Privacy policy
Soul Capital is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, store, use, share, and safeguard your personal information when you visit our website or those of any of the investment funds we manage (the "Websites"), or engage with us in connection with our investment activities, including but not limited to the submission of grant applications, business plans, pitches, fund raising or due diligence materials.
We are subject to the Privacy Act 2020 (NZ) as a New Zealand “agency”, which governs the collection, use and disclosure of “personal information” that is defined broadly in the Privacy Act as “information about an identifiable individual”. There are 13 information privacy principles (IPPs) contained in the Privacy Act which govern how an organisation should collect, store and use or share personal information.
When you engage with us, including by accessing our Websites or services, and provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. Accordingly, please read this Policy carefully, which should be read together with any other agreements you make with us.
Furthermore, by accessing or using our Websites, you agree to this Privacy Policy. If you do not agree with the terms of this policy, please do not use our Website or share any personal information with us.
“We”, “us” and “our” refer to Soul Capital Limited, the Te Pae ki te Rangi Limited Partnership and The Awhi Fund Limited and their officers, employees and contractors.
1. Information We Collect
We may collect and process the following types of information:
Personal Information: including but not limited to the following:
Contact Information: when making an inquiry or contacting us - your name, email address, phone number, and organisation name.
Pitch and Professional Information: when applying for a grant or submitting an investment pitch to us or we invest in your business - your gender, job title, role, qualifications, career history, personal and professional references, resume, links to your website/LinkedIn profile and other business-related information you (or third parties) may provide, such as details of your business or prospective business, including registration details, financial and business model information and intellectual property as well as information provided by you relating to your preferences, values, aspirations, opinions as they relate to the purpose and/or mission of your organisation or its impact objectives.
Comms Information: when communicating with us - messages, feedback, or other information you share with us through emails, online forms, or any other communication channels including your interests, preferences or opinions and associations with social causes or interests.
Employment Information: when you seek employment with us - your name, your contact details, your qualifications and employment history, your employment and/or visa status, your current remuneration details, background and/or reference checks plus other information we are required by law to collect.
Compliance Information: when required by law or regulation - data and documents you provide to us and which are required for Anti Money Laundering (AML) checks, your investor status, your date of birth and gender, your passport and other identification documents and government identifiers.
Generally we will collect personal information only from you. However, in some circumstances we may be provided with information by third parties. Whilst we obtain this personal information in various different ways we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it. And we recognise it is often subject to additional obligations of confidentiality.
Our services are not directed to children under 16. Accordingly we do not knowingly collect their personal information.
Non-Personal Information: such as
when using our Website, information about how users use our Website, such as IP addresses, browsing patterns and behaviour, pages visited, and referring websites. (This information is typically collected using cookies or similar tracking technologies.)
details of the device users have used to access any part of our Website including IP address, geo-location and network data and connection type.
2. How We Use Your Information
We may use the information we collect for the following purposes:
To Evaluate Grant Applications or Investment Opportunities: we may use your personal and professional information to assess potential investment opportunities and analyse investment proposals and grant applications.
To Report on Fund Performance or Impact Metrics: we may use information relating to an individual’s racial or ethnic origin, gender identity or sexual orientation - together with more standard business data - for the purpose of reporting on the overall performance of, or evidencing progress with impact metrics for, the investment funds we manage. Generally we will only make public anonymised aggregated information of this personal nature unless we have your express consent to use it in a way that may identify you, or such disclosure is connected with one of the purposes for which that information was originally collected, in which case we will endeavour to do so in the most appropriate manner. You may withdraw this consent at any time by providing us with written notice.
To Communicate with You: we use your contact information to respond to inquiries, provide updates, and engage with you regarding potential grants, investments, partnerships, or other matters such as your attendance at or participation in events or activities conducted by us or our partners. (You may unsubscribe from our mailing lists at any time by contacting us in writing.)
To Improve Our Services: we may analyse usage data to improve the functionality and performance of our Website.
To Ensure Compliance: we may process your information as necessary to comply with audit and legal obligations, regulatory requirements or to enforce our terms of service.
To Manage Risk: we may be required to verify your identity, including banking information, to help protect us from fraud or the fraudulent use of our services.
