Investure Privacy Notice
1. GENERAL INFORMATION
Our Services are offered to companies looking to make investments, to companies offering investment opportunities and to companies that facilitate the investment process. All personal data on the Platform and otherwise processed in connection with our Services are processed by us as controllers, meaning that we determine the purposes and means for the use of the personal data.
All definitions in this Privacy Notice shall be interpreted in accordance with applicable data protection laws which refers to the General Data Protection Regulation (Regulation no. 2016/679) and the Directive on Privacy and Electronic Communications (Directive 2002/58/EC), as well as the national implementations and related national legislation.
2. DATA PROCESSED
We collect personal data either directly from you, as provided by you to us, or we may have received the personal data about you from a colleague or team member of yours.
2.1 Website contact form
When you provide us with your contact details so that we can contact you, or an administrator adds you as a team member or representative of a company in the Platform, we will process the following personal data:
(a) your full name;
(b) the name of the company you work for or represent, and the sector you operate in;
(c) your country of residence and your gender;
(d) your phone number; and
(e) your email address.
We need the information above in order to communicate with you. Since you (or a colleague of yours) provide(s) us with this information on our Website, we believe that you are ok with us reaching out to you.
2.2 Platform data
The personal data set out above (in 2.1), and what is described below, will also be used when we operate the Platform and provide our Services.
2.3 Know-your-customer (“KYC”) for private persons
When we are required to undertake a KYC-check for private persons, we will send out a questionnaire to the person in question and thereafter process the personal data contained in the answers to that questionnaire. This processing is based on our legal obligation to comply with anti-money laundering legislation.
2.4 Facilitating deals with electronic signature solutions
When deals are concluded through our Services, we offer electronic signature solutions to make it easier for everyone. We will then process the signatories’ names, roles and contact details, together with any personal data contained in the actual agreements being signed. This processing is based on our legitimate interest to provide the services to our customers when they initiate the contract signing process.
We collect information by using technology such as cookies, pixels and tags (on your browser or device).
Insofar as the information collected from the cookies constitute personal data, we process the personal data based on your consent, as provided by you when accepting the cookie(s). Please note that without such consent, the Website and Services may not function as intended or include all features.
Our purposes for using data from cookies is to:
collect information about how visitors use our Website and to learn which pages on the Website are the most popular. This data is used to optimise our Website and make easier to navigate;
enable our Website to remember choices visitors make while browsing, such as their geographical location where they are based in order to offer localised experiences (where possible), and to remember featured projects we may have already shown the visitor in order to avoid repetition; and to
show visitors and logged in users the right information and to personalise their experience when using the Services.
3. DISCLOSURE OF PERSONAL DATA
3.1 Information exchange on the platform and to relevant authorities
As our Services are about connecting investors and investees, information such as your contact details, focus areas and investment interests will be shared with other users of our Services. We will furthermore disclose personal data about you to authorities as necessary in accordance with applicable laws. These categories of recipients may be based outside of the EU/EEA – for more information on this, please see below.
3.2 Our use of service providers
To provide our Services, we use service providers who process personal data on our behalf and in accordance with our instructions. These service providers include suppliers of hosting services, electronic signing solutions, and blockchain technology. Where the service providers will process personal data on our behalf as processors, they are bound by contractual obligations to only process the personal data in accordance with our instructions. If any of the service providers would process personal data as controllers, we would let you know here. These service providers may be based outside of the EU/EEA – for more information on this, please see below.
3.3 Recipients outside of the EU and the EEA
Some of the abovementioned recipients are located outside the EU/EEA in countries which does not ensure a level of protection for personal data that is equivalent to that ensured in the EU/EEA, and we are therefore applying safeguards for the data transfers as required by applicable law (such safeguards being comprised of the standard contractual clauses issued by the European Commission). You can acquire further information regarding the transfers and standard contractual clauses in use by contacting us at firstname.lastname@example.org.
3.4 Other websites and services
When visiting our Website or using our Services you may be directed to other websites or services where the personal data collected is not in our control. The privacy notice of the other website or service will govern the personal data obtained from you on that website or service.
4. RESPONDING TO LEGAL REQUESTS AND PREVENTING HARM
We may access, preserve and share your personal data in response to a legal request (like a search warrant, court order or a subpoena or the like), or when necessary to detect, prevent and address fraud and other illegal activity, to protect ourselves, you and other users, including as part of investigations.
We store personal data regarding users of the Services for the duration of their accounts being active. If an account is inactive for two (2) years, we will send an email to verify if the account is still in use. If we get no answer to this email, we will delete the account in question.
When we are asked to delete an account, we will retain the personal data in question for up to ninety (90) days in case there has been a misunderstanding or the user changes his or her mind.
We will store personal data about a transaction having been made until both parties request that we delete such personal data.
Personal data from cookies are not stored for longer than thirteen (13) months.
Personal data required for complying with applicable laws will be stored for the duration stipulated by or required to comply with those laws.
Personal data that is necessary for us to establish, exercise and/or defend legal claims may be stored for up to ten (10) years, and if necessary the duration of any such process where the personal data is required.
The Services are not directed to persons under the age of eighteen (18). If you are a parent or guardian of a person under the age of eighteen (18) and you become aware of that the child has provided personal data to us without your consent, please contact email@example.com to exercise your access, rectification, erasure, limiting of processing and objection rights.
7. YOUR RIGHTS
You have the right to object to our processing of personal data based on our legitimate interests, and you have an absolute right to object to the processing of your personal data for direct marketing.
You have the right to request access and further information concerning the processing of your personal data, or request that we correct, rectify, complete, erase or restrict the processing of your personal data. You have the right to obtain a copy of the personal data that we process relating to you free of charge once (1) every calendar year. For any additional copies requested by you, we may charge a reasonable fee based on administrative costs.
If the processing is based on the legal grounds consent or fulfilment of contract you have the right to data portability. Data portability means that you can receive the personal data that you have provided to us, in a structured, commonly used and machine-readable format, and have the right to transfer such data to another data controllers.
8. CONTACT INFORMATION
To exercise your rights, or if you have any questions regarding our processing of your personal data, please contact us using the details set out in the beginning of this Privacy Notice, or send an email to the following address: firstname.lastname@example.org. In your letter/email please state your full name, telephone number and account reference at Investure. Note that you should sign the request to receive information of the processing of your personal data yourself, and that we may take additional steps to verify your identity.
If you have any complaints regarding our processing of your personal data, you may file a complaint to the competent data protection authority. You can find out more about the local data protection authorities under the following link http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
8. Change of Control
If there is a change of control in our business, we may transfer your information to the new owners for them to continue to provide the Services. The new owners shall continue to comply with the commitments we have made in this Privacy Notice.
9. NOTICE OF CHANGES TO THE PRIVACY NOTICE
If we make changes to this Privacy Notice, we will make a notification regarding this on the Website, when the changes are of minor nature, and if the change is more substantial, we will notify you by email. If your consent is required due to the changes, we will provide you additional prominent notice as appropriate under the circumstances and, ask for your consent in accordance with applicable law.
Date of this Privacy Notice: 26 November 2020