Privacy Policy

This website is operated by Revetas Capital Advisors LLP. Revetas takes data protection very seriously and implements appropriate technical and organizational measures in order to meet the requirements of the EU General Data Protection Regulation (GDPR).

This Privacy Policy describes how we, as data controllers, process your personal data (data), whether in your use of our website or otherwise in our interactions with you, as applicable. The Privacy Policy applies if you use our website for personal or professional purposes. It also applies where we are processing your data because of your position as an employee at, or other connection to, a company, a government agency or another organization with which Revetas is connected. This connection may be related in some way to an investment in our funds, or our investment in any portfolio company, or your provision of services to us or companies we invest in.

Revetas is made up of different legal entities. This privacy policy is issued on behalf of Revetas Capital Advisors LLP but in it we include information about our interaction with different group companies and companies we invest in (Affiliates). By Affiliates, we mean subsidiaries or holding companies of Revetas, plus any entity which forms part of the investment portfolio of any such group company, in the event that such entity would not otherwise be considered a subsidiary. In this policy, “Revetas”, “we” or “us” refers to Revetas Capital Advisors LLP and our Affiliates. If you would like more information on Revetas or our Affiliates, you can contact us at the details set out below.

1. What data we process

In the course of your visit on this website the following data is being collected:

• the date and time of accessing a page on our website;
• your IP address;
• name and version of your web browser; and
• certain cookies (see section 2 below).

Together, connectivity data. There is no obligation to disclose the information we ask you to provide on our website. However, you may not be able to use all the features of the website, if you choose not to disclose your information.

If we engage with you in your capacity as an employee or consultant, an investor, candidate, building manager or landlord, we may also collect the following information, whether from you directly or from a third party:

• identity check information, such as copies of your ID card, passport, social security number, tax number, employment details and nationality;
• contact details, such as your email address, postal address and telephone number;
• information about your identity, such as your name, date of birth, personal characteristics, your marital status, gender, physical or personal characteristics, academic details and your family;
• financial data, such as information about your insurance, card data; and
• connectivity data as set out above.

In certain cases we may process what is called special category personal data by virtue of our relationship with you, including as part of identity checks or during the course of your employment by us or any of our Affiliate companies. This may include information on your ethnic origin, biometric or health data, or information about criminal convictions and infringement of any law, codes or regulations. Some of this data may also reveal information about your sex life or sexual orientation, philosophical or religious beliefs or genetic information, although we do not deliberately collect that information. We do not collect, process or retain data which we do not need to use as part of our business. More information on our grounds for processing is set out below.

2.         Cookies

This website uses so-called cookies. A cookie is a small piece of information that may be stored on your computer when you visit a website. In principle, cookies are used to offer users additional features on a website. For example, they may be used to help you navigate a website, to allow you to continue using a website where you left it and/or to save your preferences and settings when you return to the website. Cookies cannot access, read or modify any other data on your computer.

Most cookies on this website are so-called session cookies. They are automatically deleted when you leave our website. Permanent cookies, on the other hand, remain on your computer until you manually delete them in your browser. We use such permanent cookies to recognize them the next time you visit our website.

If you want to control the cookies on your computer, you can select your browser settings so that you receive a notification when a website wants to store cookies. You can also block or delete cookies if they are already stored on your computer. If you would like to know more about these steps, please use the "Help"-feature in your browser.

Please note that blocking or deleting cookies may affect your online experience and prevent you from fully using this website.

3.         Purposes of the processing and legal basis

When you use our website

When you use our website, we process your data for the following purposes:

• to provide you with this website and to further improve and develop this website;
• to be able to generate usage statistics;
• to detect, prevent and investigate attacks on this website; and
• to answer your requests.

We carry out these processes on the basis of our legitimate interest. This is our interest in the success of our business, and the use and analysis of our website to promote the success of our business.

Employees, consultants, candidates and building managers

If you are an employee, consultant, candidate or building manager, we may use your data in order to (i) perform a contract with you, or take steps prior to entering into a contract with you, at your request; (ii) comply with our legal obligations (such as our obligations to HMRC, the Home Office and to our regulator, the Financial Conduct Authority, or if required by a court of law, such as during legal proceedings); and (iii) satisfy our legitimate interests.

