Riovic Capital (PTY) Limited ("Riovic") enables investors to invest in insurance businesses, and enables
insurance product developers to raise capital from a range of investors, all through its online platform. This Privacy Notice describes what information Riovic collects and how it is used, and applies to all services that Riovic offers and all persons that Riovic engages with. Throughout this Privacy Notice users of the
services and other persons with whom we interact will be referred to as "you", and Riovic Capital (PTY) Limited will be referred to as "Riovic", "we" or "us".
1. Information That We Collect
We collect information on you in the following ways, and treat all of this information as your "Personal Data":
Information you give us. When you use riovic.com and any of its sub-domains (the "Website"), we may ask you
to provide certain personal information, such as your contact details, banking details, tax information,
demographic information, employment and educational history and, in the case of entrepreneurs seeking to raise
capital through the Riovic platform, information about you in connection with your business. Much of this
information enables us to comply with our legal obligations or fulfill our contractual arrangements with you and
other parties, and sharing this information may be necessary for us to provide our services. Please note that,
in the case of entrepreneurs who provide us with customer data, it is your responsibility to ensure that you
have the appropriate grounds to do so, and that this is done in a secure manner.
Information we get from your use of our services. Riovic collects information about the services you use and how
you use them, such as when you view and interact with the Website or our advertisements. In addition, we may
gather certain information about you, including details of your operating system, browser version, domain name
and IP address, and the details of any website from which you accessed the Website. We may also collect your
Personal Data when you interact with our employees on the phone or in person and we record those conversations,
either because we are required to do so under regulation, or for training purposes so that we can improve our
Cookies. Riovic may set and access cookies on your computer, which are small files that reside on your
computer's hard drive that generally contain an anonymous unique identifier and are accessible only by the
website that placed them there and not any other sites. To the extent that we have third-party advertisements on
the Website, those third parties may also place, set and access cookies on your computer. They do this to track
how many unique users have seen a particular advertisement and to provide advertisements that are more relevant
to a given user's interests. We do not have access to these cookies and, other than allowing them to be served,
we play no role in these cookies at all. You can choose to enable or disable cookies in your web browser. By
default, your browser will accept cookies, but this can be altered. In addition, you may delete cookies that
have already been placed on your hard drive. For further details please consult the help menu in your browser.
Disabling or deleting cookies may prevent you from using the full range of services available on the Website.
Information from third parties or publicly available sources. We may also collect your Personal Data (such as
contact information or purchasing habits) from third parties or publicly available sources.
2. Data Protection Principles
Riovic is committed to protecting the privacy and security of your Personal Data. Riovic is a "data controller",
meaning that we are responsible for deciding how we hold and use your Personal Data. We will comply with data
protection law, which says that Personal Data must be:
Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is
incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
3. How We Use Information That We Collect
We use the Personal Data that we collect for the following purposes.
To comply with our legal or regulatory obligations, we may use your Personal Data (and if you do not provide this
Personal Data we may not be able to provide our services to you):
To confirm your identity in order to create your account and ensure that you are eligible to use the services
provided on the Website.
To conduct required anti-money laundering checks on you, and associated financial crime and fraud monitoring,
in connection with transactions you may conduct through the Website.
In the case of investors, to confirm that you are eligible to make investments through the Website in accordance
with relevant legislation.
To enable us to comply with our obligations as a regulated financial services business, including transaction
recording, updates on your investment and fundraising activity on the Website, other compliance
responsibilities, and reporting to regulators and governmental authorities.
To carry out our obligations under our contracts with you or others, we may use your Personal Data:
To process and administer payments and investments in connection with the services provided on the Website.
In the case of entrepreneurs seeking capital and certain individuals connected to the fundraising business, to
assess your suitability for and application to fundraise on the Website, to verify and approve the disclosures
you make in your vehicle to potential investors, to provide you with any vehicle marketing and PR services, to
facilitate the investment transactions, and exercise any rights that Riovic may have as nominee.
