WE TAKE YOUR PRIVACY SERIOUSLY
Last Modified: January 6, 2021
Information or services provided to you through RENEW or www.renewstrategies.com is provided "as is" and RENEW does not make any warranties or endorsements. We apologize for any technical difficulties that you have with our Site, but do not accept responsibility for any inconveniences.
COLLECTION OF YOUR PERSONAL INFORMATION
RENEW may collect personally identifiable information directly through this Site, in corresponding with you via e-mail, web input screens and forms, by telephone, and through other interactive online activities or in person. The types of personal information we may collect include your name, job title, company, address, business telephone number, mobile telephone number and e-mail address. We may collect additional information from applicants to the Impact Angel Network or other prospective investors in an Investment Vehicle, including information about household income levels, investor suitability information, taxpayer identification numbers, bank account details, identification documents such as a driver’s license or passport, and other sensitive information. In addition, from applicants or participants in our training programs, we may collect your gender, country location, and information about your educational background and employment history. Finally, from owners or managers of companies in which we may invest, we may also collect information about your educational background, employment history and other professional qualifications, bank account details and identification documents such as national identity cards or passports.
AUTOMATIC COLLECTION OF INFORMATION
Information about your computer hardware and software may be automatically collected by RENEW when accessing the Site. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of our service, to maintain quality of our service, and to provide general statistics regarding use of the Site.
RENEW encourages you to review the privacy statements of websites you choose to link to from RENEW so that you can understand how those websites collect, use and share your information. RENEW is not responsible for the privacy statements or other content on websites outside of the Site.
USE OF YOUR PERSONAL INFORMATION
RENEW collects and uses your personal information to operate its website(s), assess your suitability for programs or services offered by RENEW, and deliver the services you have requested.
RENEW also may use your personally identifiable information to inform you of other products or services available from RENEW and its affiliates. RENEW also may contact you via surveys to conduct research about your opinion or the impact of current services or of potential new services that may be offered. If you are located in certain jurisdictions which require your consent to receive marketing materials, such as the European Economic Area, the United Kingdom and Uganda, we will only send you marketing information if you consent to us doing so.
RENEW will not use your personally identifiable information except for the reasons stated herein, unless we first obtain your written permission to do so. RENEW does not sell, rent or lease its customer lists or personal information it may collect to third parties.
RENEW may share data with trusted partners to provide services you have requested, help perform statistical analysis, send you email or postal mail, provide customer support, arrange for deliveries, or otherwise support our business. All such third parties are prohibited from using your personal information except to provide these services to RENEW, and they are required to maintain the confidentiality of your information. RENEW may also share certain data with our development partners, as may be required by our contracts with them. Such information may include the names, genders and locations (city and country) of participants in our training programs or of the owners of companies in our investment pipeline. Any such data will be limited to what is required to fulfill our contractual reporting obligations and will be anonymized where possible.
RENEW may keep track of the websites and pages our users visit within the Site, in order to determine what RENEW services are the most popular. This data is used to deliver customized content and advertising within RENEW to customers whose behavior indicates that they are interested in a particular subject area.
RENEW will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform with applicable law or comply with legal process served on RENEW or the Site; (b) protect and defend the rights or property of RENEW; and (c) act under exigent circumstances to protect the personal safety of users of RENEW or the public.
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the RENEW services or websites you visit. You can usually find these settings in the "Options" or "Preferences" menu of your browser. The following sites provide more information:
RENEW will use Employee Data only for purposes related to the prospective employee's employment and RENEW's human resources programs and will not disclose it to any person except for these stated purposes, unless it first obtains permission from the employee or is required to do so by applicable law.
SAFEGUARDING YOUR PERSONAL INFORMATION
At RENEW, your personal information is kept secure. RENEW takes reasonable measures to safeguard your personal information from unauthorized access, use or disclosure. We require that employees and third-party partners and contractors access your personal information only on a "need-to-know" basis and, in every instance, maintain the confidentiality of such information. Only authorized employees, agents and contractors (who have agreed to keep information secure and confidential) have access to your personal data.
