Privacy Policy

This UK Privacy Policy is issued by Revantage Global Services UK Ltd, a private limited company formed under the laws of England and Wales whose registered company number is 10866974 and whose registered office is at 12 St. James’s Square, London, United Kingdom, SW1Y 4LB and Revantage Real Estate UK Ltd, a private limited company formed under the laws of England and Wales whose registered company number is 12499910 and whose registered office is at 12 St. James’s Square, London, United Kingdom, SW1Y 4LB. Both parties are independent data controllers (i.e. the organisation which determines why and how to process Personal Data) within the meaning of the Data Protection Legislation. The Revantage UK entity that you are interacting with is the controller for the purposes of this Privacy Policy.

1.   Definitions

The terms and expressions in capital letters used in the UK Privacy Policy have the meanings set forth below. Words in singular include the plural and vice versa. These terms and expressions shall always be interpreted according to applicable data protection rules including, but not limited to, the UK General Data Protection Regulation (2016/679) and the Data Protection Act 2018 as may be amended, replaced or re-enacted (the “Data Protection Legislation”).

“Data Subjects”: means natural persons whose personal data is being processed by Revantage UK.

“Personal Data”: means any information allowing the direct or indirect identification of an individual either on its own or when combined with other information available to Revantage UK.

“Processing”: means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Revantage Group”: means Revantage Global Services Europe S.à r.l., Revantage Global Services UK Ltd, Revantage Real Estate Ltd, Revantage Global Services TCC Ltd, Revantage Europe Netherlands BV, Revantage Global Services Asia PTE Ltd, Revantage Corporate Services LLC and all concerned entities and affiliates, jointly referred hereinafter to as “we“, “our” or “us.

“Technical and Organizational Security Measures”: means measures aimed at protecting Personal Data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, in particular where the processing involves the transmission of Personal Data over a network, and against all other unlawful forms of processing.

2.   Collection and Processing of Personal Data

When does Revantage UK collect your Personal Data?

Revantage UK collects, stores and otherwise processes Personal Data relating to Data Subjects having interactions with Revantage UK in accordance with Data Protection Legislation. Data Subjects may include, but are not limited to, the following categories of individuals:

• Individual shareholders/investors/business or asset owners (as well as individuals linked to investors/shareholders/business or asset owners being entities), individual beneficial owners, board members, signatories, contact persons, representatives, and any other individuals involved or being a part of the Revantage Group’s business.
• Representatives, employees, contact persons and any other individuals related to the Revantage Group’s service providers.
• Any other individual having or who had interactions with a member of the Revantage Group.

Individuals under an employment, student or trainee contract with Revantage UK, job applicants and individual consultants do not fall within the scope of this UK Privacy Policy and are covered under Revantage UK’s Human Resources Privacy Policy.

Legal basis for the processing of Personal Data

We will only process your Personal Data where we have a lawful reason for doing so. The lawful basis for the processing of Personal Data performed by us will always be at least one of the following:

1. Consent: you have given clear consent for us to process your Personal Data for a specific purpose;
2. Contract: the processing is necessary for the performance of a contract you are a party to or in order to take steps at your request prior to you entering into a contract;
3. Legal obligation: the processing is necessary for us to comply with applicable laws;
4. Vital interests: in very rare circumstances where the processing is necessary to protect someone’s life;
5. Public task: the processing is necessary for us to perform a task in the public interest or for our official functions (and the task or function has a clear basis in law);
6. Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party (for instance for Revantage UK to carry out its daily activities, create statistics and tests, manage risk litigation (including disputes and collections), accounting, audits, tax returns etc) unless there is a good reason to protect your personal data which overrides those legitimate interests.

No automated decisions will be made in relation to the Personal Data processed.

Update of Personal Data

We will endeavour to keep the Personal Data in our possession or control accurate. Data Subjects providing Personal Data to us are however responsible for promptly informing us of any change to their Personal Data and making use of any relevant self-serve systems to update their own Personal Data regularly.

Do you have to provide your Personal Data to Revantage UK?

It is important that you are aware that not providing us with some specific Personal Data may unfortunately prevent Revantage Europe from interacting with you, from entering into an agreement or maintaining the related ongoing agreement with you.

• We will only use your personal data where the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• Where we need to process your Personal Data by law, or under the terms of a contract we are entering into with you or have already entered into with you, and you fail to provide that data when requested, we may not be able to enter into or perform the contract to provide you with our services. In this case we may have to cancel a service you have with us but will notify you if this is the case at the time.

If we already hold some of the Personal Data that we need, for instance if you are already an associated third party, we may not need to collect some or all of your Personal Data again. In cases where providing personal information is optional, we will make this clear.