In the case of investors, to facilitate any investments you may make, to exercise any rights you may have in
connection with those investments including by Riovic as nominee, and to provide fundraising businesses with
information about the progress of their vehicles and your investments in their businesses.
In the case of investors who have completed investments in fundraising businesses, to provide those businesses
with information to fulfill obligations to you, and ensure compliance with their corporate or regulatory
requirements, such as tax and shareholder reporting.
In the case of investors who have been referred to Riovic by an independent financial advisor or wealth
manager, to share information that we hold about you with your financial advisor or wealth manager.
To provide you with information about your account, including any vehicles you have created and any investments
or payments you have made or have indicated an interest in making.
To facilitate the participation of you or your business in any supplemental programmes that Riovic may offer
such as the Alumni Club, Riovic Club and Anchor Investor Programme.
We have a legitimate interest in ensuring that the Website and our services operate effectively, and to do this
we may use your Personal Data:
To monitor, improve and administer the Website and the services provided on the Website.
To contact you to ensure customer satisfaction in respect of our role as a service provider and assist you in
getting the best value from our services.
To respond to customer support or other enquiries requesting information. We may also intercept, record and/or
monitor any communication(s) (including telephone calls or other electronic communications) between you and us.
We may do so in order to resolve queries in the future and for the purposes of ensuring security, staff training
and complying with our regulatory and legal responsibilities. In the case of communications by email you should
note that, as emails are not encrypted (and may therefore be intercepted by third parties) and as the identity
of the sender cannot be confirmed, you must NOT provide your security details by email.
We also have a legitimate interest in communicating with you and others, facilitating communications between you
and others, publicising our business, and making sure that marketing, advertising, PR, and content we provide is
effective, so we may use your Personal Data:
To enable us to conduct surveys and analysis, aggregate user profiles, and identify other potential customers.
To advertise, publicise and promote our business, and to measure, understand, or improve the effectiveness of
advertising we provide to you and others.
In the case of individuals or businesses that have indicated an interest in Riovic or the businesses fundraising
on the Website, to contact you to provide you with information about us or fundraising businesses, and on other
selected products and services that we think may be of interest to you (unless you have asked us not to do so).
To create and share informative content about our business or the industry in which we operate, including
contacting you about reports we publish and new products we launch.
In the case of our commercial and investment partners providing goods or services to investors or entrepreneurs,
to pass on information in relation to those goods or services.
In the case of journalists who are working in the sector in which we operate or related sectors, to provide you
with news and updates about our business, businesses that are fundraising on our Website and other relevant
In the case of referred investors, to inform the party that has referred you that you have joined Riovic.
In the case of investors who have completed investments in fundraising businesses, to enable those businesses
to contact you with news of developments in the business and keep you informed as to your investment.
In certain other circumstances we may seek your consent to use your Personal Data. In this case we will ask you to
confirm your agreement to your Personal Data being processed for a specific purpose, either through the Website of
by another means.
4. Accuracy and Retention of Personal Data
If you see that any of your Personal Data that is included in the "Profile" section of your Riovic account is
inaccurate, please revise or update it using the Website. Alternatively, if you believe that any of the Personal
Data we hold about you is inaccurate, you may notify us using the contact details below in order to correct it.
It is your responsibility to ensure that any Personal Data you have provided to us remains accurate and to notify
us (either through the Website or using the contact details below) if there are any changes in your Personal Data.
We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy
Notice, or otherwise required or permitted by law, whichever is the longer.
5. Information That We Share
Any Personal Data that we collect will not be disclosed to any third parties by Riovic and its affiliates, except
under the following circumstances:
We may disclose certain of your Personal Data to third party service providers solely in the course of their
provision of services to Riovic, and will take reasonable precautions to ensure that these service providers are
obliged to keep your Personal Data secure and confidential, in compliance with relevant legal requirements.
