Uni.Fund Privacy Notice _Summary
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1Opening Note
Personal data is commonly exchanged, collected and processed in the business world without a second thought and, often, without considering privacy and data
protection. Here in Uni.Fund we value your privacy and the protection of your data significantly, considering it an indispensable part of the mutual trust between
us, therefore we make systematic efforts to protect your personal data and preserve your privacy.
We have crafted our personal data related Policy and our privacy-sensitive operations with your privacy and the protection of your data constantly in mind.
- Introduction
By “personal data” or “personal information”, we mean information about you, both as an individual and as a member of a team applying to Uni.Fund, from
which you may be identified.
There are multiple occasions or reasons for which you may choose or be asked to disclose personal data to Uni.Fund. For example:
- to contact Uni.Fund or during your communication with a Uni.Fund member,
- to apply in order to become one of the teams we invest on,
- during the application procedure,
- upon joining the Uni.Fund as a team we invest on,
- throughout other procedures related to Uni.Fund activities,
- in networking and other similar events.
Also, throughout the activities of Uni.Fund we may share information about you – including your personal data – with others, or your personal information might
be disclosed to us, by individuals or entities you have shared your personal data with.
In the following pages you will find a summary of our Privacy Notice, prepared for your convenience. You are strongly advised to read also the Detailed Version,
as it includes all the necessary information for you to know with certainty the reasons and the purposes for which we collect and process your personal data, the
ways we process it, the principles of processing we apply, for how long we retain your data and how we protect it, who has access to your data, to whom we may
disclose your data, what rights you have on your data and how you may exercise them.
If you have any question do not hesitate to contact us via e-mail at [email protected] prior to disclosing or otherwise personally sharing any data with us.
Please note that any data collected and/or processed by Uni.Fund is governed by this Privacy Notice. Disclosing your data to Uni.Fund or otherwise sharing us (for
example by e-mailing one of the Uni.Fund team members) it is assumed that you have read and accepted this Notice.
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- Update or amending the current Privacy Notice
Due to developments in business and/or technology we may need to change or amend the current Privacy Notice. We strongly encourage you to visit this chapter
of our website regularly in order to remain informed and updated about any change or alternation. If we make a material change to this Notice, you will be
provided with appropriate notification.
This privacy Notice was lastly updated on June 2019. - Persons under 18 years of age
If you are under 18 years of age you should not disclose or otherwise share your personal data with Uni.Fund, as we cannot, and we will not collect and/or process
your data. If you are disclosing the data of your team in the Application Form or sending us material about your team via e-mail, please refrain from disclosing any
personal data of a team-member that is under 18 years old.
If we realize that we have in anyway collected data of a person under 18 years of age, it will be instantly and permanently deleted in a secure way. - Who we are
This Privacy Notice governs the personal data collected by or otherwise disclosed to and/or processed by the Uni.Fund team members, as well as by our partners,
advisors, consultants, experts, mentors and members of the closer or extended Uni.Fund network.
Uni.Fund is a Fund financed by the Greek ESIF Fund of Funds TAESYM under the European Union/European Regional Development Fund/Operational Programme
EPANEK, registered under Greek Law as a venture capital management company. Our registered office is located in Agiou Dimitriou 4, Athens 10554. You may
contact us calling +30 211 8003764, sending an e-mail at [email protected], or using our website contact form (https://uni.fund/#contact). Particularly for questions
related to this Privacy Notice, the Privacy Policy we are following or in order to exercise your rights on your personal, please send an e-mail at [email protected].
Our purpose is to support entrepreneurship, unveil the hidden potential within Greek Universities, R&D and Tech Space, by focusing on people and team
development, implementation of successful go-to-market strategies and helping build the foundations of the entrepreneurial ecosystem.
To achieve our goal, apart from the Uni.Fund team, which you can find in our website (https://uni.fund/) we are also supported by a group of advisors, and we
also cooperate with a large network of business and industry partners, both individuals and legal entities, which share our purposes, and assist us in achieving our
goals.
Throughout this Privacy Notice “we”, “us”, “our” etc. refer to the Uni.Fund team.
Similarly, throughout this Notice our partners, advisors, consultants, experts, mentors and members of the closer or extended Uni.Fund network, will be referred
to as “our group of experts.”
Uni.Fund Privacy Notice _Summary
Page - What type of personal data we collect, when and how
The categories and amount of personal we collect about you depend on the purpose for which it is collected, the stage of the Application Procedure you are at
and the relationship you have with us. In principle, we collect the personal data that you share with us, in written format through the Contact Form, Newsletter
form, Application Form and through the designated forms sent to your during Stage 2 of the Application Procedure. We may also collect personal data about
you through e-mails you may exchange with members of our team, for example throughout the application procedure. In some occasions personal data about
you may be disclosed to us by third parties, including other actors of the ecosystem, in terms of reference or recommendation.