All emails and newsletters from RENEW allow you to opt-out of further mailings. If you are a resident of certain jurisdictions which require your consent to receive marketing materials, such as the European Economic Area (EEA), the United Kingdom and Uganda, we will only send you marketing information if you consent to us doing so.
Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through RENEW's public message boards, this information may be collected and used by others.
RENEW is committed to protecting the security of your information and takes reasonable precautions to protect it. However, internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100% secure, and as a result, we cannot ensure the security of any information you transmit to us; accordingly, you acknowledge that you do so at your own risk. Once we receive your data, we protect it on our servers using a combination of technical, physical, and logical security safeguards. If RENEW learns of a security system breach, we may attempt to notify you and provide information on protective steps, if available, through the email address that you have provided to us. Depending on where you live, you may have a legal right to receive such notices in writing.
CHILDREN UNDER SIXTEEN
RENEW does not knowingly collect personally identifiable information from children under the age of sixteen. If you are under the age of sixteen, you must ask your parent or guardian for permission to use this Site.
DATA PROTECTION RIGHTS, OPT-OUT & UNSUBSCRIBE
Depending on the country in which you reside, you may have the following data protection rights:
- If we have collected and processed your personal information with your consent, you may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You may prevent RENEW from disclosing, processing or using your personal information under certain circumstances, or you may opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from RENEW by contacting us by email at email@example.com. Please note you will continue to receive transactional messages related to our services and other communications we are required to send you by law or to fulfill an ongoing legal obligation we have to you, even if you opt-out.
RENEW responds to all requests from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
FOR EEA & UK USERS
RENEW uses, processes, and stores personal data, including that listed in the "Collection of your Personal Information" section, as necessary to perform our services with you, and based on our legitimate interests in order to provide such services. We rely on your consent to process personal data to send promotional emails and to place cookies on your devices. In some cases, RENEW may process personal data pursuant to legal obligation or to protect your vital interests or those of another person. In addition, RENEW uses its best efforts, to the extent practicable, to assess your residence for purposes of compliance with applicable law.
Individuals located in the European Economic Area or the United Kingdom (or any other geography where the EU General Data Protection Regulation applies) have certain rights in respect to their personal information, including the right to access, correct, or delete personal data we process through your use of the Site or any services offered by us. If you're a user resident in the EEA or UK, you can:
- Request a personal data report by sending us an email at firstname.lastname@example.org. This report will include the personal data we have about you, provided to you in a structured, commonly used, and portable format. Please note that RENEW may request additional information from you to verify your identity before we disclose any information.
- Have your personal data corrected or deleted. To update your personal data, send us an email at email@example.com with the information you would like corrected. You can remove your personal data from RENEW by sending us an email at firstname.lastname@example.org. Pursuant to applicable law, we will delete any such data upon your request, other than such data as applicable law permits us to retain (such as data related to legal obligations with which we must comply).
- Object to us processing your personal data. You can ask us to stop using your personal data, including when we use your personal data to send you marketing emails. We only send marketing communications to users located in the EEA or UK with your prior consent, and you may withdraw your consent at any time by clicking the "unsubscribe" link found within RENEW emails. Please note you will continue to receive transactional messages related to our services, even if you unsubscribe from marketing emails.
- Complain to a regulator. If you're based in the EEA or UK and think that we haven't complied with data protection laws, you have a right to lodge a complaint with your local supervisory authority.
THIRD-PARTY DATA PROCESSORS
Any third party that processes personal data subject to the EU General Data Protection Regulation and/or the UK General Data Protection Regulation shall agree to be bound by and comply with European Commission-approved or UK Information Commissioner's Office-approved standard contractual clauses (or such other contractual arrangements as will provide a substantially similar level of data protection compliance and information security as that provided for therein) in the performance of its services for RENEW.
