Privacy Policy

1. Policy Statement

Rhenium Capital, LLC is committed to protecting the privacy and confidentiality of personal information about its employees, customers, business partners, and other identifiable individuals. Our policies, guidelines, and actions support this commitment. Each employee bears a personal responsibility for complying with this policy in their role at Rhenium Capital, LLC.

2. Scope

This policy establishes the minimum standard for privacy protection at Rhenium Capital, LLC and applies to all employees and agents, regardless of jurisdiction. Supplemental policies may be developed as needed to meet specific legal or operational requirements.

3. Policy Details

3.1 Principles of Data Processing

Rhenium Capital, LLC is guided by the following principles in processing personal information:

• Notice
• Choice
• Accountability for onward transfer
• Security
• Data integrity and purpose limitation
• Access
• Recourse, enforcement, and liability

3.2 Notice

When collecting personal information, we strive to provide clear and appropriate notice regarding:

• The purposes for which data is collected and used.
• Third parties to whom the data may be disclosed.
• Choices available to individuals regarding the use and disclosure of their data.

3.3 Choice

Individuals may have choices regarding how their personal information is processed, including the ability to opt out of further processing. However, explicit consent is not required when processing personal information for:

• Purposes consistent with the original collection purpose.
• Transactional relationships.
• Legal compliance.
• Disclosures to agents or service providers.

3.4 Accountability for Onward Transfer

Rhenium Capital, LLC takes reasonable steps to ensure that:

• Personal information is transferred only for specified purposes.
• Agents and controllers uphold the same privacy protections.
• Unauthorized processing is stopped and remediated.

3.5 Security

We implement reasonable and appropriate measures to protect personal information from unauthorized access, loss, alteration, or destruction.

3.6 Data Integrity and Purpose Limitation

We process personal information in alignment with its intended purpose and take steps to ensure accuracy, reliability, and relevance.

3.7 Access

Individuals may request access to their personal information to correct, amend, or delete inaccuracies where legally permissible.

3.8 Recourse, Enforcement, and Liability

Violations of this policy by employees or contractors may result in disciplinary action, up to and including termination. Third-party violations may lead to contractual or legal remedies.

4. Purpose of Collecting and Using Personal Information

Rhenium Capital, LLC collects and processes personal information to support business operations, including but not limited to:

• Completing transactions and fulfilling service requests.
• Facilitating communication with business partners and customers.
• Marketing, selling, and delivering products or services.
• Billing and providing ongoing support.
• Conducting surveys for quality assurance and improvement.

Additionally, we collect and process human resources data to administer employment-related functions, such as compensation, benefits, performance management, and compliance with legal obligations.

5. Administration

5.1 Roles and Responsibilities

All employees, business unit heads, and legal representatives share responsibility for compliance with this policy. Specific personnel are assigned to enforce and monitor privacy protection.

5.2 Implementation

This policy may be supplemented by additional policies to address regional or functional data privacy requirements. Local laws will prevail where they impose stricter standards than this policy.

5.3 Interpretation

Where conflicts arise between this policy and supplemental policies, this policy prevails unless the supplemental policy offers stricter protections or is required by law.

6. Definitions

• Agent: Any third party collecting or processing personal information on behalf of Rhenium Capital, LLC.
• Controller: A person or entity that determines the purposes and means of processing personal information.
• Human Resources Data: Personal data relating to employees or prospective employees.
• Personal Information: Any data that identifies or can identify an individual, excluding anonymous or aggregated data.
• Processing: Any operation performed on personal information, including collection, storage, use, disclosure, or deletion.

For questions or concerns regarding this policy, please contact: