Privacy Policy

Last Updated: April 1 6, 2021

Your privacy is very important to us.  This document (the “Privacy Policy”) is provided by Rivonia Road Capital, LLC on behalf of itself and the funds and accounts it manages (collectively, “Rivonia” or “we”), and sets forth Rivonia’s policies with respect to the collection, sharing and protection of information pertaining to Rivonia’s current, prospective and former investors, service providers, other business contacts and users of our websites.   Please read this Privacy Policy carefully to understand what we do.  A link to this Privacy Policy is available on our website at www.rivoniaroad.com .

If you choose to visit our public or password-protected website, your visit and any dispute over privacy is subject to this Privacy Policy and our terms of use including limitations on damages and application of the law of the State of California. 

Updates to Privacy Policy

We may revise and update this Privacy Policy from time to time to reflect changes in the law, our data handling practices or the features of our services, including our website. The new version of the Privacy Policy will be posted on our website. We will indicate at the top of this Privacy Policy when it was last updated. By continuing to do business with us or use the website or the services that we provide to you after any changes to the Privacy Policy, you acknowledge such revised Privacy Policy governs our information practices.  If you use the password-protected portions of our website, you may be asked to read and confirm agreement to this Privacy Policy when you login to those password-protected portions of our website and each time a change is made to the policy thereafter.  

The information we collect               

Investors, Service Providers and Business Contacts

We collect personal data from current and prospective investors, service providers and business contacts, such as your name, residential address, place of business, email address, place of birth, date of birth, telephone number, copies of photo identification (e.g., passports, driver’s license, etc.), utility bills, social security or other tax identification number, account details and numbers, specimen signature, criminal history, assets, employment and education history, source of wealth, transactions, investment activity and/or income information. Much of this information is collected when you: (i) provide it to us in a subscription agreement and related documents; (ii) provide it to us in correspondence and conversations with Rivonia representatives; or (iii) otherwise transact with us, such as when you invest in one of our advised funds, tell us where to send money or make a wire transfer.  We may also collect your personal data from other sources, such as credit bureaus, investor databases, clearinghouses, data brokers, fraud databases, social media platforms, research vendors, other websites, our affiliates or other companies and other publicly available sources such as company websites.  We may combine the personal data we receive from these other sources with the personal data that we collect from you.

We may also collect your information when you email us. For example, at times, visitors to our website may choose to email individuals at Rivonia using links available on our website. In such instances, your email address, address, phone number and other contact information contained in your email, as well as any other information you choose to provide in that email may be collected as part of the process of sending the email to us in order to enable us to reply to those emails.

Website Visitors

When you use our public website at www.rivoniaroad.com and the password protected portions of our website accessible via the Investor Login page we collect personal data from you. At the present time, we do not collect any names, addresses, phone numbers, social security numbers or email addresses from visitors to the publicly available areas of our website; however, we may collect personal data as described in this Privacy Policy from investors who access the investor portal.  We may also automatically track certain information that your browser makes available whenever you visit a website whether you are visiting the public website and/or the investor portal. Thus, we may collect and analyze information such as your IP address, browser types, browser language, operating system, the state or country from which you accessed the websites, software and hardware attributes (including device IDs) referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on our websites, the date and time you used the websites, error logs, and other similar information.

How we use your information

We and our service providers, use your information for various purposes depending on the type of information we have collected from you and about you, in order to:

  • Perform services on your behalf in connection with investment related activities, such as servicing your accounts;

  • Send you correspondence and reports, including those which may contain your personal data;

  • Improve and customize our websites, products and services through the analysis of website usage to better tailor the website to meet your needs;

  • Market Rivonia products and services to you;

  • Secure, protect, and back-up our networks, facilities and websites;

  • Comply with and enforce applicable legal requirements, industry standards and our policies and terms, including, but not limited to, regulatory requirements related to tax compliance, know your customer and anti-money laundering rules;

  • Establish, exercise, or defend our legal rights;

  • Create or use aggregated or other anonymized data collected by Rivonia or obtained from third parties, which we may use and disclose without restriction; and

  • Operate, evaluate and improve our business in other ways.

How we share your information

We may share or disclose information about you in the following ways:

Affiliates and Subsidiaries.  We may share your information with our affiliates and subsidiaries, including, but not limited to, affiliated management entities and general partners to deliver our services, ensure a consistent level of service, enhance our products, services and your customer experience, and for our affiliates’ everyday business purposes.

