Rivers Capital Management Ltd. (“we”, “us”, “our”) is committed to protecting data it
receives about its investors, service providers and suppliers (“you”, “your”)
and complying with the General Data Protection Regulation (‘GDPR’).

We may obtain data directly from you in our role as investment manager for our portfolios.
We may also collect information about your usage of our Website as well as
information about you from e-mails, letters or any other correspondence between
you and us.

This notice sets out the basis by which Rivers collects, uses and discloses
your Personal Data, as well as your rights with respect to such Personal Data.


We may update this Privacy Notice from time to time and will publish an up to date
copy of the Privacy Notice from time to time on the Rivers Capital Management Website.


1.Contact Details of the Controller


When Rivers Capital Management receives information from you it is acting as data
controller under the GDPR. If you have any questions relating to your data or
how it is collected or processed, please address them using the contact details

Rivers Capital Management, 27 Gloucester Place, London, W1U 8HU


Najib El-Rayyes – Data protection registrar

2.What Personal Data we hold on you


Please see below for a summary of the personal data we may collect and use about you for compliance and contact purposes only.


of Information


note these examples are merely for guidance and not exhaustive.

about you:

address, nationality, contact information, identity verification documents, information
relating to tax residency status, and preferred language, IP addresses, job
title, place of employment.

to contact you at work:

address, telephone, and e-mail addresses.

to identify you:

passport and/or driving license details, electronic signatures.

about your suitability to invest in Rivers Portfolios:

of funds, employment status, investment objectives,


of Shareholders of Institution


amount of investment

on investment portfolio – current and historical


3.Why do we need to collect and use your personal information?


As part of its role as investment manager to its funds and to facilitate day to
day business communications, Rivers Capital Management Ltd. may process your
data in the manner described below:


for which we need your personal information:


note these examples are merely for guidance and not exhaustive.

for Processing

with you

·       When
you email Rivers, your contact information will be stored within our email

·  To
ensure we can remain contact with you for business to business contact as a
legitimate interest to the business 

Onboarding Procedures

·       To
assess your suitability to invest in Rivers Portfolios;

·       To
fulfil our internal ‘Know Your Customer’ procedures;

·       To
ensure that no conflicts exist;

·       To
ensure that Anti-Money Laundering checks are completed.

·  As
a regulated entity Rivers has a legal obligation to ensure
that is only communicates with professional investors about its Funds. As
such we require certain personal data as detailed above from you to fulfil
this obligation.


·       To
distribute marketing materials such as; factsheets, presentations etc;

·       To
invite investors to meetings and webinars;

·       To
respond to enquires or investor requests for further information.

·  In
order to inform our investors of our Funds and to ensure we are treating our
customer fairly we process contact information to in order that investors in
our funds receive relevant updates relating to their investments.

legal obligations

·       To
comply with our legal obligations;

·       To
ensure that the information being sent is being sent to the correct

·  Rivers
Capital Management is subject to regulation in the UK and as such we may
require your data to ensure we are in compliance with regulation from the FCA
from time to time.


For any queries regarding the specific legal obligations Rivers Capital Management
Ltd. is required to comply with while processing your data, please contact the
Compliance Department.

The processing of the majority of information referred to in this privacy
policy is required by us to carry out our duty or to carry out our obligations
to you. You are therefore requested to provide Rivers with the relevant information.
If you do not provide the information requested, this may lead to us not being
able carry out our responsibilities towards your investment, such as providing
you with updates on our portfolios.


4. How long we keep your data for?


We will not keep your data for longer than is required to fulfil our obligations
in section 3. 

Where we are required to collect your personal data to comply with a legal
obligation in relation to an investment in one of Rivers Capital Management Ltd.
portfolios, we may be required to retain such data for 7 years following the
end of your investment, or longer if the relevant regulatory authority


5.Transfers of Data to Third Countries


All the personal data we process is processed by us in the UK, however, for the
purposes of IT hosting and maintenance, emails containing personal data may be
located on servers based in a foreign territory. In order to ensure safeguards
in relation to this hosting, we maintain administrative, technical and
contractual safeguards designed to protect personal information we obtain
directly from you against accidental, unlawful or unauthorized destruction,
loss, alteration, access, disclosure or use. 


6. How do we protect your personal information?


We have security arrangements in place to guard against unauthorised access,
improper use, alteration, destruction or accidental loss of your personal

We take appropriate organisational and technical security measures and have rules
and procedures in place to ensure that any personal information we hold on
computer systems is not accessed by anyone it shouldn’t be. When we use third
party organisations to process information on our behalf we ask them to
demonstrate their compliance with our security requirements, and any
instructions we may give them and their compliance with relevant data
protection legislation throughout the time they work for Rivers. These
organisations take their instructions from us and their obligations with regard
to what information they process and what they can do with it are agreed in the
contracts we have with them.


7. Your Rights


You are entitled to exercise certain rights in relation to your data as of 25 May
2018. These rights may be subject to statutory restrictions, where they are
applicable. The rights include:

The right to access your data;

The right to rectify any errors in your data;

The right, in certain circumstances, to erase your

The right to restrict the processing of your data;

The right, in certain circumstances, to object to
your data being processed;

The right to withdraw consent; and

The right to complain


Where data is provided by you on the basis of consent, you are within your rights to
withdraw that consent at any time. Withdrawal of consent may result in benefits
that were otherwise provided to you being withdrawn.


Please note that where your personal data is processed for the purposes of our legitimate
interests, you have a right to object to such processing and Rivers and its
appointed service providers will no longer process the personal data until it
can be demonstrated that we have compelling legitimate grounds for the
processing which override your interests, rights and freedoms or for the
establishment, exercise or defence of legal claims.


The Information Commissioners Officer (‘ICO’) is the supervisory authority in the
UK for data protection.  You may contact them should you have a complaint
to make regarding the treatment of your personal data.


Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

0303 123 1113




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