DRAFT for legal review, comprehensive draft, not yet the final operative policy. Bracketed items […] are to be confirmed by the operator and counsel.
Privacy policy
Last updated: 20 July 2026 · Version: 2026-07-20-draft
1. Who we are
Folio is operated by BWATER LIMITED (NZBN 9429053409638), trading as Bridgewater Partners(“Folio”, “we”, “us”), an agency under the New Zealand Privacy Act 2020. This policy explains what personal information we collect, why, who we share it with, and your rights. Privacy queries: info@folionz.com.
2. What we collect
- Account & identity: name, email, contact details, hashed password.
- Property & portfolio: addresses, valuations, equity, cashflow, holdings and scenarios you enter.
- Financial: rent, expenses, ledgers, tax figures and owner statements (property-management features).
- Documents: files you upload, including leases, insurance and sale documents (some processed by AI extraction).
- Connected email & files: mailbox and cloud-drive content, only when you authorise a connection (Gmail, Outlook, Drive, OneDrive, Dropbox).
- Bank data, transactions for reconciliation, only when you connect Akahu.
- Enquiries & feedback: coaching enquiries, pre-qualification details, demo bookings, and in-app feedback you submit.
- Usage & analytics, onboarding/activation and usage telemetry.
- AI interactions, messages and context you send to the AI assistant.
- Payment, subscription and payment records; card payments are handled by Stripe and we do not receive or store card numbers.
3. How we collect it
Directly from you (when you enter data, upload documents, or contact us); automatically (usage and device data as you use the platform); from third parties that provide property data (for example CoreLogic and MBIE bond data); and from connections you authorise (email, drive, bank).
4. Why we use it
To provide the platform and its tools; generate the estimates, reports and documents you request; connect you with services you ask for; communicate with you; keep the service secure; meet legal obligations; and improve Folio (including the AI features below). We rely on the information privacy principles in the Privacy Act 2020. We do not sell your personal information.
5. AI & automated processing
To power AI features (assistant answers, drafting, and document extraction), your inputs and relevant context , which may include portfolio, financial or document data, are sent to our AI sub-processors (currently Anthropic, and Voyage AI for document search where enabled). AI output is general information and may be wrong; it does not make decisions for you. [Counsel to confirm and state each provider’s data-use terms, e.g. no training on customer data, and retention windows.]
6. Who we share it with
We share personal information with:
- service providers you ask us to connect you to;
- infrastructure and processing sub-processors that run the platform under appropriate safeguards: including [Supabase (database, auth, storage), Vercel (hosting), Anthropic and Voyage AI (AI), Resend (email), Stripe (billing, when active), Akahu (bank feeds), CoreLogic and AddressFinder (property/address data)];
- others where required by law or to protect rights and safety.
[Final sub-processor list and each one’s data and location to be confirmed with counsel.]
7. Overseas storage & disclosure (IPP 12)
Some sub-processors store or process personal information outside New Zealand, including [Supabase in Australia/Singapore] and [AI, hosting and email providers in the United States]. Where we disclose personal information overseas we rely on [comparable-safeguards protections in our contracts with those providers, and/or your consent], consistent with information privacy principle 12. [Jurisdictions and legal basis to be confirmed by counsel.]
8. Storage, security & retention
We hold data in our isolated infrastructure with access controls and encryption in transit and at rest; credentials for connected services (OAuth tokens) are encrypted. No system is perfectly secure. We keep personal information only as long as needed for the purposes above or as the law requires, then delete or de-identify it. [Retention periods per data type: account, financial, documents, connected content, leads, analytics, AI logs, to be confirmed.]
9. Your rights
You may request access to, and correction of, the personal information we hold about you (information privacy principles 6 and 7), and you can export or ask us to delete your data when you close your account. Contact us at info@folionz.com. If you’re not satisfied with our response, you can complain to the Office of the Privacy Commissioner.
10. Cookies & tracking
We use cookies and similar technologies that are necessary to sign you in, keep your session, and understand product usage. [Confirm whether any non-essential/marketing tracking is used. This decides whether a consent banner is required.]
11. Marketing & electronic messages
We send you service and transactional messages needed to run your account. Any marketing emails are sent consistent with the Unsolicited Electronic Messages Act 2007 and include an unsubscribe option.
12. Children
Folio is not directed at people under 18, and we do not knowingly collect their personal information.
13. Privacy breaches
If a privacy breach occurs that is likely to cause serious harm, we will notify the Office of the Privacy Commissioner and affected individuals as required by the Privacy Act 2020.
14. Changes & contact
We may update this policy; the “Last updated” date and version above will change and material changes will be notified through the platform. Questions or requests: info@folionz.com, (BWATER LIMITED, NZBN 9429053409638).
See also our Terms and How Folio gives guidance.