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5 Star NZ Limited
Sheet 98·Privacy · LGL-98.PRIVACY
Privacy

Privacy Policy

Last reviewed 21 May 2026 — pending final NZ legal review pre-launch.

5 STAR NZ LIMITED ("we", "us") is the agency for the purposes of the New Zealand Privacy Act 2020. This policy describes how we collect, hold, use and disclose personal information in connection with our website and the Investor Assessment process.

What we collect (IPP 1, 3, 4)

Personal information you submit via the Investor Assessment form: name, email, phone, country, business role and experience, industries, capital band, liquidity timeline, source of funds, project interest, preferred deployment timeline, preferred region, notes, and your preferred call time. We collect this directly from you (IPP 2) for the lawful purpose of assessing your interest, contacting you, and undertaking required regulatory and commercial checks (IPP 1, 3).

How we use it (IPP 10)

We use your information to assess your suitability for our investor programme, to schedule a strategy call, to coordinate with our New Zealand legal and accounting partners on potential next steps, and to comply with regulatory obligations including the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act) and the Financial Markets Conduct Act 2013. We do not sell or rent your data.

AML/CFT customer due diligence

Before any capital is deployed into a 5 Star NZ project, we conduct customer due diligence under the AML/CFT Act, including verification of identity, beneficial ownership (where applicable), and source of funds. Information you provide during the assessment forms the starting point for those checks. You may be asked to provide additional documentation (passport, proof of address, source of funds evidence) before due diligence is complete.

Disclosure (IPP 11)

We may share your information with: our New Zealand legal counsel and accounting advisors engaged on the relevant transaction; our AML/CFT reporting partners; our self-managed email infrastructure (Hostinger SMTP, for transactional email delivery); and any regulator (FMA, NZ Police Financial Intelligence Unit, IRD) where required by law. We do not transmit your investor-assessment data to our content platform (Sanity) — that platform only holds published website material.

Storage and security (IPP 5)

Investor records and form submissions — the data you provide through the Investor Assessment, together with any AML/CFT due-diligence material, is held in our self-managed PostgreSQL database on infrastructure located in New Zealand and operated by 5 Star NZ Limited. Access is restricted to authenticated administrators.

Published website content (project descriptions, photography, insights, press mentions and other public-facing material) is hosted on Sanity, a content platform operated by Sanity.io. Sanity stores this content on cloud infrastructure outside New Zealand and delivers it to your browser via a global content-delivery network. This content does not contain any information you have submitted to us — only material we have chosen to publish to the public.

Transactional emails are sent from our own infrastructure (Hostinger SMTP); no third-party email-marketing platform is in use.

Retention

We retain investor-assessment records for the period required by the AML/CFT Act (currently five years from the date of the last transaction or, if no transaction occurred, the date of the assessment), after which the record is securely destroyed unless retention is required by another statute.

Cookies, browser storage, and embeds

We have intentionally built this site to minimise the data that leaves your browser:

  • No third-party analytics. We do not run Google Analytics, Meta Pixel, HubSpot, Plausible, or any other analytics product.
  • No marketing cookies. No advertising, retargeting, or behavioural cookies are set on the public site.
  • Admin session cookies. Payload CMS sets a session cookie only after an authenticated administrator logs into /admin. These cookies are not set for public visitors.
  • Form draft (browser localStorage). While you complete the Investor Assessment, your in-progress answers are saved to your own browser's local storage under the key 5sn-lead-draft-v1 so you can resume without losing input. The draft is cleared from your browser once you submit (or you can clear it yourself from browser settings). The draft is also written to our database every 30 seconds while you fill in the form, so we can recover it if you choose to resume.
  • Self-hosted fonts. Cormorant Garamond and Inter are served from our domain — no request is made to Google Fonts when you load a page.
  • Google Maps embed. Our footer contains a map showing our office location, embedded directly from Google Maps. When the footer is in view your browser sends Google your IP address and user agent, and Google may set cookies on your device under Google's own privacy terms (policies.google.com/privacy). The map uses loading="lazy" so the request is deferred until the footer scrolls into view.

Your rights (IPP 6, 7)

Under the Privacy Act 2020 you have the right to request access to, and correction of, personal information we hold about you. Email legal@5starnz.co.nz (or info@5starnz.co.nz for general enquiries).

Complaints

If you are not satisfied with our response to a privacy concern, you may complain to the Office of the Privacy Commissioner (OPC): privacy.org.nz · 0800 803 909.

This document will be finalised by qualified New Zealand legal counsel before the website accepts investor capital. If you have questions in the interim, contact legal@5starnz.co.nz.