Fusca Privacy Policy

Version: 2.0 Effective date: 28th July 2026 Replaces: the Fusca Ltd Privacy Policy dated 30 January 2023

1. Scope and application

1.1 Fusca Ltd, a company incorporated in New Zealand under company number [INSERT], NZBN [INSERT] (Fusca, we, us, our), operates the Fusca website, the wool price preview tool, the Fusca web application, and the associated data services (together, the Services).

1.2 This Privacy Policy (Policy) governs the collection, use, storage, disclosure, retention and destruction by Fusca of personal information relating to any person who accesses or uses the Services (you, your).

1.3 Fusca is an agency for the purposes of the Privacy Act 2020. Fusca collects, holds, uses and discloses personal information in accordance with that Act and the information privacy principles set out in section 22 of that Act (IPPs).

1.4 In this Policy, personal information has the meaning given to that term in section 7 of the Privacy Act 2020.

1.5 This Policy is incorporated into and forms part of the Fusca Terms of Service. Where this Policy and the Terms of Service conflict in relation to the handling of personal information, this Policy prevails.

1.6 By creating an account, submitting an email address to the wool price preview tool, or otherwise using the Services, you acknowledge that you have read this Policy and agree to the collection, use and disclosure of your personal information on the terms set out in it.

2. Privacy Officer and contact details

2.1 Fusca has appointed a Privacy Officer in accordance with section 201 of the Privacy Act 2020.

2.2 All requests, queries, complaints and notices under this Policy must be directed to:

The Privacy Officer Fusca Ltd Email: [email protected] Postal: 50a Ossian Street, Napier, 4110

2.3 Fusca will acknowledge receipt of any request made under clause 10 within five working days.

3. Information we collect

Fusca collects the categories of personal information set out in this clause 3. Fusca does not collect personal information other than for a lawful purpose connected with its functions or activities, and only where collection of that information is necessary for that purpose.

3.1 Account and identity information

(a) Where you register using an email address: your first name, last name, email address, a password (stored only as a cryptographic hash and never in plain text), and any trial, promotional or invitation code you elect to apply.

(b) Where you register or sign in using a Google or Facebook account: your name, your email address, and the unique user identifier assigned to you by that provider. Fusca stores that identifier in order to associate future sign-ins with your account.

(c) Profile information you elect to supply, including your name, email address and an optional profile photograph.

(d) Where you are invited to, or invite others to, a team: the email addresses used to issue and accept those invitations, and your team membership records.

3.2 Authentication and security information

(a) Persistent sign-in ("remember me") tokens.

(b) Where you enable two factor authentication: the associated secret and recovery codes, stored in encrypted form.

(c) Login count, date and time of most recent sign-in, and the browser user agent string recorded at most recent sign-in.

(d) For each active session: the internet protocol (IP) address and browser user agent associated with that session.

3.3 Billing information

(a) Fusca does not require payment information in order to commence a free trial.

(b) Where you elect to subscribe, payment is processed by Stripe, Inc and its affiliates (Stripe). Fusca does not receive, process or store your full card number or card security code at any time.

(c) Fusca stores the Stripe customer identifier assigned to you, the payment method type, the last four digits and expiry date of the payment instrument, any billing address you supply, your trial end date, and your subscription, invoice and receipt records.

3.4 Information you create using the Services

(a) Wool types, specifications, saved searches and saved report layouts, including any images you upload into a saved report layout.

(b) Inputs you supply to the Pro Tools suite, including flock numbers, production estimates and cost assumptions.

(c) Your progress through the onboarding tour.

3.5 Preview tool and mailing list information

(a) Where you use the public wool price preview tool without an account, Fusca collects the micron value or values you enter and, if you elect to subscribe to the weekly micron email, your email address.

(b) Fusca generates and stores an unsubscribe token associated with that email address for the purpose of giving effect to clause 7.

(c) Information collected under this clause 3.5 is collected before, and independently of, the creation of any account.

3.6 Technical and usage information

(a) IP address, browser user agent, referring page and the date and time of each request.

(b) Records of your use of the Pro Tools suite, including where that suite is delivered by way of an embedded frame served by the Fusca data engine.

