Bermuda Privacy Policy

Renaissance Technologies LLC and its affiliates (together, "Renaissance") are committed to protecting your privacy and maintaining the confidentiality and security of your personal information. This policy (the "Bermuda Privacy Policy") explains the manner in which Renaissance uses your personal information. This Bermuda Privacy Policy applies to individuals whose personal information Renaissance uses and who are individual investors or individuals linked to investors (each, an "Investor") in any private investment fund sponsored by Renaissance (each, a "Renaissance Fund") that is a Bermuda Exempted Limited Partnership. It does not apply to Investors in any non-Bermuda domiciled Renaissance Fund regardless of the location of the Investor.

When we say "you," we mean you or any individual whose personal information you provide. Before you provide information about an individual connected to your business to Renaissance, you must make sure that you have a lawful purpose or the agreement of the relevant individual. You must also make sure the individual has been provided with this notice, which explains the way in which the individual's information will be processed and the individual's rights in relation to that information.

Reference to "using" personal information means collecting, obtaining, recording, holding, storing, organizing, adapting, altering, retrieving, transferring, consulting, disclosing, disseminating, or otherwise making available, combining, blocking, erasing, or destroying your personal information.

By "personal information," the reference is to any information from which an individual could be identified, directly or indirectly, by itself or when combined with other information or context.

Renaissance is committed to protecting and respecting your personal information and complying with all applicable data protection laws and regulations in each jurisdiction from which Renaissance operates, including Bermuda's Personal Information Protection Act 2016 ("PIPA").

How We Collect Personal Information

Renaissance collects information from the following sources:

  • from you, or from others who provide information on your behalf, in relation to your investment with Renaissance in account applications, subscription agreements, and other forms;
  • from third parties as permitted by law, such as Renaissance affiliates and service providers (which may include, e.g., attorneys, accountants, auditors, administrators, or other professionals);
  • from (i) credit reporting agencies, (ii) sanctions screening databases, or (iii) sources designed to detect and prevent fraud;
  • from public sources including registers, tax authorities, governmental agencies and departments, and regulatory authorities.

Information We Collect

Personal information we collect may include the following:

  1. name, email address, phone number, job title, social security number, birth date, photo ID, country of residence and nationality, or national and governmental identification information;
  2. sensitive personal information, defined under PIPA to include an individual's place of origin, national or ethnic origin, sex, marital status, or family status;
  3. commercial and financial information, including records of products or services purchased, obtained, or considered or other purchasing histories or tendencies, including funds invested, investments considered, or sources of funds or wealth;
  4. internet or other electronic network activity information, including interactions with Renaissance's website or use of certain online tools;
  5. professional or employment-related information, including occupation, compensation, employer, and title;
  6. inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information, including your potential interest in investing in Renaissance Funds.

Renaissance will not collect categories of personal information other than those categories listed above. If Renaissance intends to collect additional categories of personal information, it will provide you with a new notice at or before the time of collection.

The Purposes For Which We Collect Your Personal Information

We collect your personal information for the following purposes:

  • to deliver the information, products, or services you requested from Renaissance;
  • to perform services on your behalf, including maintaining or servicing accounts, providing investor relations services, processing subscriptions and redemptions, or providing similar services;
  • to communicate with you about Renaissance's products and services;
  • to carry out Renaissance's obligations and enforce its rights;
  • to detect, prevent, and report security incidents and protect against malicious, deceptive, fraudulent, or illegal activity;
  • to enable or effect commercial transactions, including using bank account details to remit funds and process distributions;
  • in any other way Renaissance describes when you provide the information or otherwise at your direction or with your consent;
  • as permitted by law or as Renaissance may notify you.

Disclosure Of Information

We may disclose personal information to the following third parties:

  • business partners with whom we work;
  • service providers and third parties that access personal information in order to perform functions on our behalf;
  • third parties you have consented to our sharing data with;
  • local or overseas bodies or authorities such as legal, regulatory, law enforcement, government, and tax authorities;
  • any third party to whom we may transfer our business, policies, or assets so it can evaluate our business and use your data after any transfer, merger, or acquisition, as long as such party has agreed to keep your data confidential;
  • professional advisers when necessary to obtain advice or otherwise protect and manage our business interests;
  • our current and future parents, affiliates, and subsidiaries.

Transfer Of Information To Other Jurisdictions

Renaissance may transfer your information to other jurisdictions. Before we do so, we will always assess the level of protection offered by that jurisdiction and whether it offers protection comparable to that of PIPA. When the level of protection is not comparable, Renaissance will seek to ensure adequate controls are in place to protect your personal information.

Retention Of Information

We will retain personal information for only as long as required to satisfy the above-stated purposes for which we use personal information. This may include a time period after the business relationship ends, for example for the purposes of satisfying any legal, regulatory, commercial, accounting, or reporting requirements.

To decide on the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your Rights

You have the following rights in relation to your personal information:

  • Access: You can request access to your personal information, including to receive a copy of your personal information and an explanation as to why we use your personal information and to whom it has been disclosed.
  • Correction: If you believe your personal information is incorrect, you can ask us to correct it.
  • Marketing: You can request that we do not, or do not continue to, market our services to you.
  • Erasure: You can ask us to erase, delete, or destroy your personal information.

We may charge a fee for the above, but it will be at a reasonable level.

If you want to exercise any of these rights, please contact us using the contact information below and submit the request in writing.

We note that when Renaissance makes a good faith determination that requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may refuse to act on the request. We also will need to retain personal information as required by law or regulatory requirements.

Further Information

Renaissance reserves the right to change this Bermuda Privacy Policy from time to time, and any such change will be effective upon posting of the revised policy. Your continued use of the website or your continued contact with Renaissance following Renaissance's posting of any revised Bermuda Privacy Policy will constitute your acknowledgment of the amended policy.

Contact Us

Renaissance's Privacy Officer is Teresa Sachs.

All inquiries regarding this Bermuda Privacy Policy should be directed to Investor Relations by telephone to (212) 829-4491 or by email to ir@rentec.com.

Last Updated January 24, 2025