Overview: Ridgewood Energy Corporation (“REC” or “we”) is committed to protecting and respecting your privacy. This policy sets out the legal basis on which any personal information (“Personal Data”) we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.
What types of Personal Data do we collect? We may control, process and use your Personal Data, which may include names, postal addresses, email addresses, telephone numbers or any other Personal Data that you provide to us. We may also, in appropriate cases and to the extent permitted by law, control, process and use certain categories of Personal Data which are more sensitive in nature (e.g. when undertaking “Know Your Customer” (KYC) or anti-money laundering (AML) checks, we may collect information about any criminal conviction offence that you or the directors of any company might have committed).
Identity of the Company: REC and the private investment vehicles it sponsors and/or manages (the “Funds”) are joint controllers of your data. REC handles all enquiries in regard to Personal Data and the GDPR.
Lawful basis for Processing: Where we act as Data controller, we rely on the following legal basis for processing your Personal Data: (a) legitimate interests – if you or the company for which you work is an investor in one or more of our Funds (“Investor”), a business affiliate of REC and/or the Funds or our website visitor; (b) performance of contract – if you are a supplier or other vendor, contractor or business affiliate (collectively “Vendor”) or our website visitor; and (d) legal obligation – if we process Personal Data according to requirements of domestic legislation or other legal process.
Data Protection Officer: Article 5 of the General Data Protection Regulation (“GDPR”) states that Personal Data must be processed lawfully, fairly and in a transparent manner. In line with the GDPR best practices, this privacy statement Privacy Notice is designed to help you better understand why and how we collect, process and destroy your data. REC has no regulatory obligations under the GDPR to appoint a DPO; the Company has no DPO currently appointed. The GDPR sets out guidelines on when the appointment of a DPO shall be required as follows: (a) where the scope or purpose of collecting Data requires a regular systematic monitoring of the data subjects; (b) where REC processes Special Categories of Data on a large scale; and (c) where Processing is carried out by a public authority. REC has instead agreed to name a Responsible Officer who may be reached at firstname.lastname@example.org.
Purpose of Data collected: The personal information we collect is for the following legitimate interest: (a) provision of services to the Funds; (b) administration of the Funds’ investments; (c) promotion of ideas and events relating to services we provide; (d) accuracy of Fund records, (e) maintenance of records of communication and management of your relationship with us and the Funds, if any; (f) to respond to your inquiries; (g) to comply with any present or future law, rule, regulation, guidance, decision or directive (including those concerning anti-terrorism, fraud, AML and anticorruption); (h) to carry out, in appropriate cases, KYC checks and other procedures that we undertake prior to you becoming a Vendor or Investor; (i) prevention and detection of fraud and other illegal activity or misconduct; and (j) for informing you about compliance with legal and regulatory obligations and provide related guidance.
Legitimate Interests: We occasionally process your personal information under the Legitimate Interests’ legal basis. Where this is the case, we have carried out a legitimate interests assessment to ensure that we have weighed your interests and any risk posed to you against our own and that such interests are proportionate and appropriate such as for the purposes of human resources, Fund management, and day-to-day operations.
With whom do we share our information: Except as described herein, REC’s Privacy Notice or as otherwise described in any agreement between you, REC, and/or a Fund, we will not share Personal Data about you with third parties without you knowing of this. We are required, by law, to sometimes pass on some of this Personal Data to: (a) law enforcement agencies; (b) financial regulators and other relevant regulatory authorities; (c) government bodies; (d) tax authorities; (e) courts tribunals and complaints/dispute resolution bodies; (f) other bodies as required by law or regulation; (g) related financial institutions such as trustees, custodians and sub-custodians; (h) insurers; (i) fraud protection agencies; and/or (j) similar suppliers or service providers.
To fulfill our contractual obligations to the Funds, Vendors and other business partners, REC may sometimes pass information to: (a) IT services, including Investor relationship management platforms; (b) intragroup to related affiliates also working on providing related services; (c) placement agents; (d) legal counsels; and (e) accountants.
Retention: We will keep your Personal Data for no longer than reasonably necessary to comply with applicable laws, rules and regulations and fulfill our contractual obligations. We will retain your personal information in accordance with legal and regulatory requirements as set out in our data retention policies.
Your rights and your Personal Data: You have a right to request a copy of your Personal Data which REC or related Data Controller holds about you; to request REC or any related Data Controller to correct any Personal Data if it is found to be inaccurate or out of date; to request your Personal Data is erased where it is no longer necessary for REC or related Data Controller to retain such Data and not to be subject to a decision based on automated processing; the Company does not currently practice such decision-making.
Further Processing: Where we may seek to further process your Personal Data other than for the original purpose for which it was collected, REC shall only further process such Personal Data where the new processing is compatible with the original purpose.
Safeguarding measures: We take your privacy seriously and take every reasonable measure and precaution to protect and secure your Personal Data. Together with our vendors and site managers, we work hard to protect you and your information from unauthorized access, alteration, disclosure or destruction and have security measures in place, including, without limitation, encryptions.
We use WordPress as our website platform and Flywheel to host the site. To keep our site secure, Flywheel:
- locks down the core files so they cannot be overwritten with a hacker’s infected code
- keeps WordPress up to date automatically
- ensures that all users use strong passwords
- blocks intruders with intelligent IP blocking by monitoring popular points of entry and keeping a database of malicious IP addresses
- provides no-cost and timely malware removal services in the event of a website hack
Special Categories of Data: Owing to the products and services that we provide the Funds, such as performance of AML, KYC and other background checks, we sometimes need to process Personal Data which are deemed to be more sensitive in nature. However, we do not intend to process any Special Categories of Personal Data under Article 9 of the GDPR. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so. If we have to rely on your consent for Processing Special Categories of Data, we will obtain your explicit consent through electronic means.
When we use third parties to collect personal information, we list those third parties and provide a link to their website. For more information, please refer to those organizations and their privacy policies.
When you access and use our site, we automatically collect personal identifiers, such as your IP address or location information (if available from your IP address or your service provider’s IP address), activity or usage information, and device information, such as hardware, operating system, browser, and website preferences, to display our website provide access to the site. We use Flywheel (managed website hosting) and Google Analytics (website analytics tool) to provide usage statistics and support your access to and use of our site.
Changes to our Privacy Statement: Any changes we may make to this Privacy Statement in the future will be posted on this page and, where appropriate, you will be notified by email.