Effective January 1, 2023
“Republic Asia”, “we” or “us” means Republic Asia Advisors LLC, any of its affiliates, any other entities under common control, and funds sponsored by Republic Asia.
We provide information on the types of Personal Data we collect, how we use that information, with whom we may share it with and the choices available to you regarding our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices.
This policy contains the following sections:
- Scope and Applicability
- Information We Collect and Receive
- Our Uses of Personal Information
- How We Share Information
- Communications and Marketing
- Data Retention and Disposal
- Cookies and Other Identifiers
- General Data Protection Regulation and International Transfers
- California Residents
- Your Privacy Preferences
- Links to Other Websites
- Children’s Data
- Information Security
- Breach Notification
- General Inquiries and Updates
1. Scope and Applicability
2. Information We Collect and Receive
Registered Users—Registered Users are persons who sign up and create a user account with us via the Republic Asia Platform. We may collect the following Personal Information from Registered Users:
- Your name;
- Your email address;
- Your username;
- Your password(s);
- Your address or geographic location; and
Investors-In connection with your investments, you may provide us or our third-party fund administrators: login credentials; financial information (such as banking information and an account number); taxpayer ID number; jurisdiction of tax residence; date of birth; and certain investment-related information.
Depending on the nature of our relationship with you, in the past 12 months we may have collected Personal Data concerning you in the following categories:
- Identifiers (e.g., real name, postal address, email address, government ID, financial information);
- Sensitive/protected characteristic information (e.g., age, race, citizenship, gender);
- Commercial information (e.g., products or services purchased, obtained, or considered, personal information disclosed in a sale or acquisition process);
- Internet or other network activity (e.g., browsing or search history, information regarding interaction with an internet website, application, or advertisement);
- Geolocation data (e.g., physical location);
- Professional or employment-related information; and
- Inferences drawn from other personal information (e.g., profiles reflecting preferences and trends).
Republic Asia Platform Visitors—Platform visitors are individuals who access or interact with the Republic Asia Platform. We may collect or receive the following information about Republic Asia Platform Visitors:
- Log Data: information collected by our servers when you access our websites, including IP addresses, referral URLs, browser type and settings, date and time of usage, language preferences, and cookie data.
- Device Data: information about your device, including the type of device, the operating system, application IDs, unique device identifiers, and crash data.
- Analytics Data: approximate geolocation based on your IP address and other information from your browser and device.
- Contact information: Your name, phone number, email and mailing address, if you engage with us through our contact methods.
- Other Webform Data: information collected when you engage with us through our webforms, surveys and questionnaires, blogs, discussion forums, or live chat.
3. Our Uses of Personal Information
We use Investor and Issuer Information to:
- Verify your identity and status with respect to securities and other laws;
- Facilitate your payment and any escrow of funds;
- Provide you with necessary tax reporting information; and
- For other purposes for which we provide specific notice at the time of collection of the information.
We use Republic Asia Platform Visitor Information to:
- Communicate with you and respond to your inquiries;
- Operate and secure our website and Services; and
- Analyze and improve our website and Services.
Lawful Basis for Processing. Depending on your circumstances and your relationship with us, we may process your Personal Information on the following lawful bases:
- Consent: where you have given consent to the processing of his or her Personal Information for one or more specific purposes;
- Contract: where the processing is necessary for the performance of a contract with you (e.g., to deliver the service you have requested);
- Legal Obligation: where processing is necessary for compliance with a legal obligation to which the controller is subject (e.g., for compliance with securities laws); and
- Legitimate Interests: where the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, not overridden by the interests or fundamental rights and freedoms of the data subject, (e.g., for product development and analytics purposes).
4. How We Share Information
Republic Asia shares and discloses Personal Information to other parties as needed to provide our Services and operate our business. The categories of other parties with whom we may share information include:
The Republic Family of Companies - Affiliates and Subsidiaries. Republic may share Personal Information about you with affiliates and subsidiaries.
Service Providers. We may share the information that you have provided us with certain third party services, including payment processors, web services providers, developers, security and storage service providers, analytics service providers, and providers used to analyze our websites’ and applications’ functionalities.
Business Services. We may share any category of Personal Information with our business services providers in the operation of our business and facilitation of the Services, including agents, auditors, financial institutions, and professional advisors.
Corporate Activities. We may share any category of Personal Information with other companies or entities as part of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock. In such case your Personal Information may be transferred to the potential or actual acquirer, successor, or assign.
Government and Legal. We may share any category of Personal Information with other parties, including public authorities, as may be required by applicable law, regulation, or legal process.
5. Communications and Marketing
When you sign up for our Services, we will send periodic emails to you regarding the Services or tell you about new Services we believe will be of interest to you; generally, such notices will specify which member of Republic has sent it to you. You may also subscribe to our blog and newsletter or sign up to hear about investing opportunities. You can also opt out of promotional or marketing email communications, including affiliate marketing, by clicking on the unsubscribe link in any email you receive from us, or by contacting us at firstname.lastname@example.org. Please note: Opting out will not unsubscribe you from important communications regarding your Republic Asia Platform account, security related matters or those notices requited by applicable law.
6. Data Retention and Disposal
Republic Asia retains Personal Information in accordance with its data retention polices consistent with applicable law. Certain Personal Information subject to record retention requirements may be retained for at least 7 years for legal and compliance purposes, as well as with respect to relevant statutes of limitations.