Broadly we collect and process:
- Your name
- Your contact details
- CV-related information about you
- CV-related information about you that you have made publicly available in your LinkedIn profile
- Information, including personal data, about you disclosed to Uni.Fund by third parties
- Information, including personal data, that you choose to share with Uni.Fund, even if they are not asked for
In terms of the Termsheet (TS) we shall collect the full name of the legal representative of the company, and information, including personal data, about the
shareholders. More specifically we will need to collect and process for the shareholders: - Their full name
- Their address
- Their identity card number
- Their tax number and taxation registry office
We will share this data with our lawyers to prepare the TS. In the same process, if it is considered necessary, a member of Uni.Fund will also introduce you via email (sharing your name and contact details) to our lawyers to work with them in order to finalize the terms.
In terms of the Legal and the Financial Due Diligence (L&F DD) a member of Uni.Fund will introduce you to our legal and financial auditors, who will ask you to
disclose and share with them additional personal data, including personal data from public authorities, economic institutions etc., in terms of the due diligence
investigation and the relevant background check, necessary before making a final investment decision. This data will be disclosed directly to our legal and financial
auditors and Uni.Fund shall have no access to information and/or personal data collected and processed throughout this procedure. Uni.Fund will only receive
the verdict, after the L&F DD is completed, to make its final decision, confirming or rejecting the investment.
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4If the decision is positive, in terms of the Shareholders Agreement (SHA), we will ask to collect, process and share with our lawyers, for every shareholder: - their father name,
- mother name
- phone number,
- an e-mail address,
along with the data from the TS, for the preparation of the contract between us.
Important Note:
In case the headquarters/registered office of your company is outside Greece, in terms of the TS, L&F DD and for the SHA, we will introduce you and ask you to
disclose the relevant data to legal and financial auditors and lawyers in the country that you have your headquarters. The same principles described formerly
apply in this case as well.
For more details, see section 6. of the Detailed Privacy Notice and bellow the summary under 14.
- Why we collect and how we process your personal data
In most cases the basis allowing us to collect and process your personal data is your consent for the purposes of assessing and evaluating your application and
your proposal and contacting you on matters related to your application, and for reasons of reference or recommendation, in terms of Uni.Fund’s aims, objectives
and purpose. We may also collect and process your data to prepare the TS, and the Shareholders’ Agreement (SHA), as previously explained, and ask you to disclose
your data to our legal and financial auditors and Uni.Fund in terms of the L&F DD.
We may collect and process your data to comply with our legal obligations, the obligations and responsibilities we have towards our investors, and/or to protect
our legal rights, including, but not limited to, complying with record-keeping, reporting to our investors and the competent public authorities, tax obligations
under applicable law etc.
Our use of your personal data is in our legitimate interest as a venture capital Fund, (for example to assess the potential of your proposal, to explore the investment
risk, to verify your identity and prevent any form of fraud, to report to our investors etc.)
Prior to collecting and processing your personal data you will be notified about the purpose for which your personal data will be processed. In case you do not
wish to provide us with this information, you wish to withdraw your consent or decide to ask us to stop the processing, we may not be able to proceed further
with the evaluation of your proposal/project/idea or investing in your company/proposal/project/idea.
For more details, see section 7. of the Detailed Privacy Notice and bellow the summary under 14.
Uni.Fund Privacy Notice _Summary
Page - Who has access to your personal data and why
We follow a purpose-specific data-access plan, aiming to reduce the diffusion of personal data, limiting access to your personal data only to those absolutely
necessary. In principle, your personal data is only accessible by the Uni.Fund team members.
More specifically, during the Application Procedure, according to the stage of the Application Procedure you are at, we may share pieces of your personal data
appropriate and absolutely necessary for the fair evaluation of your proposal with our group of experts, as described in this Notice. We will also disclose your data
to our financial and legal auditors, and lawyers to prepare the TS, the SHA and conduct the necessary L&F DD, or any additional, relevant background check
and/or to assess the investment risk, or to any administrator, auditor or trustee of our investors, in accordance to our obligations, respecting your privacy and
applying proportional limitations. If you have given your consent, we may share your personal data for purposes of recommendation or reference, to other actors
of the ecosystem and/or members of Uni.Fund closer or extended network.