(c) Application programming interface call records associated with the Fusca data engine, including client identifying information, retained for internal analytics and service integrity purposes.

(d) Diagnostic records of failed requests and background jobs, which may incidentally include request context associated with your account.

3.7 Advertising and measurement information

(a) Fusca operates the Meta Pixel on the Fusca website, the wool price preview tool and the Fusca web application. Fusca does not operate Google Analytics, Hotjar or any comparable third party analytics product within the Services.

(b) Through the Meta Pixel, Fusca collects and transmits to Meta Platforms, Inc and its affiliates (Meta) page view events, and the events described in clause 3.7(d).

(c) Where you are signed in, Fusca transmits to Meta your email address, first name and last name for the purpose of advanced matching. Fusca applies a one way cryptographic hash to those values before transmission.

(d) Fusca transmits the following events to Meta, either from your browser or from the Fusca server, or both: page views; account registration; commencement of a free trial; commencement of the subscription payment step; searches performed in the wool price preview tool; subscription to the weekly micron email; clicks on calls to action within the wool price preview tool; and a limited number of custom product events including clip value calculation.

(e) Where events are transmitted from the Fusca server, the transmission may include your hashed email address, hashed first and last name, hashed city and hashed postcode where those values are held, together with your IP address and browser user agent in unhashed form.

(f) The Meta Pixel sets and reads the cookies _fbp and _fbc, and records the fbclid parameter where you arrive at the Services from a Meta advertisement.

3.8 Information Fusca does not collect

(a) Fusca does not collect or store full payment card numbers or card security codes.

(b) The Fusca database contains fields for postal address and business details which are not presented for completion in the Services as at the effective date of this Policy. Where those fields are not populated, no such information is held.

(c) Fusca does not knowingly collect personal information from any person under the age of 16.

4. Information collected indirectly

4.1 This clause 4 applies from 1 May 2026, being the date on which IPP 3A of the Privacy Act 2020 comes into force, and applies to personal information about you that Fusca collects from a source other than you.

4.2 Fusca collects personal information about you indirectly from the following sources:

4.3 Fusca gives notice of the matters in clause 4.2 by publishing this Policy and by referring to it at the point of collection. Where Fusca collects personal information about you indirectly in circumstances not described in clause 4.2, Fusca will notify you of that collection as soon as reasonably practicable after collection, unless an exception in IPP 3A applies.

5. Purposes for which information is used

5.1 Fusca uses personal information only for the following purposes:

(a) to create, authenticate, administer and secure your account;

(b) to provide the Services, including generating the market data, analyses, estimates and reports you request;

(c) to administer free trials, including determining eligibility, calculating the trial end date and displaying the time remaining;

(d) to process subscription payments, issue receipts and invoices, and manage refunds and disputes;

(e) to send you service communications, including account verification, password reset, team invitation, subscription, receipt and trial expiry messages;

(f) to send you the weekly micron email and other commercial electronic messages, where you have consented in accordance with clause 7;

(g) to provide user support and to resolve disputes;

(h) to detect, investigate and prevent fraud, abuse, security incidents and breaches of the Terms of Service;

(i) to measure the effectiveness of Fusca advertising and to construct audiences for the purpose of Fusca advertising, in accordance with clause 3.7;

(j) to monitor, maintain and improve the performance, accuracy and reliability of the Services; and

(k) to comply with any legal obligation to which Fusca is subject.

5.2 Fusca will not use personal information for a purpose other than a purpose set out in clause 5.1 unless one of the exceptions in IPP 10 applies or you authorise that use.

5.3 Fusca does not sell personal information, and does not disclose personal information to any third party for that third party's own independent marketing purposes.

6. Disclosure of personal information

6.1 Fusca discloses personal information only as set out in this clause 6. The statement in the previous version of this Policy that Fusca does not share personal information with any third party is superseded by this clause 6.

6.2 Fusca discloses personal information to the following categories of recipient:

6.3 Fusca discloses personal information to those of its personnel and contractors who require access in order to perform their duties. Access to the Fusca administrative interface, which permits access to account records containing personal information, is restricted to authorised administrators and is subject to the controls in clause 9.

6.4 Fusca may disclose personal information where disclosure is required or authorised by law, is necessary to prevent or lessen a serious threat to the life or health of any individual, or is necessary for the conduct of proceedings before any court or tribunal.

