Privacy Policy

Last Updated: 01/10/2025

1. Introduction

This Privacy Policy explains how Horizon Fund Manager Limited collects, uses, stores, and protects your personal information. We are committed to protecting your privacy and complying with the New Zealand Privacy Act 2020 and its 13 Information Privacy Principles (IPPs).

2. Scope and Wholesale Investors

This policy applies to our wholesale investors and professional contacts. Our services are not intended for minors, and we do not knowingly collect their personal information.

3. What Personal Information We Collect

The types of personal information we collect are directly related to your professional interactions with us. Based on our current services, this is limited to:

  • Identifiers and Contact Data: Information such as your name, professional title, and business email address.
  • Commercial Information: Records of our correspondence, including your questions and feedback.

We do not use cookies or automated tracking technologies on our website at this time. Should this change, we will update this policy.

4. How We Use Your Personal Information

We will only use your personal information for the purpose for which it was collected. The primary purpose for collecting your contact details is to communicate with you and respond to your enquiries.

5. How We Store and Protect Your Information

We take reasonable steps to protect your personal information from loss, unauthorised access, and misuse. Your information is stored securely and is only accessible to authorised personnel.

6. Disclosure of Your Information

We will not disclose your personal information to any third party unless:

  • You have authorised the disclosure;
  • It is required or permitted by New Zealand law; or
  • It is necessary in connection with the services we provide to you.

7. Your Rights

Under the Privacy Act 2020, you have the right to:

  • Access: Ask for a copy of the personal information we hold about you.
  • Correct: Request correction of any inaccurate or incomplete information.
  • Object: Object to the use of your information in certain circumstances.

To exercise these rights, please contact our Privacy Officer using the details in Section 9.

8. Complaints

If you are not satisfied with our response to any privacy-related concern, you have the right to make a complaint to the Office of the New Zealand Privacy Commissioner (www.privacy.org.nz).

9. How to Contact Us & Privacy Officer

For any questions about this Privacy Policy, to exercise your rights, or to lodge a complaint, please contact our Privacy Officer:

Email: Info@hfm.co.nz

Note: This is the preferred and most efficient method of communication.

10. Changes to This Privacy Policy

We may update this policy from time to time. The latest version will always be posted on our website with the updated effective date.