Privacy Policy - Alpha Hub

ALPHA HUB PRIVACY POLICY

LAST UPDATED:  10 October 2018

Alpha Hub is committed to protecting your privacy and personal data. This “Privacy Policy” describes our practices related to use and management of personal data that we collect on and you provide to us.

By visiting www.alphahub.tech  or making use of any of the services or Program (listed in “Program”) section below, you are accepting and consenting to this Privacy Policy.

  1. IMPORTANT INFORMATION
  2. OUR SERVICES
  3. HOW WE PROCESS AND USE YOUR DATA
    1. General
    2. Investors
    3. Portfolio companies
    4. Others
  4. HOW IS YOUR PERSONAL DATA COLLECTED
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. DATA SECURITY
  7. DATA RETENTION
  8. YOUR LEGAL RIGHTS
  9. CONTACT DETAILS

 

1 – Important information

Controller

Alpha Hub is operated by Asociatia WithUs, which is an ONG registered in Cluj, Romania with registration number 168/2010. (“Asociatia WithUs”). As the controller of your personal data, Asociatia WithUS is therefore responsible for any collection, processing, use and disclosure that may be carried out in relation to your personal data.

The Alpha Hub Program is organized in partnership with other entities, herein referred to as “Program Partners.” Program Partners include Omnievents SRL (and its affiliates “Asociația Alpha IT Events” (operating as “Techsylvania”) and Paddy Power Betfair companies.

References to the terms “we”, “us” and “our” in this Privacy Policy are to Asociatia WithUs, an ONG registered in Cluj, Romania with registration number 168/2000.

 

 

Purpose of this Privacy Policy

The purpose of this policy is to ensure you are fully informed on how we collect and use personal data about you. Please read this policy, as well as any notices of policy change or updates, or fair processing notices.

 

Updates to this privacy policy

This Privacy Policy may be updated periodically. The date of last update is indicated in at the top of this Policy. Any subsequent changes made to this Privacy Policy are effective from the date of update. Your continued use of services following such changes indicates acceptance of updated Privacy Policy.

Duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Usage of Photographic and Video Material

Alpha Hub takes photographic and video material of attendees and participants at events and throughout our premises and working sessions. In registering for a program or event, you acknowledge that we and our Program Partners may include images of yourself intact or in part for material used in various publications, press releases, promotional activities, or other related endeavors. This material may also appear on the Alpha Hub and Program Partners websites and social media pages.

 

Third-party links

Our website may include links to third-party websites, plug-ins, and applications. Clicking on such links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

2 – Our services

Asociatia WithUs is an ONG dedicated to catalyzing support for early-stage startups. In order to provide our services, we may collect personal data through a number of sources. Please see the ‘How is your personal data collected’ section for more information.

When we need to collect personal data by law or in relation to a contract we have entered into or are negotiating with you, failure to provide this data when requested may render us unable to perform the contract or deliver services to you. In such a case, it may be necessary to cancel, suspend, or otherwise modify all or part of our services to you. In such a situation, we will notify you and provide reasonable time to rectify the situation.

Our website and services are intended for adults only. We do not knowingly collect, use, process, or disclose personal data relating to children.

 

3 – How we process and use your data

“Personal data” is information that identifies you as an individual or relates to an identifiable individual.

We will only use your personal data when the law allows us to. We do not sell, trade or otherwise deal with your personal data in any way that contravenes this Privacy Policy (which may be updated periodically).

Below, we describe the ways we plan to use your personal data and on what legal basis we do so. Where we rely on “legitimate interests” as the legal basis for processing, we have identified the nature of these legitimate interests.

