Privacy Policy
How we collect, use, disclose, transfer, and store your information.
Introduction
Ascentifi Limited and Ascentifi Clients Limited (both companies hereinafter referred to as “Ascentifi”, “us” or “we”) are committed to protecting your privacy. We have created this Privacy Policy to demonstrate our commitment to fair information practices and our respect for your right to privacy and the protection of privacy.
This Privacy Policy describes how we collect, use, disclose, transfer, and store your information. If you do not agree with the practices described in this Privacy Policy, please immediately cease using our services.
By continuing to use our services you are expressly accepting this Privacy Policy and agreeing to the terms and conditions contained within and are aware that it may change in the future to adapt to future practices, technology, or changes in the law.
We are a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this Privacy Notice.
The Privacy Policy explains the following:
(1) How we collect and use your personal data.
(2) The purpose and legal basis for collecting your personal data.
(3) How we store and secure personal data.
(4) Details of third parties with who we share personal data.
(5) What your rights are.
Changes to the Privacy Policy and your duty to inform us of changes
We keep our Privacy Policy under regular review. 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.
Contact details
If you have questions about this Privacy Policy or our privacy practices, including any requests to exercise your legal rights, please contact us by email at [email protected] or by physical post at Ascentifi Limited, Galway Technology Centre, Mervue Business and Technology Park, Galway, Ireland
Data protection principles
We will comply with data protection law and principles, which means that your data will be:
(1) Used lawfully, fairly and in a transparent way.
(2) Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
(3) Relevant to the purposes we have told you about and limited only to those purposes.
(4) So far as possible, accurate and kept up to date.
(5) Kept only as long as necessary for the purposes we have told you about.
(6) Kept securely.
Collected Information
In connection with the execution of our services we collect, store, and use the following personal data and information (“User Information”):
(1) Full name
(2) Postal address
(3) Contact details to include an email address and telephone number
(4) Nationality
(5) Date of Birth
(6) Identification documentation to include a copy of your passport or driving license and proof of address
(7) Know Your Client (KYC) data, such as wealth, income, indebtedness capacity, education, past investment experience, entities controlled by you, certified ID copies
(8) Payment Information
(9) IP address
(10) Visiting date to our website
(11) Login details, including dates and password
(12) Interaction with any of the services we provide
(13) Navigation details on our website such as web browser type, pages visited and saved, and any activity log files associated with same
(14) Data collected from third-party plugins/websites such as without limitation Facebook, Google, LinkedIn, Twitter, Mailchimp, GoDaddy, and DocuSign that are provided when you submit your information through these services.
How your personal information is collected
Personal data or information means any information about an individual from which that person can be identified. We will process personal information about you from the following sources:
(1) When you willingly and voluntarily submit User Information through web forms, by uploading User Information on our Website or through the Business Management Tools of the Website, or with your explicit consent by separate submission outside the website;
(2) From individuals confirmed by you to us as having been appointed by you to manage your interactions with us
(3) From organisations confirmed by you to us as having been appointed by you to manage your interactions with us
(4) When you access and navigate through our website
(5) When you submit an inquiry about a startup or Entrepreneur of your interest
(6) Through third-party plugins/websites
(7) Through cookies and other analytics tools
Cookies
We also use “cookies” to collect information. Cookies are small files, created when a user visits a website and stored on the user’s browser. Cookies are unique to each user and allow websites to customize browsing sessions for each visitor. When you access and use our website the cookie identifies your electronic device. We also use cookies to measure the traffic to and usage of the services we provide via our website and their different features. Our Cookies Policy is set out in a separate policy document that can be viewed here.
How we will use information about you
We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances:
(1) Where processing is necessary for the performance of a contract to which you are a party.
(2) Where we need to comply with a legal obligation.
(3) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
(4) To provide you with email alerts on interesting early stage ventures.
(5) To communicate with you.
(6) To provide the Business Management Tools to the Users;
(7) To allow us fulfill your subscription to our newsletter which provides news and updates such as new early stage ventures matching your interest.
(8) To provide you with targeted marketing and advertising tailored to your preferences.
