RENEW Strategies

Privacy

PRIVACY POLICY

We take your privacy seriously.

We understand the importance of protecting your private information and make it a priority. This Privacy Policy applies to RENEW LLC and its affiliates (collectively, "RENEW"), any pooled investment vehicles managed by RENEW (the “Investment Vehicles”), and RENEW’s website http://www.renewstrategies.com/, (the "Site") and governs data collection and usage. For the purposes of this Privacy Policy, unless otherwise noted, all references to RENEW include the Site and RENEW. By using the RENEW website or submitting personal information to RENEW 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 or www.renewstrategies.com is provided "as is" and RENEW 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 may collect personally identifiable information directly through this Site, in corresponding with you via e-mail, web input screens and forms, by telephone, and other interactive online activities. The types of personal information we may collect include your name, job title, company, address, business telephone number, mobile telephone number and e-mail address. We may collect additional information from applicants to the Impact Angel Network or other prospective investors in an Investment Vehicle, including information about household income levels, investor suitability information, and other sensitive information.

Automatic Collection of Information

Information about your computer hardware and software may be automatically collected by RENEW. 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 RENEW website.

RENEW encourages you to review the privacy statements of websites you choose to link to from RENEW so that you can understand how those websites collect, use and share your information. RENEW is not responsible for the privacy statements or other content on websites outside of the RENEW website.

Use of your Personal Information

RENEW collects and uses your personal information to operate its website(s) and deliver the services you have requested.

RENEW also may use your personally identifiable information to inform you of other products or services available from RENEW and its affiliates. RENEW also 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 the European Economic Area or the United Kingdom, or another jurisdiction covered by the EU General Data Protection Regulation, we will only send you marketing information if you consent to us doing so at the time you create your account or any point thereafter. Please see the section "For EEA & UK users" below.

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

RENEW may share data with trusted partners to provide services you have requested, to 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, and they are required to maintain the confidentiality of your information.

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

RENEW 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 or the Site; (b) protect and defend the rights or property of RENEW; and (c) act under exigent circumstances to protect the personal safety of users of RENEW 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 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 will use Employee Data only for purposes related to the prospective employee's employment and RENEW'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, your personal information is kept secure. RENEW 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 this site allow you to opt out of further mailings. If you are resident of the European Economic Area (EEA) or the United Kingdom, or another jurisdiction covered by the EU General Data Protection Regulation, we will only send you marketing information if you consent to us doing so at the time you create your account or any point thereafter. Please see the section "For EEA & UK users" below.

Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through RENEW's public message boards, this information may be collected and used by others.

RENEW 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, and 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 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 does not knowingly collect personally identifiable information from children under the age of sixteen. If you are under the age of sixteen, you must ask your parent or guardian for permission to use this website.

DATA PROTECTION RIGHTS, OPT-OUT & UNSUBSCRIBE

Depending on the country in which you reside, you may have the following data protection rights:

  • Access, correct, update or request deletion of your personal information. You may contact RENEW any time about accessing, correcting, updating or deleting your personal information. You can find RENEW’s contact details in the “Contact Information” section at the bottom of this Privacy Policy. We will consider your request in accordance with applicable laws.
  • If we have collected and processed your personal information with your consent, you may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You may prevent RENEW from disclosing or using your personal information under certain circumstances or opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from RENEW by contacting us by email at renew@renewstrategies.com. Please note you will continue to receive transactional messages related to our services and other communications we are required to send you by law or to fulfill an ongoing legal obligation we have to you, even if you opt out.

RENEW responds to all requests from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

For EEA & UK Users

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

Individuals located in the European Economic Area or the United Kingdom (or any other geography where the EU General Data Protection Regulation applies) 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 the EEA or UK, you can:

  • Request a personal data report by sending us an email at renew@renewstrategies.com. This report will include the personal data we have about you, provided to you in a structured, commonly used, and portable format. Please note that RENEW 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@renewstrategies.com with the information you would like corrected. You can remove your personal data from RENEW by sending us an email at renew@renewstrategies.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).
  • 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. We only send marketing communications to users located in the EEA or UK with your prior consent, and you may withdraw your consent at any time by clicking the "unsubscribe" link found within RENEW emails. Please note you will continue to receive transactional messages related to our services, even if you unsubscribe from marketing emails.
  • Complain to a regulator. If you're based in the EEA or UK and think that we haven't complied with data protection laws, you have a right to lodge a complaint with your local supervisory authority.

