WE TAKE YOUR PRIVACY SERIOUSLY

Last Modified: October 11, 2023

We understand the importance of protecting your private information and make it a priority. This Privacy Policy applies to Renew Capital LLC and its affiliates (collectively "Renew Capital"), any pooled investment vehicles managed by Renew Capital (the “Investment Vehicles”), and Renew Capital’s website www.renewcapital.com (the "Site"). This Privacy Policy governs data collection and usage. For the purposes of this Privacy Policy, unless otherwise noted, all references to Renew Capital include the Site and Renew Capital. By using the Site or submitting personal information to Renew Capital through this Site or in any other fashion, you consent to the terms of this Privacy Policy.

WARRANTIES

Information or services provided to you through Renew Capital or www.renewcapital.com is provided "as is" and Renew Capital 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 Capital may collect personally identifiable information directly through this Site, in corresponding with you via email, 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 email address. We may collect additional information from applicants to the Renew Capital Angels 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 Capital 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 Capital encourages you to review the privacy statements of websites you choose to link to from Renew Capital so that you can understand how those websites collect, use and share your information. Renew Capital is not responsible for the privacy statements or other content on websites outside of the Site.

USE OF YOUR PERSONAL INFORMATION

Renew Capital collects and uses your personal information to operate its website(s), assess your suitability for programs or services offered by Renew Capital, and deliver the services you have requested. Renew Capital also processes your personal information for internal data analytics purposes, to identify trends and patterns that will help Renew Capital optimize its operations and services. 

Renew Capital also may use your personally identifiable information to inform you of other products or services available from Renew Capital and its affiliates. We 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, we will only send you marketing information if you consent to us doing so. 

Renew Capital will not use your personally identifiable information except for the reasons stated herein, unless we first obtain your consent to do so. Renew Capital does not sell, rent or lease its customer lists or personal information it may collect to third parties.

Renew Capital 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 Capital, and they are required to maintain the confidentiality of your information. Renew Capital 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 Capital may keep track of the websites and pages our users visit within the Site, in order to determine what Renew Capital services are the most popular. This data is used to deliver customized content and advertising within Renew Capital to customers whose behavior indicates that they are interested in a particular subject area.

Renew Capital 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 Capital or the Site; (b) protect and defend the rights or property of Renew Capital; and (c) act under exigent circumstances to protect the personal safety of users of Renew Capital or the public.

USE OF COOKIES

The Site uses "cookies" and other technologies to conduct analytics and improve the quality of your experience on the Site. A cookie is a text file that is placed on your hard disk by a web page server. Cookies are uniquely assigned to you and may store information about your preferences. We may use cookies to improve the quality of your experience on the Site by, for example, storing user preferences and tracking user trends.

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:

Managing cookie settings in Internet Explorer

Managing cookie settings in Firefox

Managing cookie settings in Safari web and iOS

Managing cookie settings in Chrome

EMPLOYEE DATA

Renew Capital may collect personal information from or about prospective and current employees for human resources purposes through this Site or through other means. All information gathered about prospective or current employees, regardless of the source, is collectively referred to in this Privacy Policy as "Employee Data."

Renew Capital will use Employee Data only for purposes related to the prospective employee's employment and Renew Capital'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 Capital, your personal information is kept secure. Renew Capital 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 Capital allow you to opt-out of further mailings. If you are a resident of certain jurisdictions which require your consent to receive marketing materials, 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 Capital's public message boards, this information may be collected and used by others.

Renew Capital 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. 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 Capital 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 Capital does not knowingly collect personally identifiable information from children under the age of 16. If you are under the age of 16, you must ask your parent or guardian for permission to use this Site.

RIGHTS OF CERTAIN USERS

Renew Capital 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 Capital may process personal data pursuant to legal obligation or to protect your vital interests or those of another person. In addition, Renew Capital uses its best efforts, to the extent practicable, to assess your residence for purposes of compliance with applicable law.

Individuals located in certain jurisdictions which have enacted comprehensive data privacy laws may 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 such a jurisdiction and depending on the applicable laws in your jurisdiction, you may be entitled to:

• Request a personal data report by sending us an email at renew@renewcapital.com. This report will include the personal data we have about you, provided to you in a structured, commonly used and portable format. Depending on your jurisdiction, the report may also include additional details on the purpose of collecting your personal information, the source of your personal information, whether your information has been provided to third parties (and if so, the identity or categories of such third parties), and whether your data has been transferred internationally. Please note that Renew Capital 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 renew@renewcapital.com with the information you would like corrected. You can remove your personal data from Renew Capital by sending us an email at renew@renewcapital.com. 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).

• Request that we restrict our processing of your personal data or 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. Depending on your jurisdiction, we only send marketing communications with your prior consent, and you may withdraw your consent at any time by clicking the "unsubscribe" link found within Renew Capital emails. Please note you will continue to receive transactional messages related to our services, even if you unsubscribe from marketing emails.

