Privacy Policy

Astra Capital Limited (“Astra Capital”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store and disclose personal information in accordance with the Privacy Act 2020 and other applicable New Zealand laws.

1. Information We Collect

We may collect personal information when you visit our website, contact us, enquire about an investment opportunity, subscribe to communications, attend an event or engage with us as an investor, prospective investor, business partner or service provider.

Information we collect may include:

• your name and contact details;

• company, occupation and professional information;

• investment interests and preferences;

• information relevant to determining wholesale investor eligibility;

• identification and verification information where required;

• information required for due diligence, compliance or regulatory purposes;

• financial, banking or source-of-funds information where relevant to an investment;

• communications and correspondence with us; and

• technical information relating to your use of our website, such as IP address, browser information, device information and cookies.

We will only collect personal information that is reasonably necessary for our business activities or where otherwise permitted or required by law.

2. Information Collected from Other Sources

In some circumstances, we may receive personal information about you from third parties, including professional advisers, business partners, introducers, service providers, publicly available sources or organisations involved in an investment transaction.

Where required by the Privacy Act 2020, we will take reasonable steps to ensure you are aware that we have collected your information, why it was collected, who may receive it and your rights in relation to that information.

3. How We Use Your Information

We may use your personal information to:

• respond to enquiries and communicate with you;

• assess and manage investment opportunities;

• determine investor eligibility;

• undertake due diligence and verification;

• establish and manage investor or business relationships;

• administer investments and transactions;

• meet legal, regulatory, tax and compliance obligations;

• prevent fraud and manage business risk;

• improve our website, services and investor experience;

• provide information about Astra Capital and relevant opportunities where permitted; and

• carry out other purposes directly related to the reason the information was collected.

Where applicable, this may include meeting obligations under New Zealand financial services, taxation, anti-money laundering or other regulatory requirements.

4. Disclosure of Personal Information

We may disclose personal information where reasonably necessary to:

• our employees, directors and authorised representatives;

• fund managers, investment partners, developers or project partners;

• legal, accounting, tax and other professional advisers;

• banks, financial institutions and payment providers;

• technology, data storage and website service providers;

• identity verification, compliance and due diligence providers;

• regulators, government agencies or law enforcement authorities where required or permitted by law; and

• other parties involved in a proposed or completed investment or transaction.

We do not sell personal information to third parties.

5. Overseas Service Providers

Some of our service providers or business partners may store or process information outside New Zealand.

Where the Privacy Act 2020 applies to an overseas disclosure, we will take reasonable steps to ensure the recipient provides privacy safeguards comparable to those required under New Zealand law, or otherwise comply with the requirements for overseas disclosure.

6. Storage and Security

We take reasonable steps to protect personal information against loss, unauthorised access, misuse, alteration or disclosure.

Information may be held electronically or physically by Astra Capital or trusted service providers acting on our behalf.

If a privacy breach occurs that has caused, or is likely to cause, serious harm, we will take appropriate action and make notifications as required under the Privacy Act 2020.

7. Retention of Information

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, or as required by applicable legal, regulatory, tax or record-keeping obligations.

When information is no longer required, we will take reasonable steps to securely delete, destroy or anonymise it.

8. Cookies and Website Analytics

Our website may use cookies and similar technologies to help the website function, understand how visitors use the site and improve the user experience.

You may be able to control or disable cookies through your browser settings. Disabling certain cookies may affect the functionality of parts of the website.

Where third-party analytics or website services are used, those providers may also process information in accordance with their own privacy policies.

9. Marketing Communications

Where permitted by law, we may use your contact information to send you updates about Astra Capital, investment opportunities, events or other information that may be relevant to you.

You can unsubscribe from marketing communications at any time using the unsubscribe function provided in the communication or by contacting us.

10. Accessing and Correcting Your Information

Under the Privacy Act 2020, you have the right to request access to personal information we hold about you and to request correction if you believe the information is inaccurate or incomplete.

To make an access or correction request, please contact our Privacy Officer using the details below.

We may need to verify your identity before providing access to personal information.

11. Links to Other Websites

Our website may contain links to third-party websites. Astra Capital is not responsible for the privacy practices, security or content of external websites. We recommend reviewing the privacy policy of any third-party website you visit.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our business, technology, regulatory requirements or privacy practices.

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The latest version will be published on our website together with the date it was last updated.