6.5 Fusca maintains a current register of the third party service providers to which it discloses personal information, including the jurisdiction in which each provider stores that information. That register is available on request to the Privacy Officer.

7. Disclosure outside New Zealand

7.1 Certain recipients identified in clause 6.2 are located outside New Zealand. Disclosure to those recipients is a cross border disclosure for the purposes of IPP 12 of the Privacy Act 2020.

7.2 Before disclosing personal information to a recipient outside New Zealand, Fusca will satisfy itself that at least one of the following applies:

(a) the recipient is required to protect the information in a way that, overall, provides comparable safeguards to those in the Privacy Act 2020, whether by binding contractual terms or by the law of the jurisdiction in which it operates;

(b) the recipient is subject to the privacy laws of a country prescribed under section 214 of the Privacy Act 2020; or

(c) you have expressly authorised the disclosure after being informed that the recipient may not be required to protect the information in a way that provides comparable safeguards.

7.3 You acknowledge that where you elect to sign in with Google or Facebook, or where you subscribe using Stripe, disclosure to the relevant provider is necessary in order to provide the function you have requested, and that declining that disclosure requires you to use an alternative method of registration or payment.

8. Cookies and tracking technologies

8.1 Fusca and its advertising provider set cookies and similar identifiers on your device, including:

(a) strictly necessary cookies used to maintain your session, authenticate you and protect against cross site request forgery; and

(b) advertising and measurement cookies, being _fbp and _fbc, set by the Meta Pixel.

8.2 You may configure your browser to refuse or delete cookies. Refusing strictly necessary cookies will prevent you from signing in to and using the Services.

8.3 You may object to the use of advertising and measurement cookies by contacting the Privacy Officer, by using the advertising controls made available by Meta, or by using a browser or extension that blocks those technologies.

9. Marketing and commercial electronic messages

9.1 Fusca sends commercial electronic messages, including the weekly micron email, only where you have given express or inferred consent within the meaning of the Unsolicited Electronic Messages Act 2007.

9.2 Every commercial electronic message sent by Fusca will:

(a) clearly identify Fusca as the sender and include accurate contact details for Fusca; and

(b) contain a functional unsubscribe facility which remains operative for not less than 30 days after the message is sent.

9.3 Fusca will give effect to an unsubscribe request within five working days of receipt.

9.4 Fusca will retain a record of each unsubscribed address for the sole purpose of ensuring that no further commercial electronic messages are sent to that address. That record will be retained on a suppression list and will not be used for any other purpose.

9.5 Service communications necessary for the operation of your account, including account verification, password reset, security notices, receipts, and notices of trial expiry, are not commercial electronic messages for the purposes of clause 9.1 and cannot be unsubscribed from while your account remains open.

10. Access, correction and other rights

10.1 You are entitled under IPP 6 to obtain confirmation of whether Fusca holds personal information about you and to have access to that information.

10.2 You are entitled under IPP 7 to request correction of any personal information Fusca holds about you, and to request that a statement of the correction sought be attached to that information where Fusca does not make the correction requested.

10.3 A request under clause 10.1 or 10.2 must be made to the Privacy Officer. Fusca will notify you of its decision on the request as soon as reasonably practicable, and in any event not later than 20 working days after the day on which the request is received, in accordance with section 44 of the Privacy Act 2020 in the case of a request under clause 10.1 and section 63 of that Act in the case of a request under clause 10.2.

10.4 Fusca may extend the period in clause 10.3 to the extent permitted by section 48 of the Privacy Act 2020, and will notify you of any extension and the reasons for it within the original period.

10.5 Fusca will not charge you for access to your personal information except as permitted by section 66 of the Privacy Act 2020.

10.6 Fusca may refuse an access request in whole or in part on a ground set out in sections 49 to 53 of the Privacy Act 2020, and may decline a correction request in accordance with IPP 7 and section 63 of that Act. Where Fusca refuses a request, it will give you written reasons and notify you of your right to complain to the Office of the Privacy Commissioner.

10.7 You may verify and, where necessary, correct much of your account information directly through the profile and account settings within the Services.