Purpose/Activity Types of Personal Data Basis for use and processing

 

(a) General

 

Providing our services and managing our relationship with you

·                     to provide services or proposals to you;

·                     maintaining a record of contacts;

·                     organizing meetings with you;

·                     to respond to your inquiries and fulfill your requests, when you contact us for example, when you send us questions, suggestions or feedback, or when you request a quote, or other information about our services, and

·                     to complete your transactions, and provide you with the related client or investor related services

·                     Name

·                     Residential Address

·                     Date of Birth

·                     Tax ID/national insurance number

·                     Passport or similar documented identification

·                     Nationality

·                     Email Address

·                     Telephone/mobile number(s)

·                     Bank account details

·                     Necessary for our legitimate interests (for providing our services, running our business, administrative purposes and making or advising on investment decisions)
Communications/Correspondence ·                     Name

·                     Residential/Office Address

·                     Email Address

·                     Nationality

·                     Job title/position of responsibility

·                     Name of employer

·                     Necessary for your legitimate interests (to develop our services, to grow our business and to inform our marketing strategy)

 

(b) Investors (existing or potential) 

Please note that for investors in any fund managed by Alpha Hub. Alpha Hub Program Partners, or it’s affiliates, this may include personal data obtained from professional advisers, including placement agents, administrators, investment managers, custodians and legal service providers.

 

Please note, Alpha Hub may also enlist the assistance of third parties to undertake due diligence on individuals, investors, co-investors and entities looking for funding (including any persons connected to such entities)

 

Purpose/Activity Types of Personal Data Basis for use and processing

 

To perform:

·                     identity verification;

·                     investor/investment communications including monthly newsletter;

·                     ongoing investment management;

·                     due diligence and know-your-customerchecks;

·                     to respond to your inquiries and fulfill your requests;

·                     investor registration;

·                     the completion of fund related documentation e.g. limited partnership agreement, subscription agreements, management arrangement agreements, investment agreements, regulatory filings, amongst others

·                     cash distributions and payments;

·                     maintaining a record of contacts; and

·                     organizing meetings with you

·                     Name

·                     Residential Address

·                     Date of birth

·                     Tax ID/national insurance number

·                     Passport or similar documented identification

·                     Nationality

·                     Email Address

·                     Telephone/mobile number(s)

·                     Bank account details

·                     Necessary for our legitimate interests (for providing our services, running our business, administrative purposes and making or advising on investment decisions

·                     To allow the performance of contractual relations with you

·                     To comply with legal, tax, and compliance obligations (e.g. under anti money laundering regulations

·                     To establish whether you are a politically exposed person

·                     Criminal background checks

 

(c) Portfolio Companies and Companies or non-incorporated teams in our Programs
(existing or potential)
 

 

Purpose/Activity Types of Personal Data Basis for use and processing

 

·                     Founder, director and shareholder identity verification;

·                     due diligence and know-your-customerchecks;

·                     ongoing investment management;

·                     investor/investment communications;

·                     analysis of company/ management presentations or proposals;

·                     maintaining a record of contacts; and

·                     organizing meetings with you

·                     Founder, director and shareholder names

·                     Founder, director and shareholder addresses

·                     Founder, director and shareholder email addresses

·                     Founder and director nationalities

·                     Residential address

·                     Date of birth

·                     Job title/position of responsibility

·                     nationality

·                     gender

·                     Bank account details

·                     Necessary for our legitimate interests (for providing our services, running our business, administrative purposes and making or advising on investment decisions

·                     To allow the performance of contractual relations with you

·                     To comply with legal, tax, and compliance obligations (e.g. under anti-money laundering regulations

·                     Details required to establish whether you are a politically exposed person

·                     Criminal background checks

 

(d) Other

 

Transacting with suppliers ·                     Name

·                     Email address

·                     Telephone/mobile number(s)

·                     Job title/position of responsibility

·                     Necessary for our legitimate interests (for providing our services, running our business, administrative purposes and making or advising on investment decisions)
Dealing, managing and considering employment/internship/program applications ·                     Name

·                     Residential Address

·                     Date of birth

·                     Tax ID/National insurance number

·                     Passport or similar documented identification

·                     Nationality

·                     Email address

·                     Telephone/mobile number(s)

·                     Job title/position of responsibility

·                     Curriculum vitaes (CVs), Resumes, or other documents similar documents provided by you

·                     Employment history

·                     Necessary for our legitimate interests (for providing our services, running our business, administrative purposes and making or advising on investment decisions

·                     To allow the performance of contractual relations with you

·                     Party consent

·                     Necessary to take steps at your request prior to entering into an employment or internship

We may collect, use, and share aggregated data such as statistical or demographic data for any purpose. This data may be derived from your personal, data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

Unless we request it, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., national insurance numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services or otherwise.

