Privacy Notice

At RWM we take your client privacy seriously and will take all such reasonable measures to protect it. This Privacy Notice is provided by Renaissance Wealth Management (Pty) Ltd (“RWM”). All Renaissance Funds will collectively be referred to as the “Funds” and any reference to RWM includes, where relevant, reference to the Funds. For the purpose of this Privacy Notice, “affiliates” will mean Independent Fiduciary Services (Pty) Ltd, Lynx Fund Managers (Pty) Ltd and Renaissance Wealth Management (UK) Limited.

This Privacy Notice sets forth the policies of RWM for the collection, use, storage, sharing, disclosure (collectively referred to as “processing”) as well as protection of personal data relating to current, prospective and former clients of RWM. This Privacy Notice is being provided in accordance with the requirements of data privacy laws, including the Protection of Personal Information Act, No 4 of 2013 (“POPIA”), the EU General Data Protection Regulation 2016/679 (“GDPR“) and the UK Data Protection Act, 2018, as well as any other laws relating to privacy or the processing of personal data and any statutory instrument, order, rule or regulation implemented thereunder, each as applicable to us as a “Data Controller” (collectively referred to as “Data Protection Law”). References to “you”, “investor” or “client” in this Privacy Notice means any investor or recipient of financial advice who is an individual, or any individual connected with an investor who is a legal person (each such individual being referred to as, a “Data Subject”), as applicable.

We commit to treating your personal information as strictly confidential and will take appropriate technical and organisational measures to ensure that your personal information is kept secure and protected against unauthorised or unlawful processing, accidental loss, destruction and damage, alteration, disclosure or access.

Personal data types we may collect and use:

We maintain an electronic and hard copy filing system and hold information that prospective, current and past clients, and investors provide us. The categories of personal data we may collect include names, residential addresses or other contact details, signature, nationality, place of birth, tax identification number, date of birth, place of birth, copies of identification documents, bank account details, information about assets or net worth, credit history, source of funds and source of wealth details, as well as other sensitive information. We also collect and store any relevant communication between us and investors (e.g. emails, meeting notes, financial analysis, etc.).

Using your personal data: The legal basis and purpose

RWM is entitled to process your personal data for the purposes of administering the relationship between you and RWM (including communications and reporting), marketing of our products and services, monitoring and analysing RWM’s activities and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities with competent jurisdiction). Your personal information is processed in accordance with Data Protection Laws and may be processed with your consent, upon your instruction, to allow RWM to deliver services to you in terms of the agreement between you and RWM, or for any of the purposes set forth herein, including where RWM or a third-party consider there to be any other lawful purpose to do so. We may also receive your personal information from third parties, such as our affiliates, the administrators of funds, third-party service providers, or publicly accessible sources, such as the internet and public records. Where personal data is required to satisfy a statutory obligation (such as compliance with applicable anti-money laundering or sanctions requirements, as well as court orders) or a contractual requirement, failure to provide such information may result in RWM terminating its relationship with you. Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.

How RWM shares your personal data:

We are entitled to disclose personal information about you to our service providers, affiliates or third parties, including the Administrator, Manager, Investment Managers and Custodians of any of the Funds, for our everyday business purposes, such as to facilitate transactions and maintain your account(s) in terms of your mandate with RWM, or respond to court orders and legal investigations. It may also be necessary, under anti-money laundering and similar laws, to disclose information about the Funds’ investors in order to accept subscriptions from them or to facilitate the establishment of trading relationships for the Funds with executing brokers or other trading counterparties. We are entitled to also release information about you if you direct us to do so. We are entitled to disclose personal information about your transactions and experiences with us to our affiliates for their everyday business purposes; alternatively in order to ensure that we can deliver the service in terms of our mandate with you. When you are no longer an RWM client or investor, we may continue to share your personal information as described in this Privacy Notice for the purposes of contractual, regulatory or legal purposes. Should your personal information change, please inform us and provide us with updates to your personal information as soon as reasonably possible to enable us to update your personal information. RWM does not accept liability for Personal Data which is incorrect or outdated where a client has failed and/or neglected to inform us of the change in their personal information and provided the necessary supporting documentation.

Monitoring of communications:

We are entitled to record and monitor telephone conversations and electronic communications with you for the purposes of: (i) ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances; (ii) ensuring compliance with our regulatory obligations; and/or (iii) detecting and preventing the commission of financial crime.

Retention periods and security measures:

We will not retain personal data for longer than is necessary in relation to the purpose for which it is collected, subject to Data Protection Law. Personal data will be retained for the duration of your tenor as a client, your investment with us and for a minimum period of five to seven years after a redemption of an investment from the Fund, liquidation of the Funds or termination of your mandate with RWM. In certain circumstances we may be entitled to retain your personal data for a longer period in order to comply with applicable law. From time to time, we will review the purpose for which personal data has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us or our mandate with you. To protect your personal information from unauthorised access and use, we apply organisational and technical security measures in accordance with Data Protection Law. These measures include computer safeguards and secured files in buildings. We will notify you of any material personal data breaches affecting you in accordance with the requirements of Data Protection Law.

International transfers:

RWM is a South African entity with affiliates that conduct business in South Africa, the United Kingdom and Channel Islands and provides clients and investors with an international service. Accordingly personal data may be transferred to countries outside of South Africa (“Third Countries”), such as to jurisdictions where we conduct business or have an affiliate or service provider, including countries that may not have the same level of data protection as that afforded by Data Protection Laws in South Africa. In such cases, we will process personal data (or procure that it be processed) in the Third Countries in accordance with the requirements of the Data Protection Law, which may include having appropriate contractual undertakings in legal agreements with service providers who process personal data on our behalf in such Third Countries.

Your rights under Data Protection Law:

You have certain rights under Data Protection Law in relation to our processing of your personal data and these are, generally: (i) the right to request access to your personal data; (ii) the right to request rectification of your personal data; (iii) the right to request erasure of your personal data (the “right to be forgotten”); (iv) the right to restrict our processing or use of personal data; (v) the right to object to our processing or use where we have considered this to be necessary for our legitimate interests; (vi) where relevant, the right to request portability; (vii) where your consent to processing has been obtained, the right to withdraw your consent at any time; and (viii) the right to lodge a complaint with a supervisory authority. You should note that your right to be forgotten in certain circumstances under Data Protection Law is not likely to be available in respect of the personal data we hold, given the purpose for which we collect such data, as described above. You may contact us at any time to limit our sharing of your personal information. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. Should you be a US citizen, US law might provide you with additional rights. Neither Renaissance Wealth Management (Pty) Ltd, nor Renaissance Wealth Management UK Limited is registered as an investment advisor with the SEC.

Contact us with regards to this Privacy Notice:

Compliance Officer: +27 (0)11 707 9940
Email: janeke@rwm.co.za


Or write to us at:
Renaissance Wealth Management (Pty) Ltd
PO Box 71256
Bryanston
2021

Updates to our Privacy Notice:

We reserve the right to make changes to this Privacy Notice and any changes to this Privacy Notice will be posted accordingly. All changes will apply going forward and not on a retrospective basis. For any questions about this Privacy Notice or requests with regards to the personal data we hold, please contact us.

5 February 2024