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Runway Limited: Privacy Policy

Last updated: 29 July 2026

Introduction

Runway Limited (Runway, we, us, or our) provides the online investor portal (Investor Portal) for investors to consider, invest and monitor the performance of investment opportunities created, managed, or administered by us or another company in the Runway Limited group (a Runway Group Company). For the avoidance of doubt, this privacy policy applies to investments created, managed, or administered by Runway Limited, including the Runway Private Credit Fund (No.1) Limited Partnership, and to your use of the Investor Portal in connection with such investment.

We respect your privacy rights and recognise the importance of protecting the Personal Information we collect about you.

This privacy policy sets out how we collect, use, store and disclose Personal Information about you in connection with your use of the Investor Portal and our related online fund management services (together our Services). In this policy, when we say "Personal Information", we mean information, or an opinion, that relates to an identified or identifiable individual. If an individual can't be identified from the information (for example, when Personal Information is aggregated and anonymised to the extent that there is no reasonable likelihood of re-identification occurring) then the information is not Personal Information, and this privacy policy doesn't apply to it.

When handling your Personal Information, we will comply with all privacy and data protection laws applicable to our processing of your Personal Information, including (as applicable), the New Zealand Privacy Act 2020 and the Australian Privacy Act 1988 (Cth) (Applicable Privacy Laws).

Unless a term has been defined in this privacy policy, it uses the same definitions as those used in our terms and conditions (available at www.portal.runway.co.nz) (Terms).

We encourage you to read this privacy policy carefully, if you have any questions regarding this policy or our processing of your Personal Information, please contact us at runway.fund@runway.co.nz.

What kinds of personal information do we collect?

In connection with your use of the Investor Portal and our Services, we may collect Personal Information from you. The Personal Information we may collect and hold includes (but is not limited to):

  • your name, addresses, contact details, date of birth, place of birth, tax identification number, tax residency status and citizenship;
  • information about your bank account details and financial and personal circumstances, including your source of funds (in some cases evidence of this), and transactional and financial information relating to your User Account;
  • documents that verify your identity and other personal details; and
  • other information which assists us in conducting our business, providing and marketing our services and meeting our legal obligations.

How do we collect personal information?

We collect your Personal Information in a number of ways when you use the Investor Portal or our Services. These can broadly be categorised as follows:

  • Information that comes directly from you. This is the Personal Information about you that you enter into the Investor Portal or Services yourself, including any Personal Information you provide through the registration or investment process, through any contact with us (e.g. telephone calls, face to face meetings, Investor Portal enquiry forms or emails, or through the use of the services and facilities available through our websites and social media channels) or when you use the Services. If you don't want to provide your Personal Information, you don't have to, but it may restrict your ability to access all or some of the Investor Portal or Services.
  • Information we receive from third parties. We may receive Personal Information about you from third parties and other sources, for example:
    • we may use third parties to analyse traffic on our Investor Portal and related services, which may involve the use of cookies;
    • where a third party provides security-related or identity verification services;
    • in some circumstances we might collect Personal Information about an individual from a third party (for example, for the purposes of our compliance with our anti-money laundering and sanctions compliance obligations);
    • from publicly available websites.
  • Information we receive from your use of the Investor Portal and Services. Some Personal Information is automatically collected when you perform any action on, or interact with, any part of our Investor Portal or Services, including:
    • clickstream data, which is a record of how you navigate or click through our Investor Portal or our Services; and
    • information obtained through the use of cookies, web beacons and similar storage technologies. Please refer to the section of this privacy policy entitled "Cookies and Tracking" for further information, including information on how you can disable these technologies,

Whenever you lodge a support query using our "Help" or "Contact us" features on the Investor Portal, we collect your name, email address and any other information that you provide us in connection with your query, in order to be able to reply to you and provide the support or advice requested.

How we may use your personal information?

We'll only use your Personal Information for the purposes set out in this policy or for other purposes where you have authorised that use, or we are otherwise permitted to do so by law.

