Privacy Policy

This Privacy Notice (“Notice”) is directed at investors and related parties in Renaissance´s alternative funds and their general partners domiciled or operating in the European Union (where the Fund, its General Partner and Renaissance AIFM Sarl, the appointed alternative investment fund manager, is each a “Company” and together referred to as the “Companies”). The identity and contact details of the Company are as set out in the relevant subscription documents. For more information or confirmation of Company details, please contact your Renaissance relationship manager.

In the course of running its business, the Company will collect and process the Personal Data (as defined below) of natural persons who are limited partners, applicants for interests, beneficial owners of limited partners and applicants for interests, personal representatives, financial advisors, directors, officers, employees, agents, trustees and / or authorised signatories of limited partners and applicants for interests (“Individuals” or “you”) and other information relating to the dealings of Individuals with the Company and / or its service providers.

This Notice explains how the Company will manage the Personal Data of such Individuals, why the Company uses it, and how Individuals may contact the Company in relation to the use of Personal Data.

The terms of this Notice shall furthermore apply to the handling of the personal data of any individual in the European Union (“EU”) by a member of Renaissance, to the extent such handling is subject to Data Protection Legislation.

Definitions

In this Notice, “Data Protection Legislation” means the EU General Data Protection Regulation 2016/679 (“GDPR“)[1], together with all other applicable legislation relating to privacy or data protection in the jurisdictions in which we operate. Capitalised terms used herein shall have the meanings given to them in the Data Protection Legislation unless otherwise defined or where the context requires.

The Companies are each a separate independent “controller”, as defined under the Data Protection Legislation, because they each determine the means and purposes for which Personal Data is processed.

Please note that where the Company needs to process Personal Data in connection with an Individual’s contract with the Company or in anticipation of an applicant for interests becoming a limited partner, or where the Company has a legal obligation to collect certain Personal Data relating to an Individual (for example, in order to comply with AML or other “know your customer” obligations), the Company will not be able to deal with the limited partner or applicant for interests if the Individual does not provide the necessary Personal Data and other information required by the Company.

“Personal Data”, as defined in the Data Protection Legislation, means any information which the Company has or obtains in relation to Individuals, or which an Individual provides to the Company or the Company’s service providers, such as their name, address, email address, date of birth, from which that Individual can be directly or indirectly personally identified, and may include, among other things, information such as identification and account numbers, professional information, tax identifiers and other financial data, residency information, and online identifiers. Some of this Personal Data may be special category Personal Data, such as data revealing racial or ethnic origin, political opinions, or trade union membership (“Special Category Personal Data”[2]). In the context of Renaissance’s alternative funds business, any collection and processing of Special Category Personal Data is limited in frequency and scope. Particularly, Special Category Personal Data will be processed when necessary for reasons of substantial public interest, on the basis of applicable law.

[1] The GDPR may also include the domestic law of the United Kingdom by virtue of the European Union (Withdrawal) Act 2018, the Swiss Data Protection Act and its Ordinances (together the “Swiss DPA“), to the extent the Company does business in these jurisdictions.

[2] Under the Swiss DPA, sensitive/special category personal data is also data which includes details of:

  • administrative proceedings and sanctions against data subjects;
  • social security measures, excluding social security number but including social security benefits; and
  • the intimate sphere in general where “intimate sphere” includes data relating to sex life and sexual orientation but also applies to similarly private facts .

Use of Personal Data and Legal Basis of Processing

The table below describes the categories of Personal Data that the Company collects, stores, uses and shares and the lawful ground on which the Company relies for processing this Personal Data.

Generally, the Company does not rely on consent as a legal basis for processing Personal Data. Where, however, the Company asks for consent to process Personal Data for a particular purpose and it is provided, you have a right to withdraw consent for that processing purpose in writing at any time by contacting the Company (see the section titled “an Individual’s Rights in relation to the Personal Data” below). The same Personal Data may continue to be processed for another purpose as described in this notice.

Personal Data Processing Activity and Purpose Legal Basis for Processing
Identity Data, Contact Data, KYC data Processing data in order to:

– provide services to the limited partner, and set up and administer the applicant’s or limited partner’s account(s), as the case may be;

– collect subscriptions and pay redemptions, distributions and dividends; and

– deal with queries or complaints from limited partners.

 Performance of the Company’s contract with you (including in anticipation of an applicant interested in becoming a limited partner)
  Processing data in order to comply with:

– anti-money laundering and anti-terrorist financing (collectively “AML”) and fraud prevention purposes, including OFAC and PEP screening for these purposes and to comply with UN, EU and other applicable sanctions regimes; and

– applicable tax and regulatory reporting obligations.

