Privacy Policy

Startup Growth Advisors IKE, a company registered in Greece, on behalf of Venture Friends 400W Management B.V., a company registered in The Netherlands, acting under its capacity as data controller is committed to safeguarding your privacy and protecting your personal data in compliance with applicable data protection laws, especially the General Data Protection Regulation EU 2016/679 (GDPR). Contact us at info@venturefriends.vc if you have any questions or concerns regarding the use of your Personal Data and we will gladly assist you. By using this website or/and our services, you accept the Processing of your Personal Data as described in this Privacy Policy.

Table of Contents

• 1. Definitions used in this Policy
• 2. Data protection principles we follow
• 3. What rights do you have regarding your Personal Data
• 4. What Personal Data we gather about you
• 5. How we use your Personal Data
• 6. How we secure your data
• 7. Information about cookies
• 8. Data Protection Authority
• 9. Contact Information

Definitions

Personal Data – any information relating to an identified or identifiable natural person.

Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.

Data subject – a natural person whose Personal Data is being Processed.

Child – a natural person under 16 years of age.

We/us/our (either capitalized or not) – Startup Growth Advisors IKE, a company registered in Greece, on behalf of Venture Friends 400W Management B.V. a company registered in The Netherlands.

Data Protection Principles

We promise to follow the following data protection principles:

• Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing your Personal Data. We will provide you with information regarding such Processing upon request.
• Processing is limited to its purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
• Processing takes place with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
• Processing is limited with a time period. We will not store your personal data for longer than necessary.
• We will do our best to ensure the accuracy of data.
• We will do our best to ensure the integrity and confidentiality of data.
• We are responsible for and we are able to demonstrate our compliance with the GDPR at any time (accountability principle).

Data Subject’s rights

In all the cases in which we collect your Personal Data, the Data Subject has the following rights and, in most cases, the Data Subject can exercise them free of charge:

1. Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.

2. Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.

3. Right to rectification – meaning you have the right to request rectification of your Personal Data that is inaccurate or incomplete.

4. Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.

5. Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.

6. Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.

7. Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing, whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.

8. Right to data portability – you have the right to obtain your Personal Data in a structured, commonly used and machine-readable format or if it is feasible, and you have the right to request that we transmit directly your Personal data to another Controller. Please note that this right applies only to Personal Data which you have provided directly to us.

9. Right to lodge a complaint with the competent supervisory authority – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled, please contact us.

10. Right to withdraw your consent – you have the right to withdraw any given consent for Processing of your Personal Data at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before this withdrawal.

Data we gather

Information you have provided us with This might be your e-mail address, full name or other information you submit in our contact forms – mainly information that is necessary for delivering you a service or to enhance your customer experience with us. We save the information you provide to us. We may be provided from time to time with CVs of job candidates for openings at VentureFriends or any of our portfolio companies.

Information automatically collected about you This includes information that is automatically stored by cookies and other session tools. For example, your IP address, your navigation path within the website etc. This information is used to improve your customer experience. When you use our services or look at the contents of our website, your activities may be logged.

Information from our partners We gather information from our trusted partners with confirmation that they have legal grounds to share that information with us. This is either information you have provided them directly with or that they have gathered about you on other legal grounds.

Publicly available information We might gather information about you that is publicly available.

How we use your Personal Data

We use your Personal Data in order to:

• to identify you;
• to communicate with you;

On the ground of legitimate interest (including a legitimate interest in performing our services, conducting our business, internal administration functions, defending legal claims etc.), we Process your Personal Data for the following purposes:

• to administer and analyse our visitors base (purchasing behaviour and history);

With your consent we Process your Personal Data for the following purposes:

• to contanct you or send you newsletters;
• for other purposes we have asked your consent for (e.g. in order to send you relevant marketing communications that we believe may be of interest to you);

We Process your Personal Data in order to fulfill obligation rising from the law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data (e.g. for statistical purposes). We will use data outside the scope of this Policy only when it is anonymised. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law.

We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:

• the link between purposes, context and nature of Personal Data is suitable for further Processing;
• the further Processing would not harm your interests and
• the further Processing would not harm your interests and

We will inform you of any further Processing and purposes.

