Rede Partners LLP (“Rede Partners”) is authorised and regulated by the Financial Conduct Authority in the United Kingdom.
Rede Partners is represented in the U.S. by its partners and employees who are registered representatives of Growth capital Services Inc. (“GCS”), a limited purpose securities broker that distributes private placements offered under Regulation D. GCS is registered as an independent broker dealer under the Securities and Exchange Act of 1934 with the SEC, and is a member in good standing of FINRA and SIPC.
NOTICE TO CANADIAN INVESTORS
Rede Partners is relying on the international dealer exemption pursuant to sections 8.18 of National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations in Alberta, British Columbia, Ontario, Quebec and Saskatchewan (collectively, the Jurisdictions).
Further to relying on such exemption, we advise that: (i) Rede Partners is not registered in the Jurisdictions to act as a dealer; (ii) the address of the head office of Rede Partners is 110 Park Street, 3rd Floor, London W1K 6NX, United Kingdom; and (iii) all or substantially all of Rede Partner’s assets may be situated outside of Canada. For details of the appointed service agent in the relevant province please contact us at email@example.com.
This website, including, without limitation, the information and documents herein (the “Contents”), is intended exclusively for professional clients as defined under the Markets in Financial Instruments Directive 2004/39/EC. This website and its Contents are made available exclusively for the educational purposes only. This website is not intended for any other use or purpose.
CONTENTS NOT TO BE CONSTRUED AS A FINANCIAL PROMOTION, SOLICITATION, RECOMMENDATION OR ADVICE
This website does not constitute an offer or solicitation to buy or sell securities, a recommendation, or advice. Rede Partners only deals with institutional accounts as defined in FINRA Rules 2111(b) and does not make any assessment as to suitability of any investment opportunity on behalf of any person.
CUSTOMER IDENTIFICATION PROGRAM
Rede Partners is a regulated financial services provider and is required under various regulations aimed at combatting the finding of terrorism and money laundering activities to obtain, verify, and record information about the identities of each person or entity with which it deals. We may require information to assist in verifying the identity of your firm, its owners and principals. All information provided to us will be treated in the strictest confidence. We may not be able to provide services where we are unable to verify the identity of any firm or its owners and principals. Should you have any question with respect to this notice please do not hesitate to contact us at firstname.lastname@example.org.
The identification and prevention of conflicts of interest and the proper management of such conflicts represent an important task for any financial services firm. We analyse and manage potential conflicts of interest in such a way as to ensure the fair treatment of all parties involved in a manner that does justice to their interests and avoids any detriment to client interests.
We have put in place and maintain appropriate systems and controls to enable us to identify, record, monitor and manage conflicts of interest.
GIFTS, HOSPITALITY AND INDUCEMENTS POLICY
Rede is subject to the UK bribery Act and the FCA’s anti-bribery and corruption rules. Any gift, hospitality, fee or other benefit that we offer or are offered will be considered in accordance with UK best practice relating to anti-bribery and corruption and the guidance issued by the Ministry of Justice. This covers fees and benefits to and from clients as well as third parties.
As a MiFID investment firm, we are also subject to the FCA rules on inducements, which apply to any fee or other benefit that we receive from or provide to a third party in relation to regulated activities that we perform.
We will only offer or accept third party fees or benefits where it is necessary to do so for conducting regulated business or where we consider that it would enhance the service that we provide to our client(s) and does not affect our ability always to act in the best interest of our client(s).
We take all complaints very seriously. We have summarised our complaints policy and procedure below. If you require any further information please contact email@example.com.
We allow complaints (including MiFID complaints as defined under the rules of the FCA) to be made by any reasonable means and to be made free of charge. This may include by letter, fax, email, telephone or in person. Upon receiving a complaint, we will provide prompt written acknowledgement that the complaint has been received and that we are dealing with such complaint. Please note that we do not conduct eligible business for eligible complainants, therefore are not subject to the jurisdiction of the Financial Ombudsman Service.
We will investigate all complaints competently, diligently and impartially, obtaining additional information as necessary. We will promptly assess the specific circumstances surrounding a complaint by reviewing all appropriate records and speaking to the individuals involved, with a view to deciding whether the complaint should be upheld, whether any remedial action and/or redress may be appropriate and if appropriate, whether we have reasonable grounds to be satisfied that another respondent may be solely or jointly responsible for the matter alleged in the complaint.
In the event that, we identify any recurring or systemic problems, we will consider whether other customers who have not complained may have suffered detriment from, or been potentially disadvantaged by, the same underlying matter. If so, we will take appropriate and proportionate measures to ensure that those customers are given appropriate redress or a proper opportunity to obtain it.
Rede keeps complainants informed of the progress of the measures it is taking to resolve their complaint. When handling a complaint, we will always aim to communicate with clients or potential clients clearly, in plain language that is easy to understand and shall reply to the complaint without undue delay.
After full consideration of the matter we will write to the complainant providing an assessment of the complaint, informing the complainant whether we are upholding or rejecting the complaint and, where appropriate, making an offer of redress or remedial action. If such an offer is accepted, we will comply promptly with such redress.
We will keep a record of all complaints received and the measures taken for their resolution.
Rede Partners LLP will be what’s known as the ‘Controller’ of the personal data you provide to us. For clients we only collect personal data that includes name, address, email and phone number. For suppliers, we do collect sensitive information such as bank details for payment purposes.
Why we need your data
We need to know your basic personal data in order to provide you with on-going organisational updates, funding information and analysis services in line with the service we offer. We will not collect any personal data from you we do not need in order to provide and oversee this service.
What we do with your data
All the personal data is processed by our staff in the UK and US, however for the purposes of IT, hosting of this information is located on servers within the European Union. No third parties have access to your personal data unless the law would require them to do so.
Your data may be transferred to, and stored at, a destination outside the European Economic Area. It may also be processed by staff operating outside the EEA, who work for us or for one of our suppliers/clients.
We may combine information that we receive about you from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
We have a Data Protection Policy in place that is regularly reviewed to oversee the effective and secure processing of your personal data.
How long we keep your data for
We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of six years after which time it will be deleted.
What we would also like to do with your data
If you have given your consent for marketing then we would like to use your name and email address to keep you updated on market and Rede Partners developments. This information is not shared with third parties and you can unsubscribe by removing your consent at any time via phone or email.
Our site may, from time to time, contains links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
IP addresses and cookies
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us to:
- estimate our audience size and usage pattern;
- store information about your preferences, and so allow us to customise our site according to your individual interests;
- speed up your searches; and
- recognise you when you return to our site.
What are your rights
You have the right to be informed of your rights and how your personal data will be stored, treated, deleted and controlled, as all is set out in this policy.
If at any point you believe the information we process on you is incorrect you can request to see your information and have it corrected or deleted. If you wish to raise a complaint on how we have handled your personal data or to raise a subject access request, please do so by contacting our Compliance Officer by clicking this link.
If you wish to raise a concern about the Rede Partners’ handling of your data you should first contact the Compliance Officer at Rede Partners using the link above. If you are unhappy with the response you receive from the Rede Partners, you can contact the Information Commissioner’s Office at www.ico.org.uk or contact their helpline on 0303 123 1113.