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Privacy Policy

Alimentary Systems 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).

This policy sets out how we will collect, use, disclose and protect your personal information, including how we use artificial intelligence tools to process data.

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.

CHANGES TO THIS POLICY

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

This policy was last updated on 14 July 2026.

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 the website and any related service, through any registration or subscription process, through any contact with us (e.g. telephone call, email, or meeting), or when you engage with our services and products
  • Third parties where you have authorised this or the information is publicly available
  • Recording and transcription services when you participate in meetings or communications with us (described in the Use of AI Tools section below)

If possible, we collect personal information from you directly.

HOW WE USE YOUR PERSONAL INFORMATION

We will use your personal information to:

  • Verify your identity
  • Provide services and products to you
  • Market our services and products to you, including contacting you electronically (e.g. by text or email)
  • Improve the services and products we provide
  • Undertake credit checks of you (if necessary)
  • Bill you and collect money that you owe us, including authorising and processing credit card transactions
  • Respond to communications from you, including complaints
  • Conduct research and statistical analysis (on an anonymised basis)
  • Protect and/or enforce our legal rights and interests, including defending any claim
  • Process your participation in our capital raise, stakeholder engagement, or regulatory consultation processes
  • For any other purpose authorised by you or the Act

Use of Personal Information Provided in Investment or Stakeholder Contexts

If you provide personal information to us as part of our capital raise, due diligence process, stakeholder consultation, regulatory engagement, or board-level communications, we will use that information only for the purpose you provided it and for related business-critical operations (e.g. investor communications, regulatory compliance, council engagement). We will not repurpose this information for marketing, product development, or any other use without your explicit consent.

USE OF ARTIFICIAL INTELLIGENCE TOOLS

Alimentary Systems Limited uses third-party artificial intelligence (AI) tools to assist with data processing, analysis, and communication. This section explains how and why we use these tools, and what safeguards protect your information.

AI Tools We Use

We currently use the following AI services:

ToolProviderUse CaseData Types Processed
Claude (API)AnthropicInternal analysis, document processing, stakeholder communications draftingInternal reports, market research, communication templates (no personal data unless explicitly processed)
Otter.aiOtter TechnologiesMeeting transcription and note-takingAudio recordings of meetings; transcribed text with speaker identification
Google GeminiGoogleInternal research, data analysis, communication supportDocuments, reports, strategic analysis (no personal data unless explicitly processed)

What Data is Processed by AI Tools

We only submit to AI tools:

  • Information you have consented to share with us (including participation in recorded meetings or calls)
  • Internal business information (our strategic documents, financial reports, regulatory submissions)
  • Anonymised or aggregated data (where individual identity has been removed)
  • Public information (council meeting records, published research, regulatory filings)

We do not submit to AI tools:

  • Your personal information without your knowledge or consent
  • Confidential investor personal information (e.g. passport numbers, financial details, personal emails from due diligence)
  • Health or sensitive personal information
  • Third-party data you have provided to us in confidence

How We Protect Your Information When Using AI Tools

When we use AI tools:

  1. We use only necessary data — we anonymise or redact personal identifiers before submitting information to AI systems
  2. We review all outputs — any analysis generated by AI tools is reviewed by our team before use or disclosure
  3. We maintain records — we document what data was submitted to which tool and when
  4. We comply with vendor privacy agreements — each AI service provider (Anthropic, Otter Technologies, Google) has committed to privacy protections that meet or exceed New Zealand Privacy Act standards

Your Rights When AI is Used

If we have used AI tools to process information about you, you have the right to:

  • Know that AI was involved in processing your information
  • Request access to any personal information we hold about you, including information that may have been processed by AI
  • Request correction of personal information that is inaccurate or incomplete
  • Request that we not use AI to process your information in future (subject to operational feasibility)

Please contact us (see Contacting Us section) to exercise these rights.

DISCLOSING YOUR PERSONAL INFORMATION

We may disclose your personal information to:

  • Another company within our group
  • Our partners (including technology partners, suppliers, and regulatory advisors)
  • Any business that supports our services and products, including persons that host or maintain IT systems or data centres we use to provide services (including cloud service providers and AI tool vendors)
  • A credit reference agency for the purpose of credit checking you
  • Other third parties for anonymised statistical information
  • A person who can require us to supply your personal information (e.g. a regulatory authority, council, government ministry)
  • Any other person authorised by the Act or another law (e.g. a law enforcement agency)
  • Any other person authorised by you

Cross-Border Data Flows

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

  • Cloud storage providers (e.g. Google Drive, hosted in the United States and other jurisdictions)
  • AI service providers (e.g. Anthropic's Claude API, Otter.ai, Google Gemini — data centres located internationally)

We take reasonable steps to ensure that overseas recipients are bound by privacy obligations consistent with the Privacy Act 2020.