3. How We Share Your Information
We may disclose or share your information in the following circumstances:
With Service Providers: we may share your information with trusted third-party service providers or vendors who provide services to us or for the purposes of our business activities, functions or services including hosting, IT support, data analytics , professional advisors, audit purposes. These service providers are required to use your information only for the purposes for which it was provided.
With Affiliates and Partners: we may share your information with affiliates, investors, business partners or grant providers as part of our grant making or investment processes, subject to confidentiality agreements. To enable us to carry on our business activities and continue to provide our services, we may transfer your information to, store at, or disclose to any of our affiliates, partners or third-party service providers, which may be located outside of New Zealand.
In particular, we may store your information in a cloud or other types of networked or electronic storage. As such storage may be accessed from various countries via an internet connection, it is not always practicable to know in which country your information may be held. If your information is held in this way, disclosures may occur in countries other than New Zealand.
With Portfolio Entities and Investors: we may share your information for the purposes of introducing you to our portfolio entities, their management team or shareholders and in order to meet our reporting obligations to the investors in the investment funds we manage.
Where Required by Legal Proceedings: we may disclose your information if permitted or required by law, regulation, or legal process such as a subpoena, court order, or regulatory investigation. In certain circumstances, your information may be shared with the Inland Revenue (IRD) or the New Zealand Companies Office (NZCO) and the Financial Markets Authority (FMA), which will then exchange this information with similar overseas regulatory bodies as a result of New Zealand’s participation in the Common Reporting Standard and Foreign Account Tax Compliance Act.
Where in accordance with this Privacy Policy, we disclose your personal information to third parties who reside outside New Zealand, you acknowledge that we may not be able to ensure that those third parties comply with New Zealand privacy laws. Wherever practically feasible, we will contractually require overseas providers to protect your information to standards comparable to NZ law. However, overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.
4. Security of Your Information
Your information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure. While we implement security measures to protect your information, we cannot guarantee the absolute security of any information that is transmitted to or by us over the internet. No method of transmission over the internet is completely secure. Such transmission and exchange of information is carried out at your own risk.
When your information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information. However, for internal governance and risk management purposes, most of the information we collect is, or will be, stored in files which will be kept by us for a minimum of 7 years.
5. Your Data Rights
Depending on your location, you may have the following rights with respect to your personal information:
Access: you have the right to request access to the personal information we hold about you.
Correction: you have the right to request that we correct any inaccuracies in your personal information.
Deletion: you have the right to request that we delete your personal information, subject to applicable legal and regulatory requirements.
Opt-Out: you can opt out of receiving promotional or marketing communications from us by following the unsubscribe instructions included in our communications or contacting us directly.
To exercise any of these rights, our contact details are set out in section 10 below.
You may also lodge a complaint with the Office of the Privacy Commissioner NZ (www.privacy.org.nz) if you are not satisfied with our response to you seeking to exercise these rights.
6. Cookies and Tracking Technologies
We may use cookies and similar tracking technologies to enhance your experience on our Websites. Cookies are small data files stored on your device that help us understand your usage patterns, improve Website functionality, and personalise your experience. You can control the use of cookies through your browser settings. However, please note that disabling cookies may affect your ability to use certain Website features.
7. Third-Party Links
Our Website may contain links to third-party websites, services, or applications. These third-party websites are not operated by us, and we are not responsible for their content or the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy. Clicking on any of those links subjects you to the privacy policies of the relevant third-party sites you visit, which we encourage you to review carefully.
8. Transfer of Information Outside of NZ
If you are accessing our Website from outside of New Zealand, please be aware that your information may be transferred to and stored in New Zealand where our servers are located or to the countries of contracted third party hosting providers. By using our Website, you consent to the transfer of your information to countries that may have different data protection laws than your own.
9. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Any update will be published on our Website, and will take effect from the date it is updated. This Policy was last updated on 10 July 2025.
We encourage you to check our Website periodically to ensure you are aware of our current Privacy Policy and to stay informed about how we are protecting your information.
10. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or your personal information, please email our Privacy Officer: privacy@soul.capital
If you wish to make a complaint, you may do so by providing your written complaint to the email address above. Where possible, the complaint should include enough information to help us resolve it. We will investigate and respond to your complaint in writing within 20 working days, setting out the outcome of our investigation and the steps we will take in response to your complaint.
You also have the option of lodging a complaint with the Privacy Commissioner NZ: enquiries@privacy.org.nz.