 Compliance with the Company’s legal obligations
  Processing data:

– for day to day operational and business purposes;

– to take advice from the Company’s external legal and other advisors;

– for board reporting and management purposes, including quality assurance; and

– to facilitate a merger / proposed merger of the Company or any sub-fund of the Company or any other restructuring or reorganisation of the Company or any sub-fund of the Company or relating to the assets of the Company or any sub-fund of the Company (if this is applicable).

 Processing is necessary for the purpose of legitimate interests pursued by the Company

–          to ensure that business is carried out in compliance with principles of transparency and accountability as well as with security standards;

–          to defend and exercise rights,

–          to carry out business operations and fulfilling contractual obligations with third parties, including limited partners, applicants for interests, beneficial owners of limited partners;

–          to pursue corporate transactions such as mergers, acquisitions, or restructuring.
  Processing data:

– for day to day operational and business purposes;

– investor relationship management; and

– calculation and payment by the recipient of commissions and rebates.

 –          Processing is necessary for the purpose of legitimate interests pursued by the Company, or of a third party to which the Company provides the Personal Data

–          to ensure that business is carried out in compliance with principles of transparency and accountability and security;

–          to carry out business operations and fulfilling contractual obligations with third parties, including limited partners, applicants for interests, beneficial owners of limited partners.

The Company will not undertake automated decision-making or profiling in relation to Individuals’ Personal Data.

Disclosure of Personal Data to third parties

The Company will not disclose any Personal Data to any third party, except as outlined above and / or as follows:

  1. to anyone providing a service to the Company or acting as the Company’s agent (which may include the investment managers, the administrators, depositaries or companies within their respective group of companies, and it’s or their sub-contractors), as data controllers and/or data processors, for the purposes of providing services to the Company and on the understanding that they will keep the Personal Data confidential;
  2. to enable the Company to carry out the obligations under the contract with a limited partner or in anticipation of an applicant for interests becoming a limited partner;
  3. where Personal Data needs to be shared with an administrator or a depositary appointed to the Company, in order to enable it to discharge its legal and regulatory obligations;
  4. where the depositary or administrator to the Company is subject to a separate legal obligation requiring it to act as controller of the Personal Data, including where it is required to use the Personal Data for the discharge of its own AML obligations, or where an Individual has otherwise consented to the Personal Data being shared with the administrator for specific purposes;
  5. where the limited partner or applicant for interests is a client of Renaissance, a third party financial advisor or investment manager, or a company within its or their group of companies, in relation with such company or advisor for the purposes outlined above;
  6. with its auditors, and legal and other professional advisors, where it is necessary for the Company to do so for the purposes outlined above;
  7. with any of its affiliated companies, for the purposes outlined above;
  8. in the event of a merger or proposed merger, to any (or any proposed) transferee of, or successor in title to, the whole or any part of the Company’s business, and their respective officers, employees, agents and advisors, to the extent necessary to give effect to such merger; and / or
  9. the disclosure is required by law or regulation, or court or administrative order having force of law, or is required to be made to any of the Company’s regulator(s).

In any case where the Company shares Personal Data with a third-party controller, the use by that third party of the Personal Data will be subject to the third party’s own privacy policies

International transfers

Personal Data may be transferred outside of the EEA, United Kingdom and / or Switzerland (collectively the “Relevant Jurisdictions”) in connection with administering a limited partner’s account(s) and / or in anticipation of an applicant for interests becoming a limited partner, in accordance with an Individual’s instructions, where an Individual has explicitly consented, and / or as otherwise required or permitted by law.

To the extent that Personal Data is transferred outside of the Relevant Jurisdictions, it may be transferred to countries that do not have equivalent protections to those in the EEA and, in such cases the Company shall ensure that such transfers are subject to appropriate safeguards being in place in accordance with the conditions in the Data Protection Legislation (unless we can rely on a legal derogation)[1].

For all international transfers of personal data, we conduct transfer impact assessments (TIA) to determine the level of risk and whether any additional safeguards need to be implemented. In certain cases, we may also require the recipient of the data to subscribe to international frameworks intended to enable secure data sharing.

Please contact us if you wish to obtain more information on the appropriate safeguards. See “Contacting the Company” below.

[1] A derogation may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented

Marketing

The Company will not use Personal Data to send marketing materials if the Individual has requested not to receive them. The Company will require your prior consent, unless the Individual already entered into contract with the Company, in which case, provided that the Individual has not refused to receive such communications, we might use his/her email to send marketing materials on services similar to those in the object of the contract.