We will retain your information in line with our retention policies and, in any event, for no longer than is necessary given the purpose for which it was collected, after which it will be deleted or anonymized.
Note that we may retain some limited information about you (even when we know that you have left the organization that you represent) so that we can maintain a continuous relationship with you if and when we are in contact with you again.
7. Cookies and Other Identifiers
8. General Data Protection Regulation and International Transfers
International Transfers. Republic Asia is based in the United States and your Personal Information may be collected and processed in the United States. Republic has affiliates outside of the United States. If transferred, data is transferred subject to appropriate transfer mechanisms and safeguards.
Privacy Rights of UK, EU/EEA, and Swiss Data Subjects. If you are a located in the UK, EU/EEA, or Switzerland, subject to certain limitations, you have the following data protection rights:
- Withdrawal of Consent. If processing is on the basis of consent, you have the right to withdraw consent to the processing at any time.
- Access and Rectification. You have the right to access, correct, and update your Personal Information.
- Deletion/Erasure. You have the “right to be forgotten” through the erasure or deletion of your Personal Information.
- Portability. You may have the right to move, copy, and/or transfer certain Personal Information from our service to another service.
- Stop Processing. If processing is on the basis of legitimate interests, you have the right to object to the processing of your Personal Information and to ask us to restrict the processing of your Personal Information, subject to certain limitations.
- Submit a Complaint. You have the right to submit a complaint to a data protection authority about our collection and use of your Personal Information. Contact details for the UK data protection authorities is located here, for the EU/EEA here, and for Switzerland here.
You may exercise many of your rights through your account or by submitting a request to our Data Protection Officer at email@example.com. We will process verified data subject requests within 30 days. If we require more time, we will inform you of the reason and extension period in writing. Please note that requests are subject to appropriate verification before processing.
9. California Residents
Privacy Rights of California Residents. If you are a California resident, under the California Consumer Privacy Act (“CCPA”) and its successor, the California Privacy Rights Act (“CPRA”) you have additional rights regarding your Personal Information. Subject to certain limitations, your rights include:
- Right to Know. You have the right to know and see what Personal Information Republic has collected about you over the preceding 12 months, including:
- the categories of Personal Information Republic has collected about you;
- the categories of sources from which Personal Information is collected;
- the purposes for collecting your Personal Information in accordance with the Services;
- the commercial purposes for collecting your Personal Information;
- the categories of third parties with whom Republic Asia has shared your Personal Information; and
- the specific pieces of Personal Information Republic Asia has collected about you.
- Right to Deletion. You have the right to request that Republic Asia delete the Personal Information we have collected from you. However, there are exceptions under which we may retain your Personal Information and where we are not required to delete your Personal Information.
- Right to Correction. You have the right to request that Republic Asia correct the Personal Information collected from you.
- Right to Portability. You may have the right to request that we transfer certain Personal Information to another entity, subject to certain exceptions.
- Right to Opt-Out of the Sale or Sharing of Personal Information.We do not “sell” or “share” Personal Information as defined by the CCPA or the CPRA. You have the right to opt out of any processing for purposes of cross-context behavioral advertising, targeted advertising or profiling in connection with decisions that produce legal or similarly significant effects, if applicable.
- Right to Opt-Out of Automated Decision-Making. You have the right to opt out of automated decision-making, if applicable.
- Right to Opt-Out of the Use and Disclosure of Sensitive Personal Information. If we collect sensitive Personal Information, we will restrict its use to what is necessary to perform the Services requested by you.
- Right to be free from discrimination. You have the right to be free from discrimination for exercising your rights under the CCPA/CPRA.
If you are a California resident and would like to exercise your rights in accordance with the CCPA, you may contact Republic Asia using any of the following methods:
- Via email at firstname.lastname@example.org;
- Or via our toll-free California Personal Information Privacy Line at (800) 634-0599.
We will process a verified California consumer privacy request within 45 days of receiving the request. If we require more time, we will inform you of the reason and extension period in writing. Please note that requests are subject to appropriate verification before processing.
10. Your Privacy Preferences
Republic Asia may provide you the opportunity to exercise certain preferences with respect to your Personal Information, such as accessing, updating, deleting, and exporting Personal Information, by logging into your account or by making a request to:email@example.com. Republic Asia may, in its discretion, process such requests as a courtesy, subject to appropriate prior verification.
11. Links to Other Websites
Our website may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked websites may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites are not owned or controlled by us, we are not responsible for their content, any use of the websites, or the privacy practices of the websites.
12. Children’s Data
Republic Asia recognizes the sensitivity of Personal Information concerning children under the age of majority (“Minors”). Our websites and Services are not marketed to Minors and we do not knowingly solicit or collect Personal Information from Minors. If you believe that a Minor has disclosed Personal Information to us, please notify us immediately at firstname.lastname@example.org.
13. Information Security
We take reasonable measures to protect our systems from harm and to safeguard the confidentiality, integrity, and availability of your Personal Information. Our efforts include implementing appropriate physical, technical, and administrative controls to ensure a level of security commensurate with the risk, in particular, to protect against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information transmitted, stored, or otherwise processed.
14. Breach Notification
If your Personal Information is the subject of a data breach under applicable law or regulation, we will take appropriate action, including providing you with notice, as such law or regulations may require.
15. General Inquiries and Updates
149 5th Avenue
New York, NY 10010
Attn: Privacy Compliance