11. Retention and destruction

11.1 Fusca will not retain personal information for longer than is required for the purposes for which the information may lawfully be used.

11.2 Subject to clause 11.4, Fusca applies the following retention periods:

11.3 Fusca will give you not less than 30 days written notice before deleting an inactive account under clause 11.2, addressed to the email address held for that account.

11.4 Where Fusca is required by law to retain information for a period longer than that stated in clause 11.2, including under section 22 of the Tax Administration Act 1994 and section 194 of the Companies Act 1993, the longer statutory period applies and prevails over clause 11.2.

11.5 On expiry of the applicable retention period, Fusca will destroy the personal information or render it non identifiable. Aggregated and de identified market data derived from your use of the Services which does not identify you and cannot reasonably be used to identify you may be retained indefinitely.

11.6 Deletion from encrypted backups occurs on expiry of the backup cycle stated in clause 11.2. Fusca will not restore deleted personal information from backup except where required to remediate a system failure, and will re apply any deletion within five working days of any such restoration.

12. Closing your account

12.1 You may close your account at any time through the account settings within the Services, or by written request to the Privacy Officer.

12.2 On closure of your account, Fusca will:

(a) cease all commercial electronic messages to you within five working days;

(b) cancel any active subscription with effect from the end of the then current billing period;

(c) delete or render non identifiable the categories of information in clause 11.2 other than those subject to clause 11.4, within 30 days; and

(d) retain financial and billing records for the period required by clause 11.4.

12.3 Fusca is unable to recall personal information already disclosed to a recipient identified in clause 6.2. Where you wish to have information deleted by such a recipient, you must exercise the rights available to you directly against that recipient. Fusca will provide reasonable assistance on request.

13. Security

13.1 Fusca will take such security safeguards as are reasonable in the circumstances to protect personal information against loss, unauthorised access, use, modification, disclosure and other misuse, in accordance with IPP 5.

13.2 Those safeguards include encryption of data in transit, encryption of data at rest, cryptographic hashing of passwords, encryption of two factor authentication secrets, role based access control, restriction of administrative access to authorised personnel, and logging of administrative access to records containing personal information.

13.3 No method of transmission or storage is entirely secure. Fusca does not warrant that the Services are immune from unauthorised access, and your use of the Services is at your own risk to that extent.

14. Privacy breaches

14.1 Where Fusca becomes aware of a privacy breach that it is reasonable to believe has caused, or is likely to cause, serious harm to any affected individual, Fusca will notify the Office of the Privacy Commissioner and each affected individual as soon as practicable, in accordance with Part 6 of the Privacy Act 2020.

14.2 A notification under clause 14.1 will be given in accordance with sections 114 and 115 of the Privacy Act 2020 and will include the information required by section 117 of that Act, including a description of the breach, the steps taken or proposed in response, and the steps the affected individual may wish to take.

14.3 Fusca maintains a register of all privacy breaches, whether or not notifiable, and reviews that register at the intervals stated in its internal audit requirements.

15. Complaints

15.1 If you consider that Fusca has interfered with your privacy, you should first make a complaint in writing to the Privacy Officer. Fusca will respond within 20 working days.

15.2 If you are not satisfied with the response, you may complain to:

Office of the Privacy Commissioner PO Box 10094, Wellington 6143 Telephone 0800 803 909 Web: privacy.org.nz

16. Changes to this Policy

16.1 Fusca may amend this Policy from time to time.

16.2 Where an amendment materially affects the way in which Fusca collects, uses or discloses your personal information, Fusca will give you not less than 14 days notice before the amendment takes effect, by email to the address held for your account and by notice within the Services.

16.3 Where an amendment does not materially affect the matters in clause 16.2, Fusca will publish the amended Policy with a revised version number and effective date.

16.4 Continued use of the Services after the effective date of an amended Policy constitutes acceptance of that Policy.

17. General

17.1 This Policy is governed by New Zealand law and the parties submit to the non exclusive jurisdiction of the New Zealand courts.

17.2 If any provision of this Policy is held to be invalid or unenforceable, that provision is severed and the remainder of the Policy continues in full force.

17.3 A reference to an enactment includes that enactment as amended, replaced or re enacted from time to time.

Version 2.0. Effective 28th July, 2026.