Privacy Policy

Reinova Partners is committed to protecting and respecting your privacy and following all applicable laws related thereto. This webpage sets out when and how we may use your personal information that you or others provide to us, including through this website (the “Website”). Your privacy is of the utmost importance to us. We want to make sure you fully understand the terms and conditions surrounding the capture and use of that information. This Privacy Notice describes what information we collect about you, how we use it, and the rights you have in relation to that collection and usage.

Whenever you provide personal information, we are legally obliged to use it in accordance with the laws concerning the protection of personal information.

Who We Are

Reinova Partners Limited is a limited company registered in Jersey with company number 157759. Its subsidiary, Reinova Capital Advisors LLP is a limited liability partnership registered in England & Wales under company number OC455558, whose registered office is at Adams House 2, Springfield Lyons Approach, Chelmsford, Essex, CM2 5LG (“Reinova Partners” or “We”).

For the purposes of the General Data Protection Regulation and any other applicable data protection and privacy laws and regulations, including the UK GDPR and the Data Protection Act 2018 (“Data Protection Legislation”), Reinova Partners will be the ‘data controller’ for all Personal Information for which we determine the means and purpose of processing, including that of our suppliers and investors.

By “Personal Information” we refer to data collected or held by Reinova Partners, that identifies and relates to you as an individual.

Information We May Collect

We may collect Personal Information about you in the following circumstances to enable us to provide you with the investment services we offer.

Prior to or during your engagement with us, we may collect Personal Information including:

Your name;

Date of Birth;
Residential address;
Financial information (this may include your financial history, National Insurance number and tax numbers);
Bank Details;
Information collected from a personal utility bill and a passport;
Information regarding the investment services you request;
Supplementary information you provide us about yourself when contacting us;
Email address; and Telephone numbers (including mobile).

We collect the above information to allow us to operate our services effectively Reinova. Some of the information listed above is required to enable us to fulfil our due diligence obligations required under law.

We may also collect technical information about you when you visit the Website. This information may include:

The Internet protocol (IP) address used to connect your computer to the Internet;
Your browser type and version;
Time zone setting, operating system and platform;
Browser plug-in types and version;
The full URL clickstream to, through and from the Website;
Page response times, download errors, length of visits to certain pages, page interaction (such as scrolling, clicks and mouse-overs); and
Methods used to browse away from the page.

The collected information is used to provide an overview of how people are accessing and using the Website.

We may also receive details about you from third parties who have provided us with your information under an appropriate legal ground for sharing, notably AML service providers, fund administration service providers and placement agents. We will always inform you of how we received your information when we contact you.

If you become an employee, worker or contractor for Reinova, we may collect Personal Information including:

Your name;
Date of Birth;
Residential/postal address;
Contact details (work or personal);
Information collected from a personal utility bill and a passport;
CV and career professional history including qualifications relating to your suitability for any role;
Information relating to your eligibility to work within Reinova;
Other information in connection with our company policies, including among others, information relating to your personal directorships, personal trading, next of kin, bank or invoice details, national insurance or tax numbers and other HR related information.

If you fail to provide us with Personal Information: You always reserve the right to withhold your Personal Information but this may affect how we provide our services to you.

We may collect Personal Information about you in the following circumstances to enable us to provide you with the investment services we offer.

Prior to or during your engagement with us, we may collect Personal Information including:

Your name;

Date of Birth;
Residential address;
Financial information (this may include your financial history, National Insurance number and tax numbers);
Bank Details;
Information collected from a personal utility bill and a passport;
Information regarding the investment services you request;
Supplementary information you provide us about yourself when contacting us;
Email address; and Telephone numbers (including mobile).

We may also collect technical information about you when you visit the Website. This information may include:

The Internet protocol (IP) address used to connect your computer to the Internet;
Your browser type and version;
Time zone setting, operating system and platform;
Browser plug-in types and version;
The full URL clickstream to, through and from the Website;
Page response times, download errors, length of visits to certain pages, page interaction (such as scrolling, clicks and mouse-overs); and
Methods used to browse away from the page.

The collected information is used to provide an overview of how people are accessing and using the Website.

If you become an employee, worker or contractor for Reinova, we may collect Personal Information including:

Your name;
Date of Birth;
Residential/postal address;
Contact details (work or personal);
Information collected from a personal utility bill and a passport;
CV and career professional history including qualifications relating to your suitability for any role;
Information relating to your eligibility to work within Reinova;
Other information in connection with our company policies, including among others, information relating to your personal directorships, personal trading, next of kin, bank or invoice details, national insurance or tax numbers and other HR related information.

If you fail to provide us with Personal Information: You always reserve the right to withhold your Personal Information but this may affect how we provide our services to you.

What We Do With The Information We Collect

We will only ever use your Personal Information when allowed to by law and always under a documented lawful basis for processing.

We will use Personal Information provided to us by investors or individuals related to the investments held by funds we advise for a number of purposes including:

To initiate and process the investment services you request;
To ensure our records are complete and accurate;
To provide the specific services agreed by you;
To undertake performance analysis and management of the business;
To give you information that you request from us and to improve our services;
To notify you about changes to our services;
To allow us to operate the Website efficiently;

Any relevant troubleshooting, testing or statistical analysis as appropriate; and to keep the Website secure.

To perform our obligations under Anti-money laundering and due diligence laws, we may use third-party data processing and due diligence firms.

We will use Personal Information provided to us by employees, workers or contractors to perform the relevant contract between us in the following ways:

Making decisions regarding your recruitment or appointment;
Checking your eligibility to work for or with us;
Remunerating you for your services and paying any taxes due under those services;
Administering the terms of the agreement between us;
Managing any legal or internal disciplinary procedures that may arise;
To prevent fraud;
To ensure the safety and security of all of our internal networks and assets; and
To monitor your use of our information and communication systems to ensure compliance with all of our internal policies.

