ONLINE PRIVACY NOTICE

March 16, 2020

Republic Capital Adviser LLC (“Republic Capital”) respects your concerns about privacy and is committed to keeping your personal data secure. This Online Privacy Notice explains how we use and process personal data that you provide to us, that we collect on republiccapital.co, or through other data collection points or notices that reference this Online Privacy Notice. “Personal Data” is any information that relates to, describes, identifies or can be used, directly or indirectly, to identify an individual, such as name, address, date of birth, personal identification numbers, sensitive personal information, and economic information).

“Republic Capital”, “we” or “us” means Republic Capital Adviser LLC, any of its affiliates, any other entities under common control, and funds sponsored by Republic Capital.

We provide information on the types of Personal Data we collect, how we use that information, with whom we may share it with and the choices available to you regarding our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices.

Information We Obtain

Information that you give us

The types of information we collect concerning individuals includes:

  1. business and personal contact information (such as name, postal and email addresses, and telephone number);

  2. other information you provide to us (such as information provided by registering for email alerts, filling in forms, and online registration details); and

  3. information we need in order to identify you and complete necessary security and safety checks, where you visit one of our buildings (such as a form of ID).

In connection with your investments, you may provide us or our third-party fund administrators: login credentials; financial information (such as banking information and an account number); taxpayer ID number; jurisdiction of tax residence; date of birth; and certain investment-related information.

Depending on the nature of our relationship with you, in the past 12 months we may have collected Personal Data concerning you in the following categories:

  1. Identifiers (e.g., real name, postal address, email address, government ID, financial information);

  2. Sensitive/protected characteristic information (e.g., age, race, citizenship, gender);

  3. Commercial information (e.g., products or services purchased, obtained, or considered, personal information disclosed in a sale or acquisition process);

  4. Internet or other network activity (e.g. browsing or search history, information regarding interaction with an internet website, application, or advertisement);

  5. Geolocation data (e.g. physical location);

  6. Professional or employment-related information; and

  7. Inferences drawn from other personal information (e.g. profiles reflecting preferences and trends).

Other information:

In connection with electronic interactions you have with us or our service providers (including by email, phone or other forms of electronic communication), we may record and monitor details of those interactions, including their content, to the extent permitted or required by applicable law.

We may also collect some information from other sources, including:

  1. if we have a business relationship with the organisation that you represent, your colleagues or other business contacts may give us information about you such as your contact details or details of your role in the relationship; and

  2. information from third party data providers or publicly available sources for anti-money laundering, background checking and similar purposes, and to protect our business and comply with our legal and regulatory obligations.

If you provide information to us about another person, you should ensure that you comply with any legal obligations that may apply to your provision of the information to us.

Information We Obtain By Automated Means

When you visit our website or open our emails, we may collect certain information by automated means (such as by cookies, web server logs, web beacons and JavaScript). The information we collect in this manner includes your IP address, network location, browser characteristics, device characteristics, operating system, referring URLs, information on actions taken on our website, and dates and times of website visits.

In conjunction with gathering information through cookies, our web servers may log information such as your device type, operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone in which your device is located. We also may record information such as the address of the web page that referred you to our site and the IP address of the device you used to connect to our website. We may log information about your interaction with the websites, such as which pages you visit. To control which web servers collect information by automated means, we may place tags on our web pages called “web beacons”, which are small files that link web pages to particular web servers and their cookies. We also may send instructions to your device using JavaScript or other computer languages to gather the sorts of information described above and other details about your interactions with the site.

We may use third-party web analytics services on our site, such as those of Google Analytics. These service providers help us analyze how visitors use the websites. The information obtained for this purpose (including your IP address and other information collected by automated means) may be disclosed to or collected directly by these service providers. To learn about opting out of Google Analytics, please click here.

The providers of third-party plugins and widgets on our site, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of the site and your interactions with the plugins and widgets. This information is subject to the privacy policies or notices of the providers of the plugins and widgets.

How We Use the Information We Obtain

We may use, disclose or otherwise handle the information described in this Online Privacy Notice for the following purposes to:

  1. operate, evaluate, develop, promote, and improve our business (including developing new products and services; enhance, improve and analyze our products and services; manage our communications; manage our premises; and perform accounting, auditing and other internal functions);

  2. create and manage your account;

  3. manage your relationship and/or investments with Republic Capital;

  4. comply with and enforce applicable legal requirements, relevant industry standards and our policies;

  5. protect against, identify and prevent fraud, money-laundering, breach of confidence, cyber attack, theft of proprietary materials, financial or business crimes, and other unlawful activity;

  6. in some cases, in order to operate, administer and improve the user’s experience of our website;

  7. provide our products and services to you, such as market commentary and email alerts;

  8. send you (or produce) promotional materials, newsletters and other communications, including in visual and audio form (such as videos, podcasts and online seminars);

  9. communicate with you about, and administer your participation in, special events, programs, promotions, offers, surveys and market research;

  10. respond to your inquiries;

  11. verify your information;

  12. perform data analyses (including market and consumer research, demographic analyses and anonymisation and aggregation of information);

  13. operate, schedule and facilitate online meetings, webinars and (video) conferences (for example, using Zoom and other online meeting platforms); and

  14. record audio and video content (for example, of our in-person or online events, training, and meetings where permitted by, and collected in accordance with, applicable data protection law).