Recipients of your Personal Data

We do not allow Personal Data collected about you to be sold, traded, disclosed to or viewed by any third party. We may, however, disclose your Personal Data in limited circumstances, including:

• To service providers, third party agents and contractors who perform services on our behalf based on our instructions. We always conclude a data processing agreement with such third parties to ensure the appropriate level of security and confidentiality of your Personal Data. Examples of these are service providers that help us operate our Website, accounting services providers, vendors, professional advisors etc.;
• To our business partners;
• To other third parties, after obtaining your consent to disclose certain information;
• To law enforcement authorities, government officials, regulatory agencies or other parties, when we are required to do so by applicable law, regulation or legal process in connection, for instance, with an investigation conducted by judicial authorities regarding suspected and/or actual illegal activity or with a court order served on us, or when such disclosure is necessary upon our legitimate interests.

Transfers of Personal Data outside EU/EEA

We generally process your personal data within the EU/EEA. Nonetheless, as the case may arise, we may have to transfer your personal data outside EU/EEA, for example to a service provider located outside EU/EEA as necessary in order to organize an exhibition. However, the level of personal data protection in countries outside the EU/EEA may be lower than the respective provided within the EU/EEA. Where this is the case, we will implement appropriate safeguards in accordance with applicable data protection laws, in order to conduct such data transfer and ensure that your personal information remains protected and secure, such as Adequacy Decisions and Standard Contractual Clauses adopted by the European Commission.

Retention Period of your Personal Data

Our general approach is to retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, as outlined in this Privacy Policy, and in any case, as required or permitted under applicable law and the corresponding statute of limitations. The criteria used to determine our retention periods include: (i) the time period we have an ongoing relationship with you; (ii) whether there is a legal retention obligation to which we are subject, such as legal, tax or accounting requirements; or (iii) whether retention is advisable in light of our legitimate interest to have an accurate record of your dealings with us in the event of any complaint or challenge, litigation or regulatory investigation.

How we secure your data

We do our best to keep your Personal Data safe. We implement appropriate technical and organization measures including safe protocols for communication and transferring data (such as HTTPS), to protect adequately your Personal Data, in particular against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. We use anonymization and pseudonymization where suitable. We monitor our systems for possible vulnerabilities and attacks.

Even though we try our best we cannot guarantee the security of information since no personal data transmitted over the Internet is guaranteed to be 100% secure. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.

If you have an account with us, note that you have to keep your username and password secret.

Children

We do not intend to collect or knowingly process information from children. We do not target children with our services.

Links to Other Websites

As a resource of information and convenience to our on-line visitors, our website may provide links to other websites owned or operated by third parties (e.g. Facebook and Twitter). Please be aware that we do not control other websites, nor have any liability for their content, security safeguards or privacy practices and that, in any case, the present Privacy Policy does not apply to these websites. Therefore, we strongly encourage you to get informed on the privacy policy of any linked website you visit.

Cookies and other technologies we use

We use cookies and/or similar technologies to analyse customer behaviour, administer the website, track users’ movements, and to collect information about users. This is done in order to personalise and enhance your experience with us.

A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.

We use cookies for the following purposes:

• Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
• Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.
• Analytics cookies – these cookies are used to track the use and performance of our website and services
• Advertising cookies – these cookies are used to deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organisations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.

We use Google Analytics to measure traffic on our website. Google has their own Privacy Policy which you can review here. If you’d like to opt out of tracking by Google Analytics, visit the Google Analytics opt-out page.

Data Protection Authority

Contact Information

Hellenic Data Protection Authority

http://www.dpa.gr/

1-3 Kifissias

Avenue, PC 11523, Athens

contact@dpa.gr

tel: +30 210 6475 600

Contact Information

You may contact us for any matter or request concerning the handling of your private data at: info@venturefriends.vc

Changes to this Privacy Policy

We may periodically update the present Privacy Policy, in order, for instance, to comply with new legal requirements. Any changes to this Privacy Policy will be posted on our website in order to keep you informed, while we may personally notify you in case of any material changes, including but not limited to, by sending you an e-mail. Accordingly, we encourage you to consult this website frequently, so that you are aware of our latest Privacy Notice and/or any updates. Last modification was made in April 2019.