LEGAL

Privacy Policy

How Cruz Group collects, uses and protects your personal information.
Last updated:28 October 2026

Cruz Group is committed to ensuring the confidentiality and security of your personal information. This policy outlines why we need to collect personal information and how we manage the personal information we collect about individuals.

In this policy, “Cruz Group”, “Cruz Capital”, “Cruz”, “We”, “Us” refers to all staff, representatives, and associated entities of the following companies:

  • Cruz Group Holdings, ABN 89 627 532 718
  • Base2 Asset Management Pty Ltd (trading as Cruz Capital), ACN 682 060 260
  • Cruz Tech Pty Ltd, ABN 76 664 631 038
  • Cruz Money Holdings Pty Ltd, ABN 48 656 662 154
  • Cruz Money Pty Ltd, ABN 89 627 532 718
  • Cruz Money IP Pty Ltd, ABN 36 656 662 921

“You” means an individual whose personal information we hold, and “your” has a corresponding meaning.

We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) set out in Schedule 1 of the Privacy Act, in our handling of personal information. The Privacy Act protects ‘personal information’, which means ‘information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not and whether the information is recorded in a material form or not.’

This Policy details our treatment of personal information that we gather, including any personal information that we gather from you when you enquire about, apply for or participate in any investment, lending or tokenisation arrangement offered through Cruz Capital. We undertake to collect and handle your personal information lawfully, respect your privacy, and be transparent about how we handle personal information.

Collection of Your Personal Information

We may collect the following types of personal information about you:

  • Identification and contact information: This includes your name, address, phone number, email address, username, and identification documents.
  • Financial information: This includes your financial credentials, bank account information, transaction history, account balances, limits, investor eligibility information and other payment-related information.
  • Customer service information: This includes any messages you submit to us regarding inquiries about Cruz Group or requests for technical support.
  • Technical information: This includes details such as the IP addresses, devices, and locations used to access Cruz Group.

In the context of Cruz Capital, we may collect personal information relating to investors, commodity holders and their representatives for the purpose of identity verification, wholesale client assessment, transaction processing, fraud prevention, audit trail creation, and compliance record-keeping, including under anti-money laundering and counter-terrorism financing laws.

How We Collect Personal Information

We may collect personal information in the following ways:

  • Directly from you: When you submit an enquiry, apply to invest or seek funding, or contact us directly with any queries.
  • From third-party services: This includes technologies and service providers that enable the operation of Cruz Group, such as identity verification services, custodians, lenders and payment technologies that facilitate transactions on your behalf.

Use and Purposes of Personal Information

We may use your personal information for the following purposes:

  • To operate and maintain the services provided by Cruz Group, such as assessing and facilitating investments and secured lending arrangements.
  • To provide you with the features, functions, and benefits of Cruz Group, such as displaying information regarding your investments or facilities.
  • To assist in verifying identity and related information through third-party service providers.
  • For internal purposes, such as tracking usage trends, developing and improving our services, and performing research and analytics.
  • To send you notifications, emails, and respond to your inquiries.
  • To comply with our legal obligations towards our service providers, regulators, and licence holders.

Disclosure of Personal Information

We may disclose your personal information in the following circumstances:

  • To third-party technologies and data processors for the purpose of performing services through Cruz Group, such as identity verification checks and financial information.
  • To business partners and suppliers for the purpose of providing services through Cruz Group, including our Australian financial services licensee, trustees, custodians and lenders.
  • To third parties as part of a sale or change of control of our business, ensuring continuity by the buyer or controller.

We do not disclose personal information to overseas recipients.

Security of Personal Information

We take reasonable steps to ensure that the personal information we collect, use, and disclose is accurate, complete, up to date, and securely stored in cloud-based facilities located in Australia. We protect your information from misuse, interference, loss, and unauthorised access.

Destruction of Personal Information

We will delete or de-identify personal information when it is no longer needed for the purposes for which it was collected, or upon request, unless a specified retention period is required by applicable laws.

How You Can Access and Update Your Personal Information

If you wish to access or correct the personal information we hold about you, please contact our Privacy Officer by emailing privacy@cruz.tech.

Notifiable Data Breach (NDB) Scheme

As required by the NDB Scheme under the Privacy Act, if there is any loss, unauthorised access, or disclosure of your personal information likely to result in serious harm, we will investigate and notify both you and the Australian Information Commissioner as soon as practicable.

Complaints

If you are not satisfied with how we handle your personal information or this policy, please contact our Privacy Officer at privacy@cruz.tech.

Our Privacy Officer will work to understand your concerns and discuss potential resolutions. If you remain unsatisfied, you may contact the Office of the Australian Information Commissioner (OAIC). Visit the OAIC website or call 1300 363 992 for further assistance.

Privacy Policy Changes

We may update this Privacy Policy from time to time, providing additional notice as required by applicable laws. Please refer back to this policy regularly for updates.

Contact Information

If you have any queries about this policy or wish to access your personal information, please contact our Privacy Officer at privacy@cruz.tech.