Privacy Policy
This policy was last updated on 1 December 2025.
1. Introduction
Victor Lima 6 Limited (we, us, our) complies with the New Zealand Privacy Act 2020 (the Act) when dealing with personal information. Personal information is information about an identifiable individual (a natural person) and includes, without limitation, names, addresses, phone numbers, email addresses and internet protocol (IP) addresses.
This privacy policy (Policy) sets out how we will collect, use, disclose and protect your personal information.
You accept this Policy, and consent to the collection, use, disclosure, storage and retention of your personal information as described in this Policy when you use, visit or participate on our website vl6.co.nz (Website), use our products and/or services, or otherwise provide us with any of your personal information. If you wish to revoke this consent, you must immediately cease to use our Website and all of our products and/or services.
Providing your personal information to us is voluntary. However, if you do not provide us with all the information requested, or provide us with insufficient information, we may be unable to provide you with access to our Website, or to provide you with our products and/or services.
This Policy does not limit or exclude any of your rights under the Act. If you wish to seek further information on the Act, see www.privacy.org.nz.
2. Changes to this policy
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 on our Website. Accordingly, you should review this Policy each time you visit our Website, use our products and/or services, or provide us with your personal information.
3. Types of information we collect
Generally, the personal information we may collect from you includes:
date of birth;
nationality;
gender;
address;
phone number;
email address;
employment details;
identification documentation (including passport, national ID and/or drivers licence);
financial details (including income information, liquidity savings details, investment details, trading derivatives history);
banking details;
credit information (including credit history);
proof of address;
New Zealand IRD number or equivalent; and
any other personal information necessary to provide our products and/or services to you; and
Our Website may also automatically collect and store the following information about you:
date and time of access;
your IP address;
type of browser you use,
and other similar information sent to us by your browser.
4. Who do we collect your personal information from
We collect personal information about you from:
you, when you provide that personal information to us, including via our Website and any related service, through any registration or subscription process, through any contact with us (e.g. telephone call or email), or when you buy or use our services and products;
third parties where you have authorised this or the information is publicly available.
If possible, we will aim to collect personal information from you directly.
5. How we use your personal information
We collect and use your personal information to operate our business, meet our legal obligations, and provide you with secure access to investment opportunities through the Propopoly platform.
We may use your personal information for the following purposes:
To verify your identity and perform customer due diligence (CDD) checks in accordance with the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act).
To establish and manage your account with us, including enabling you to invest in, hold, and trade digital tokens that represent shares in investment entities.
To process payments and transactions, including authorising and reconciling bank transfers and electronic payment services (such as Pay It Now and POLi Pay).
To provide our services and products to you, including investor onboarding, access to offers, and ongoing investor reporting.
To communicate with you, including sending confirmations, updates, reports, notices, and responding to your queries or complaints.
To comply with our legal and regulatory obligations, including anti-money laundering and countering financing of terrorism (AML/CFT) monitoring, record-keeping, tax reporting, and requests from regulators or law enforcement agencies.
To improve our platform and services, including data analysis, testing, and product development.
To conduct research and statistical analysis on an anonymised or aggregated basis to better understand investor behaviour and improve user experience.
To protect and enforce our legal rights and interests, including the prevention, detection, and investigation of fraud, cyber incidents, or unauthorised activity.
To manage credit, risk, and compliance, including conducting credit or background checks if required.
For any other purpose that you authorise or that is permitted by the Act or other applicable law.
We may also re-verify your information or request updated details from time to time, in line with our AML/CFT policy and ongoing due diligence obligations.
6. Electronic communications
We are committed to compliance with the Unsolicited Electronic Messages Act 2007.
By subscribing to email communications, or otherwise providing an email address, you consent to receiving emails which promote and market our services from time to time.
You can unsubscribe from our email communications at any time by clicking the "Unsubscribe" link in any promotional or marketing email, or by emailing privacy@vl6.co.nz.
Once you have unsubscribed from the email communications, you will be removed from the corresponding email/distribution list as soon as reasonably practicable.
7. Disclosing your personal information
We respect the confidentiality of your information and will only disclose it where necessary for lawful business purposes, or as required by law.
We may disclose your personal information to:
Entities with direct and indirect ownership links through 52 Alpha Holdings Limited, including any related companies, subsidiaries, or special purpose vehicles (SPVs) incorporated for investment purposes (the SPV Entities).
Our service providers who support our operations — including IT and cloud hosting providers, data storage facilities, payment processors, blockchain service partners, and marketing platforms.
Third-party electronic identity verification providers (such as Pay It Now and POLi Pay) to confirm your identity and perform AML/CFT checks.
Regulators, law enforcement agencies, and supervisory authorities, such as the Financial Markets Authority (FMA), the Department of Internal Affairs (DIA), or the New Zealand Police Financial Intelligence Unit (FIU), when required under the AML/CFT Act or other applicable laws.
Credit reporting or fraud prevention agency, where necessary for credit or background checks.