DATA BREACH NOTIFICATION

If we become aware of a serious risk to your privacy due to a data breach (including loss, theft, or unauthorised access to personal information), we will:

  1. Notify you directly and without unreasonable delay
  2. Provide information about the breach, affected data types, and steps you can take to protect yourself
  3. Notify the Office of the Privacy Commissioner if required by Privacy Act principles
  4. Document the breach, our response, and any steps taken to prevent recurrence

A "serious risk" means the breach is likely to result in serious harm to your privacy, security, or interests (e.g. identity theft, financial loss, reputational harm).

PROTECTING YOUR PERSONAL INFORMATION

We take the following steps to keep your personal information safe from loss, unauthorised activity, or other misuse:

  • Encryption: We encrypt personal information in transit (using HTTPS/TLS) and at rest (in secure cloud storage)
  • Access controls: Only authorised team members can access personal information; access is limited to business-critical needs
  • Physical security: Our offices are secured; devices containing personal information are password-protected
  • Vendor management: We conduct due diligence on third-party service providers and maintain contracts that require them to protect personal information
  • Security reviews: We conduct regular reviews of our security practices and update them as risks evolve
  • Employee training: Our team is trained on privacy principles and data security practices
  • Data retention: We do not keep personal information longer than necessary for the purpose we collected it

We acknowledge that while we take reasonable steps, no system is completely secure. If you have concerns about the security of personal information you provide to us, please contact us immediately.

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
  • Request correction to your personal information if it is inaccurate or incomplete

How to Request Access or Correction

Email us at hello@alimentary.systems with:

  • Evidence confirming your identity
  • A clear description of the personal information you wish to access or correct

We will respond within 20 working days (or as required by the Act).

Our Assessment of Your Request

If you request correction and we believe the correction is reasonable and we are reasonably able to make it, we will do so. If we do not make the correction, we will take reasonable steps to note on your personal information that you requested the correction.

Charges

We may charge you our reasonable costs of providing copies of your personal information or correcting that information. We will advise you of any charge before proceeding.

INTERNET USE

Personal Information Over the Internet

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. We recommend using a secure connection (HTTPS) and avoiding public WiFi networks.

Public Forums

If you post your personal information on our website's message board, blog, or chat room, you acknowledge and agree that the information you post is publicly available and may be accessed or shared by others.

Third-Party Websites

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.

COOKIES

We use cookies (small text files stored on your device) to:

  • Monitor your use of the website
  • Remember your preferences
  • Improve your user experience

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.

Third-party tools we use (e.g. Google Gemini, meeting recording services) may also set cookies on your device. Please refer to those providers' privacy policies for more information.

IP-BASED GEOLOCATION

To show visitors region-appropriate content (for example, displaying a New Zealand contact phone number only to visitors located in New Zealand), our website sends your IP address to a third-party geolocation service (geojs.io) to determine your approximate country. We do not store your IP address for this purpose or use it to identify you individually; it is used only to select which content to display, in your browser, at the time of your visit. Please refer to that provider's privacy policy for how they handle IP data.

PRIVACY IMPACT ASSESSMENT

We conduct Privacy Impact Assessments (PIAs) when we introduce new technology, data collection processes, or AI tools. Our most recent assessment (conducted July 2026) covered our use of AI services (Claude, Otter.ai, Google Gemini) and our data handling practices. A summary of that assessment is available on request.

CONTACTING US

If you have any questions about this privacy policy, our privacy practices, or if you would like to request access to, or correction of, your personal information, you can contact us:

Email: hello@alimentary.systems

Mailing Address: Alimentary Systems Limited, New Zealand

We will respond to your enquiry within 20 working days.

If You Have a Privacy Concern

If you believe we have breached your privacy or the Privacy Act 2020, you can also contact the Office of the Privacy Commissioner:

Website: www.privacy.org.nz

Email: info@privacy.org.nz

Phone: 0800 803 202

IMPORTANT NOTICES

This privacy policy is current as at 14 July 2026. We review and update it regularly. Your continued use of our services and website means you accept the terms of this privacy policy.

Nothing in this policy constitutes legal, financial, or privacy advice. If you have specific concerns about how your personal information is being used, or if you believe your privacy has been breached, we recommend seeking independent legal advice.