THE INFORMATION WE COLLECT AND PROCESS:
Your full name and contact details (email address, phone number, postal address, country of residence, etc.).
Information about your employment, profession, title, background, and interests, and information about your business relationship with New Rhein.
Technical information related to how you used our website, specifically, the browser, device, internet connection, IP address, time zone setting, operating system, and platform, etc.
Details of visits to our website, including the volume of traffic received, logs, and the resources that you have accessed.
Personal data relating to your attendance at a New Rhein event.
HOW WE COLLECT YOUR INFORMATION
We may collect your personal information directly from you, when you provide it to us when you visit our website www.newrhein.com, or the New Rhein Extranet investor portal, give us your business card or correspond with us by mail, telephone, email, or otherwise.
If you connect to our website, it will automatically collect some information about you and your visit, including the Internet protocol (IP) address used to connect your device to the Internet and some other information such as your browser type and version and the pages on our site that you visit. This information is used to improve website performance and for our business purposes. If you prefer not to receive cookies through our website, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser. If you turn off cookies (or refuse to accept a request to place a cookie), you may not have access to some features on our website and some of our services.
If you exchange electronic communications with our employees or representatives by email, text, or telephone conversations, our information technology systems will record details of those conversations, sometimes including their content to comply with New Rhein’s legal obligations as a Registered Investment Advisor with the Securities and Exchange Commission.
Our offices may have closed-circuit TV systems which may record your voice and image if you visit our premises, for security and safety purposes.
WE MAY ALSO COLLECT SOME INFORMATION FROM OTHER SOURCES. FOR EXAMPLE:
If we have a business relationship with a firm or organization that you represent, your colleagues or other business associates may give us information about you, such as your contact details or details of your role in the firm or organization.
We may collect information from third-party data providers or publicly available sources for anti-money-laundering, background checking, and similar purposes, and to protect our business and comply with our legal and regulatory obligations.
HOW WE USE YOUR INFORMATION:
to operate, manage, develop and promote our business and, in particular, our relationship with you and the organization you represent (if any) and related investments and/or transactions;
to operate, administer and improve our website and premises and other aspects of the way in which we conduct our operations;
to protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials, and other financial or business crimes;
to send marketing communications to you, if applicable and
to comply with our legal and regulatory obligations and bring and defend legal claims.
We may review information about you that we maintain in our systems, including the contents of and information related to your emails and other communications with us, for compliance and business-protection purposes as described above. This may include reviews to disclose information relevant to litigation and/or reviews of records relevant to internal or external regulatory or criminal investigations. To the extent permitted by applicable law, these reviews will be conducted in a reasonable and proportionate way and approved at an appropriate level of management. They may ultimately involve the disclosure of your information to governmental agencies and litigation counterparties as described below. Your emails and other communications may occasionally be accessed by persons other than the staff member with whom they are exchanged for ordinary business management purposes (for example, where necessary when a staff member is out of the office or has left New Rhein).
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
WE RELY ON LEGAL BASES TO PROCESS YOUR PERSONAL INFORMATION:
We will only process your personal information when the law allows us to and as necessary so that we can pursue the purposes described above. We will process your personal information where we need to perform the contract we are about to enter or have entered into with you. Where the processing is necessary for our legitimate interests (or those of a third party), we will do so only where we have concluded that our processing does not prejudice you or your privacy in a way that would override those interests. In exceptional circumstances, we may also be required by law to disclose or otherwise process your personal information. We rely on the legal basis of consent and/ or legitimate interests (as appropriate) to send marketing communications to you via email. You have the right to opt-out or if you have previously provided consent, you have the right to withdraw such consent to receive the marketing communications at any time by contacting us at the details below or by following the opt-out links on any marketing message we send to you.
DISCLOSURE AND INTERNATIONAL TRANSFER OF YOUR INFORMATION:
We may disclose personal information about you, where reasonably necessary for the various purposes set out above:
to the other members of the New Rhein group of companies;
to your colleagues within the organization that you represent;
to service providers who host our website or other information technology systems or otherwise hold or process your information on our behalf, under strict conditions of confidentiality and security;
business partners, suppliers, and subcontractors for the performance of any contract we enter into with them or you;
to a person who takes over our business and assets, or relevant parts of them; or
in exceptional circumstances:
to competent regulatory, prosecuting, and other governmental agencies, or litigation counterparties, in any country or territory; or
where we are required by law to disclose.
These disclosures may involve transferring your personal information to New Rhein affiliates and their service providers in Luxembourg, Cayman Islands, and the United States or other countries as services are added. If you are dealing with us within the European Economic Area or the UK, you should be aware that this may include transfers to countries outside the European Economic Area / UK that do not have similarly strict data privacy laws.1 In those cases, where we transfer personal data to other members of the New Rhein group or our service providers, we will ensure that our arrangements with them are governed by data privacy policies if within the New Rhein group of companies or data transfer agreements outside the New Rhein group of companies, designed to ensure that your personal information is protected, on terms approved for this purpose by the European Commission. Please contact us (see contact details below) if you would like to know whether any such agreements are in place or, if so, to see a copy.
HOW WE MAINTAIN AND STORE YOUR INFORMATION:
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
We have procedures to periodically delete the information that we hold about you when we no longer need it. Usually, this will be after your involvement with New Rhein has come to an end, however, as a Registered Investment Adviser with the Securities and Exchange Commission, we are required to main such information for a minimum of six years from when we no longer use your data.
YOUR EU RIGHTS REGARDING YOUR PERSONAL INFORMATION:
To the extent that EU data protection laws apply to the processing of your personal information, you have certain rights regarding your personal information. You have a right to access the personal information that we hold about you, and to some related information. You can request that inaccurate personal information be corrected or deleted. You may have the right to object to our processing of some or all of your personal information and require them to be deleted, in some other circumstances. In certain situations, you have the right to request that we transfer the personal information we hold on you to yourself or a third party. When we rely on your consent to process your personal information (such as when we send you marketing communications), you have the right to withdraw your consent.
If you wish to exercise any of these rights, please contact us using the contact details set out below. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.[Control]
You can also lodge a complaint about our processing of your personal information with the body regulating data protection in your country. However, we would appreciate the chance to deal with your concerns before you approach the regulatory body.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.