We may use and disclose information about you as we believe proportionally and reasonably necessary to protect the rights and legitimate interests, including
to establish legal claims or defenses, to obtain legal advice, to defend our legal rights, to protect our rights and our investors, to protect against fraud and abuse,
and to protect the life, body, or property of others (individuals or entities).
We also may disclose information about you in order to comply with the law, judicial proceeding, court order, or other legal process, such as in response to a
court order or direction.
For more details, see section 9. of the Detailed Privacy Notice and bellow the summary under 14. - International Personal Data Transfer
For purposes directly connected with the fair evaluation of your proposal, we may need to seek input from our group of experts, for which we may need to
transfer information, and in some cases personal data, principally within the European Union (E.U) or, if you have so consented, also outside the E.U. Additionally,
if you have given us your consent, we may also share your data in terms of recommendation or reference with actors of the ecosystem and/or members of
Uni.Fund closer or extended network, within or outside the E.U.
In case during the evaluation procedure we consider that it is absolutely necessary to seek input from our group of experts residing outside the EU, in principle
we do so without sharing your personal data. However, if we consider that for the fair evaluation or to receive meaningful feedback regarding your proposal, it
is absolutely necessary the background, experience and skillset of the team to be also taken into account, we shall share your proposal and the CV-related
information you have disclosed through the Executive Summary Template without your name, provided that you have given us your consent.
Similarly, you may give us your consent to share your data for recommendation or reference purposes within the E.U. and/or outside the E.U. through the Executive
Summary Template without your name.
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6In case the headquarters/registered office of your company is outside Greece, in terms of the TS, L&F DD and for the SHA, we will share your full name and contact
details with legal and financial auditors and lawyers in the country that you have your headquarters, after introducing you, so that you will share the necessary
information, including personal data, with them, for the purposes of preparing the TS and/or the SHA, and conduct the L&F DD, or any additional, relevant
background check and/or to assess the investment risk.
In case of transfer of your personal data to any third countries, as defined by GDPR, applicable legislation and regulations concerning such transfers are observed
and relevant legal and security safeguards are ensured before such transfer.
In accordance to Art. 45§1 of the GDPR, we transfer personal data only to third countries that the E.U. Commission has decided that ensure an adequate level
of protection.
For more details, see section 10. of the Detailed Privacy Notice and bellow the summary under 14. - General Principles of Collection and Processing
The collection and processing of your personal data by Uni.Fund is always in line with our legal obligations, in compliance with the GDPR 2016/679. (For more, see
our Detailed Privacy Notice)
The collection and processing of your data will be always lawful, fair and transparent, in accordance to our legal obligations and the requirements of the General
Data Protection Regulation (GDPR) and the relevant legal provisions. More specifically:
- Your data will be collected and processed only for the specific, concrete and legitimate purposes for which you shared it with us.
- We only collect and process the type and amount of personal data that is relevant, appropriate and absolutely necessary depending on the purpose for which we
have asked you to share it with us. - We will not disclose or otherwise share your personal data without your consent, and we shall not process it for any other reason than those explicitly explained
and directly connected with the purposes and activities of Uni.Fund. - We process your data respecting your privacy and in accordance to the principles and limitations set by law.
- We will process and retain your data only for the period of time necessary and appropriate in accordance to the purpose of collection and processing.
- We make systematic efforts for your data to be always safe and accurate for the entire period of time that it will be processed and retained by Uni.Fund. To that
end we have applied and follow a specific Privacy Policy, while we have also taken all the necessary and suitable technical and organizational measures to ensure
the integrity, availability, safety, security and protection of your personal data and the preservation of your privacy. - Whenever we share your data with others we make sure that we have informed you and obtained your consent, while we have also taken every reasonable and
necessary measure to ensure that your data is safely transferred and processed according to the requirements of the GDPR and the relevant legal provisions,
following the same high standards of privacy and data protection that we apply.
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710.Where your data is stored
Your personal data is digitally stored in HubSpot and Google Drive. All information you provide to us is stored on our secure servers.
More specifically:
o All the information, including personal data, that is disclosed to Uni.Fund throughout the Application Procedure is stored for each application in the
Applicants’ Folder.
o All the information, including personal data, that is stored from individuals or teams whose project was collected by Uni.Fund for the purpose of
recommendation or reference, or for future projects, along with information collected by business cards, or references by third parties that are not
disclosed for application purposes, as well as personal data from our consultants, advisors, experts etc. will be stored in the Contacts’ of Interest Folder.
You can read more about our Processing Agreement with HubSpot at https://legal.hubspot.com/dpa and the Privacy Policy of HubSpot at
https://legal.hubspot.com/privacy-policy.