We may collect your Personal Information for the following purposes:

  • to create, manage and administer your User Account within the Investor Portal;
  • to review your eligibility to create or continue to use a User Account with us;
  • to process your application to become an investor and other matters in connection with the operation of the Investor Portal and your User Account including, without limitation, transfers, deposits, payments, generating reports and record keeping of investment portfolios;
  • to provide our Investor Portal and Services and otherwise carry out our obligations under the Terms;
  • to bill you (or the Investment Entity on whose behalf you are acting) and to collect money that is owed.

We also collect your Personal Information:

  • to verify your identity, including (as applicable):
    • to check your identity against governmental, and other, databases, including the National Register of driver licences;
    • to check your identity against databases maintained by the New Zealand Department of Internal Affairs (including birth or death information recorded under the Births, Deaths, Marriages, and Relationships Registration Act 1995, citizenship information recorded under the Citizenship Act 1977, and/or travel document information recorded under the Passports Act 1992);
    • to check your identity against the records of the Document Verification Service (and related databases) maintained and provided by the Commonwealth of Australia; to check your identity against other governmental databases;
  • to identify, prevent or investigate any actual or suspected fraud, unlawful activity or threats to our systems; and
  • to comply with our legal obligations, including (but not limited to) our obligations under the New Zealand Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (NZ AML/CFT Act), the Australian Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth) (AUS AML/CTF Act), the Double Tax Agreements (United States of America—FATCA) Order 2014 (FATCA) and general tax regulation as applicable.
  • to communicate with you (including responding to feedback and information requests relating to our Investor Portal and the Services, to let you know when we are experiencing technical difficulties, and to alert you of new features or developments);
  • to communicate with, and comply with our obligations to, our third-party service providers, suppliers and other users of our Investor Portal and/or Services;
  • to send administrative messages, reminders, notices, updates, security alerts, and other information relevant to your use of the Investor Portal and/or the Services;
  • to engage third parties on your behalf;
  • to track access to the Investor Portal and Services in order to help detect and prevent any fraudulent or malicious activity;
  • to analyse and report on usage of the Investor Portal and Services, so we can improve the Investor Portal and Services;
  • to send you (or Investment Entity on whose behalf you are accessing the Investor Portal) marketing and promotional messages and other information that may be of interest to you where you (or the Investor Entity on whose behalf you are accessing the Investor Portal) have consented to receiving such material. You can opt out of receiving marketing materials from us by using the opt-out facility provided (e.g. an unsubscribe link) or by emailing us using the contact details set out at the top of this policy;
  • to keep you informed of investments we consider may be of interest to you, unless you ask us not to provide you with this information;
  • to protect and/or enforce our legal rights and interests, including defending any claim; and
  • to comply with our legal obligations, including (but not limited to) in relation to our obligations under the AML/CFT Act, the AUS AML/CTF Act, the Financial Markets Conduct Act 2013, FATCA and general tax regulation. This may include any notification and reporting obligations and any access directions imposed on us by an applicable Government agency, law enforcement agency or regulatory authority.

We may also process your Personal Information for such other purposes that are directly related to the purposes described above, where you have authorised our use of your Personal Information for another purpose or where we are otherwise permitted to use your Personal Information by Applicable Privacy Law.

We may anonymise and aggregate information such that no person could be re-identified from the information. We apply safeguards designed to reduce the risk of re-identification. This aggregated and anonymised data is not Personal Information and this privacy policy does not apply to it.

Automated processing and artificial intelligence

We may use automated processing tools, analytics systems and artificial intelligence technologies to support the operation of the Investor Portal and Services, including to verify identity, detect and prevent fraud or suspicious activity, analyse usage, and improve our Services. These tools are designed to assist, and not replace, responsible human oversight and governance. Where a decision that significantly affects you is made solely by automated means, we will, where required by law, provide appropriate transparency and review rights. We do not sell your Personal Information, and we do not provide it to external AI developers for their own independent commercial use.