Third Party Data Processors

As stated above, RENEW 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 which shall require that the service provider uses your personal information only for the provision of services to RENEW 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 UK Data Protection Act 2018 shall agree to be bound by and comply with RENEW’s standard third party data processing 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.

INTERNATIONAL TRANSFERS

We operate in, and have employees, offices, independent contractors and/or servers located in, the United States, Canada, India, Ethiopia and Uganda, and we may use cloud technology to store or 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 takes many steps to protect your privacy, including limiting access to your personal data among RENEW employees to specific, authorized employees located primarily in the United States and Canada who need to access your data to enable RENEW to provide services to you or for RENEW to comply with its contractual or legal obligations.

For EEA, Swiss or UK Users:

Where your information originates from within the EEA, Switzerland or UK, we will transfer your personal data outside the EEA, Switzerland or UK. By using the Site or submitting personal data to RENEW 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 operates that do not ensure adequate protection for personal data as determined by the European Commission or other applicable regulatory authority, and (2) onward transfers of your personal data to third-party service providers based in the United States on a “need-to-know” basis and in accordance with this Privacy Policy. Risks of such transfer outside the EEA, Switzerland or UK 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 your 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, India, Ethiopia and Uganda 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 employees worldwide to comply with this Privacy Policy and with RENEW’s internal privacy and data protection policies and procedures;
  • Limiting access to your personal data among RENEW employees to specific, authorized employees located primarily in the United States and Canada who need to access your data to enable RENEW to provide services to you or for RENEW to comply with its contractual or legal obligations.
  • For onward transfers to other service providers in the United States as described in this Privacy Policy, we may use specific contracts approved by the European Commission which give personal data the same protections it has in the EEA. For further details, 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 so do, 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 IAN, whether such members would reasonably expect that we would retain the data until their membership in the IAN 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 provides management and administrative services to its Investment Vehicles. In the normal course of the formation, operation and dissolution of the Investment Vehicles, RENEW 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’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’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 who require such access to provide services to RENEW, the Investment Vehicles and the Investors. RENEW will maintain physical, electronic, and procedural safeguards to guard private information about the Investors. In all events, RENEW 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 and all Investment Vehicles managed by RENEW.

Changes to this Privacy Policy

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

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

Contact Information

RENEW welcomes your questions or comments regarding this Privacy Policy.

If you believe that RENEW has not adhered to this Privacy Policy, please contact us at:

RENEW LLC
1031 33rd Street
Denver, Colorado 80205
Email Address: renew@renewstrategies.com
Attention: Chief Compliance Officer

This policy is effective as of November 4, 2020.


PREVENTION OF SEXUAL EXPLOITATION & ABUSE POLICY

We are committed to the prevention of and response to sexual exploitation and abuse.

RENEW will not tolerate harassment/sexual harassment of any applicant, employee or customer by a managing partner, fellow employee, or independent contractor on RENEW premises or at "on location" sites, nor will RENEW tolerate sexual exploitation and abuse of any member of the communities in which RENEW operates by any staff member, employee or independent contractor of RENEW or of our partners or portfolio companies.

Sexual harassment is defined as unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature when (1) submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment, (2) submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual or (3) such conduct has the purpose or effect of substantially interfering with an individual’s work performance or creating an intimidating, hostile, or offensive working environment.

Sexual harassment can take two distinct forms: “quid pro quo” and “hostile work environment.” Quid pro quo harassment occurs when submission to sexual conduct is made a condition of employment or employment benefits. Hostile work environment occurs when sexual conduct unreasonably interferes with an employee’s work performance or creates an intimidating, abusive or offensive work environment.

Sexual harassment includes verbal harassment, such as epithets, derogatory comments or slurs; physical harassment, such as assault, impeding or blocking movement, or any physical interference with normal work movement; and visual harassment, such as derogatory posters, cartoons, or drawings.