You can read more about Google Drive Privacy Policy at https://policies.google.com/privacy.
In physical form your data is stored in folders in Uni.Fund registered office. Particularly the business cards we collect or those that are shared with us, are stored
in physical form in our Business Cards Repository.
Important Note:
Unfortunately, the transmission of information via the Internet is not completely secure. Even though we make systematic efforts to protect your personal data,
it is impossible for us to guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information,
including personal data, we shall apply the protective procedures as described under 13.
11.For how long we retain your data
Uni.Fund applies a purpose-specific policy to define the period of time for which it processes and stores your data.
In principle, we retain information, including personal data only for as long as necessary in accordance to the purpose for which you shared your personal data
with us, to fulfil the purposes described in this Notice, or as required by law, regulation, or internal policy, considering also our obligations towards our investors
and the requirements – set by the public authorities and law. We are obliged to retain certain information to ensure accuracy, to help maintain quality of service,
and for legal, regulatory, fraud prevention and legitimate purposes related to the operation of a venture capital Fund.
For more details, see section 11. of the Detailed Privacy Notice and bellow the summary under 14.
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812.How we protect your data
We use every commercially reasonable physical, electronic, technical, organizational and procedural safeguard to preserve your privacy and protect your personal
data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction in accordance with applicable law.
We apply every available, reasonable and appropriate protective procedure to ensure the integrity, confidentiality and availability of your personal data. Yet please
keep in mind that despite our best efforts, no data security measures can guarantee 100% security all of the time.
The information you share with Uni.Fund, including personal data, is safe stored in Hetzner Online servers, awarded with ISO/IEC 27001, the best-known standard
in the family providing requirements for an information security management system (ISMS).
We have established policies and procedures for the protection of personal data and the preservation of your privacy, including raising awareness among our team
members, incorporating clauses and confidentiality agreements that bind all the members of the Uni.Fund team, as well as all group of experts, advisors and
everyone else with whom we may share your data in terms of the evaluation procedure, as previously explained. We will not transfer your data to third parties
unless we ensure that they apply equivalent security measures to protect your data.
We shall not grant access or transfer your personal data to our group of experts, advisors or any third party, even without your name and information that allow
your direct identification, without ensuring that they apply and follow similar measures and plans regarding the protection of your personal data and the
preservation of your privacy.
Our digital files are kept in computer systems and in cloud, accessible only by the Uni.Fund team. All our assets used for the collection and process of personal
data are regularly reviewed to ensure that they are protected against malicious attacks and unauthorized access through relevant software and passwords. We
make regular backups to ensure the preservation of the integrity and availability of your personal data.
We make every reasonable effort to use encryption and other means of data protection to the extent possible.
In the effort to keep your data up to date we invite you to inform us about any meaningful alteration in your personal data. We will promptly update your
applicant’s folder upon receiving relevant information.
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913.The rights you have on your personal data
The GDPR provides you with some specific rights concerning your personal data, that Uni.Fund respects totally, and will actively ensure that you can exercise each
and/or all of them freely. More specifically you have the right:
(i) to be always informed about the reasons and purposes for the collection and processing of your data, the time limits of processing and storing of your
data, the principles of processing, those involved in collection and processing, as well as asking and obtaining any relevant information,
(ii) to access the data we have about you, namely ask us to disclose which data we have about you, how and when we obtained it, and receive a copy,
(iii) to rectify the data we have about you, in case a piece of your personal data has changed while we retain it, so as to ensure that the data we have
about you is always accurate, updated and suitable for the reasons/purposes for which you have disclosed it to Uni.Fund,
(iv) to request a copy of your data in a convenient/ appropriate format to be transferred to a third party or used for other purposes (data portability),
(v) to request us to erase your data,
(vi) to object to further processing and ask us to refrain from furtherly processing your data,
(vii) to withdraw your consent,
(viii) to file an official complaint: if you have any concerns about possible interference with your privacy or misuse of your personal data on our behalf, you
may contact us to file a complaint. We hope that we can answer any questions you may have about how we process your personal data and resolve
any issue that may occur. However, if there are unresolved issues that concern you, you also have the right to complain to the relevant data protection
authorities. For the authority’s responsibility and how to submit a complaint, you can visit its website (www.dpa.gr-My rights-submit a complaint),
where there is detailed information.
The rights related to automatic decision making and profiling are not applicable in this case, as we are not using automated procedures and/or profiling via
similar means, and for all that matters, no significant decision will be made about the applicants and their applications solely based on even manually conducted
profiling.
You may freely exercise your rights sending an e-mail at [email protected].
