INDUS: PRIVACY POLICY

Introduction

This Privacy Policy outlines how Indus collects, manages, and protects your personal information.

At Indus, we are committed to safeguarding your privacy and are required to comply with the Privacy Act 2020 (Privacy Act) when handling your personal data. In this Privacy Policy, "your information" refers to personal information as defined and protected under the Privacy Act. Any personal information you provide to us will be securely stored, used, and disclosed in accordance with this policy.

Throughout this Privacy Policy, the terms "Indus", "we", "us", and "our" refer to Indus Limited. We prioritise transparency and ensure that your data is managed with the utmost care as part of our commitment to providing a secure investment experience.

Your information will be collected by Indus and held by:

Indus Limited, 14 Edison Place, St Heliers, Auckland, 1071, New Zealand.

Acceptance of this Privacy Policy

By accessing or using the Platform, our services, or providing us with your information, you agree to this Privacy Policy and authorise the collection, use, and storage of your information as outlined in the policy.

Information we may collect about you

We collect information you give us

When you create an account, use our app or services, or register your interest in research or feature releases, we may collect information from you, including your name, date of birth, email address, phone number, physical address, identification details, payment information, tax details, account preferences, voice recordings of any inquiries, and feedback on our services.

You are not required to provide us with your information. However, if you choose not to, or if we are unable to collect your information, it may limit our ability to provide our services to you.

We collect information created when you use our services

We may collect information about you when you use our services, including details of your orders, investment records, your instructions, and data on how you interact with our services.

We collect information from third parties

We may collect information about you from third parties, including service providers that assist with identity verification, bank account verification, and payment initiation. This includes financial institutions, fraud prevention agencies, and electronic verification services that help us confirm your identity and facilitate secure transactions. Additionally, we may gather information from publicly available sources and third-party providers that support marketing, compliance, and operational functions.

By using our services, you consent to our use of electronic verification services for identity confirmation, payment processing, and account verification.

How we can use your information

We use your information where necessary to provide our services, to comply with legal and regulatory obligations, for our legitimate business purposes, or where you have provided your consent, as outlined in this Privacy Policy.

We can use your information to provide our services

We use your information to deliver, personalise, and enhance our services. For instance, we may use it to create and update your account, verify your identity, process transactions such as trades, withdrawals, and payments, resolve operational issues, and conduct testing and research.

We can use your information to keep things safe, secure and comply with legal and regulatory obligations

We may collect, use, and disclose your information to detect, prevent, and safeguard against fraud, criminal activity, and other risks, and to comply with our legal and regulatory obligations, including obligations under anti-money laundering and countering financing of terrorism (AML/CFT) laws and other applicable financial services regulations.

This may include using your information to:

• verify your identity and perform electronic identity checks;
• conduct sanctions screening and ongoing customer due diligence;
• monitor transactions and account activity;
• investigate and prevent fraud or other unlawful activity; and
• report to regulators, law enforcement agencies, or other authorities where required.

We can use your information for customer support

We may use your information to communicate with you, enhance our customer support, and resolve any disputes.

We can use your information for research and development

We may use your information for testing, research, analysis, and development to improve and ensure the safety of our services. Information collected from you and other users of our websites, app, or services, whether directly or through third parties, may be combined to generate aggregated and anonymised analytics and market data, as well as to provide general insights on the market. We may also use your information to collect feedback through third parties.

We may use your information to promote Indus and share content we believe will interest you.

We may use your information to send you communications about our services or those of our partners, where permitted by law. You can opt out of receiving marketing communications at any time by using the unsubscribe function in our communications or adjusting your preferences within your account settings.

Who we can share your information with

We may share your information with third parties, such as:

• subsidiaries of Indus;
• custodians or sub-custodians;
• investment providers, for example listed companies and managed fund providers
• the exchanges that you invest through
• third parties that help us to carry out the service (for example, to verify your identity or process transactions);
• software-as-a-service providers that we use to provide the service;
• cloud-storage providers;
• marketing partners and third party providers (such as Google, Facebook, and programmatic display) who assist us to market or promote our services to you—as described in the 'A note on cookies and similar technology' section below;
• data analytics or research partners;
• third parties that help us to enhance the safety and security of the Service;
• where required, local and international regulators (for example, the Financial Markets Authority and Securities and Exchange Board of India);
• our consultants, lawyers, accountants, insurers, and professional advisors.