Sexual exploitation is defined as actual or attempted abuse of a position of vulnerability, power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another. Sexual abuse is defined as actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. All sexual activity with a child is considered as sexual abuse. Sexual exploitation and abuse are distinct from sexual harassment. Sexual exploitation and abuse occurs when a position of power is used for sexual purposes against a beneficiary (whether of RENEW’s products or services, or of RENEW’s partners or portfolio companies) or vulnerable member of the communities in which RENEW operates, whereas sexual harassment is directed against a colleague, employee or other person in the workplace.

In addition, RENEW will not tolerate harassment on other grounds, including race, color, national origin, religion, age, disability, and any other basis prohibited by applicable law. Harassment includes jokes, verbal abuse and epithets, degrading comments, the display of offensive objects and pictures, and other physical or verbal conduct that the individual might reasonably find to be offensive or that creates a hostile work environment.

In addition, supervisors are prohibited from dating employees who are employed in their immediate area of supervision or responsibility. Any supervisor who is involved in a relationship with a subordinate must report the relationship to the Operations Manager or a managing partner so that a reassignment of supervisory duties can be made. Employees who engage in personal relationships with co-workers should conduct themselves in a business-like manner and not engage in inappropriate physical contact while on RENEW premises or at “on location” sites.

REPORTING EXPLOITATION, HARASSMENT OR ABUSE

Any individual who believes that he/she has been subject to harassment/sexual harassment or sexual exploitation and abuse, or has reason to believe harassment/sexual harassment or sexual exploitation and abuse may be taking place towards other individuals, either within RENEW or externally in related organizations or settings (such as in our portfolio companies, Chigign Tobiya or other RENEW-led initiatives), whether or not it directly affects that individual, should report the circumstances as soon as possible to the Operations Manager or a managing partner. All complaints will be treated with confidentiality, to the extent possible given RENEW’s obligation to investigate and report to development partners, and no retaliatory or punitive action will be taken against an employee on account of filing a complaint in good faith.

In exceptional circumstances where a person has been discouraged from reporting to the Operations Manager or a managing partner or may fear retaliation impacting his job or well-being by reporting, reporting anonymously is possible via the following link: LINK. We note, however, that anonymous reporting can present fact-finding and verification challenges and be prone to abuse and may be subject to legal limitations. Typically, the most effective way to address a problem is by speaking first with the Operations Manager or a managing partner and allowing the individual to whom you report the incident to take the appropriate action.

When reporting an incident or series of incidents, please provide the following information (“Incident Information”):

  • All relevant facts related to the alleged event or circumstances
  • The name of the individual/s involved
  • The dates, times, location and frequency of the alleged events
  • If the circumstance requires immediate attention, please state this clearly and explain the reasons why
  • Describe documents, witnesses or other evidence available to support the allegations and the rules or laws that were violated

Incidents of alleged harassment/sexual harassment, or sexual exploitation and abuse, will be taken seriously by RENEW and will be promptly investigated by the Operations Manager and one or more managing partners of RENEW when such allegations are made. Investigations will include the review and collection of as much of Incident Information as is possible and appropriate in light of the seriousness, nature of allegations, and urgency of addressing the matter and reaching a resolution.

RETALIATION AND INTERMEDIATION PROHIBITED

Persons who feel that they are experiencing harassment or discrimination must feel free to come forward with complaints, and RENEW must be free to conduct a thorough investigation without any interference.

Accordingly, RENEW wants to make it clear that no one may retaliate or discriminate against a person for making a complaint or for participating in an investigation. Prohibited retaliation includes intimidation, coercion, harassment or negative acts or comments against a complainant. Reports of any type of conduct of this sort should be made to a managing partner.

TRAINING AND REMEDIAL MEASURES

RENEW’s policy on preventing harassment, sexual exploitation and abuse is incorporated in its employee handbook, which team members must review and affirm when they begin working with RENEW and annually. Trainings on this policy are conducted periodically, including with major updates to the policy.

The HR department will retain reports of harassment, exploitation and abuse and will analyze any trends that may emerge with respect to team members’ behavior and investigation outcomes. Appropriate corrective action, up to and including termination, will be taken if claims are determined to be true. Under certain circumstances, law enforcement officials may be notified and involved in addressing alleged events.


CONTACT US

If you have questions about our policies included on this page, please contact RENEW at renew@renewstrategies.com.