Uni.Fund Privacy Notice _Summary
Page1014.Summary of the main information related to collection and processing of personal data by Uni.Fund
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Stage 3a: Term Sheet
- In case the headquarters/registered office of your company is outside Greece, in terms of the TS, the lawyers involved will be based in the country that you have your
headquarters, following the same principles applied for companies in Greece.
Uni.Fund Privacy Notice _Summary
Page16*The purpose for which we may collect and process the personal data from a business card may vary, also according to your own request when sharing your card.
**Offering your business card to a Uni.Fund member we assume we have your consent to collect and process your data for the purpose for which you have shared it with us,
and for the purposes, visions and functions of Uni.Fund.
***Access may vary according to the purpose for which you shared your business card with Uni.Fund, or the ways Uni.Fund may process your data in accordance to the
purposes, visions and functions of Uni.Fund, for example to recommend you.
Personal data shared with our advisors
Apart from our group of experts, Uni.Fund cooperates on a permanent basis with two advisors, an Intellectual Property Rights (IPRs) attorney and an Information
Technology (IT) expert.
We may share your data with our IPRs attorney in cases related to patents or other IPRs. More specifically, in case your project/proposal/idea involves IPRs, during
the Second Stage of the application procedure, we will share with her the information you disclose through the Uni.Fund_ExecutiveSummary_Questionnaire,
asking for her insight. To share your data with her we follow the principles of International Data Transfer described in our Detailed Privacy Notice. Additionally, if
we consider it necessary, for the fair evaluation of your application, or if we have valid reasons to believe that your application/proposal would be benefited from
her consultation, we may personally introduce you to our IPRs attorney via e-mail. In that case, she will have access to your name and e-mail addresses used for
the communication, and any other personal data you may share with her in terms of your communication.
Our IT expert has an active role in the Application Procedure. Due to his expertise and valuable experience, we may share with him non-personal information
regarding your application/proposal, seeking for his input throughout the evaluation process. Moreover, he will have access to the data you disclose through the
Uni.Fund_ExecutiveSummary_Questionnaire. Finally, if we consider it necessary for the fair evaluation of your application, or if we have valid reasons to believe
that your application/proposal would be benefited from his consultation in technology-related issues, we may personally introduce you to him via e-mail. In that
case we may share with him your team contact information for communication purposes or to arrange meetings. Thereafter, he will have access to whatever
personal information you share with him in terms of your communication.
Personal Data shared with Uni.Fund by third parties
Within the rich ecosystem of business, startups and Funds it is a common practice to share personal data, making references, commonly without asking for the
permission/consent of the person in question. Therefore, your personal data, most commonly name and contact information, and sometimes also CV- related
data, for example employment information, education and job experience details, might have been disclosed to us by a third party, for example another Fund, an
external partner etc. in the form of reference or recommendation.
If, according to the reference and/or recommendation made, your company/team/project/idea/ or you as a professional, expert etc., seem to be within the
interests, purposes, visions or functions of Uni.Fund, we may use the least intrusive way, according to your contact details available to us, in order to contact you,
asking for your consent to retain and further process your data and your permission to continue our communication.
If you are not interested in applying to Uni.Fund, yet you wish to have an open line of communication with us, you may ask us, or respond positively in our request,
to become “a contact of interest”. In that case we shall retain your name, contact details and the most important CV-related information (education background,
Uni.Fund Privacy Notice _Summary
Page17current employment, working field/experience, field of expertise) to be able to contact you again in case something within your interests and Uni.Fund’s aims,
objectives and purposes comes up in the future.
If, according to the reference and/or recommendation, your company/team/project/idea/expertise etc does not fall within the interests of Uni.Fund, your data
will be promptly permanently erased in a safe way. Similarly, if you deny giving us your consent for either purposes, we will promptly erase your data, permanently
and in a safe way.
Access to your data will have the member(s) of Uni.Fund to which your personal data was disclosed.
If we obtain your consent to store and process your data, we will do so for the period of time defined by the purpose and your consent. If the purpose and your
consent allow it, we may retain your personal data for as long as Uni.Fund operates.
Important note on communication over the phone or via e-mail
During the Application procedure, or at any other point, you may wish to contact us directly, over the phone or via e-mail. We will be happy to talk to you and
answer any question you may have! Yet keep in mind that we do not collect personal data you share with us over the phone. If for some reason your question/the
reason you wish to communicate with us entails personal data that you wish us to collect and process, send us an e-mail, stating also that you are consenting for
your data to be collected and process by Uni.Fund for the purpose you disclosed it. We shall collect, process and grant access to it according to the purpose for
which you shared it with us and retain it for the time necessary according to that purpose.