PRIVACY POLICY

Elevation Capital Management Limited

FSP #1011848  |  Version 1.0  |  Effective: 1 March 2026

1. Introduction

Elevation Capital Management Limited (“ECML”, “we”, “our”, or “us”) is committed to protecting the privacy of individuals who interact with our website and services. This Privacy Policy explains how we collect, use, disclose, and protect personal information in accordance with the Privacy Act 2020 (New Zealand) and any other applicable New Zealand privacy legislation.

ECML is a Registered Financial Service Provider in New Zealand (FSP #1011848) registered under the Financial Service Providers (Registration and Disputes Resolution) Act 2008. We operate as a global asset manager providing investment management services exclusively to wholesale investors as defined in Schedule 1 of the Financial Markets Conduct Act 2013.

This Privacy Policy applies to information collected through our website at www.elevationcapital.co.nz (the “Website”), and in the course of our business dealings. By accessing or using our Website, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy.

2. Information We Collect

We may collect personal information in the following circumstances:

2.1  Information You Provide Directly

  • Contact details such as name, email address, phone number, and postal address when you contact us via our website or otherwise;

  • Professional information including your role, organisation, and investment experience when you engage with us as a prospective or existing client;

  • Correspondence and communications you send to us, including emails and messages submitted via any contact forms; and

  • Documentation required to verify your status as a wholesale investor under the Financial Markets Conduct Act 2013.

2.2  Information Collected Automatically

When you visit our Website, we or our service providers may automatically collect certain technical information, including:

  • Your IP address and general geographic location;

  • Browser type, version, and operating system;

  • Pages visited, time spent on pages, and referring URLs; and

  • Device identifiers and other usage data collected via cookies or similar technologies.

Please refer to Section 7 (Cookies) for further information.

3. How We Use Your Information

We collect and use personal information only for lawful purposes that are directly related to our business functions and activities. Specifically, we may use your personal information to:

  • Respond to enquiries and communicate with you about our services;

  • Assess your eligibility as a wholesale investor and manage our client relationships;

  • Fulfil our obligations under applicable financial services legislation including the Financial Markets Conduct Act 2013 and the Anti-Money Laundering and Countering Financing of Terrorism Act 2009;

  • Provide investment management services, reporting, and related communications;

  • Monitor, analyse, and improve the performance and functionality of our Website;

  • Comply with our legal, regulatory, and contractual obligations; and

  • Protect the security and integrity of our systems and services.

We will not use your personal information for any purpose that you would not reasonably expect, or that is not otherwise permitted under applicable law.

4. Disclosure of Personal Information

ECML does not sell, rent, or trade personal information to third parties. We may disclose personal information in the following limited circumstances:

4.1  Service Providers

We may share personal information with trusted third-party service providers who assist us in operating our business, including IT infrastructure providers, custodians (including Public Trust), compliance and legal advisers, and fund administrators. Such parties are engaged on terms that require them to keep your information confidential and to use it only for the purposes for which it was disclosed.

4.2  Regulatory and Legal Obligations

We may disclose personal information to regulators, law enforcement agencies, or other authorities where required or permitted to do so by law, including the Financial Markets Authority (FMA), Inland Revenue Department (IRD), or New Zealand Police.

4.3  Professional Advisers

We may disclose personal information to our lawyers, auditors, insurers, or other professional advisers where necessary for the conduct of our business.

4.4  Business Transactions

In the event of a merger, acquisition, restructuring, or sale of all or part of our business, personal information held by us may be transferred to the relevant successor entity, subject to equivalent privacy protections.

5. Overseas Disclosure

ECML is a global asset manager and may, from time to time, transfer personal information to recipients located outside New Zealand, including in connection with investment management activities or the use of overseas technology service providers.

Where personal information is transferred overseas, we take reasonable steps to ensure that the recipient is subject to privacy protections comparable to those required under the Privacy Act 2020, or that the transfer is otherwise permitted by New Zealand law. By providing us with your personal information, you acknowledge that it may be transferred to and processed in jurisdictions outside New Zealand.

6. Security of Personal Information

ECML takes reasonable technical and organisational measures to protect personal information against unauthorised access, disclosure, alteration, or destruction. These measures include access controls, secure communication protocols, and regular review of our data handling practices.

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security. In the event of a privacy breach that is likely to cause serious harm, we will notify affected individuals and the Privacy Commissioner in accordance with our obligations under the Privacy Act 2020.

7. Cookies and Tracking Technologies

Our Website may use cookies and similar tracking technologies to enhance user experience, analyse website traffic, and understand how visitors interact with our content. Cookies are small data files stored on your device by your browser.

The types of cookies we may use include:

  • Essential cookies: necessary for the basic functioning of the Website;

  • Analytics cookies: used to collect aggregate, anonymised information about how visitors use the Website (e.g. pages visited, session duration); and

  • Preference cookies: used to remember settings or choices you have made on previous visits.

You may configure your browser to refuse cookies or to alert you when cookies are being sent. Please note that disabling cookies may affect the functionality of certain parts of the Website. We do not use cookies to track you across third-party websites or to serve targeted advertising.

8. 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 of that information if it is inaccurate, incomplete, or misleading.

To exercise these rights, please contact us using the details set out in Section 10 below. We will respond to access and correction requests within a reasonable timeframe and in accordance with our obligations under the Privacy Act 2020. We may need to verify your identity before processing your request.

In limited circumstances, we may decline to provide access or make a correction, for example where doing so would unreasonably prejudice the interests of another individual, where information is subject to legal privilege, or where the request is frivolous or vexatious. Where access or correction is refused, we will provide written reasons.

9. Retention of Personal Information

We retain personal information only for as long as is necessary for the purposes for which it was collected, or as required by law. In particular, we are subject to record-keeping requirements under applicable financial services legislation, including the Financial Markets Conduct Act 2013 and the Anti-Money Laundering and Countering Financing of Terrorism Act 2009, which may require us to retain certain information for minimum prescribed periods.

When personal information is no longer required, we will take reasonable steps to destroy or de-identify it in a secure manner.

10. Third-Party Websites

Our Website may contain links to external websites that are not operated or controlled by ECML. This Privacy Policy does not apply to those websites. We are not responsible for the privacy practices of third-party sites and encourage you to review the privacy policies of any external sites you visit. The inclusion of any link on our Website does not constitute an endorsement of the linked site.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational circumstances. Any updates will be posted on our Website with a revised effective date. We encourage you to review this Privacy Policy periodically. Continued use of our Website following any changes constitutes your acceptance of the revised policy.

12. Complaints

If you have a complaint about how we have handled your personal information, please contact us in the first instance using the details below. We will investigate your complaint and respond within a reasonable timeframe.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Privacy Commissioner:

  • Website: www.privacy.org.nz

  • Phone: 0800 803 909

  • Post: PO Box 10 094, The Terrace, Wellington 6143, New Zealand

13. Contact Us

For any enquiries relating to this Privacy Policy, or to exercise your rights under the Privacy Act 2020, please contact:

Elevation Capital Management Limited

Attention: Privacy Officer

Level 17, 1 Albert Street, Auckland 1010, New Zealand

Email: chris.swasbrook@elevationcapital.co.nz

Website: www.elevationcapital.co.nz