Types of Personal Data and purposes of the processing

We aim to be transparent about what we process and why. For further information on our processing activities please review the relevant sections below:

• Shareholders/investors/business or asset owners being individuals and individuals associated with shareholders/investors/business or asset owners being entities:
  • How is the Personal Data collected?
    • Directly from Data Subjects (such as or where they interact with us regarding our services, on our website or any other interaction with the Data Subject);
    • From other members of the Revantage Group;
    • From third parties;
    • From public sources (such as when we use specific tools for Anti Money Laundering (“AML”)/Know your customer (“KYC”) checks).
  • What types of Personal Data are collected?
    • Identification data (such as name, date and place of birth, gender);
    • Private and business contact details (such as phone and fax numbers, home and professional address, email address, country of (tax) residence);
    • Other relevant personal details (such as nationality, citizenship, marital status, mandates);
    • Government identification numbers (social security numbers, tax number, copy of ID card or passport);
    • Images of passport, signatures;
    • KYC related information;
    • Criminal records or history when required and in accordance with applicable laws;
    • Financial details (billing address, bank account numbers, transaction and counterparty details, amount of shares owned);
    • Any other Personal Data related to the conduct of Revantage UK’s business towards and/or with shareholders, investors, owners, etc.

• • How is the Personal Data used?
    • To administer and manage our contractual relationship, for the performance of our business, to manage ongoing deals, to communicate with you;
    • For AML/KYC purposes: fulfilling our regulatory compliance obligations, including KYC checks and confirming and verifying your identity and screening against government bodies, supranational bodies (including but not limited to the United Kingdom) and/or law enforcement agency sanctions lists as well as internal sanctions lists and other legal restrictions;
    • For financial and billing management;
    • For fraud prevention: detecting, preventing and investigating fraud;
    • For investigation: detecting, investigating and preventing breaches of policy.

• Business contacts: The Personal Data of business contacts that are not otherwise shareholders/investors/business or asset owners or suppliers of Revantage UK can be collected and stored by Revantage UK.

• • How is the Personal Data collected?
    • Directly from Data Subjects (such as when you provide us with business cards or interact with us in any other way including via our website);
    • From other members of the Revantage Group;
    • From third parties;
    • From public sources.

• • What types of Personal Data are used?
    • Identification data (such as name);
    • Business contact information (such as professional phone number, email address, professional address);
    • Other relevant professional details (such as nationality, preferred language, job title, function within a company);
    • Any other Personal Data related to the conduct of Revantage UK’s business.

• • How is the Personal Data Used?
    • For contact and communication purposes:
    • In order to make your contact details available to our employees and other members of Revantage UK (such as to allow them to accomplish their daily work and contacting you when required by you or when necessary);
    • In order to perform analytics (such as trends, sales intelligence, marketing effectiveness, uptake and progress).

• Suppliers including individual contractors:
  • How is personal data collected?
    • From our suppliers being individuals or from individuals related to our suppliers (employees, persons of contacts) and from individual contractors;
    • From other members of the Revantage Group;
    • Directly from Data Subjects;
    • From third parties (such as when a supplier being an entity provides us with the contact details of one of its employees).
  • What types of Personal Data are used?
    • Identification data (such as name);
    • Business contact information (such as phone number, email address, professional address);
    • Other relevant professional details (such as job title, function within a company);
    • Types of services provided to Revantage UK;
    • Any other Personal Data related to the management by Revantage Europe of its suppliers.
  • How is the Personal Data used?
    • For the entry into and the performance and management of the contractual relationship with our suppliers.
    • For administration and billing purposes (such as to agree on payment arrangements with our suppliers and to make payments to them).

We do not routinely collect or otherwise process any Special Categories of Personal Data, (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data), or information about criminal convictions and offences except where:

• the processing is necessary for compliance with a legal obligation (such as for AML/KYC purposes with information on criminal convictions);
• the processing is necessary for the detection or prevention of crime (including the prevention of fraud) to the extent permitted by applicable law;
• the processing is necessary for the establishment, exercise or defence of legal rights; or
• we have, in accordance with applicable law, obtained your explicit consent prior to processing such Personal Data.

Such Personal Data will be processed in accordance with applicable Data Protection Legislation and will be subject to appropriate technical and organisational security measures.

3.   Disclosure of Personal Data

Personal Data will not be shared with third parties, except as provided below.

To achieve the above-listed purposes, we may disclose Personal Data to the following recipients:

• Other entities within the Revantage Group;
• Professional advisors such as accountants, auditors, financial and tax advisors, lawyers, notaries and other outside professional advisors to Revantage UK, subject to binding contractual obligations of confidentiality;
• Anti-fraud services;
• Governmental, legal, tax and regulatory or similar authorities, ombudsmen, and central and/or local government agencies, upon request or where required;
• Official registers (when required by law);
• Banks, non-bank lenders, company administrators, trade and corporate registries and depositaries;
• General partners of funds;
• Debt-collection agencies and tracing agencies;
• Accreditation bodies;
• Third party processors; and
• Any relevant party, claimant, complainant, enquirer, law enforcement agency or court, to the extent necessary and as permitted under applicable law.

If we engage a third-party processor to process your Personal Data, the processor will be subject to binding contractual obligations to: (i) only process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data, together with any additional requirements under applicable law.

In such circumstances, Revantage UK ensures that Personal Data is kept secure from unauthorised access and disclosure.