Trustee, custodian, or nominee entities involved in holding assets or managing investor interests for the SPV Entities.
Professional advisers (including auditors, accountants and legal advisers) to assist us in meeting our legal and compliance obligations.
Any person or entity authorised by you, including your financial adviser or representative.
Any other person authorised by the Act or other applicable law (for example, where disclosure is required by a court order).
Other third parties on an anonymised or aggregated basis (for example, for statistical reporting that does not identify you).
Some of our service providers and partners may be located outside of New Zealand, meaning your personal information may be disclosed to, stored or processed in other jurisdictions (including Australia and the United States). Any disclosures of your personal information to these third parties will be subject to their privacy policies. For example, for more information on Pay It Now's protection and privacy, see Pay It Now's Privacy Policy at https://payitnow.io/privacy-policy. We take reasonable steps to ensure that any overseas recipients handle your information in accordance with the Act and comparable safeguards.
This Policy does not apply where we act solely as a processor of personal information collected by organisations using our services. Such personal information is subject to the privacy policies of the organisation collecting that personal information. You should refer to that organisation's privacy policies.
If we undergo a restructure, sale, merger, acquisition, or similar corporate transaction, we may transfer your personal information to the relevant party as part of that process, provided that your privacy rights continue to be protected.
8. Security
Protecting the security of your personal information is of the utmost importance to us. We maintain a variety of safeguards and procedures in order to protect your personal information from unauthorised access, use, interference, modification or disclosure.
We will take reasonable steps to keep your personal information safe from loss, unauthorised activity, or other misuse.
9. Accessing and correcting your personal information
Subject to certain grounds for refusal set out in the Act, you have the right to access your readily retrievable personal information that we hold and to request a correction to your personal information, in accordance with the Act. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.
In respect of a request for 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 refuse to make the correction (in accordance with the Act), you may request that we include a note on the personal information describing the correction sought but not made.
If you want to exercise either of the above rights, contact us at the contact details below. 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).
We may charge you our reasonable costs of providing to you copies of your personal information or correcting that information.
10. Cookies & other tracking technology
We, along with our affiliated partners and service providers, use cookies to monitor your use of our Website. Cookies are alphanumeric identifiers stored on a device with a web browser, such as a personal computer, tablet and smart phone. A cookie can contain information about your IP address, your device, or the online activity of a person who uses that device. The information in each cookie is sent to the party that controls that cookie.
We use cookies where it is necessary for our legitimate interests of conducting our business, which may include managing, analysing and improving our Website or optimising your experience as a user of our Website. If you do not agree with our use of cookies, you can manage and control them through your browser, including removing cookies by deleting them from your browser history when you leave our Website. Although, this may mean that you cannot use all of the features of our Website.
We may also use third party cookies for marketing and promotional purposes, and to gather website analytics. When we collect cookies from third parties, that information is collected in aggregated form. Where a third party is collecting the information, you will need to opt out in accordance with the process set out in that third party's privacy policy or ad preferences material.
While we take reasonable steps to maintain secure connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.
Examples of tracking technologies we may use on our Website is set out below:
Local storage and session storage: Our Website may use browser-based storage technologies to remember settings, maintain your session, and improve your experience (for example, keeping you logged in or remembering form inputs).
Tracking Pixels: Our Website may use tracking pixels. Tracking pixels are transparent graphic images (usually 1 pixel x 1 pixel) that are placed on a webpage and, in combination with a cookie, allows for the collection of information regarding the use of the webpage that contains the tracking pixel. We use tracking pixels to tell when you have clicked on certain website features or otherwise interacted with those features, and use that information to learn about visitor use.
Web Beacons: Our Website may use snippets of code with a unique identifier for several purposes, including to deliver or communicate with cookies, to track and measure the performance of our Website, and to monitor how many visitors view our Website. Unlike cookies, which are stored on the device, web beacons are typically embedded invisibly on web pages or in an email.
Analytics and performance tools: Our Website may use technologies (such as Google Analytics) that help us understand how visitors use our Website so we can improve layout, content, and navigation. For more information on Google Analytics, see Google's Privacy Policy at https://policies.google.com/privacy?hl=en-US.
11. Governing law
This Policy is governed and construed in accordance with the laws of New Zealand. You submit to the non-exclusive jurisdiction of the Courts of New Zealand and you agree that the Courts of New Zealand have the non-exclusive jurisdiction to hear and determine any matter arising out of or in connection with this Policy.
12. Contact Us
Please contact us if you:
have any questions or complaints about this Policy;
wish to access, update, erase and/or correct your personal information; or
you have a question or complaint about the handling of your personal information by us.
You can contact our Privacy Officer by email, including any supporting documentation, at privacy@vl6.co.nz.
The Privacy Officer will investigate the matter and attempt the resolve the issue, and will inform the complainant in writing about the outcome of the investigation. If the complaint is not resolved to the satisfaction of the complainant, the Privacy Officer will provide contact details of the Office of the Privacy Commissioner where the complaint may be escalated.