4 – How is your personal data collected?

We use different methods to collect data from and about you including through:

    • Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
      • request or apply for our products or services;
      • complete an online submission form;
      • request marketing to be sent to you;
      • submit employment applications or queries;
      • submit funding, program, or service applications and any related materials including pitch decks, one-pages, videos, presentations, web submissions, and other such documents;
      • provide us solicited or unsolicited feedback or suggestions;
      • use our website (www.alphahub.tech); or
      • use our social media pages and other web presences including Twitter, Facebook, LinkedIn, Instagram, or others.
      • use third party websites we use for various program and funding applications, including F6S.com and Vestbee.com and other such platforms.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. This information does not reveal your specific identity. We collect this personal data by using server logs and other similar technologies such as IP address identification and logging.
  • Alpha Hub may also use cookies to collect information on you, including browser type, time spent on the services, pages visited, language preferences, and other traffic data. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting particular cookies. You are not obligated to accept cookies to use the Alpha Hub website. However, if you choose to not accept cookies, your website experience may be suboptimal and you may experience inconvenience using our services.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties including analytics providers, advertising networks and search information providers.
  • Identity data from data brokers or aggregators.
  • Public sources. Identity data from publicly availably sources.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the contact details provided in the “Contact Details” section.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

 

5 – Disclosures of your personal data

Alpha Hub will only disclose personal data in accordance with this Privacy Policy (which may be updated from time to time).

We may disclose personal data to Program Partners, in order to evaluate your candidacy for or deliver services related to an Alpha Hub program you’ve applied to. We may disclose personal data to third party service providers (including IT system administrators, professional advisers, consultants, providers of finance, tax authorities, regulators, and other authorities) to facilitate services they provide to us. We require all Program Partners and third parties to respect the security of your personal data and to treat it in accordance with the law. In such circumstances, we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6 – International transfers

Alpha Hub is based in the European Economic Area (“EEA”).  If we transfer personal data to our group or affiliate entities or to third parties outside of the EEA, we will ensure your personal data is protected, for example by ensuring one or more of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Standard contractual clauses approved by the European Commission are in place with the transferee.
  • Where we transfer personal data to service providers or affiliates based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us using the contact details provided in the “Contact Details” section if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

7 – Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We cannot guarantee the security of any personal data that you disclose online, for example when it is sent by email. You accept the inherent security risks of providing information online over the internet and will not hold Alpha Hub responsible for any breach of security unless this is due to Alpha Hubs’s negligence or willful default.

 

8 – Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

You can request details of retention periods for specific categories of your personal data by contacting us using the details provided in the “Contact Details” section.

 

9 – Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Such rights include your right to:

  • request access to your personal data;
  • request correction of your personal data;
  • request erasure of your personal data;
  • object to processing of your personal data;
  • request restriction of processing your personal data;
  • request transfer of your personal data; and
  • right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us using the details provided in the “Contact Details” section.

We give you choices regarding our use and disclosure of your personal data for marketing purposes. You may opt-out from receiving electronic communications from us by following the ‘Unsubscribe’ link provided at the footer of any marketing materials that you may have received from Alpha Hub by email or by contacting us using the details provided in the “Contact Details” section.

 

Complaints

You have the right to lodge a complaint at any time to the National Authority for the Supervision of Personal Data Processing. But, we hope you’ll first address any concerns to us so that we can find a mutually agreeable solution.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

10 – Contact Details

If you have any questions about this Privacy Policy, please contact our data privacy representative using the details set out below.

We may be contacted at: Asociatia With Us, Strada Henri Barbusse 44, Cluj-Napoca 400616, Romania or at privacy@alphahub.tech.