We may process special categories of Personal Information collected from Personnel in the following circumstances:

In limited circumstances, with your explicit written consent;
Where we need to carry out our legal obligations or exercise rights in connection with employment; and where it is needed in the public interest. We do not need your consent if we use special categories of your Personal Information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law.

In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You may withdraw your consent for this form of processing at any time by emailing connect@reinovapartners.com.

Lawful Basis of Processing

We always ensure that a lawful basis exists for all off the Personal Information we process, notably, performance of a contract, legal obligations and legitimate interests.

We will only process your information for as long as we have a relevant lawful basis to do so. All of the information collected and detailed in the sections above is processed to provide you with the contractual services you have requested unless stated otherwise in the ‘Information we may collect’ section, or if you have provided us with adequate consent to process your information for other purposes.

If we choose to process your information under the lawful basis of legitimate interests, we will always inform you of our legitimate business interest and your right to object. The legitimate interests serve the purpose of our business advancement and protection. If you choose to access your Personal Information under the rights afforded to you by Data Protection legislation, we will always inform you of the lawful basis under which we process your information.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Protecting Your Information

We take our security obligations very seriously and constantly monitor for breaches and potential weaknesses.

We are committed to ensuring that your information is secure, and we have procedures in place to try and prevent any unauthorised access or disclosures and to safeguard and keep secure the information that we collect online.

We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, all electronic communications to and from our cloud based service providers are made under SSL encryption, and we store and authorise access to Personal Information only for those employees who require it to fulfil their job responsibilities. However, you should be aware that providing information over the internet can never be guaranteed as being completely safe and if you choose to send such information to us via the internet, you do so at your own risk.

Sharing Your Information With Others

If and when we share your data, we always do so under a written agreement governing how your data must be protected.

Please be assured that we will not share your information for any other reason unless we are required by law or permitted to do so under this Privacy Policy. The main circumstances in which we will be permitted or required to disclose this is by law will be by court order, to government bodies and law enforcement agencies. However, sometimes we may share your information with third parties in the following ways:

We may use carefully selected sub-processors to help us collect, store or manage your information. This will always be managed under the terms of a written data processing agreement;

Analytics and search engine providers that assist us in the improvement and optimisation of the Website.

Your Right Under Data Protection Laws

You can exercise the following rights to your data by contacting us. We will only take instructions from you or your legal representative to effect or to alter a policy and we will protect your privacy when you contact us by asking specific and relevant questions to make sure we are speaking to you or your legal representative and not to an unauthorised person.

Right of Access

You are entitled to receive confirmation as to whether your Personal Information is being processed by us, as well as various other information relating to our use of your Personal Information. You also have the right to a copy of the Personal Information which we are handling regarding you.

Right of Rectification

You have the right to require us to rectify any inaccurate Personal Information we hold about you. You also have the right to have incomplete Personal Information we hold about you completed, by providing a supplementary statement to us.

Right to Restriction

You can restrict our processing of your Personal Information where:

You think we hold inaccurate Personal Information about you;
Our handling of your Personal Information breaks the law, but you do not want us to delete it;
We no longer need to process your Personal Information, but you want us to keep it for legal reasons; or
We are handling your Personal Information because we have a legitimate interest you and are in the process of objecting to this use of your Personal Information
Where you exercise your right to restrict us from using your Personal Information, we will then only process your Personal Information when you agree, except for storage purposes and to handle legal claims.

Right to Data Portability

You have the right to receive the Personal Information we hold about you in a structured, standard machine readable format and to send this to another organisation controlling your Personal Information.

Right to Erasure

You have the right to require us to erase your Personal Information which we are handling in the following circumstances:

We no longer need to use your Personal Information for the reasons we told you we collected it for;
Where we needed your consent to use your Personal Information and you have withdrawn your consent;
You object to our use of your Personal Information and we have no compelling reason to carry on handling your Personal Information;
Our handling of your Personal Information has broken the law; or

We must erase your Personal Information to comply with a law we are subject to.

Right to Withdraw Consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

To withdraw your consent, please contact Reinova at connect@reinovapartners.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Right to Complain

You have the right to issue a complaint directly with the Information Commissioners Office, the data protection supervisory authority for England and Wales (https://iconcernsco.org.uk//).

Your Right To Object Under Data Protection Laws

You have the right to object to us handling your Personal Information when:

We are handling your Personal Information based on our legitimate interests. If you ask us to stop handling your Personal Information in this way, we will stop unless we can show you that we have compelling grounds as to why our use of your Personal Information should continue. This may be to protect ourselves against any potential legal actions that may arise or to continue conducting our business in a fair and profitable fashion. Our use of legitimate interests will always be balanced against your right to privacy under Data Protection Legislation and we will conduct a data protection impact assessment wherever necessary; or

We are using your Personal Information for marketing purposes. If you ask us to stop handling your Personal Information on this basis, we will stop.

A cookie is a small data file that certain websites write to your hard drive when you visit them. The only personal information a cookie can obtain is information supplied by the user. A cookie cannot read data from your hard disk or read cookie files created by other sites.

You can refuse cookies by turning them off in your web browser and you do not need to have cookies turned on to successfully use our website. Most browsers are defaulted to accept and maintain cookies and you can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it or not.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Changes To This Privacy Policy

We may change this Privacy Notice at any time to ensure it always accurately reflects the way we collect, use and safeguard your Personal Information.

Please check this notice from time to time to ensure you are aware of any updates we may have made to our Personal Information handling practices. We will post the relevant announcement on our website homepage.

We recommend that you print a copy of this page for your reference.

Contacting Us

Please contact us at connect@reinovapartners.com if you have any questions, comments or requests regarding this Privacy Policy.