If an Individual requests that the Company stops processing his/her Personal Data for marketing purposes, the Company shall stop processing his/her Personal Data for those purposes.

Special Category Personal Data

The Company may, in limited circumstances, collect and process Special Category Personal Data, for example, where required to do so for legal or regulatory purposes or if necessary for reasons of public interest, as laid down in applicable laws (e.g. in connection with its obligations under applicable AML laws, the Company may need to verify whether an Individual is a politically exposed person) or where the Individual has provided the Company with such information. Any Special Category Personal Data will only be used and disclosed, as necessary, for such purpose.

Third Party Providers of Information
The Company may obtain Individuals’ Personal Data from the relevant Individual. However, the Company may also obtain Personal Data relating to Individuals from someone other than that Individual. This may include Personal Data relating to beneficial owners, partners, directors, officers, employees, advisors or other related persons of an investor or of the person providing the Personal Data. This may concern the following categories of Personal Data: identity data, contact data, KYC data. The Personal Data may be obtained from a variety of sources, such as publicly available sources, financial advisors to investors, employers of Individuals, and / or direct and indirect service providers to the Company, such as vendors providing AML/CTF and sanctions checking databases. The person providing the information will be asked to warrant that it will only do so in accordance with applicable Data Protection Legislation, and that it will ensure that before doing so, the Individuals in question are made aware of the fact that the Company will hold information relating to them and that it may use it for any of the purposes set out in this Notice, and where necessary that it will obtain consent to the Company’s use of the information. The Company may, where required under applicable law, notify those individuals that it has been provided with their Personal Data and provide a copy of this Notice to them.

Updates to Personal Data

The Company will use reasonable efforts to keep Personal Data up to date. However, each Individual will need to notify the Company without delay in the event of any change in their personal circumstances, or those of the others mentioned above, so that the Company can keep the Personal Data up to date. Please see the section “Contacting the Company” below for information on how to do this.

Retention of Personal Data

The Company is obliged to retain certain information to ensure accuracy, to help maintain quality of service and for legal, regulatory, fraud prevention and legitimate business purposes.

It is obliged by law to retain AML related identification and transaction records for ten (10) years from the end of the relevant investor relationship or the date of the transaction, respectively.

Other information will be retained for no longer than is necessary for the purpose for which it was obtained by the Company or as required or permitted for legal, regulatory, fraud prevention and legitimate business purposes. In general, the Company (or its service providers on its behalf) will hold this information for a period of ten (10) years, unless it is obliged to hold it for a longer period under law or applicable regulations.

Thereafter, we will refrain from collecting any further Personal Data on you and shall take appropriate steps to dispose of, delete or anonymise any records containing your Personal Data, to the extent this is operationally feasible and proportionate. Where your Personal Data has been anonymised, we may retain this information indefinitely.

An Individual’s Rights in relation to Personal Data

An Individual may at any time, and within the limits of the applicable legal obligations of the Company, request information about how the Company uses and shares his/her Personal Data and may access their Personal Data, as well as obtain his/her data in a structured, commonly used format to be transmitted to another party. These rights can be exercised by contacting the Company as specified below.

An Individual also has the right to correct any inaccuracies in, and in certain circumstances, to request erasure, or restriction on the use, of their Personal Data, and to object to certain uses of their Personal Data, in each case subject to the restrictions set out in the applicable Data Protection Legislation. Further information on these rights, and the circumstances in which they may arise in connection with the Company’s processing of Personal Data can be obtained by contacting the Company as specified below.

In any case where the Company is relying on an Individual’s consent to process their Personal Data, that Individual has the right to change their mind and withdraw consent by contacting the Company as specified below.

Where the Company is relying on a legitimate interest of the Company, a member of the Renaissance group of companies or a third party recipient of the Personal Data in order to use and disclose Personal Data, an Individual is entitled to object to such use or disclosure of their Personal Data, and if he /she does so, the Company will cease to use and process the Personal Data for that purpose unless the Company can show there are compelling legitimate reasons for it to continue or it needs to use the Personal Data for the purposes of legal claims.  The Individual can also object any time to marketing communications.

An Individual also has the right to lodge a complaint about the processing of their Personal Data by the Company with the National Commission for Data Protection (CNPD), www.cnpd.public.lu or with the data protection supervisory authority in their local EU member state.

Contacting the Company

Any queries or complaints regarding the use of the Personal Data should be addressed to your Renaissance relationship manager in the first instance and DataPrivacy@rpalt.com.

Dated 31 March 2025

We reserve the right to amend this Notice at any time. The Notice will be published on our website.