Privacy Policy

This website is operated by HPA Group Limited, a New Zealand registered company with its head office at 46 Gavin Street, Ellerslie, Auckland 1060 (PO Box 11 535, Ellerslie, Auckland 1542).

In this policy, “we”, “us” and “our” mean HPA Group Limited. “You” means anyone using this website or contacting us through it.

We handle personal information in accordance with the Privacy Act 2020 and its information privacy principles.

This policy applies to the HPA Investors website and to the investor portal accessed through it. It does not cover other HPA Group websites, individual village websites, or third-party sites we link to, each of which may have its own privacy policy.

Information you give us. When you create an investor account, request the Information Memorandum, or contact us, we collect:

• Your name
• Your email address
• Your organisation, if you provide one
• The investor category you identify with (for example, New Zealand high-net-worth, international investor, landholder, lender or adviser)
• Any message or enquiry you send us
• Your confirmation as to whether you qualify as a wholesale or eligible investor under the Financial Markets Conduct Act 2013

Information collected automatically. Like most websites, our hosting and analytics tools may record technical information such as your IP address, browser and device type, the pages you view, and the site you arrived from. We use this in aggregate to understand how the site is used and to keep it secure.

Information from meetings and site visits. If you attend a site visit or director call arranged through this site, we may record contact details and notes about your interests so we can follow up appropriately.

You do not have to give us personal information. If you choose not to, we may not be able to provide investor materials or respond to your enquiry.

We use personal information to:

• Respond to your enquiry and stay in contact with you
• Assess whether you qualify to receive restricted investment information
• Create and administer your investor portal account
• Provide the Information Memorandum, pipeline briefs, project updates and related materials
• Arrange site visits, meetings and investor events
• Meet our legal and regulatory obligations, including record-keeping under financial markets legislation and, where applicable, customer due diligence under anti-money laundering law
• Improve the website and understand how it is used

We will not use your information for a materially different purpose without telling you first, unless the Privacy Act permits it.

If you create an investor account, we may send you occasional updates about the pipeline, project progress and investment opportunities. Every message includes a way to unsubscribe, and you can ask us to stop at any time by emailing info@hpa.co.nz. Unsubscribing does not remove your account or affect information we are required to keep.

We do not sell personal information, and we do not share it for third-party marketing. We may share it with:

• HPA directors and staff who need it to respond to you
• Our professional advisers: legal, accounting and financial
• Service providers who operate parts of this site on our behalf, such as hosting, email delivery and customer relationship management
• A statutory supervisor, trustee or auditor where a project structure requires it
• Regulators, law enforcement or others where we are required or permitted by law to do so

Where a service provider handles personal information for us, they are required to protect it and may only use it for the purpose we engaged them for.

Some of our service providers store information on servers outside New Zealand. Where that happens, we take reasonable steps to satisfy ourselves that the information will be protected by standards comparable to those in the Privacy Act 2020, as required by information privacy principle 12.

We take reasonable technical and organisational steps to protect personal information against loss, misuse and unauthorised access. Investor materials sit behind account-based access rather than being published openly.

No website can be completely secure. If you hold an investor account, please keep your sign-in details to yourself and tell us promptly if you think your account has been accessed by someone else.

We keep personal information for as long as we need it for the purposes described above, and for as long as we are required to by law. Investor records are generally retained for the life of the relationship and for the statutory period afterwards. When information is no longer needed, we securely dispose of it.

This site uses cookies and similar technologies to keep you signed in to the investor portal and to understand how the site is used. Most browsers let you refuse or delete cookies. If you block them, parts of the investor portal may not work.

Under the Privacy Act 2020 you have the right to ask us for a copy of the personal information we hold about you, and to ask us to correct it if it is wrong. There is no charge for making a request, and we will respond within 20 working days.

To make a request, email info@hpa.co.nz or write to us at the address above. We may need to verify your identity first.

If you are unhappy with how we have handled your personal information, please tell us first. Email info@hpa.co.nz and we will look into it.

If you are not satisfied with our response, you can complain to the Office of the Privacy Commissioner at privacy.org.nz or on 0800 803 909.

We may update this policy from time to time. The current version is always published on this page, with the date it was last updated shown at the top. Material changes affecting how we use your information will be notified to account holders directly.

Privacy questions can be directed to HPA Group Limited, 46 Gavin Street, Ellerslie, Auckland 1060, or info@hpa.co.nz, or +64 9 974 3641.