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Privacy Policy

Last Updated: May, 2022

1. ABOUT US

Underline Ventures B.V., a private company with limited liability (“besloten vennootschap met beperkte aansprakelijkhed”), organised under the laws of the Netherlands, having its registered seat at Basisweg 10, 1043AP Amsterdam and registered at the Trade Register of the Dutch Chamber of Commerce under number: 84625945 (“Underline”, “we”, “us” or “our”) is the controller with respect to your personal data. This means that we decide the purpose and the way your personal data is processed, as specified in this Policy.

2. ABOUT THIS POLICY

This Policy describes how we collect and use the personal information you provide to us when you use our Website (as defined in the Terms), when you access any tools to submit any applications or requests to us and go through any of our application processes (including, but not limited to jobs applications) (collectively referred to as the “Services”).

From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any material change to the way we collect or process your personal data we will provide you with more information or additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.

Our Cookie Policy provides more information on how we use cookies. You will also find information about how you can manage your cookie preferences and opt-out of certain types of tracking.

3. WHAT DO WE UNDERSTAND BY PERSONAL DATA?

Personal data is the information related to a natural person and which can be used to identify that person such as name, email address, telephone number, social media usernames, location data or business titles.

This means that when you use our Services, we will collect certain information about you (“personal data”) which can identify you directly (name, email) or indirectly (IP address or another online identifier).

4. WHAT PERSONAL DATA WE PROCESS?

When you use or interact with our Services, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the table below the categories of personal data we process:

User data

This is the personal data that is provided by you to Underline, including, but not limited to, by subscribing to our email communications or newsletters, by submitting any application or request to us, by using our Website (as defined in the Terms), or by any other means. Such data may include your first and last name, email address, phone number, mailing address, IP, as well as other personal data you may provide directly to us, and/or if requested by Underline in order to fulfill the purposes described below. 

Usage Data 

This is the personal data that is collected about you when you’re accessing and/or using and visiting our website. Such data may include URL information, IP addresses, online identifiers including cookies, browsing or search history, non-identifiable request IDs, statistics associated with the interaction between device or browser and the services, which are subject to our Cookie Policy and to this Privacy Policy.

Job Applicant Data

We use the personal data contained in the CVs and/or job applications we receive in order to assess the applicants’ qualifications for a position within Underline and/or any of its Affiliates.

The categories of data processed in the context of our relationship with you are the personal data included in the provided CV and/or job applications, which can contain your name, e-mail, phone, fax, address, education and training details, professional qualifications, job title, job history, as well as other personal data you may provide directly to us, as per our additional request.

Professional Data

This is the personal data that is provided by you as a Underline partner or as company’s representative, contact person, employee or other collaborator of said company. Such data may include your name, title/position, email address, phone, fax, business address IP, professional qualification as well as other personal data you may provide directly to us (for example when you seek our investment or promotion as a company founder), and/or when requested by Underline in order to fulfill the purposes described below.

Contests, Surveys and Sweepstakes Data

When you complete any forms, respond to a survey or questionnaire, or participate in a contest, we collect the personal data you provide.

We do not and will never collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, health, genetic or biometric data).

5. HOW IS YOUR DATA USED AND ON WHAT GROUNDS

We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data (identified above under ‘WHAT PERSONAL DATA WE PROCESS’) used for these purposes:

Processing purpose
Legal basis for the processing purpose
Categories of personal data used for the processing purpose

To provide and perform the Services you requested from us

  • Performance of a contract
  • Legitimate Interest
  • User Data
  • Professional Data
  • Usage Data

To communicate with you with respect to any relevant matters in connection to your requests

  • Performance of a contract
  • Legitimate Interest
  • User Data
  • Professional Data
  • Usage Data
  • Job Applicant Data

To ensure a good contractual relationship with you 

  • Performance of a contract
  • Legitimate Interest
  • User Data
  • Professional Data

For marketing, promotion, and advertising purposes and for sending you related email communications and/or newsletters

  • Consent
  • Legitimate Interest
  • User Data
  • Professional Data
  • Usage Data

To comply with legal obligations and law enforcement requests

  • Compliance with legal obligations
  • Legitimate Interest
  • User Data
  • Professional Data
  • Job Applicant Data
  • Usage Data
  • Contests, Surveys and Sweepstakes Data 

To fulfill contractual obligations with third parties and to take appropriate action with respect to reports of intellectual property infringement and inappropriate content

