Privacy Policy

1. Who We Are

Reno Investment Ltd (company number 14890210) is an asset management firm registered in England and Wales with our registered office at 71 Queen Victoria Street, London, EC4V 4AY. We are the data controller for the personal data we collect through our platform.

This privacy policy explains how we collect, use, disclose, and safeguard your personal data when you use our platform, in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. What Data We Collect

We may collect the following categories of personal data:

• Identity data: full name, title, date of birth, and proof of identity documents;
• Contact data: email address, phone number, and postal address;
• Financial data: investment experience, annual income, net worth, and investment objectives;
• Risk profile data: responses to risk assessment questionnaires and resulting risk scores;
• Technical data: IP address, browser type, device information, and usage analytics.

3. How We Use Your Data

Your personal data is used for the following purposes:

• To create and maintain your client account;
• To process risk assessment questionnaires and generate portfolio tier suggestions;
• To communicate with you about your account, platform updates, and relevant disclosures;
• To comply with legal and regulatory obligations, including anti-money laundering checks;
• To improve and secure our platform through analytics and monitoring.

4. Legal Basis for Processing

We process your personal data on the following legal bases:

• Consent: where you have explicitly agreed to the processing of your data for a specific purpose, such as receiving marketing communications;
• Contractual necessity: where processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract;
• Legitimate interest: where processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• Legal obligation: where processing is necessary to comply with a legal or regulatory obligation to which we are subject.

5. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. Generally, we retain client data for a period of seven years following the end of our business relationship, after which it is securely deleted or anonymised.

Where data is processed on the basis of consent, we will retain the data until you withdraw your consent, unless another legal basis applies.

6. Your Rights

Under UK data protection law, you have the following rights:

• Right of access: to request a copy of the personal data we hold about you;
• Right to rectification: to request correction of inaccurate or incomplete data;
• Right to erasure: to request deletion of your data where there is no compelling reason for continued processing;
• Right to restrict processing: to request that we limit the processing of your data;
• Right to data portability: to receive your data in a structured, commonly used format;
• Right to object: to object to processing based on legitimate interests or direct marketing;
• Right to withdraw consent: to withdraw your consent at any time where processing is based on consent.

To exercise any of these rights, please contact our Data Protection Officer using the details below. We will respond to your request within one month.

7. Cookies

Our platform uses cookies and similar tracking technologies to enhance your experience and gather analytics. For full details, please see our separate Cookie Policy.

8. Data Protection Officer

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing our compliance with data protection laws. You can contact our DPO at:

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at any time. We encourage you to contact us first so that we may resolve your query directly.

9. Changes to This Policy

We may update this privacy policy from time to time. Any changes will be posted on this page with an updated revision date. Where changes are material, we will notify you by email or through a prominent notice on the platform.