Icehouse Ventures Limited (IV, we, us, our), its wholly owned subsidiaries, employees, agents, subcontractors and any authorised third party shall comply with all applicable laws relating to data protection and privacy in New Zealand, including the New Zealand Privacy Act 2020 (the Act) when dealing with personal information. Personal information is information about an identifiable individual (a natural person). 

This privacy policy (Policy) sets out how we will collect, use, disclose and protect your personal information. 

This Policy does not limit or exclude any of your rights under the Act.  If you wish to seek further information on the Act, see www.privacy.org.nz.  

This Policy explains how your data is stored and used on IV’s website and its sub-domains and in the investor portal.

We collect personal information to conduct our business, to provide and market our services and meet our legal obligations.

By accessing or using any of our services, contacting us, visiting any of our websites, or otherwise providing us with your personal information, you are deemed to have accepted the terms of this Policy, including the collection, use, disclosure, storage and retention of your personal information by IV as described in this Policy. If you do not accept the terms of this Policy you are not permitted to use any of our services.

We collect and hold personal information about (but not limited to):

- Our prospective investors, investors, business associates, and portfolio companies and their employees, contractors, owners and directors;

- Individuals we deal with in the course of providing services to our investors, investing in portfolio companies and otherwise carrying on our business;

- Our third party suppliers and their employees and contractors;

- Prospective employees, employees and contractors; and

- Other people who come into contact with us.

We collect personal information about you from: 

- You directly, when you provide that personal information to us, including via our website, the investor portal and any related service, through any registration or subscription process, through any contact you may have with us (e.g. telephone call or email), or when you buy or use our services;

- Information provided by you through automated technologies or interactions with the Icehouse Ventures website or investor portal. We use Google Analytics, Google Ads, Tag Manager, Facebook, LinkedIn, FullStory, HotJar, and Hubspot Analytics to collect aggregated data on user usage; and

- Third parties where you have authorised this or the information is publicly available (including Getro, EventBrite, Whispli and First AML and Cloudcheck (as part of our AML compliance)).   

We will collect, process and store your information as provided to us as set out above. Personal information covers any information which relates to you as an identifiable individual. Below are examples of the type of information that this may include: 

- “Identity Data”, such as forenames and last name, personal or job     title and position, location, or similar identifier;

- “Contact Data”, such as physical address, email address and telephone number;

- “Transaction Data”, such as requests for services you have made to us, or in relation to services that we have supplied to you;

- “Technical Data”, such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices used to access this Website;

- “Usage Data”, such as enquiries submitted by you, information supplied, and how you use our website; and

- “Marketing Data”, such as details of any preference that you have advised us of in relation to marketing communications from us.

We may also collect non-personal information such as aggregated data which is data that may be obtained from your personal information, but which does not directly or indirectly identify you.

This may include Profile and Usage Data detailing how you use the investor portal and areas that you have interacted with.  IV only requires personal information to be provided to the extent necessary to perform our services.  In some cases, if specific personal information we request is not provided, we may not be able to perform a service for you.  

You agree that any information you give us will be accurate, correct and up to date. In the event that your information changes please notify us so that we can update our records. 

We may process personal information that you provide to us in accordance with this Policy for the following purposes:

- To enable us to provide our services to you and to communicate with you. This may include Identity, Contact, and Transactional Data;

- To notify you about any changes to our business, such as improvements to our investor portal or service/product changes, that may affect our service or relationship with you. This may include Identity and Contact Data; 

- To notify you of any activities happening within the investor portal including but not limited to new forum posts and updates in groups you are a member of. This may include all data. You may unsubscribe to receiving email campaigns from us in the investor portal;

- To market our services and products to you, including contacting you electronically; 

- To improve the services and products that we provide to you;

- To gain feedback from you and to respond to communications from you, including a complaint;

- To conduct statistical analysis (on an anonymised basis);

- To collect our impact measures (Revenue, FTE and Export data), collected and collated confidentially;

- Where we need to comply with a legal obligation. This may include Identity, Contact, Transactional and Technical Data;

- 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. This may include all types of data;

- As otherwise permitted by the Act and other laws and legal requirements to which we are subject; and  

- For any other purpose expressly authorised by you or the Act. 

We will only use your personal information for a reason other than the purpose for which it was originally obtained if we consider that we need to use it for that other purpose and have a legitimate interest in doing so. 

In carrying out the purposes set out above, we may disclose your data to third parties, including:

- Regulatory bodies as required by applicable law;

- Our third-party suppliers who may be involved in the fulfilment of our services to you;

- Any business that supports our services and products, including any person that hosts or maintains any underlying IT system or data centre that we use to provide the website or other services and products;

- Third party marketing, where you have consented for us to do so;

- For anonymised statistical information to our investors or portfolio companies;

- And any other person or organisation that you have expressly authorised us to disclose your information to. 

If we need to disclose your personal information to third parties outside of NewZealand we will comply with our obligations under the Act in relation to offshore disclosures of personal information including, if necessary, ensuring that those third parties are subject to privacy obligations that overall provide comparable safeguards to those in the Act.  

We will take reasonable steps to keep your personal information safe from loss, unauthorised activity, or other misuse. 

Subject to certain grounds for refusal set out in the Act, you are entitled to request access to, or correction of, the personal information we hold about you. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates. 

In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the personal information, we will make the correction.  If we do not make the correction, we will take reasonable steps to note on the personal information that you requested the correction. If you want to exercise either of the above rights, email us at admin@icehouseventures.co.nz  or contact our Privacy Officer on 0800 ICEHOUSE. 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). 

We may charge you our reasonable costs of providing to you copies of your personal information or correcting that information. If a fee is to be charged, we will advise you of the likely cost in advance.

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. 

We may use cookies (an alphanumeric identifier that we transfer to your computer’s hard drive so that we can recognise your browser) to monitor your use of the website.  You may disable cookies by changing the settings on your browser, although this may mean that you cannot use all of the features of the website or the portal. 

By accessing or using our services, and/or otherwise providing us with your personal information, you acknowledge that you have read and understand this Policy and that you authorise us to collect, hold, use and disclose your personal information in accordance with this Policy.

This Policy is in addition to any other applicable terms and conditions that may apply to your relationship and/or engagement with us.

You might find links to third party websites on our website.  This policy does not apply to those websites and IV takes no responsibility for the privacy practices of other third parties or websites.

If you wish to raise a complaint regarding our use of your personal information, then please email us on admin@icehouseventures.co.nz or contact our Privacy Officer on 0800 ICEHOUSE. 

We may ask you to lodge your complaint in writing. Any complaint will be investigated by the Privacy Officer and you will be notified of the decision in relation to your complaint as soon as practicable after it is made, usually within 10 working days.

If we are unable to satisfactorily resolve your concerns about our handling of your personal information, you can contact the Office of the Privacy Commissioner at: PO Box 10-094, The Terrace, Wellington 6143, phone 0800 803909, http://privacy.org.nz/.

We may update this Policy from time to time to reflect changes to the website, the portal and customer feedback. 

Any amendments will be effective from the time that the updated Policy is uploaded to our website.

Please regularly review these policies to be informed of how we are protecting your personal information. 

We welcome any queries, comments or requests you may have regarding this Policy. Please do not hesitate to contact us via admin@icehouseventures.co.nz. 

This Policy has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us via the contact details specified in this Policy to obtain this Policy in an alternative format.

The address details of Icehouse Ventures Limited, as the person collecting and holding your personal information is: 

The Textile Centre, Level 4, 117-125 St Georges Bay Road,Parnell, Auckland 1052, New Zealand.