Service Providers. We provide access to or share your information with select non-affiliated third parties who perform services on our behalf, including, but not limited to, administrators, email and document retention service companies, customer relationship management software service providers, IT infrastructure providers, banks, prime brokers, custodians, law firms, compliance consultants, auditors, tax preparers, tax reclaim service providers, fund directors and advisory committee members, counterparties and other service providers. These parties have access to information to help us perform our everyday business purposes, such as to correspond with you, process your transactions, maintain your account(s), send you marketing materials, respond to subpoenas, court orders, regulatory requests and legal investigations, cooperate with legal and regulatory bodies, or make required filings and reports to government authorities.  We require non-affiliated service providers to maintain the confidence of your private information. In some instances, these non-affiliates may collect information directly from you.  If you provide additional information to a service provider directly, their use of your information is governed by their applicable privacy policy.

With Your Consent. We may share or disclose information about you if you direct us to do so. 

Protection of Rivonia and Others. You acknowledge and agree that we may access, retain and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order); (b) enforce our Terms of Use, this Privacy Policy, Subscription Agreements or any other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of Rivonia, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.

Business Transfers.  As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), user information, including personal data, may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third-party, customer information (including your email address and other personal data) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.

Aggregate/Anonymous Information. From time to time, we may share aggregate and/or anonymous information about you. The sharing of such data is unrestricted.

Marketing

Sharing with Non-Affiliates for Marketing Purposes. While we do not currently share your information with non-affiliates for them to market their own products and services to you, we may do so in the future.  You may prevent this type of sharing by emailing info@rivoniaroad.com.  If we do decide in the future to engage in such sharing and you are a new investor, we can begin sharing your information to enable our non-affiliates to market their products and services to you 30 days from the date we sent you notice of this Privacy Policy or 30 days from the date you acknowledge this Privacy Policy, whichever is earlier.  When you are no longer our investor, we may continue to share your information as described in this Privacy Policy.  However, you may contact us at any time to limit our sharing.  If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. 

Marketing communications from Rivonia. You may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding our products, services, promotions and special events that might appeal to your interests by contacting us using the information below. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy as required by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you, or important notifications.

Legal bases for use of your information

The legal bases for using your information as set out in this Privacy Policy are as follows:

  • Where use of your information is necessary to perform our obligations under a contract with you or in order to take steps at the request of the data subject prior to entering into a contract (for example, to comply with the Terms of Use of our websites which you accept by browsing the websites or to comply with the terms of our subscription agreement with an investor in one of our advised funds); or

  • Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our website; operate our websites; comply with legal requirements and defend our legal rights; prevent fraud and to know the user to whom we are providing our service and the website, for marketing, analyzing and improving our business, managing legal issues and to provide customer service).

  • Where required by law, and in some other cases, we may handle personal data on the basis of consent.

You are responsible for the use and security of your password

The password-protected areas of our website are established for investors and their representatives only.  If you wish to access the password-protected areas of our website, you will need to apply for a password.  If you apply for a password to access password-restricted areas on our website, you must provide us with your name, mailing address, email address, phone number, investor affiliation and other relevant information, in addition to the information you have provided to us as an investor (if applicable). 

You are responsible for all actions taken with your username and password.  Therefore, we recommend that you do not disclose your password to anyone.  You may not allow others to use your username or password to access or use any part of our website.  If your password has been compromised for any reason, you should contact us immediately for a new password.

You can review and change the information that you submit to us by emailing info@rivoniaroad.com.  You can change your User ID, email address, contact information, other personal information and user preferences. You must promptly update your personal information if it changes or is inaccurate.

On your request, we will deactivate your password and remove your contact information and financial information from our active databases. Your password will be deactivated promptly based on your account activity and in accordance with our deactivation policy. 

How long we keep personal data

We generally retain personal data for so long as it may be relevant to the purposes described in this Privacy Policy. To dispose of personal data, we may anonymize it, delete it or take other appropriate steps.  Data may persist in copies made for backup and business continuity purposes for additional time. 

Security

We maintain strict operational policies, including physical, electronic and logical controls to safeguard and secure our data, facilities, and networks to attempt to prevent the unauthorized access to data we may collect online, and have appropriate policies in place to ensure that any information we collect is used in compliance with this Privacy Policy. These controls vary based on the sensitivity of information that we maintain about you.

We cannot ensure, however, that all of your private communications and other personal data will never be disclosed in ways not described in this Privacy Policy.  For example (without limiting the foregoing), unauthorized third parties may unlawfully intercept or access transmissions or private communications, or service providers may abuse or misuse your personal data that they collect and use on our behalf. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your personal data, private communications, or other information will always remain private.

Children’s Privacy

Our services and websites are not intended for persons under the age of 18 and persons under the age of 18 are not eligible to use our website or our services. If we become aware that we have collected personal data from a person under the age of 18, we will take reasonable steps to delete such information as soon as possible