Privacy Policy

South Bastion Limited ("South Bastion", "we", "us") respects your privacy. This policy explains how we collect, use, store and share personal information, and the rights you have over it. We are a New Zealand company and we handle personal information in line with the Privacy Act 2020 and its Information Privacy Principles.

This policy applies to personal information we collect through our website, by email, in meetings, and in the course of our investment activities.

1. Information we collect

We only collect personal information that we need for a lawful purpose connected with our business. Depending on how you deal with us, this may include:

• Contact details — your name, email address, phone number, organisation and role.
• Investor information — if you invest with or alongside us, identity and verification details, eligibility information (for example, to confirm wholesale investor status), and bank account details for payments.
• Founder and company information — if you seek investment from us, information about you and your business that you share with us, such as pitch materials, financials and references.
• Correspondence — the content of emails, messages and meeting notes.
• Website data — basic technical information such as IP address, browser type and pages visited, collected through cookies or similar tools.

We usually collect information directly from you. Sometimes we collect it from others — for example, co-investors, introducers, public registers or verification providers — where you would reasonably expect this or have agreed to it.

2. How we use it

• To respond to your enquiries and communicate with you.
• To assess, make and manage investments in public and private companies.
• To onboard investors and confirm eligibility.
• To meet our legal and regulatory obligations, including anti-money laundering and countering financing of terrorism requirements where they apply, tax reporting and record-keeping.
• To send you updates you have asked for. You can opt out at any time.
• To run, secure and improve our website.

We will not use your information for a purpose that is unrelated to why we collected it unless you agree, or the law allows it.

3. Who we share it with

We do not sell personal information. We share it only where needed, with:

• Our professional advisers, such as lawyers, accountants and auditors.
• Service providers who help us operate — for example, email, cloud storage, identity verification and banking providers — under obligations to keep it confidential and secure.
• Co-investors, fund administrators or portfolio companies, where this is part of a transaction you are involved in.
• Government agencies, regulators or courts, where the law requires or permits it.

4. Overseas storage and disclosure

We invest globally and some of our service providers store data outside New Zealand, including in Australia, Singapore, the United Kingdom, the European Union and the United States. Where we disclose personal information overseas, we take reasonable steps to make sure it will be protected in a way comparable to New Zealand law, as required by the Privacy Act 2020.

5. Security and retention

We take reasonable steps to protect personal information from loss, misuse and unauthorised access, including access controls, secure systems and confidentiality obligations. We keep information only for as long as we need it for the purposes above or as the law requires — for example, records we must keep for tax or anti-money laundering purposes — and then securely delete or destroy it.

If a privacy breach occurs that has caused, or is likely to cause, serious harm, we will notify the people affected and the Office of the Privacy Commissioner as the law requires.

6. Cookies

Our website may use cookies and similar tools to make it work properly and to understand, in aggregate, how visitors use it. You can block or delete cookies through your browser settings, although some parts of the site may not work as intended.

7. Your rights

You have the right to ask for access to the personal information we hold about you, and to ask us to correct it if you think it is wrong. To make a request, contact us using the details below. We will respond within 20 working days, as the Privacy Act requires. We may need to verify your identity first, and in limited cases the law allows us to decline a request — if so, we will tell you why.

8. Contact and complaints

Questions, requests or complaints about privacy should go to our Privacy Officer:

Privacy Officer, South Bastion Limited
Suite 9098, 17b Farnham Street, Parnell, Auckland 1052, New Zealand
marcus@southbastion.co.nz

If you are not satisfied with our response, you can complain to the Office of the Privacy Commissioner at privacy.org.nz.

9. Changes to this policy

We may update this policy from time to time. The current version will always be on this page, with the date it took effect.