How we may disclose your personal information?

We may need to disclose your Personal Information to third parties to achieve the purposes outlined above. We may disclose your Personal Information to:

  • your professional advisers, your authorised signatories and your agents;
  • other members of our group, including our subsidiaries (if any) and related parties;
  • the Caruso group of companies. We use Caruso to enable your use of the Investor Portal and our Services. Caruso will access and process your Personal Information as required to provide their services to us in order to fulfil the purposes outlined above. Further details regarding Caruso's processing of your Personal Information are set out in Caruso's privacy policy available (available at www.getcaruso.com/general-terms);
  • service providers and suppliers who provide necessary goods and/or services to us (including identity checks), and any other partners who help us market and sell the Investor Portal and/or the Services - for instance to manage customer relations, send out newsletters and/or to process payments;
  • any business that supports us, including hosting or maintaining any underlying software, IT system or data centre that we use to provide our Investor Portal and/or Services;
  • other companies, agencies or individuals that maintain databases against which your identity may be verified, which may include (but is not limited to) the New Zealand Department of Internal Affairs, New Zealand Transport Agency, and the Commonwealth of Australia Document Verification Service;
  • our professional advisers (such as our lawyers who assist us to ensure we are complying with our legal obligations), and banks and other financial institutions as part of our obligations when paying or receiving funds on your behalf;
  • social media sites on which we have a presence, to the extent that you interact with us via a social media site. We limit interactions on social media sites that may disclose Personal Information to the private messaging functions of those sites, unless you otherwise request or give permission;
  • anyone who assists us to identify, prevent or investigate fraud, unlawful activity, misconduct or threats to our systems;
  • other third parties to anonymise and aggregate statistical information;
  • a person who can require us to supply Personal Information (e.g. a Government agency, regulatory authority or law enforcement agency);
  • respond to due diligence requests and/or transfer Personal Information in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition of our business; and
  • any other person or entity authorised by you.

The rights of disclosure in this section may, if applicable, be subject to further restrictions contained in data processing agreements with our third party service providers (as applicable).

For the avoidance of doubt, we do not sell your Personal Information.

Overseas transfers of Personal Information

We may process your information in countries outside your local jurisdiction or region. Any disclosure of your Personal Information to overseas recipients will be managed in accordance with our obligations under all Applicable Privacy Laws, including where necessary, by putting in place contractual safeguards to ensure your personal information remains appropriately protected. Where we are subject to the New Zealand Privacy Act 2020, any overseas disclosure will be managed to meet Information Privacy Principle 12, including by ensuring the overseas recipient is subject to comparable privacy safeguards or by putting in place contractual protections.

If you are Australia-based, we may share your personal information with overseas recipients located in Australia, New Zealand, the United States. These recipients include:

  • our service providers who may handle, process or store your personal information on our behalf. For example, we may share your personal information with service providers who assist us with storing our data on data storage servers, or with improving our products and services;
  • other members of the Caruso group.

Internet Use

While we take reasonable steps to maintain secure internet connections, the supply of Personal Information over the internet is at your own risk.

If you follow a link on our Investor Portal to another website, the owner of that website will have its own privacy policy that will apply to its use of your Personal Information processed on that website. We suggest you review that website's privacy policy before you provide access to your Personal Information.

For example, if you are a client of multiple fund managers who use the Caruso platform services, you may access the Caruso Investor Console via the Investor Portal for a centralised view of your investments across different fund managers. Caruso's privacy policy available at www.getcaruso.com/general-terms will apply in respect of your access and use of the Caruso Investor Console.

Caruso provides the Investor Portal to us as our service provider and processes your Personal Information on our behalf under contract. Caruso's own privacy policy governs the separate Caruso Investor Console.

How long we keep Personal Information

We will keep your Personal Information:

  • until we no longer have a valid reason for keeping it;
  • until you request us to stop using it; or
  • for as long as required by law e.g., we keep invoice information for 7 years to fulfil our tax obligations.

