2. Key policy principles
3. Data collection
4. Why does Balderton Capital collect your personal data?
5. Accurate Data
6. Access and rectification
7. Timely Processing
8. Data Security
9. Data Compliance Officer (DCO)
10. Use of personal data for direct marketing purposes
12. Disclosure of personal data
13. Disclosures outside the EU/EEA
14. Your choices and your rights
Balderton Capital respects your privacy. This Data Protection Policy (the Policy) describes how we process personal data, which personal data we collect and why we collect it, with whom we share this personal data, how we protect it, and the choices you can make about how we use your personal data.
This Policy applies to any personal data collected, held or processed by or on behalf of Balderton Capital, relating to any individual in his or her dealings with Balderton Capital as investee, stakeholder or member of the general public
The scope of this Policy also includes all the websites, sponsored social media platforms and any other online initiatives that are owned by Balderton Capital, where personal data is processed. Unless an express consent is required by the data privacy laws of your country, by using our media platforms, you consent to the collection and use of your personal information by us as described in this Policy. If you chose not to provide us with your personal information, in most cases, we will not be able to provide you with information about Balderton Capital
The requirements of this Policy are in addition to, not in substitution for, any other requirements under the applicable data protection laws and regulations. In case of conflict between the applicable data protection laws and regulations and the provisions of this Policy, the applicable data protection laws and regulations shall prevail.
Balderton Capital may amend this Policy at any point in time. Please check this Policy periodically by emailing firstname.lastname@example.org to obtain an up to date copy to inform yourself of any changes.
1.1 In this Policy, the following terms shall have the following meanings:
2.1 We value the Personal Data entrusted to us and we are committed to Processing Personal Data in a fair, transparent and secure way. The key principles of this Policy are as follows:
3.1 Personal Data you provide us directly
We collect information directly from you in circumstances for example when you:
The Personal Data you provide to us directly can include:
3.1.1 Personal data that you provide at different points of contact with Balderton Capital may include :
3.1.2 In case of the need to verify your Identity (e.g. subject access requests, know your customer (KYC)) data that will be collected from you can include:
Such data will only be used for verification of identity relating to the purposes it was requested for.
3.1.3 When interacting with Balderton Capital through online channels (e.g. website) the following information can be captured (in accordance with the cookies policy):
3.1.4 For travel services the following data can be collected:
3.1.5 When receiving or applying for investments, the following data can be collected and treated under the local banking legislation (i.e. it will not be shared with any other entities of Balderton Capital):
3.1.6 For special events (e.g. new initiatives) Balderton Capital might take – with your permission –photos and videos of you:
3.2 Personal Data we receive from third parties
We may obtain the same categories of Personal Data about you from third parties such as our network of authorised third parties, carefully selected business partners who provide services on behalf of us, and any other third party who may lawfully pass to us information about you.
3.3Personal Data we collect automatically
We may collect certain information by automated means (e.g. cookies, log-files or web beacons) when you visit websites and digital applications and services. For further information on these technologies, we refer to section 8 of this Policy.
4.1 Balderton Capital may Process the Personal Data for the following purposes (the Purposes):
4.2 Balderton Capital shall only Process Personal Data to the extent that it is required for the Purposes and for any other purpose specifically permitted by the applicable data protection laws and regulations.
4.3To the extent required under the applicable data protection laws and regulations, Balderton Capital shall notify the Processing of Personal Data to the relevant authorities.
5.1 It is important for us to maintain accurate and up to date records of your Personal Data. Please inform us of any changes to or errors in your Personal Data as soon as possible by contacting email@example.com. We will take reasonable steps to make sure that any inaccurate or out-of-date data is deleted, destroyed or amended accordingly.