In addition, we use information collected through cookies, web beacons, web server logs and other automated means for purposes such as (i) customising our users’ visits to our site, (ii) delivering content tailored to our users’ interests and the manner in which our users browse our website, and (iii) managing our site and other aspects of our business.

We may also use the information in other ways for which we provide specific notice at the time of collection.

We will only process your Personal Data as necessary so that we can pursue the purposes described above. Where we process your Personal Data for our legitimate interests as a business or those of a third party, we do so only where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes.

When we collect Personal Data from you, unless indicated otherwise, if we ask you for information, we need it for our business or compliance purposes. In limited circumstances, we are required to collect Personal Data to comply with a legal obligation and/or might ask you to provide information which is purely voluntary; in either case, this will be indicated to you.

Information We Disclose to Others

We do not disclose Personal Data we obtain about you through the website or other channels covered by this Online Privacy Notice, except as described in this Online Privacy Notice. We may share your Personal Data with our affiliates and subsidiaries. Depending on the nature of our relationship with you, we also share Personal Data with service providers who perform services on our behalf (including cloud services), our financial and transaction counterparties, our professional advisors, and your agents and representatives. We do not authorise these persons to use or disclose the information except as necessary for the purposes for which it is provided or to comply with legal requirements.

We also may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities, regulators and/or other government entities and/or other competent authorities based on a lawful disclosure request, or (iii) when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We reserve the right to transfer Personal Data we have about you or otherwise process in the event that we sell or transfer all or a portion of our business or assets (including in the event of a reorganisation, spin-off, dissolution or liquidation).

In addition, we may share anonymous/aggregated information with third parties, such as service providers, in order to facilitate our business operations.

For California Residents, in the preceding 12 months, we may have disclosed Personal Data listed in any of the categories in the “Information We Obtain” section above for business purposes (in particular, as described in this section).

We have not sold Personal Data in the 12 months preceding the date of this Online Privacy Notice.

Retention and Deletion of your Information

We intend to keep your Personal Data accurate and up-to-date. We will delete the information that we hold about you when we no longer need it.  We retain your Personal Data for as long as it is required by us for our legitimate purposes, to perform our contractual obligations, or where longer, such longer period as is required or permitted by law or regulatory obligations which apply to us.

We will retain your information in line with our retention policies and, in any event, for no longer than is necessary given the purpose for which it was collected, after which it will be deleted or anonymised.

Note that we may retain some limited information about you (even when we know that you have left the organization that you represent) so that we can maintain a continuous relationship with you if and when we are in contact with you again.

Your Rights and Choices

We offer you certain choices in connection with the Personal Data we collect from you. To update your preferences or submit a request, please contact us as indicated in the “How to Contact Us” section of this Online Privacy Notice. To the extent provided by the law of your jurisdiction or otherwise applicable to our processing of your information, you may request access to the Personal Data we maintain about you or request that we correct, amend, delete or block the information by contacting us as indicated below. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your Personal Data, and we will apply your preferences going forward.

These rights, subject to certain limitations, may include:

Rights of access, correction and deletion. You may have a right of access to the Personal Data that we hold about you, and to some related information, including the purpose for processing the Personal Data, the categories of recipients of that Personal Data to the extent it has been transferred internationally, and, where the Personal Data has not been collated directly from you, the source (the “category information“). You may also have the right to require any inaccurate Personal Data to be corrected or deleted.

Right to object, and portability. You can object to our use of your Personal Data for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your Personal Data (and require it to be deleted) in some other circumstances. In some circumstances, you may also have a “data portability” right to require us to transfer your personal data to you or a third party, in a data portable format.

California residents may also request certain information about our disclosure of Personal Data during the prior year, including category information (as defined above).

We review and verify requests to protect your Personal Data, and will action data protection requests fairly and in accordance with applicable data protection laws and principles.

If you wish to exercise any of these rights, please contact us as set out below.

Complaints. You can also lodge a complaint about our processing of your Personal Data with the body regulating data protection in your country.

How We Protect Personal Data

We maintain administrative, technical and physical safeguards designed to protect Personal Data we obtain through our website against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.

Links To Other Websites

Our website may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked websites may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites are not owned or controlled by us, we are not responsible for their content, any use of the websites, or the privacy practices of the websites.

Updates To Our Online Privacy Notice

This Online Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our Personal Data practices. We will post the updated version on our website and indicate at the top of the Notice when it was most recently updated. Please check for any updates regularly.

How To Contact Us

If you have any questions or comments about this Online Privacy Notice, or if you would like us to update information we have about you or your preferences, please email us or access our web form at https://www.republiccapital.co/#contact-form.

Please also contact us via any of the above methods if you have a disability and require an alternative format of this Online Privacy Notice.