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymise such information, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

Cookies and tracking

Web Analytics

We use web analytic tools to allow us and our third-party service providers to recognise your device, and collect and receive information about you from our Investor Platform and Services and elsewhere on the internet, with the goal of improving our Investor Portal and Services. These web analytic tools collect information such as how often users visit the Investor Portal and Services, what pages they visit when they do so, and what other sites they used prior to coming to the site.

We may use various technologies to collect and store information about you when you use the Investor Portal and/or the Services, and this may include using cookies and similar tracking technologies, such as pixels and web beacons, as described below.

Cookies

A cookie is a piece of information that our web server may send to your machine when you visit our Investor Portal. The cookie is stored on your device, but does not identify you or give us any information about your device.

The types of cookies we use may include (but are not limited to):

  • Session Cookies: These are temporary cookies that are erased when the user closes their web browser. They're used to remember user activity within a single session, making it smoother to navigate the site.
  • Persistent Cookies: Also known as permanent or stored cookies, they remain on the user's device even after the browser is closed. These cookies can be used to remember a user's login information, preferences, and other persistent information for future visits.
  • First-Party Cookies: These cookies are set by the website the user is visiting, and they typically allow the website to keep track of the user's activity during their visit.
  • Third-Party Cookies: These are set by domains other than the one the user is visiting, often by advertising and tracking services. They can be used to track a user's activity across multiple websites and build up a profile of their interests.
  • Secure Cookies: These cookies can only be transmitted over an encrypted connection (i.e., HTTPS). They help to ensure that the user's information is secure and prevent unauthorized access.
  • HTTP-Only Cookies: These cookies can't be accessed by client-side scripts, which makes them more secure against potential cross-site scripting (XSS) attacks.
  • SameSite Cookies: These cookies help prevent Cross-Site Request Forgery (CSRF) attacks by allowing servers to assert that a particular cookie should not be sent along with cross-site requests.

With most internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. If you want to do this, refer to your browser instructions or help screen to learn more. If you reject the use of cookies, you will still be able to access our Investor Portal but please note that some of its functions may not work as well as if cookies were enabled.

Protecting Personal Information

We take the protection of Personal Information seriously and we will take reasonable steps (using physical, electronic and procedural safeguards) to keep Personal Information in our possession safe from loss, unauthorised activity, or other misuse. These safeguards include encryption, access controls, monitoring, staff confidentiality obligations, secure infrastructure, and governance oversight of automated systems. Staff who handle your Personal Information are provided with training on how to do so appropriately.

Your rights

You have the right to access your Personal Information that we hold about you, and to ask for it to be corrected if you think it is wrong.

You may request access to, or correction of, your Personal information by contacting us using the details set out at the top of this policy.

There are circumstances where we are entitled to refuse your request. Where we refuse access to any Personal Information subject of your request, we will do so in accordance with Applicable Privacy Law. If your request is refused, we will give you a written notice with the reasons why your request has been refused and your options in respect of our decision.

Contact and complaints

If you wish to exercise your rights under this privacy policy or any Applicable Privacy Laws, you can do this by contacting us using the contact details set out at the top of this policy. Your email should provide evidence of who you are and set out the details of your request (e.g. the Personal Information, or the correction, that you are requesting).

If you believe we are unlawfully processing your personal information and wish to lodge a complaint, you can lodge a complaint with us directly using the above contact details, or you can lodge a complaint with the New Zealand Privacy Commissioner (using the information available at the New Zealand Privacy Commissioner's website) the Australian Privacy Commissioner (using the information available on the Australian Privacy Commissioner's website) as applicable.

Changes to this policy

From time to time, we may make changes to this privacy policy (for example, to reflect any changes in the Investor Portal, our Services or any Applicable Privacy Laws). Where a change is significant, we'll make sure we let you know – usually by displaying a notice on our Investor Portal or by sending you an email.

Acknowledgment

By registering for or accessing the Investor Portal, you acknowledge that you have read and understood this privacy policy.