We are committed to safeguarding the privacy of our newsletter subscribers, website visitors and clients. This policy applies where we are acting as a data controller with respect to the personal data of newsletter subscribers, website visitors and clients; in other words, where we determine the purposes and means of the processing of that personal data.
Personal data is defined in article 4(1) of the European Union’s General Data Protection Regulation (GDPR):
“(1) ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls on the relevant internet browser that you use.
In this policy, “we”, “us” and “our” refer to The Start up VC.
What personal information do we collect from the people that visit our website, or subscribe to the newsletter?
When registering to subscribe to the The Startup VC Newsletter, as appropriate, you may be asked to enter your name, email address or other details to help you with your experience.
When do we collect information?
We collect information from you when you subscribe to a newsletter or enter information on our site.
How do we use your information?
We may use the information we collect from you in the following ways:
We may process information contained in any enquiry you submit to us regarding our services. The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is consent.
We may process information that you provide to us for the purpose of subscribing to our newsletters. The notification data may be processed for the purposes of sending you the relevant newsletters. The legal basis for this processing is consent.
We may process data about your use of our website and services. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services.
We may process all relevant data in the course our service provision. The source of the service data is you or your employer. The service data may be processed for the purposes of providing our services, ensuring the security of our services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
We may process information that you post for publication on our website or through our services. The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Customer Relationship Data
We may process information relating to our customer relationships, including customer contact information. The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our services to customers. The legal basis for this processing is consent OR our legitimate interests, namely the proper management of our customer relationships.
We may process information relating to transactions, including purchases of services, that you enter into with us. The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests.
We may process information contained in or relating to any communication that you send to us. The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
Other Types of Data
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
In addition to the specific purposes for which we may process your personal data set out previously, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
How do we protect your information?
We do not use vulnerability scanning and/or scanning to PCI standards.
We only provide articles and information. We never ask for credit card numbers through the company website.
We use regular Malware Scanning.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information.
For your convenience we may store your credit card information kept for more than 60 days in order to expedite future orders, and to automate the billing process.
Do we use ‘cookies’?
Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.
If you turn cookies off; it won’t affect the user’s experience.
We do not sell, or trade, to outside parties your Personally Identifiable Information unless we are outsourcing tasks to our partner companies in other Latin American countries, and if this changes, we will provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when it’s release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property or safety.
In essence, we may disclose your personal data to any member of our group of companies. This means our subsidiaries, our ultimate holding company and all its subsidiaries. Insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
In addition to the specific disclosures of personal data set out in this policy, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
We may include or offer third-party products or services on our website.
International transfers of your personal data
The Startup VC operates outside the European Economic Area (EEA), and the majority of our business operations are outside the EEA. However, we will adhere to the requirements set out by the European Union in regards to the GDPR and implement safeguards to protect personal data of residents within the European Union.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary.
We will retain data collected whilst providing a service to clients for as long as stipulated in the agreed contract, if applicable.
In some cases it is not possible for us to specify in advance the periods for which your data will be retained. In such cases, we will determine the period of retention based on the customer relationship and series provided.
We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
We will notify you of changes to this policy by email.
We have implemented the following:
Demographics and Interests Reporting
We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.
How does our site handle Do Not Track signals?
We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Does our site allow third-party behavioral tracking?
It’s also important to note that we allow third-party behavioral tracking
Course of Action to be taken by The Startup VC if there is a data breach in compliance with the GDPR
The GDPR introduces a duty on all organisations to report certain types of personal data breach to the relevant supervisory authority. The Startup VC will notify the relevant supervisory authority within 72 hours of becoming aware of a breach, where feasible.
If the breach is likely to result in a high risk of adversely affecting individuals’ rights and freedoms, we will inform those individuals without undue delay.
We have in place robust breach detection, investigation and internal reporting procedures. This will facilitate decision-making about whether or not we need to notify the relevant supervisory authority and the affected individuals.
We will keep a record of any personal data breaches, regardless of whether authorities or individuals are required to be notified.
We do not SPAM
We collect your email address in order to:
- Send information, respond to inquiries, and/or other requests or questions
- Process orders and to send information and updates pertaining to orders.
- Send you additional information related to our services and contract with you.
- Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
We comply with several country regulations, and implement the following:
- Not use false or misleading subjects or email addresses.
- Identify the message as an advertisement in some reasonable way.
- Include the physical address of our business or site headquarters.
- Monitor third-party email marketing services for compliance, if one is used.
- Honor opt-out/unsubscribe requests quickly.
- Allow users to unsubscribe by using the link at the bottom of each email.
Your principal rights under data protection law are:
(a) the right to access
(b) the right to rectification
(c) the right to erasure (in some circumstances)
(d) the right to restrict processing (but only to the extent that the legal basis allows)
(e) the right to object to processing for direct marketing, historical or statistical research (but only to the extent that the legal basis allows)
(f) the right to data portability
(g) the right to complain to a supervisory authority
(h) the right to withdraw consent where consent is the legal basis for holding the data
Some of the rights are complex. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
If at any time you would like to unsubscribe from receiving future emails, you can
Follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.
You can contact us at any time to:
- Request information that The StartupVC has about you
- Correct any information that The StartupVC has about you
- Delete information that The StartupVC has about you
Data Protection Officer
Calle 98 #22-64