Our legitimate interests in such processing include our ability to run our business, to keep our records updated, to make sure our investors are satisfied, to provide administration and IT services, to ensure network security and to grow our business.

The processes which fall under the aforementioned legal bases are:

• hiring processes, disciplinary regimes, payroll management, incident management, training and evaluation and contract negotiation;
• internal and external commercial communications, including policies such as for security development and compliance, managing stakeholders and media relationships;
• logistics, due diligence and managing contracts and assets; and
• security measures such as anti-fraud, anti-money laundering, loss prevention and physical security over assets, security and technical support services. 

Where we use data in marketing communications, this will only be first and last name.

Investors and landlords, professional advisers and other service providers

If you are an investor or landlord, or an employee or consultant working for or with an investor or landlord, we may use your personal data in order to (i) perform a contract with you, or take steps prior to entering into a contract with you, at your request; comply with our legal obligations (such as our obligations to HMRC and to our regulator, the Financial Conduct Authority, or if required by a court of law, such as during legal proceedings); and (iii) satisfy our legitimate interests. You may also act for us in your professional capacity, or otherwise to provide a service to us. The same legal bases for processing apply in that case.

Our legitimate interests when processing as above include running our business, arranging investments (including due diligence), managing assets, ensuring investors are satisfied, keeping records updated, growing our business and ensuring legal and regulatory compliance.

The processes which fall under the aforementioned legal bases are:

• establishing a fund, arranging investments and acquiring assets;
• contract negotiation, logistics, due diligence, incident management, insurance compliance and other asset management activities;
• security and technical support, information security and compliance; and
• internal and external communications including to manage stakeholders and media relationships.

Where we use data in marketing communications, this will only be first and last name.

Special category data

If we have access to your special category personal datawe will use this only: (i) as is necessary for us to carry out our responsibilities in the field of employment and social security and social protection law in so far as we are authorised to do by EU or Member State law or other collective agreement which provides appropriate safeguards; (ii) if needed to protect an individual’s vital interests in certain circumstances; (iii) if it is manifestly made public by you; (iv) it is needed to establish, exercise or defend legal claims; or (v) as is necessary for preventative or occupational health purposes.

Consent

We will not usually process data on the basis only of your consent. However, if we do, you usually have the right to request that we stop such processing. Please note that if you do make such a request, we may not be able to carry out our part in our relationship with you.

4. Recipients of data

We, Revetas Capital Advisors LLP, may share your data with our Affiliates in London, Vienna, Luxembourg and Guernsey. For the purposes mentioned in section 3 above, we may also disclose your data to the following categories of recipients:

• employees of Revetas;
• external processors of Revetas such as consultants, investors and service providers who act as sub-processors; and
• authorities (where necessary for legal reasons).

Some of the recipients listed above are seated outside of the EU. However, we only disclose your data:

• to recipients in countries that provide an adequate level of data protection according to a decision by the European Commission;
• if we have taken measures to ensure that the recipients provide an adequate level of data protection. For example, in such case, we may use standard contractual data protection clauses approved by the European Commission; or
• to recipients in the US who are certified according to the EU-US Privacy Shield Framework approved by the European Commission.

For further information on how to obtain a copy of the safeguards used to protect your data, please contact us by using our contact details in section 8 below.

5. Data Retention

We will retain your data only for as long as we need it, whether for our legitimate interest (as identified above), as required by applicable law or legal requirement, to fulfil a contract or perform a service at your request, after which we will take steps to delete your data or hold it in a form that no longer identifies you.

6. Data Security

We have put in place measures to prevent your data from being lost, used or accessed in a way that isn’t authorised, as well as to prevent it being altered. We also ensure that we don’t disclose your data to our Affiliates or third parties unless we have a legal basis to do so, as set out at 3 above.

7. Your rights under the GDPR

You have the right to request from Revetas access to or correction or erasure of your data or restriction of the processing of your data as well as the right to data portability. In addition, you can object to the processing of your data in some circumstances. Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Revetas processing your data, this will not affect any processing which has already lawfully taken place at that time, but may prevent us from performing services for you, if we are unable to do so without your data. We will advise you of that if is it the case when you withdraw your consent.

8.         Contact details

If you have any comments or questions about this privacy policy or our processing of your data, please contact: info@revetas.com