(9) To keep you engaged with Ascentifi and our services;
(10) To improve our services;
(11) For cybersecurity.
(12) For statistical and planning purposes.
Generally, we do not rely on consent as a legal basis for processing your personal data.
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. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Third-party websites
Our website may contain links to other websites. This Privacy Policy does not apply to the practices of any company or individual that Ascentifi does not control, nor to any websites that may be linked from our website.
You should carefully review the privacy policies of any websites that your visit from our website to learn more about their information and privacy practices. The collection and use of User Information or any other personal information shall be governed by such other party or website’s privacy policy. Ascentifi cannot be held responsible for their privacy practices. In particular, our website contains links to third-party websites such as listed in the “Collected Information” paragraph of this Privacy Policy. Their privacy policies can be found on their respective websites.
Data sharing with third parties
Ascentifi may in some limited instances communicate User Information to specific third parties, on a strict need-to-know basis, to achieve the purposes described in this Privacy Policy. These parties include;
(1) Our employees and personnel
(2) Investors, with respect to Entrepreneurs and vice versa;
(3) Service providers such as the companies listed in the “Collected Information” paragraph of this Privacy Policy.
(4) Competent courts or supervisory or regulatory bodies, when we shall compellingly disclose User Information, pursuant to any applicable law, regulation or order.
(5) Our IT systems providers, cloud service providers, database providers and consultants.
(6) Business partners with whom we conduct business with which are necessary for us to jointly offer services
(7) Any third-party to whom we assign or transfer any of our rights or obligations.
(8) Our legal counsel
(9) Any companies you may invest in using our services, but only if they specifically request it (for instance to ensure there are no conflicts of interest)
(10) The other investors who are signing the same Agreements and/or Investment Documentations as you. For example, the names, addresses, and phone numbers of all investors party to any specific investment may be listed in certain documents specific to that investment.
All third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Requirement to Provide Data
You are not under a statutory or contractual duty to provide us with any personal data. However, there are some pieces of information, such as your name, postal address, email address, phone number and KYC information that you must provide to us to facilitate any investments you choose to make. If you do not provide us with this information, we will not be able to facilitate your investment.
Transfers of personal data outside the EEA
Our website and associated databases are stored on servers that reside in the EU. However, it is possible that User Information may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction, where the privacy laws may not be as protective as those in your jurisdiction. In submitting such User Information, you specifically agree to that transfer.
Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Data retention
We will retain your personal information for as long as necessary to facilitate any investments you choose to make through us. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have complied with our obligations. After this period, we will contact you to confirm whether you wish us to (a) retain your personal information so you can be contacted by us in relation to facilitating other investments or (b) securely destroy it.
Your legal rights
Under certain circumstances, by law you have the right to:
(1) Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
(2) Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected
(3) Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
(4) Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
(5) Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
(6) Complain to the Data Protection Commission (“DPC”) the Irish supervisory authority for data protection issues (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.
If you have any questions or concerns about your rights, when they apply or our Privacy Notice or data processing; wish to review the information you have supplied to us; request that we correct any errors or update your Personal Data; or if you would like to make a complaint about a possible breach of applicable privacy laws, please contact us using the contact details provided in this document.
We are obliged to respond within a reasonable time frame. In most instances, we will respond within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar months. Should this be necessary, we will explain the reasons why.
You have the right to complain to the Data Protection Commission or another supervisory authority. You can contact the Office of the Data Protection Commission at:
https://www.dataprotection.ie/docs/Contact-us/b/11.html
Telephone: +353 (0)761 104 800 or Lo Call Number 1890 252 231
Fax: +353 57 868 4757
E-mail: [email protected]
Postal Address: Data Protection Commission, Canal House, Station Road, Portarlington, R32 AP23, Co. Laois
Governing law and jurisdiction
This Privacy Policy and all matters arising out of or relating to this Privacy Policy shall be governed by Irish law at the exclusion of any provisions of conflict of law rules that might lead to the application of other than Irish law. You irrevocably submit to the exclusive jurisdiction of the competent courts of Galway, Ireland, for any conflict arising from or in connection with this Privacy Policy.