  • Legitimate Interest
  • User Data
  • Professional Data
  • Usage Data

To establish, exercise, or defend legal claims

  • Legitimate Interest
  • User Data
  • Professional Data
  • Usage Data
  • Contests, Surveys and Sweepstakes Data
  • Job Applicant Data

To conduct business planning, reporting, and forecasting

  • Legitimate Interest
  • User Data
  • Professional Data
  • Usage Data

To detect fraud, including the and fraudulent use of the Services

  • Compliance with legal obligations
  • Legitimate Interest
  • Performance of a Contract
  • User Data
  • Professional Data
  • Usage Data

To conduct research, contests, surveys, and sweepstakes

  • Consent 
  • Legitimate Interest
  • User Data
  • Usage Data
  • Professional Data
  • Contests, Surveys and Sweepstakes Data

To process job applications

  • Legitimate Interest
  • Compliance with a legal oblications
  • Job Applicant Data

6. TO WHOM WE DISCLOSE YOUR PERSONAL DATA?

Your Data may be shared with the recipients listed below:

  • as Underline is a global company, we may disclose your contact details to our affiliates, including Underline Advisor SRL, to be able to providee any services and to fulfil the purposes stated above.
  • we may provide access to or share your information with selected third parties, such as fund management services providers, intermediaries or external advisors who perform services on our behalf, including without limitation administration and fund management activities (such as know your client and any-money laundering), investment services, communications, market research, payment, emailing and computer services, and legal services. 
  • we may share your personal data with Intertrust Group B.V. (the Netherlands, 1097 JB Amsterdam, Prins Bernhardplein 200) and with to Intertrust N.V. (with same registered office) and to its direct or indirect subsidiaries (hereinafter “Intertrust”). Intertrust will process your Personal Data in accordance with Intertrust’s Privacy Notice, available here https://www.intertrustgroup.com/legal/data-protection-and-privacy/. 
  • we may share your personal data with our business partners, investors, and with persons who have subscribed to our newsletter;
  • we may further disclose your information to any third parties based on your consent to do so.

We may also provide personal data to third parties in the following situations:

  • to public authorities, auditors, or institutions competent to exercise inspections on Underline, which may ask us to provide information, based on their legal obligations.
  • to comply with a legal requirement or to protect the rights and assets of Underline or other entities or people
  • to third party acquirers, if Underline’s business would be subject to a change of control or other similar procedure or acquisition and your personal data would be part of the transaction.

You can always reach out to us at […] find out more details on the third parties we may share your data with.

7. WHAT ANALYTICS TOOLS DO WE USE?

When you are visiting our website, we are using cookies, a small software file stored temporarily or placed on the hard drive of your device to allow a web server to identify your device and the web browser you use, to recognize you when you are visiting the site again. Cookies may also store preferences or other information about you.

8. IS YOUR DATA TRANSFERRED ABROAD?

Underline is a global company so your data is shared with Underline’s affiliates; therefore, in order to achieve the purposes described to you in this policy and in accordance with our legal and contractual obligations we may share your data with our affiliates located in Romania, namely Underline Advisors SRL. 

We make sure that your data is kept and transferred safely, by respecting European legal requirements for data transfers.

Some of our external third-party suppliers may be based outside the European Union (“EU”). Their processing of your personal data will involve a transfer of data outside the EU. Whenever we transfer your personal data out of the EU, we endeavour to ensure one 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 decisions;
  • where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe and which cannot be changed by the parties;
  • where such data cannot be afforded one of the safeguards above, we shall only transfer such data outside the EU where it is necessary for performing our contract with you or we have your fully informed, active, clear and specific consent. We shall take all steps necessary to ensure that your personal data is protected when we transfer it outside the EU.

9. HOW LONG DO WE STORE YOUR DATA?

We will store and process your personal data only for the period of time necessary in order to achieve the purposes described to you in this policy and in accordance with our legal and contractual obligations.

For using Underline’s website we store your data up to 3 years from your termination of such use, except for the cases when legal requirements state otherwise. After the duration of the processing expires and Underline no longer has legal or legitimate reasons to process your personal data, the data will be deleted in accordance with its procedures, which may involve archiving, anonymizing or destroying it. 

In the case of Job Applicant Data, if no offer shall be provided to you in the recruitment process, or you shall decline the offer provided you with, we shall erase all your personal data from our system 1 year thereafter, as long as you do not request us to keep your data in our data base for future recruitments.