We operate in, and have employees, offices, independent contractors and/or servers located in, the United States, Canada, India, Nigeria, Ethiopia, Rwanda and Uganda, and we use cloud technology to store and process your personal information. This means that your personal data will be transferred outside of the country in which you reside, among any of the countries in which we operate. In particular, your data will be processed in the United States and Canada. In certain circumstances, courts, law enforcement agencies, national security authorities, regulatory agencies, or securities authorities in these other countries may be entitled to access your personal information. RENEW takes many steps to protect your privacy, including limiting access to your personal data among RENEW employees to specific, authorized employees located primarily in the United States and Canada who need to access your data to enable RENEW to provide services to you or for RENEW to comply with its contractual or legal obligations.
For Users in the EEA, Switzerland, UK and Uganda:
Canada’s laws have been deemed to provide an adequate level of protection for your personal data by the European Commission (for further details, see European Commission: Canada Adequacy Decision). While the data protection and privacy laws of the United States, India, Nigeria, Ethiopia, Rwanda and Uganda might not be as comprehensive as those in your country, we take many steps to protect your privacy and to ensure a similar degree of protection is afforded to your personal data, including:
- For members of the Impact Angel Network or other prospective or actual investors in RENEW’s Investment Vehicles, limiting access to your personal data among RENEW employees to specific, authorized employees located primarily in the United States and Canada who need to access your data to enable RENEW to provide services to you or for RENEW to comply with its contractual or legal obligations.
RETENTION OF DATA
We retain personal data where we have a legal or contractual need to so do, or where we have an ongoing legitimate business interest in retaining such data. Our retention periods will vary depending on the type of data involved, but, generally, we use the following criteria in order to determine the retention period:
- Whether we have a legal or contractual need to retain the data.
- Whether the data is necessary to provide our services to you.
- Whether we have another legitimate business interest in retaining such data.
- For members of the IAN, whether such members would reasonably expect that we would retain the data until their membership in the IAN is canceled or terminated.
When we have no further need to process your personal data, we will either delete or anonymize it. If this is not immediately possible, then we will isolate your personal data from any further processing until deletion is possible.
GRAMM-LEACH BLILEY ACT NOTICE
RENEW provides management and administrative services to its Investment Vehicles. In the normal course of the formation, operation and dissolution of the Investment Vehicles, RENEW will collect and disclose certain private information about the members or prospective members of the Investment Vehicles (collectively, the “Investors”). Personal financial information about the Investors, such as their names, addresses, social security or tax identification numbers, assets and incomes, will be obtained from subscription agreements, investor questionnaires and other documents. Other personal information about the Investors, such as capital account balances, contributions, distributions, account data and information about their participation in other investments, will be obtained in the course of transactions between the Investors and the Investment Vehicles or its affiliates.
Except as described below, this private information will be disclosed only as permitted by applicable law to the Investment Vehicles’ or RENEW’s affiliates and service providers, including accountants, attorneys, broker-dealers, custodians, transfer agents, tax preparers, and any other parties whose services are necessary or convenient to the formation, operation or dissolution of the Investment Vehicles or to RENEW’s everyday business purposes. Any party receiving private information about the Investors pursuant to the preceding sentence will be authorized to use such information only to perform the services required and as permitted by applicable law.
Access to private information about the Investors will be restricted to those employees of RENEW who require such access to provide services to RENEW, the Investment Vehicles and the Investors. RENEW will maintain physical, electronic, and procedural safeguards to guard private information about the Investors. In all events, RENEW may disclose Investor information: (a) to other Investors as required or permitted under the governing documents of the Investment Vehicles; (b) to entities other than our affiliates and service providers with the consent of the Investor; and (c) as otherwise required by applicable law.
This notice is being provided on behalf of RENEW and all Investment Vehicles managed by RENEW.
Attn: Chief Compliance Officer
PO Box 598
Denver, CO 80201
For persons in Uganda:
RENEW Investments Uganda-SMC Ltd.
Attn: Data Protection Officer
Plot 3 Dewinton Road, Kassam Building
PO Box 9446