Transfer of Personal Data

Because of the international nature of our business, we may need to transfer your Personal Data within the Revantage Group and to external third parties as mentioned above, in connection with the purposes set out in this UK Privacy Policy.

For this reason, we may transfer your Personal Data to recipients located outside the UK. Whenever we transfer your Personal Data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• The country to which the Personal Data is being transferred has been deemed, by the UK Government, to provide an adequate level of protection for Personal Data.
• We will enter into specific contracts approved for use by the UK government which give Personal Data the same protection it has in the UK.
• The transfer is otherwise authorized under the Data Protection Legislation, as the case may be, as such transfer is necessary for the performance or execution of a contract concluded in the Data Subject’s interest or for the establishment, exercise or defence of legal claims or for the performance of a contract between the Data Subject and us.

The Data Subject may obtain more information on the specific mechanism used by us when transferring your Personal Data out of the UK by contacting us at dataprivacy@revantage.eu.

4.   Data Subjects’ Rights in Relation to the Processing of their Personal Data

Rights granted to Data Subjects.

• Where our processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing your personal data for that purpose, unless there is another lawful basis we can rely on – in which case, we will let you know. Your withdrawal of your consent won’t impact any of our processing up to that point.
• Where our processing of your personal data is necessary for our legitimate interests, you can object to this processing at any time. If you do this, we will need to show either a compelling reason why our processing should continue, which overrides your interests, rights and freedoms or that the processing is necessary for us to establish, exercise or defend a legal claim.

In accordance with applicable law, Data Subjects have certain other legal rights depending on relevant circumstances, which are briefly summarised below, in relation to any Personal Data which we hold:

• the right to be informed about the collection and use of their Personal Data;
• the right to request access to their Personal Data stored by Revantage UK;
• the right to update or correct any of their Personal Data, if the Personal Data is incorrect or incomplete;
• the right to request from Revantage UK; the erasure of their Personal Data, to the extent such Personal Data (i) are no longer necessary in relation to the initial purpose(s) for which they were collected; (ii) consent, where applicable, has been withdrawn and there is no other means of legitimating the processing of Personal Data; (iii) the Data Subject objects to the processing of the Personal Data; and (iv) the Personal Data is unlawfully processed;
• the right to request the restriction of the processing of Personal Data, if such Personal Data is found to be inaccurate or unlawful, is no longer needed for the purposes of the processing, or should a court decision on a complaint lodged by a Data Subject be pending;
• the right to data portability;
• the right to object to the processing of their Personal Data, on grounds related to their particular situation;
• rights in relation to automated decision making and profiling.

Revantage UK will deal with your request as quickly as possible and in line with the statutory deadlines which apply. In some cases, it may be appropriate to carry out identity verification checks and / or request further information before being able to process your request and we will let you know where this applies.

How to exercise such rights

You can exercise the rights mentioned above or challenge compliance with this UK Privacy Policy by contacting Revantage UK at dataprivacy@revantage.eu.

You also have the right to complain to the Information Commissioner’s Office, who regulates data protection in the UK. You can make a complaint in writing to the ICO, Wycliffe House, Water Lane, Wilmslow, SK9 5AF, United Kingdom or you can go to https://ico.org.uk/make-a-complaint/. Data Subjects can find further information by visiting www.ico.org.uk or by calling the ICO on 0303 123 1113.

5.   Data Retention

How long we keep your information for depends on the relationship we have with you. We will retain your personal information for as long as we reasonably need it, for the purposes explained in this UK Privacy Policy in compliance with the Data Protection Legislation. We will need to keep your Personal Data for the period necessary to offer our products and services to you and deal with queries you may have. We may need to keep information for a period of time after our relationship has ended, for example:

• To ensure we have an accurate record in the event of any complaints or challenges or we reasonably believe there is a prospect of litigation;
• To carry out relevant fraud checks;
• Where we are required to do so for legal, regulatory or tax purposes; or
• For research and statistical purposes to ensure we continue to make informed investment decisions and understand the performance of our products in order to sustain and safeguard Revantage UK for the benefit of all our clients.
• When we no longer need your data, we will destroy it safely and securely.

If you would like further information about our data retention practices please contact dataprivacy@revantage.eu.

6.   Technical and Organizational Security Measures

Ensuring that Personal Data is appropriately protected from data breaches is a matter of high priority for Revantage UK.

Revantage UK implements adequate technical and organisational security measures, such as, depending on the equipment, password protection, encryption, physical locks, etc., to ensure a level of security appropriate to the risks represented by the processing and the nature of the Personal Data to be protected.

7.   Internal Training Program

All individuals within Revantage UK, having access to Personal Data are provided with specific training programs/information in order to improve their practical skills and knowledge that relate to data protection issues.

8.   Amendment

We may change this policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy, and if the changes are significant, we may provide you with additional notice such as adding a statement to the homepage of the site or sending you an email with the update.

9.   Contact

If you have any questions or comments about this UK Privacy Policy, or if you would like us to update information we have about you, please email us at dataprivacy@revantage.eu.

This UK Privacy Policy was last updated in April 2023.