Octagon Privacy Policy

1.            Investing in the Octagon Investment Funds 

1.1       By investing in or applying to invest in the Octagon Investment Funds or by signing up for or using the Octagon Wallet, you authorise us to (and acknowledge that we may): 

(a)           collect, hold and disclose information about you for the purposes of us or any of our affiliates providing services to you, compliance with applicable laws (whether the relevant laws apply to us or our affiliates or to a third party with whom you are dealing through us), conducting verification or security checks, administering your account, or for our own marketing purposes or to further the relationship between you and us; 

(b)           collect information about you from, or disclose information about you to: 

(i)           your joint unit holders (if any), or any of our affiliates in connection with any of the purposes above; and 

(ii)          for the purpose of verifying your identity to comply with applicable laws or for other business purposes,

Department of Internal Affairs (www.dia.govt.nz),

New Zealand Companies Office (https://companies-register.companiesoffice.govt.nz),

Land Information New Zealand (www.linz.govt.nz),

New Zealand Transport Agency (www.nzta.govt.nz),

New Zealand Government Confirmation Service (www.digital.govt.nz/products-and-services/products-and-services-a-z/confirmation-service),

Equifax (www.equifax.co.nz),

Experian / Illion (www.experian.co.nz),

Data Zoo (www.datazoo.com), through third-party service provider GB Group PLC (www.gbg.com) and its subsidiary Cloudcheck (www.gbg.com/nz/verify-identity/cloudcheck-identity-verification), and

any other entity that we notify you of;

(c)         disclose information about you to: 

(i)            any person where required by applicable laws or where we believe the giving of the information will help prevent fraud, money laundering or other crimes; and

(ii)           any third party with whom you are dealing through us to the extent that that person reasonably requires that information in connection with compliance with applicable laws; and 

(d)           use information about you for any of the purposes above. 

1.2       Except as authorised in this Privacy Policy, we will not disclose information about you acquired in connection with your account to other persons, unless you authorise that disclosure. If we do disclose information about you, we may not be allowed to tell you. 

1.3       You agree that we may disclose information about you to overseas third parties who may not be required to protect the information in a way that, overall, provides comparable safeguards to those that apply in New Zealand. However, we use reasonable efforts to make sure that these third parties have adequate privacy safeguards in place. 

1.4       Where you provide information about other individuals to us, you confirm and/or agree: 

(a)           you are authorised to do that, 

(b)           you make the authorisation in clause 1.1 above on their behalf and you are authorised to do that, 

(c)            you will let those people know (to the extent they may not otherwise be aware and where you are not legally responsible for that person) about the collection of their personal information, the purpose for which it’s collected, who it may be shared with, their rights of access, our identity, and how to contact us; and 

(d)           upon request, we will assist you in responding to any individual’s request to access or update their personal information that you have provided to us. 

2.             Use of Digital Platforms 

2.1       “Digital Platforms” refers to how we engage with you online, including our website. We respect the privacy of the users of https://www.octagonasset.co.nz (our ‘website’). This part of the privacy policy explains how we may collect, store, use, and disclose personal information that you provide to us across our digital platforms. By continuing to use our digital platforms you consent to our collecting, storing, using, and disclosing your personal information in the manner set out in this privacy policy. 

2.2        Collection 

(a)           We may collect personal information from you (including, without limitation, your name, email address, phone number, and postal address) when you use our digital platforms, including by using our digital platforms to update personal information we hold about you. You may decide not to provide your personal information to us. However, if you do not provide it, we may not be able to provide you with access to certain information or services. 

(b)           When you use our digital platforms, we may use automated tools and methods (such as cookies and sessions) to collect certain information about your visit, including (without limitation):

(i)            the internet protocol address and domain name used by your computer, or digital device to connect to the Internet

(ii)          the operating system and the browser your computer or digital device uses, and any search engine or inbound hyperlink used to reach this website;

(iii)        the date, time, and duration of your visit; and

(iv)        the content viewed by you. 

(c)            We will also use this information, in a personalised form, to present content we believe is relevant to the user. 

(d)           We may gather more extensive information if we are concerned, for example, about abnormal website usage patterns or website security breaches. 

2.3        Use and disclosure 

(a)           We will not use or disclose your personal information except in accordance with the Privacy Act 2020. We may use your personal information to:

(i)             present you with website content that we believe is relevant to you;

(ii)           provide you with products and services and information on products and services;

(iii)         progress an account application for you, where you have agreed to that;

(iv)        provide you with information (including promotional material and news) where you agree to receive such information;

(v)          improve or update our digital platforms and our information and services; communicate with you; and

(vi)        analyse usage of our digital platforms. 

(b)           We may use information collected from use of our digital platforms in aggregate form to analyse how our digital platforms are being used (for example to analyse usage patterns in order to improve our digital platforms)

(c)      We will not sell, rent, or lease your personal information to third parties except in accordance with this privacy policy. Your personal information may be made available internally and to our agents or contractors for the above purposes. We will only use or disclose personal information that you have provided to us, or which we have obtained about you:

(i)            for the above-mentioned purposes;

(ii)          if you have authorised us to do so (including as part of any application for units in the Octagon Investment Funds);

(iii)         if we have given you notification of the intended use or disclosure and you have not objected to that use or disclosure;

(iv)        if we believe that the use or disclosure is reasonably necessary to assist a law enforcement agency or an agency responsible for national security in the performance of their functions;

(v)          if we believe that the use or disclosure is reasonably necessary to enforce any legal rights we may have, or is reasonably necessary to protect the rights, property and safety of us, our customers, or others; or

(vi)        if we are required or permitted by law to disclose such information. 

2.4        Google Analytics 

(a)           We use Google Analytics to analyse the use of digital platforms. In addition to data collected through a standard Google Analytics implementation, we may also use Google Display Network Impression reporting, Google Analytics Demographics and Interest Reporting, and Google Tag Manager. We may collect data this via Google Analytics cookies and other first-party identifiers, and third-party cookies (such as DoubleClick cookies) or other third-party identifiers together. Further information about how Google Analytics collects and processes data can be found here.  

(b)           You are able to opt out of the Google Analytics advertising features we use through Google Ad Settings. In addition you can use Google Analytics’ opt outs. 

2.5        Storage, Security and Retention 

(a)           Personal information collected on this website is collected and stored by us. We will take reasonable steps to protect personal information that is held by us from unauthorised access, use, disclosure, alteration, or destruction. 

(b)           Where you have provided personal information through our digital platforms in order to progress an account application, we will delete the personal information from our databases if the application is not progressed within a period that we consider to be reasonable. 

2.6       Third Party Websites and Services 

(a)          Our digital platforms may contain hyperlinks to, or content sourced from, websites or services operated by third parties. We are not responsible for such websites or services, or the manner in which those third parties collect, store, use, and distribute any personal information that you provide to them or that we provide to them in accordance with this privacy policy. When you visit third party websites from hyperlinks displayed on our digital platforms, we encourage you to review the privacy statements of those websites so that you can understand how the personal information you provide may be collected, stored, used and disclosed.  

3.            Right to Access and Correct 

3.1       You may request access to, or correction of, any personal information we hold about you by emailing us at info@octagonasset.co.nz. To ensure that the personal information we hold about you is accurate and current, please notify us of any changes to such personal information as soon as possible. 

4.            Changes to our privacy policy 

4.1       We reserve the right, at our discretion, to alter this privacy policy at any time. Changes to this privacy policy will take effect immediately once they are published on this website.

This privacy policy was updated on 23 April 2026.