6.1 You have the right to access the Personal Data we hold about you and, if such Personal Data is inaccurate or incomplete, to request the rectification or erasure of such Personal Data. If you require further information in relation to your privacy rights or would like to exercise any of these rights, please contact firstname.lastname@example.org
7.1 We shall retain your Personal Data in a manner consistent with the applicable data protection laws and regulations. We will only retain your Personal Data for as long as necessary to comply with the applicable laws and regulations or for the Purposes for which we Process your Personal Data. For guidance on how long certain Personal Data is likely to be kept before being destroyed, please contact email@example.com
8.1 We shall ensure that appropriate technical and organisational security measures are taken against unlawful or unauthorised Processing of Personal Data, and against the misuse, destruction, disclosure, acquisition, accidental loss of, or damage to Personal Data. Personal Data shall only be processed by a third party Data Processor if that Data Processor agrees to comply with those technical and organisational measures.
8.2 Maintaining data security means guaranteeing the confidentiality, integrity and availability of the Personal Data:
8.3 Security procedures include:
8.3.1 Security Policy
8.3.2 Organisation and human aspect of security
8.3.3 Physical and environmental safety
8.3.4 Network Security
8.3.5 Access logging, tracking and analysis
8.3.6 Monitoring, review and maintenance
8.3.7 Management of security incidents and continuity
8.3.8 Complete and updated documentation.
9.1 Balderton Capital have nominated a Data Compliance Officer to assist with the lawful processing of personal data.
9.2 If you have a query in relation to this Policy or our Processing of your Personal Data, you can contact the Data Compliance Officer via firstname.lastname@example.org.
10.1 We will only use your Personal Data for the purpose of sending marketing material via electronic means (e.g. email,) if we have obtained your prior consent. You can withdraw your consent at any point in time, by following the unsubscribe instructions included in the marketing material or by contacting email@example.com
12.1 For the above mentioned Purposes, we may disclose your Personal Data to the following categories of recipients:
12.1.1 Authorised staff members of Balderton Capital.
12.1.2 Corporate affiliates and subsidiary companies of the Balderton Capital;
12.1.3 Our advertising, marketing and promotional agencies: to help us deliver and analyse the effectiveness of our advertising campaigns and promotions;
12.1.5 Other parties when required by law or as necessary to protect Balderton Capital: Balderton Capital may share your Personal Data with other third parties:
12.1.6 Other parties with your consent or upon your instruction: Balderton Capital may share your Personal Data with third parties when you consent to or request such sharing; and
12.1.7 Any other third party communicated to you by Balderton Capital prior to sharing tour Personal Data with that third party.
13.1 Your Personal Data may be transferred to any of the recipients identified in this Policy, some of which may be outside the EU/EEA and may be Processed by us and any of these recipients in any country worldwide. The countries to which your Personal Data is transferred may not offer an adequate level of protection. In connection with any transfer of Personal Data to countries that do not offer the same level of protection as in the EU/EEA, Balderton Capital shall implement appropriate measures to ensure an adequate level of protection of your Personal Data.
We want to be as transparent possible with you, so that you can make meaningful choices about how you want us to use your information.
We can contact you by post and by phone, and if you give us your prior consent to do so, by email, SMS and other electronics means.
14.1 Your choices:
In this context, you can make a variety of choices about how you want to be contacted by us, through which channel (e.g. email, mail, Social Media, …), for which purpose and how frequently, by adjusting the privacy setting on the relevant device or updating your user or account profile or by following the unsubscribe instructions included in the communication.
Please note that by default, if you don’t make a choice, you will receive our promotional communications at the following frequency: at date of publication.
14.2 Your personal information
You may always contact us by post or email to find out what personal information we have concerning you and the origin of these.
14.3 Your corrections
If you find any mistake in your personal information or if you find it incomplete or incorrect, you may also require from us that we correct it or complete it.
14.3 Your objections
You may also object to the use of your data for direct marketing purposes (if you prefer, you can also advise us on which channel and how frequently you prefer to be contacted by us) or to the sharing of your personal information with third party for the same purpose.
Finally, you may request for us to erase any data concerning you (except in some cases, for example to provide proof of a transaction or when required by law).
15.1 For any privacy issues, questions or complaints concerning the application of this Policy or to exercise your rights of access or rectification within the context of this Policy, you may contact Balderton Capital at firstname.lastname@example.org.
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