When we process data based on your consent and/or based on our legitimate purpose, we shall process your personal data for a period of 3 years, afterward being immediately deleted from our records, unless we have compelling legitimate interests that override your rights under this policy and the GDPR. 

When the processing is based on the need to comply with a legal  or contractual obligation, we shall retain the data for as long as it is required to comply with such obligation.

Data obtained by your subscription to our newsletter will be processed for as long as you do not unsubscribe.

10. DO WE PROCESS PERSONAL DATA FROM CHILDREN?

Our Services are not designed or intended for use by children. If you are under the age of eighteen (18), please do not submit any personal data through the Services. If you have reason to believe that a child under the age of 18 has provided personal data to us through the Services, please contact us at […] and we will endeavour to delete that information from our databases.

11. IS YOUR DATA SECURE?

We care about the security of your personal data. Therefore, we implement appropriate and proportional security measures, in accordance with industry standards.

12. WHAT HAPPENS IF YOU DON’T AGREE TO YOUR PERSONAL DATA BEING PROCESSED?

If you refuse to have your personal data processed, we will not be able to enter into contract with you for providing the Services, or otherwise interact with you as described in this Policy.

13. WHAT ARE YOUR RIGHTS?

When we process your personal data, it is important to know that you have the following rights:

  • The right of access to the personal data we process about you: you have the right to obtain a confirmation whether or not we process your personal data, and, if so, to have access to the type of personal data and to the conditions of processing, by sending us a request in this regard
  • The right to request the rectification or deletion of personal data: you have the right to request, the rectification of inaccurate or incomplete personal data which we have about you, or the erasure of your personal data in case (i) the data are no longer necessary for their original purpose (and no new lawful purpose exists), (ii) we initially process your data based on your consent and you withdraw your consent and therefore no lawful ground exists anymore, (iii) you object and we have no overriding grounds for continuing the processing, (iv) the data have been processed unlawfully, (v) erasure is necessary for compliance with EU law or other applicable law;
  • The right to request the restriction of processing: you have the right to ask for the restriction of processing in cases where: (i) you consider that the personal data processed is inaccurate, for a period enabling us to verify the accuracy of the personal data; (ii) the processing is unlawful, however you don’t want us to erase your personal data, but to restrict the use of data; (iii) in case we no longer need your personal data for the purposes we described in this Policy, but you are requiring the data for establishing, exercising or defending a legal claim or (iv) you have objected to processing pending the verification whether our legitimate grounds prevail;
  • The right to withdraw your consent for processing, when the processing is based on your consent, without affecting the lawfulness of processing undertaken until that moment
  • The right to object to the data processing on grounds related to your particular situation, when the processing is based on legitimate interest and to object at any moment to the data processing for direct marketing purposes, including profiling
  • The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects for your similarly affect you in a significant manner
  • The right to data portability, meaning the right to receive your personal data, which you provided us in a structured, commonly used and machine-readable format and the right to transfer those data to another controller, if the processing is based on your consent or the performance of a contract and is undertaken by using automatic means
  • The right to object to direct marketing – from time to time, Underline may send emails containing information about our people, organization and application process, topics relevant to startups, and profiles of founders and companies and other news about us.  This is considered direct marketing. Where personal data are processed for direct marketing purposes, you have the right to object at any time and free of charge to the processing of your personal data for direct marketing purposes by clicking “Unsubscribe” when you receive the respective e-mail or by writing at […]. If you object to the processing for direct marketing purposes, the your personal data shall no longer be processed for such purposes. These options, however, do not apply to other communications where the main purpose of such communications is not of promotion.
  • The right to file a complaint with the with your national Data Protection Authority and the right to address to the competent courts of law.

No fee is usually required for the exercise of the above rights

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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 and contact details

We are happy to ensure your exercise of these rights. You may exercise your aforementioned rights and find out more about such rights by filing with us, as data controller by e-mailing us at […]. We shall review your request and reply within a 30 days term. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

We are committed to always treat your requests with the utmost attention and address any queries you may have in the shortest time possible.

UPDATES TO THIS POLICY

This Privacy Policy may be changed and updated by us from time to time as it could become necessary. We will notify you of any substantial changes to this Privacy Policy and will ensure that the notification is made in a way which ensures that you acknowledge them, for example by using the email address that you have provided to us, or by displaying a prominent notice within the Service. If you do not agree with the changes, you may always stop using the Services.

Thank you for reading our Policy. You can always reach out to us at […] if you have any questions regarding the processing of your data by Underline.