Finbase Privacy Policy

HP Capital Limited (trading as Finbase) is committed to respecting your privacy. Personal Information means information about an identifiable individual e.g. your name and contact details. We will always collect, store, use and disclose your Personal Information in accordance with the Privacy Act 2020 (Privacy Act).

However, we have also put in place the following Privacy Policy to protect your Personal Information when you submit, or we collect, that information – including via our Online Services, such as:

• information offered on, and provided by our website (Website);

• social media pages, including Facebook, YouTube and Instagram;

• email communications and subscription services; and

• our Investor Portal.

By providing us with your Personal Information and/or using our Online Services, you consent to the collection, storage, use and disclosure of Personal Information in accordance with this Privacy Policy.

We may amend this Privacy Policy from time to time, and will notify you of any changes by posting an updated version on our website. It is your responsibility to check this Privacy Policy periodically for changes.

What Information Do We Collect?

Information you provide

You may directly give us Personal Information about yourself, when, for example, you use our Online Services, invest or borrow with Finbase. This Personal Information may include:

• your name, addresses, contact details, date of birth, place of birth, tax identification number, tax residency status and citizenship;

• information about your bank account details and financial and personal circumstances, including your source of funds (in some cases evidence of this), and transactional and financial information relating to your user account;

• in the case of prospective employees, occupation, employment history and/or details, education and qualifications, testimonials and feedback;

• documents that verify your identity and other personal details; and

• other information which assists us in conducting our business, providing and marketing our services and meeting our legal obligations.

Information collected about you

When you visit our Website or other Online Services, we may collect more information, such as the address of your Internet service provider, the name of the web page directing you, and your clicks and activity on our site.

Clickstream data and other related information about visits to our Online Services may be collected. In addition to this, usage and performance data through using various platform specific tracking technologies available to the Online Services may be collected.

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Information collected from third parties

Information may be collected about you from third parties (including our third party affiliates or partner companies and from marketing or advertising companies) who may provide us with such information as a part of their relationship with us. We may combine this information with other information that we hold.

Third party service providers may be allowed to use technologies including mobile monitoring and tracking technologies in relation to our Online Services. These third party service providers may collect information sent by your browser or mobile device.

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Cookies and other monitoring devices

We may collect aggregated information by using cookies. Cookies are unique identification numbers like tags that are placed on the browser of internet users. The cookies do not in themselves identify users personally, but may link back to a database record about them. We may use cookies to track any aspect of our website or other Online Services.

We may use services such as Google Analytics, which will issue cookies from their own servers and which will be able to track website visitors throughout relevant websites. We do not control how those cookies are issued, or the data that they store.

We may use "web beacons" (electronic images also known as pixel tags or clear gifs) to recognise a cookie on your computer when you view or act upon a web page, an advertisement that we have placed on a third party web page, or an email or other electronic communication that we have sent.

We may also use Local Shared Objects, sometimes referred to as "Flash" cookies. Use of Local Shared Objects can help deter, detect and prevent fraud and can support our Online Services.

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How Is Your Personal Information Used?

We may (and may authorise third parties to) use your Personal Information to process your transactions and to help us develop, improve, manage, administer and facilitate our services and operations - including to provide the Online Services, to help us to develop our Online Services to be more available and user friendly to our customers, to administer your account, for safety and security issues, for our own internal purposes (such as risk management, staff training and billing), to conduct market research, for employment opportunities within and outside of our organisation for any purpose permitted by law, and for any other use associated with such purposes or which you may authorise.

In addition, we may use your Personal Information to promote and market our products and services, or the products and services of others. However, we will not do this by email or text (except as part of an email which facilitates, completes or confirms a transaction with you) unless we have your express or deemed consent to do so.

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In What Circumstances Might We Disclose Your Personal Information

We do not sell, trade or rent your Personal Information to others.

However, we may use other companies and individuals to perform services on our behalf, including but not limited to sending mail and emails, processing payments, performing credit checks and for debt recovery purposes. They will have access to your Personal Information needed to perform these services, but we will not authorise them to use your information for other purposes.

In addition, we may provide statistics about our customers, sales, traffic patterns and related site functions to reputable third parties.

When we disclose your Personal Information to overseas recipients, we ensure that the recipients of your Personal Information are required to protect it in a way that overall provides comparable safeguards to those in the Privacy Act.

We will not otherwise disclose your Personal Information unless we believe on reasonable grounds that you have provided your authorisation. However, you should be aware that we may be required to disclose your Personal Information without your consent in order to comply with any court orders, subpoenas or other legal process or investigation including by tax authorities, if such disclosure is required by law. Where possible and appropriate, we will notify you if we are required by law to disclose your Personal Information.

Storage and Security

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We are committed to protecting the security of your Personal Information and we take all reasonable precautions to protect it from loss, unauthorised or accidental access, disclosure, alteration, destruction, other misuse and actions which prevent us from accessing your information on a temporary or permanent basis (each event being a Privacy Breach).

We use industry standard (or better) administrative, physical and technical protections to safeguard the security, privacy, confidentiality and integrity of your Personal Information.

If your personal information is subject to a Privacy Breach that is likely to cause you serious harm we will notify you and the Privacy Commissioner in accordance with our obligations under the Privacy Act.

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We will only keep your Personal Information for as long as we require it for the purpose for which it was collected. However, we may also be required to keep some of your Personal Information for specified periods of time, for example under certain laws relating to companies, money laundering and financial reporting legislation.

What About Links to Other Websites?

Our Online Services may contain links to other websites that are not under our control. These websites may use cookies. It is the responsibility of those third parties to collect appropriate consents from you in order to permit their own cookies (to the extent this is required by law) and to inform you about the cookies they use. You should check the Privacy Policy on all third party websites to ensure you are comfortable with third party cookies.

We have no responsibility for linked websites, and provide them solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or warranties about their accuracy, content or thoroughness. Your disclosure of Personal Information to third party websites is at your own risk.

Email and Text Communications

We are committed to complying with the Unsolicited Electronic Messages Act 2007.

By subscribing to emails and/or text communications, or otherwise providing your email address and/or mobile number, you consent to receiving emails and/or texts (as the case may be) which promote and market our products and services, or the products and services of others, from time to time.

You can unsubscribe from our email communications and/or text communications at any time by clicking the "Unsubscribe" link in any promotional or marketing email or text received or by contacting us (our contact details can be found on www.Finbase.nz).

Once you have unsubscribed from the email or text communications, you will be removed from the corresponding marketing list as soon as is reasonably practicable.

How Can You Request Access or Correct Your Personal Information

You may request access to the information we hold about you, or request that we update or correct any Personal Information we hold about you, by setting out your request in writing and sending it to us at our contact details found at www.Finbase.nz.

We will review your request as soon as reasonably practicable. If we are unable to give you access to the information you have requested, we will give you reasons for this decision when we respond to your request.

Privacy Officer

We take your concerns seriously. If you have any concerns about privacy or the use or collection of your personal information by us, please contact our Privacy Officer at pernell@Finbase.nz and or call us on 021 143 4291.

We will respond as quickly as possible (our target response is 10 working days) and handle all complaints in a way that is fair and consistent. However, if you remain dissatisfied, you can make a formal complaint with Office of the Privacy Commissioner.

This represents our Privacy Policy as at [1 March 2024].