Privacy Policy

We are committed to protecting and respecting your privacy and personal information.

We handle your personal information in accordance with the Privacy Act 2020 (the Privacy Act). This Privacy Policy explains how we collect, use, disclose, and store your personal information.

This Policy may be updated from time to time. Any changes will be posted on our website, and continued use of our services will constitute acceptance of those changes. We encourage you to review this Privacy Policy periodically. If you provide personal information about another person, you must have their authorisation to do so.

References to “Newland Credit Fund,” “we,” “us,” and “our” in this Privacy Policy refer to Silver Fern Asset Management Limited, the manager of the Newland Credit Fund, and its related companies, agents, and delegates where applicable. This Privacy Policy applies to all products and services made available by us.

What Information We Collect

Most personal information we collect comes directly from you. This may include:

Your name, date of birth, identification details (e.g. driver’s licence, passport), address, email, and phone number
Nationality, income, bank account, and tax information
Investment and financial information related to your relationship with us
Any information you provide through our website, forms, or correspondence
Behavioural data relating to your use of our website (pages visited, links clicked, date/time of visits, referring sites, browser type, IP address, etc.)

How We Collect Your Information

We collect personal information when you:

Interact with us by phone, email, post, or in person
Use our website or online services
Provide information in connection with investment applications or inquiries

Personal information you provide is securely stored within authorised systems, accessible only to individuals with appropriate permissions.

We may also collect information from publicly available sources, government agencies, professional advisers, or third-party service providers (such as credit agencies or analytics tools) where legally permitted.

When you use our website, we may use cookies or analytical tools to understand how our site is used and improve user experience. Cookies do not personally identify you but may link to anonymised data for analytics. You can control or disable cookies through your browser settings.

How We Use Your Information

We collect and use your personal information to operate our business, comply with our legal obligations, and deliver the best possible service to you. This includes:

Managing your investment or enquiry with us
Complying with legal, regulatory, and reporting obligations (including AML/CFT, KYC, and tax requirements)
Processing applications, payments, and instructions
Communicating with you about your investment and our services
Maintaining and improving our website and business operations
Providing information about our products, services, and investment opportunities that may interest you
Conducting internal research and analysis to improve our offerings

By providing your contact details, you consent to us sending you relevant updates and information via email or other communication channels. You may opt out at any time by following the instructions in our communications.

When We Disclose Your Information

We may disclose your personal information to:

Our professional advisers, auditors, administrators, and service providers
Regulatory or government authorities where required by law
Third parties assisting with compliance, marketing, or technology services (under strict confidentiality obligations)
Other parties where disclosure has been authorised by you or is permitted under the Privacy Act

We do not sell or rent personal information to third parties. We will not disclose your information to overseas recipients without your consent unless the recipient is subject to comparable privacy safeguards or we have taken reasonable steps to ensure your information is protected.

How We Store and Protect Your Information

Your personal information is stored securely in both physical and electronic formats. We take reasonable steps to protect it from unauthorised access, loss, misuse, or disclosure. Our systems are protected by secure servers, restricted access, and regularly reviewed data-protection measures.

We will retain your personal information only for as long as necessary to fulfil the purposes for which it was collected or as required by law.

Accessing and Correcting Your Information

You have the right to request access to, or correction of, the personal information we hold about you. We will respond to such requests within 20 working days, in accordance with the Privacy Act 2020.

To make a request, or if you have any privacy concerns, please contact our Privacy Officer at:

Email: invest@ncf.co.nz
Postal: Silver Fern Asset Management Limited
c/ Newland Capital Management, 656 Great South Road, Ellerslie, Auckland 1051

If you believe we have not handled your personal information appropriately, please contact us. We will investigate your concerns promptly.

Nothing in this Privacy Policy limits your rights under the Privacy Act 2020. This Policy is governed by the laws of New Zealand.

This Privacy Policy is current as at 7 October 2025.