• Object to us using automated decision making as the sole means of making a decision using your personal data which may significantly affect you.

• Complain to a regulator. If you think that we haven't complied with data protection laws in your jurisdiction, you have a right to lodge a complaint with your local data protection supervisory authority.

Users in Rwanda may also request to designate an heir to their personal data.

You may make any of the above requests by sending us an email at renew@renewcapital.com. We will review your request in line with the applicable data privacy laws in your jurisdiction and will respond in accordance with those laws. We may request additional information from you to verify your identity before we disclose any information. 

THIRD-PARTY DATA PROCESSORS

As stated above, Renew Capital may engage third-party service providers from time to time to provide various services for our investors or to otherwise support our business. Depending on the scope of services, such service providers may need to access and process your personal data. Any such third party that processes personal data will do so pursuant to a contract with Renew Capital which shall require that the service provider uses your personal information only for the provision of services to Renew Capital and in a manner that is consistent with this Privacy Policy. 

Any third party that processes personal data subject to the EU General Data Protection Regulation and/or the U.K. General Data Protection Regulation shall agree to be bound by and comply with European Commission-approved or U.K. 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 Capital.

INTERNATIONAL TRANSFERS

We operate in, and have employees, offices, independent contractors and/or servers located in, the United States, Canada, India and several jurisdictions throughout Africa, 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 Capital takes many steps to protect your privacy, including limiting access to your personal data among Renew Capital employees to specific, authorized employees who need to access your data to enable Renew Capital to provide services to you or for Renew Capital to comply with its contractual or legal obligations.

By using the Site or submitting personal data to Renew Capital through this Site or in any other fashion, you acknowledge and agree to (1) the transfer of your personal data to the United States and/or other countries in which Renew Capital operates that may not ensure adequate protection for personal data as determined by the data protection authority in your country, and (2) onward transfers of your personal data to third-party service providers and/or development partners based in the United States, Canada, Europe or Africa on a “need-to-know” basis and in accordance with this Privacy Policy. Risks of such transfer include that there will be no local supervisory authority and limited or no individual data protection or privacy rights. In addition, in certain circumstances, courts, law enforcement agencies, national security authorities, regulatory agencies, or securities authorities in those other countries may be entitled to access your personal information.

Canada’s laws have been deemed to provide an adequate level of protection for 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 or other jurisdictions in which we operate 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:

• Requiring all Renew Capital employees worldwide to comply with this Privacy Policy and with Renew Capital’s internal privacy and data protection policies and procedures;

• For members of the Renew Capital Angels or other prospective or actual investors in Renew Capital’s Investment Vehicles, limiting access to your personal data among Renew Capital employees to specific, authorized employees who need to access your data to enable Renew Capital to provide services to you or for Renew Capital to comply with its contractual or legal obligations.

• For onward transfers to other service providers or development partners as described in this Privacy Policy, we may use specific contracts approved by data privacy authorities (including the European Commission or U.K. Information Commissioner's Office) which give personal data the same protection it has in your home country. For further details regarding transfers outside the European Union in particular, see European Commission: Standard contractual clauses for data transfers between EU and non-EU countries.

RETENTION OF DATA

We retain personal data where we have a legal or contractual need to do so, 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 Renew Capital Angels, whether such members would reasonably expect that we would retain the data until their membership in the network 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 Capital provides management and administrative services to its Investment Vehicles. In the normal course of the formation, operation and dissolution of the Investment Vehicles, Renew Capital 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 Capital’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 Capital’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 Capital who require such access to provide services to Renew Capital, the Investment Vehicles and the Investors. Renew Capital will maintain physical, electronic, and procedural safeguards to guard private information about the Investors. In all events, Renew Capital 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 Capital and all Investment Vehicles managed by Renew Capital.

CHANGES TO THIS PRIVACY POLICY

Renew Capital will occasionally update this Privacy Policy to reflect company and customer feedback.

Renew Capital encourages you to periodically review this Privacy Policy to be informed of how Renew Capital is protecting your information.

CONTACT INFORMATION

Renew Capital welcomes your questions or comments regarding this Privacy Policy.

If you have questions about our Privacy Policy or believe that Renew Capital has not adhered to it, please contact Renew Capital at:

RENEW LLC
Attn: Chief Compliance Officer
renew@renewcapital.com 
PO Box 598
Denver, CO 80201
USA

For persons in Uganda:

RENEW Investments Uganda-SMC Ltd.
Attn: Data Protection Officer
renew@renewcapital.com 
Plot 3 Dewinton Road, Kassam Building 
PO Box 9446
Kampala, Uganda 

For persons in Rwanda:

Renew Investment Advisors Ltd
Attn: Data Protection Officer
renew@renewcapital.com 
Norrsken House Kigali
KN 78 St.

Kigali, Rwanda

For persons in Kenya:

Renew Capital Kenya Limited
Attn: Data Protection Officer
renew@renewcapital.com 
PO BOX 764 Sarit Centre
Nairobi, Kenya
00606