. telephone call, email or web chat).
• use of the Website, any action an individual takes while using our website. We use this information to provide the Website, understand what content and features are effective and improve our website and services.
• Third parties, including for credit checks, AML/KYC checks, information provided by Portfolio Companies.

How We Use Your Personal Information

We will not process Personal Information, other than as outlined in this Privacy Policy, without having a lawful basis to do so.

We process Personal Information:

• to provide services and products to you;
• to communicate with you;
• to undertake credit checks and AML/KYC requirements;
• to provide you with updates on investments and services;
• to market to you and provide you with information around events;
• to provide our website and otherwise carry out our obligations under the terms of use and any other terms with you and enforce these terms;
• to assess suitability of employment or other engagement and undertake employment obligations towards you;
• to verify your identify and other such verification of information required at law;
• to protect and/or enforce our legal rights and interests, including defending any claim;
• to review potential portfolio companies and undertake services in relation to the portfolio companies;
• to improve our website, services and products;
• to communicate with third parties (including our suppliers and service providers), as necessary to provide the services;
• to comply with our obligations to our third-party service providers, suppliers and other users of our website and services;
• to analyse usage of the website and services, or carry out research and analysis, so we can improve the website and services;
• to send you marketing and promotional messages and other information that may be of interest to you where you have consented to receiving such material. You can opt out of receiving marketing materials from us by using the opt-out facility provided (e.g. an unsubscribe link) or by emailing us at [email protected];
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
• for any other purpose authorised by you or the Act.

We may also use Personal Information collected for such other purposes that are compatible with the original purpose described above, or that we the relevant individual has otherwise consented to from time to time.

We may anonymise and aggregate information such that no person could be re-identified from the information. This aggregated and anonymised data is not Personal Information and this privacy policy does not apply to it.

Disclosing Personal Information

We may disclose Personal Information to:

• service providers and suppliers who provide necessary goods and/or services to us;
• third parties, as necessary to provide the services;
• any business that supports us, including hosting or maintaining any underlying IT system that we use to provide our website and/or services;
• other third parties to anonymise and aggregate statistical information;
• protect and defend the rights or property of GD1 and its officers, directors, contractors, employees and agents;
• prevent or investigate possible wrongdoing in connection with the services or products;
• protect the personal safety of users of the products, services or the public; or
• protect against legal liability;
• a person who can require us to supply Personal Information (e.g. a regulatory authority or law enforcement agency); and
• any other person or entity that we have been validly authorised to disclose information to.

Overseas Transfers

We utilise the services of entities in various countries (including, Australia, the United States, Singapore, Japan, Taiwan, the Cayman Islands, the EU and the UK). Consequently, we may transfer Personal Information to parties located in these countries. Although we will endeavour to ensure that Personal Information is treated securely and in accordance with this Privacy Policy as well as applicable Data Privacy Laws, we advise that some of these countries may not have an equivalent level of data protection laws as those in New Zealand.

Third Party Services

We use third party services for providing the Website and Purchasing Service, to ensure a better experience for users and for improving the Website and Purchasing Service. In the process of doing so, the third party service provider may have access to Personal Information. However, these third parties do not have the right to use the Personal Information for their own use.

Internet Use

While we take reasonable steps to maintain secure internet connections, if you provide us with Personal Information over the internet, the provision of that information is at your own risk.

If you follow a link on our websites to another website, the owner of that website will have its own privacy policy relating to your Personal Information. We suggest you review that website’s privacy policy before you provide access to your Personal Information.

How Long We Keep Personal Information

We will keep Personal Information:

• until we no longer have a valid reason for keeping it;
• until the relevant individual requests us to stop using it; or
• for as long as required by law e.g., we keep invoice information for 7 years to fulfil our tax obligations.

You should be aware that we do keep backups and logs for a period before they are automatically deleted.

Cookies and Tracking

We may use various technologies to collect and store information about individuals when they use the website and the Investor Portal, and this may include using cookies and similar tracking technologies, such as pixels and web beacons.

Cookies

A cookie is a piece of information that our web server may send to your machine when you visit our website. The cookie is stored on your device, but does not identify you or give us any information about your device.

The types of cookies we use may include:

• Strictly necessary cookies: These cookies are essential for the full functionality of our websites. They enable you to navigate around our websites and use its features. Without these cookies, you may not be able to access all the functions of our websites.
• Performance cookies: These cookies collect information about how you use our websites. All information these cookies collect is anonymous and only used to improve how our websites.
• Functionality cookies: These cookies allow our websites to remember the choices you make (for example, your user name, language or your region). Although these cookies are used to enhance the performance of our websites, they are non-essential to their use. However, without these cookies, certain functionality may become unavailable.

The length of time a cookie will stay on your browsing device depends on whether it is a persistent or session cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies will stay on your browsing device until they expire or are deleted.

With most internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. If you want to do this, refer to your browser instructions or help screen to learn more. If you reject the use of cookies, you will still be able to access our websites but please note that some of its functions may not work as well as if cookies were enabled. To learn more about how to enable, edit, or disable cookies on your computer, please visit the aboutcookies.org website.

Web analytics

We use Google Analytics to collect information about use of our websites, with the goal of improving our websites. Google Analytics collects information such as how often users visit the websites, what pages they visit when they do so, and what other sites they used prior to coming to the site.

Web beacons

Web beacons are tiny graphics with a unique identifier that may be included on the websites for several purposes. For example, we may use web beacons to deliver or communicate with cookies, to track and measure the performance of the websites, to monitor how many visitors view our websites, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on an individual’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an email). We use these web beacons to customise content and advertising and to analyse traffic to our websites.

Protecting Personal Information

We take the protection of Personal Information seriously and we will take reasonable steps to keep Personal Information in our possession safe from loss, unauthorised activity, or other misuse.

Your Rights

You have the right to access and correct your readily retrievable Personal Information that we hold about you, and to ask for it to be corrected if you think it is wrong. We may refuse on certain grounds set out in the Data Privacy Laws.

If you wish to exercise your rights under this Privacy Policy, you can do this by emailing our Privacy Officer at [email protected]. Your email should provide evidence of who you are and set out the details of your request (e.g. the Personal Information, or the correction, that you are requesting).

There may still be residual information such as errors logs, emails, calendar invites, data backups etc that record some Personal Information about you (primarily email address, name, and any content sent via email). If you also require this information to be deleted, please include this in your request.

Changes to this Privacy Policy

From time to time we may make changes to this Privacy Policy (for example, to reflect any changes in our Purchasing Service or any Data Privacy Laws). Where a change is significant, we’ll make sure we let you know – usually by displaying a notice on our Website.

Other

This Privacy Policy relates to your Personal Information and should not be used as the basis for any decision to purchase or redeem investments in GD1. The views and information expressed in this Policy do not constitute and may not be relied upon as constituting any form of investment advice or inducement to invest, and prospective investors must obtain appropriate independent professional advice before making investment decisions.