As part of providing our services, your information may be transferred to, stored in, or accessed from countries outside of New Zealand. This may include jurisdictions such as India and other countries where our service providers, custodians, brokers, or partners operate.

These transfers are necessary to:

• facilitate investments into international markets;
• enable custody, settlement, and transaction processing;
• meet legal and regulatory requirements in those jurisdictions.

In some cases, the laws of those countries may differ from New Zealand privacy laws.

Where we transfer your information overseas, we take reasonable steps to ensure that the recipient is required to protect your information in a manner that, overall, provides safeguards comparable to those under the Privacy Act 2020. This may include contractual protections and working with regulated financial institutions and service providers.

By using our services, you acknowledge and authorise these international disclosures.

We may also share your information if we believe it’s allowed by Law or is appropriate due to fraud, security, or similar concerns.

We may share your information in the event that we sell or merge some or all of our business or assets with another company.

We may also use and share your information in other ways with your consent.

We may use and share information that does not personally identify you for any purpose.

A note on cookies and similar technology

Cookies and similar technologies are used to recognize your browser or device during and between visits to our website or app. Our service may include these technologies for purposes like remembering your preferences and settings, enhancing security, analysing traffic and trends, and measuring the effectiveness and popularity of features or marketing. This helps us improve our website, app, and services, providing you with a better overall experience.

This technology is connected to your browser or device and collects information such as your device type, date and time of use, referring website or advertisement, IP address, and advertising identifiers. We may also link this data to other information we have collected about you.

We may use third-party advertising platforms (such as Google and Facebook) to display our ads on their websites or platforms. We may also use analytics to track and understand the performance of these ads and our services. These platforms may use cookies and similar technologies to recognize your browser or device when you use our service, as well as when you visit other websites and online services.

Retaining and deleting your information

We may keep your information:

• for as long as you have an Account;
• for a minimum of seven years (after your Account is closed) to comply with regulatory, tax, insurance, and other requirements;
• for as long as we believe necessary for the purposes set out in this Privacy Policy; or
• for an indefinite period if we deem it necessary, such as for fraud prevention, safety, and security purposes.

We're committed to keeping your information safe and secure

We continually implement and update security measures to protect your information. However, despite our efforts, we cannot guarantee the complete security of your information during transmission or storage.

Your rights regarding your information

You may:

• withdraw any consents given in relation to the handling by us of your information;
• request access to your information (we may charge a fee); or
• request that we correct information that is inaccurate or out of date by contacting us through the Platform.

If you request us to correct your information, we will take reasonable steps, in accordance with our obligations under the Privacy Act, to update or amend the information.

If you no longer wish to receive marketing emails from us or our business partners, or prefer not to have your information shared for direct marketing purposes, you can opt out by using the unsubscribe feature in any marketing communications we or our business partners send.

Third-party links

Our service may include links to third-party websites, but our terms do not apply to them. We are not responsible for the content, functionality, or privacy practices of those websites.

Changes to our Privacy Policy

This document outlines our current Privacy Policy, last updated on August 31, 2024. We may review and update this policy periodically, and any changes will be communicated by posting the revised version on our website.

Contact us

If you have any questions about our Privacy Policy or would like to request access to or correction of the information we hold about you, please contact our Privacy Officer at:

Attention: The Privacy Officer
Email: support@indus.nz

If you have concerns that we have not met our obligations to you as required by the Privacy Act, you may contact us and make a complaint at the email listed above.

More information about your rights and our obligations in respect to privacy and information on making a privacy complaint are available from the Office of the Privacy Commissioner at:

Website: www.privacy.org.nz
Email: investigations@privacy.org.nz