Privacy Policy


Paloma Digital Pty Ltd, Paloma Digital Ltd, Paloma Capital Fund Manager Pty Ltd, and Paloma Capital Fund 1 VCMP GP Pty Ltd (we, us, our) respect your right to privacy and are committed to safeguarding the privacy of our clients and website visitors in accordance with applicable law when dealing with personal information.

Personal information is information about an identifiable individual (a natural person) and includes personal data, personally identifiable information and equivalent information under applicable privacy and data protection laws.

This policy sets out how we will collect, use, disclose and protect your personal information.

We comply with the New Zealand Privacy Act 2020, the Australian Privacy Principles contained in the Australian Privacy Act 1988 (Cth), the General Data Protection Regulation of the European Union (GDPR), and the UK GDPR, as defined in The Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (UK GDPR) when dealing with personal information. This policy does not limit or exclude any of your rights under such legislation. When we collect data directly from you we are a Data Controller for the purposes of the GDPR and the UK GDPR.

For further information on: (a) the New Zealand Privacy Act 2020, see; (b) the Australian Privacy Act 1988, see; (c) the GDPR, see; and (d) the UK GDPR, see


We may change this policy by uploading a revised policy onto our website. The change will apply from the date that we upload the revised policy.

This policy was last updated on 8 December 2021.


This policy sets out how we will collect, use, disclose and protect your personal information when you visit and use our website and any related service, through any contact with us (e.g. telephone call or email), when you subscribe to email alerts, purchase or use our products and services from us, as part of the recruitment process or when you otherwise deal with us.


Directly from you

We collect the following information directly from you: when you fill in a contact or enquiry form on our website, call us, subscribe to our email newsletter, meet us in person, apply for a position or otherwise contact us, we collect your name, email address, phone number and any other information you choose to provide to us.

Some of the personal information that we collect directly from you may be mandatory, and some may be optional. We will let you know which of these applies at the time we collect the relevant personal information. While you do not have to provide us with some of the information that we may request, this might mean that our products and services may not perform as well as they should, or that we may not be able to provide some parts of the website or all of our products or services to you. If you require further information about the consequences of not providing us with any information, please contact us at

Automatically when you use our website

When you access and use our website or related services, we may automatically collect information about your device and usage of our website, products and services, including your IP address, operating system, browser type, time spent on certain pages of the website, pages visited and links clicked. This information is used in an aggregated manner to analyse how people use our site, so that we can improve our services.

From our clients and other third parties

We may also receive personal information about you from third parties, such as our clients where you have authorised this or where the information is publicly available. If we do, we will protect it as set out in this Privacy Policy.


We may use your personal information to:

(a) verify your identity;

(b) provide services and products to you;

(c) market our products and services to you, including contacting you electronically (e.g. by text or email for this purpose) via the telephone or by mail;

(d) improve the services and products that we provide to you;

(e) consider your application for recruitment and follow through a recruitment process;

(f) bill you and to collect money that you owe us, including authorising and processing credit card transactions;

(g) respond to communications from you, including a complaint;

(h) protect and/or enforce our legal rights and interests, including defending any claim; or

(i) for any other purpose authorised by you or by applicable law.

We may transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition.


We may disclose your personal information to:

(a) another company within our group (Related Companies) and to the share registry;

(b) any agents, contractors, third parties and business that support our services and products and those of our Related Companies, including any person that hosts or maintains any underlying IT system or data centre that we use to provide the website or other services and products;

(c) a credit reference agency for the purpose of credit checking you;

(d) a person who can require us to supply your personal information (e.g. a regulatory authority);

(e) any other person authorised by applicable law (e.g. a law enforcement agency);

(f) any other company in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition;

(g) any third party to protect the copyright, trademarks, legal rights, property or safety of us,, our customers or third parties;

(h) any other person authorised by you.

Where we disclose your personal information to third parties, we will request that the third party follow this Policy regarding handling your personal information.

A business that supports our services and products may be located outside New Zealand and Australia. This may mean your personal information is held and processed outside New Zealand and Australia.

Recruitment partners

We use Workable, an online application provided by Workable Software Limited and Bamboo HR, online HR software provided by Bamboo HR LLC, to assist with our recruitment process. We use Workable and Bamboo HR to process personal information as data processors on our behalf. Workable and Bamboo HR are only entitled to process your personal data in accordance with our instructions.

Where you apply for a job opening posted by us, this Privacy Policy applies to our processing of your personal information. Where you apply for a job opening via the application function on a job site or similar online service provider (Recruitment Partner), you should note that the relevant Recruitment Partner may retain your personal data and may also collect data from us in respect of the progress of your application. Any use by the Recruitment Partner of your data will be in accordance with the Recruitment Partner’s Privacy Notice.


We will take reasonable steps to keep your personal information safe from loss, unauthorised activity or other misuse. We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks inherent in processing personal information. This includes suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

You play an important role in keeping your personal information secure by maintaining the confidentiality of any passwords and accounts used in relation to our products and services. You should not disclose your user names and passwords to third parties. Please notify us immediately if there is any unauthorised use of your account or any other breach of security.


Subject to certain grounds for refusal under applicable law, you have the right to access your readily retrievable personal information that we hold and to request a correction to your personal information. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.

Where you request a correction, if we think the correction is reasonable and we are reasonably able to change the personal information, we will make the correction. If we do not make the correction, we will take reasonable steps to note on the personal information that you requested the correction.

If you want to exercise either of the above rights, email us at Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information to be corrected and the correction that you are requesting).

Subject to applicable law, we may charge you an administration fee for providing to you copies of your personal information or correcting that information.


While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.

If you follow a link on our website to another site, the owner of that site will have its own privacy policy relating to your personal information. We suggest you review that site’s privacy policy before you provide personal information.

We use cookies (an alphanumeric identifier that we transfer to your computer’s hard drive so that we can recognise your browser) to monitor your use of the website. You may disable cookies by changing the settings on your browser, although this may mean that you cannot use all of the features of the website too.


The personal information that we collect and use will not be kept longer than necessary for the purposes for which it is collected or for the duration required for compliance with applicable law, whichever is longer.


If you have any questions or complaints about this privacy policy or our privacy practices, or if you would like to request access to, or correction of, your personal information, you can contact us at We take all complaints very seriously and will respond shortly after receiving written notice of any complaint.