In some instances, your Personal Data may be transferred outside the European Economic Area; if this is the case
we will take steps to ensure that the transfer is protected by safeguards provided under EU and UK law, such as
model contract clauses or the EU-US Privacy Shield. For more information on these safeguards, please notify us
using the contact information provided in below.
We may disclose certain of your Personal Data if we, in good faith, believe that we are required to do so by
law, regulation or the order of court or other legitimate government body or arbitration panel. This includes,
among other things, any Personal Data that may be requested by HM Revenue & Customs and the Financial Conduct
We may tell you in one of the agreements that you enter into with us (for example the Membership Agreement that
you will enter into when signing up to the Website, the Engagement Letter and Campaign Terms & Conditions that
you will enter into when you wish to raise funds for your business, or the Investment Agreement that you will
enter into when making an investment) or otherwise on the Website that we will disclose certain of your Personal
Data in connection with a transaction you conduct through the Website. We may also tell you how we will use or
disclose your Personal Data when you provide information to us in certain other circumstances (for example if
we are collecting information about a potential fundraise on behalf of a fundraising business).
In the event that we intend to enter into a major corporate transaction, such as a sale of control of our or
another business on a stock exchange, we may disclose certain of your Personal Data to potential buyers,
underwriters or advisors. If we do this, we will take reasonable precautions to ensure that the recipients of
your Personal Data are obliged to keep it secure and confidential, in compliance with relevant legal
We may, from time to time, expand, reduce or sell our business, and this may involve the transfer of certain
divisions or the whole business to other parties. Your Personal Data will, where it is relevant to any division
so transferred, be transferred along with that division and the new owner or newly controlling party will, under
the terms of this Privacy Notice, be permitted to use your Personal Data for the purposes for which it was
supplied by you.
6. Your Rights
You may have the right to request the following actions regarding your Personal Data, which will be fulfilled in
accordance with applicable data protection law:
If you wish to raise an objection to the processing of your Personal Data or wish it to be deleted you may do so
by notifying us using the contact details below. It may be possible for us to restrict processing of your
Personal Data, or to delete it so long as we can still comply with our legal, regulatory and contractual
If you wish to object to direct marketing please notify us using the contact details below or, in the case of
emails, if you are a user of the Website you can go to the "Profile" section as set out above and you may also
use the 'unsubscribe' feature which you can find on our emails. To ensure that we respect your request we may
retain your contact details on a suppression list.
Where we have processed information with your consent then you may notify us using the contact details below to
withdraw that 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 information conducted in reliance on
lawful processing grounds other than consent.
If you would like to receive a portable copy of the Personal Data you have provided to us, please notify us
using the contact details below.
If you have created a Riovic account, you can see some of the Personal Data we hold about you in the "Profile"
section of your account. If you wish to see a copy of all of your Personal Data that we hold, please notify us
using the contact details below. A request for a copy of your Personal Data will generally be fulfilled free of
charge, but we may charge a reasonable fee if the request is manifestly unfounded, excessive, or repetitive, or
if you request multiple copies of the same information.
If you have concerns about how we collect and use your data, please contact us.
7. Security of Your Personal Data
We endeavour to take all reasonable steps to protect your Personal Data, including the use of encryption technology. We also require that all Riovic employees undergo
mandatory data protection training. However, we cannot guarantee the security of any Personal Data you disclose
online. In using the Website, you accept the inherent security implications of engaging in transactions online
over the internet, and you agree that you will not hold us responsible for any breach of security unless we have
been grossly negligent or in wilful default.
From time to time we may update this Privacy Notice. We will post any Privacy Notice changes on this page and, if
the changes are significant, we will provide a more prominent notice (such as a email notification of Privacy
10. Communicating With Us
If you with to make a notification to us, or have any questions about this Privacy Notice, you can reach us by
sending a letter to:
Data Protection Team
Riovic Capital (PTY) Limited
2 Merchant Place, 1 Fredman Drive
or by sending an email to email@example.com.