§1 Scope
This Privacy Policy ("Policy") describes how Republic Investment Group and its affiliates (collectively, "Republic," "we," "us," or "our") collect, use, share, and protect personal information of individuals who visit our website at republicinvestment.example (the "Site"), inquire about our services, become investors in our funds, or otherwise interact with us.
By accessing or using the Site or providing personal information to us, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, please do not use the Site or provide personal information to us.
This Policy applies to personal information processed by Republic in connection with our investment management business. It does not apply to personal information processed by third parties to whom we may direct you, who are governed by their own privacy policies.
§2 Information We Collect
We collect personal information in several ways and for the limited purposes described below.
2.1 Information You Provide Directly
When you submit an investor access request, contact us, or engage with our services, you may provide:
- Identifying information: name, business affiliation, professional title
- Contact information: email address, business mailing address, telephone number
- Financial information necessary to verify accredited investor status under Rule 501(a) of Regulation D, which may include income, net worth, employment, or professional licensing information
- Information about your investment preferences, objectives, and prior experience
- Authentication information including any account credentials you create
2.2 Information Collected Automatically
When you visit the Site, we and our service providers may automatically collect:
- Device and browser information: IP address, browser type and version, operating system, device identifiers, screen resolution
- Usage information: pages viewed, time spent on the Site, referring URL, navigation paths, click data
- Location information: approximate geographic location inferred from your IP address
2.3 Information from Third Parties
We may receive information about you from third parties, including accredited investor verification services (such as Parallel Markets or VerifyInvestor), background check providers, credit reference agencies, public databases, and referral sources.
§3 How We Use Information
We use personal information for legitimate business and operational purposes, including:
- Verifying eligibility. Confirming that prospective investors qualify as accredited investors under U.S. securities laws and any applicable non-U.S. requirements.
- Communicating. Responding to inquiries, sending offering documents, distributing investor letters, and providing fund-related correspondence.
- Managing investments. Onboarding investors, processing subscriptions and redemptions, calculating distributions, and providing tax reporting.
- Operating the Site. Maintaining, securing, and improving the Site's performance and user experience.
- Legal and regulatory compliance. Meeting our obligations under the Investment Advisers Act of 1940, the Securities Act of 1933, anti-money laundering and know-your-customer requirements, FATCA, CRS, and other applicable laws.
- Fraud prevention and security. Detecting and preventing fraudulent activity, identity theft, and security threats.
§6 Data Security
We maintain administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. These measures include encryption of data in transit, access controls, employee training, vendor due diligence, and incident response procedures.
No system is impenetrable. While we take security seriously, we cannot guarantee absolute security of information transmitted over the internet.
§7 Retention
We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, tax, regulatory, or reporting requirements. Under SEC Rule 204-2, investment advisers are generally required to retain certain records for at least five years. Records relating to investors and fund activity may be retained for longer periods consistent with our regulatory obligations.
§8 Your Rights
Depending on your jurisdiction, you may have rights regarding your personal information, including:
- The right to access the personal information we hold about you
- The right to correct inaccurate or incomplete information
- The right to deletion (subject to retention obligations)
- The right to restrict or object to processing
- The right to data portability
- The right to withdraw consent where processing is based on consent
- The right to lodge a complaint with a supervisory authority
California Residents
If you are a California resident, you have additional rights under the California Consumer Privacy Act ("CCPA") as amended by the California Privacy Rights Act ("CPRA"), including rights to know, delete, correct, and opt-out of certain disclosures. Republic does not "sell" or "share" personal information for cross-context behavioral advertising as those terms are defined under California law.
European Economic Area, United Kingdom, and Switzerland
If you are located in the EEA, UK, or Switzerland, processing of your personal information is governed by the General Data Protection Regulation ("GDPR") or equivalent law. The legal bases on which we rely include performance of a contract, compliance with legal obligations, our legitimate interests, and where applicable, your consent.
Hong Kong
Personal data of Hong Kong residents is processed in accordance with the Personal Data (Privacy) Ordinance ("PDPO"). You have rights to access and correct personal data we hold about you, and to be informed about our data practices.
To exercise any of these rights, contact us using the information in Section 12.
§9 International Transfers
Republic operates offices in the United States (Dallas, Texas), Italy (Milan), and Hong Kong, and may transfer personal information across borders for the purposes described in this Policy. When we transfer personal information from the EEA, UK, or Switzerland, we rely on appropriate safeguards such as Standard Contractual Clauses approved by the European Commission.
§10 Children's Privacy
The Site and Republic's services are intended for adults and not for children. We do not knowingly collect personal information from individuals under the age of 18 (or the applicable age of majority in their jurisdiction).
§11 Changes to this Policy
We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will revise the "Last Updated" date above and, where appropriate, provide additional notice (such as posting a notice on the Site or contacting you directly).
§12 Contact Us
If you have questions about this Policy or wish to exercise any of your rights, please contact:
Email: [email protected]
For EU/UK data subjects, our designated representative or Data Protection Officer (where one is appointed) can be contacted at [email protected].
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