Privacy & Cookie Policy

Privacy Policy

1. Introduction

Venture Valuation will collect and process your personal data and any other information relating to your interactions and dealings with us. This Privacy Policy explains how we will manage your personal data, the purposes for which we use it, the security measures we have put in place to protect your data and what your rights under data protection legislation are and how you may choose to exercise these. 

Personal Data is defined as information relating to identifiable living individuals, which we have obtained or you provide to us, such as your name, address, email address, telephone number, date of birth, from which you can be directly or indirectly identified, and may include information such as employee number, IP addresses and online identifiers. 

2. Data Controller

Venture Valuation is defined as the Data Controller and is therefore responsible for protecting your personal data in line with our obligations under data protection legislation.
We may use third parties to process your personal data (Data Processors) where we have outsourced a particular function or where we wish to avail of that third party’s expertise in providing the particular service. These third parties will be carefully selected to ensure that your data is adequately protected by the use of appropriate technical and organisational security measures. 

3. Sources of Personal Data

Customers
We obtain personal data where you provide this directly to us where you enter in or provided your information into an online form, by e-mail or phone to contact us regarding our services. 

4. Purposes of Data Collection

We use personal data in our capacity as a commercial enterprise in furtherance of our business activities and as an employer. The purposes for which we use personal data can be summarised as follows:
• For services carefully designed to assist you in your fundraising, partnering or investing efforts;
• For the purposes of advertising, direct marketing and public relations i.e. where you provide your email address to receive our newsletter;
• To perform functions of a commercial enterprise i.e. to perform accounting and other record-keeping functions;
• To perform the duties and responsibilities of an employer i.e. to provide personnel, payroll and pension administration services.

For further information on how we process personal data for our ventures Biotechgate and Hello Partnering, please contact the respective Privacy Notices on those websites. 

Legal Basis for using Personal Data
We rely on the following legal bases under data protection legislation to process your personal data:

5. Consent

Where you provide your email address for the purpose of signing up to receive our newsletter, we rely on Article 6(1)(a) of the GDPR in process your data for this purpose. You may revoke this consent at any time by unsubscribing from our email list by clicking the unsubscribe link at the end of every email and by emailing us using the contact details provided below.
Performance of a Contract
Where you provide your personal details to us in the context of engaging our services we rely on Article 6(1)(b) of the GDPR to process your data i.e. we require your personal data for the performance of this contract with you.
Legitimate interests
Where we rely on legitimate interests or the legitimate interests of a third party to process your personal data we will require data for legitimate purposes such as:

• For day to day operational and business purposes
• The pursuit of our activities as a commercial enterprise or that of a third party e.g. managing our contracts and relationships with our customers, suppliers, service providers, vendors and other commercial partners
• Compliance with legal and regulatory obligations
• Development of any guidelines, improvement and development of business operations and service offerings
• Conducting analytical and statistical research and profiling
• To help us improve our services and systems and to improve your experiences on our website
• To provide you with information in relation to our products and services where we are permitted to do so
• The reorganisation or sale of the whole or part of our business

6. Disclosure of Personal Data

We will not disclose your personal data except as outlined above and/or as follows:

• Where the disclosure is necessary to enable us to carry out our obligations under any agreement we have with you
• Where we need to provide your data to counterparties to transactions entered into by you e.g. payment service providers
• Where we need to share your personal data with our auditors in accordance with applicable tax and regulatory reporting obligations
• Where we need to share your personal data with our legal advisors where necessary to establish, exercise or defend our legal rights or for the purposes of legal proceedings.
• Where we are required to share information to any (or proposed) assignee, transferee or successor in title to the whole or any relevant part of our business, and their respective officers, employees, agents and advisers; and
• If the disclosure is required by law or regulation, or court or administrative order having force of law, or is required to be made to any of our regulators

7. Other Recipients of your Personal Data

In any case where we share your personal data with a third party data controller, your personal data will be used by that third party subject to their own privacy policies. 

8. International Transfers of Personal Data

Personal data may be transferred outside of the European Economic Area (EEA) in line with the purposes set out above and this may include transfer to a country that is not currently deemed by the European Commission to have adequate data protection legislation in place.
In such cases we will use data transfer mechanisms approved under the General Data Protection Regulation such as standard contractual clauses or data transfer agreements such as the EU-US Privacy Shield.

9. Security of Personal Data

We use appropriate technical and organisational measures to protect your personal data.
Where data is stored electronically, we have implemented appropriate IT security measures to secure your personal data. These measures include anti-virus protection, firewalls and data encryption technologies. Where data is stored in hard copy format, we have procedures in place and staff training to ensure that paper records are stored securely. Unfortunately, no data transmission over the Internet or electronic storage system can be guaranteed as secure, however, we will ensure that the technical and organisational measures in place are regularly reviewed to ensure that they are up-to-date and functioning effectively. 

10. Retention of Personal Data

Personal data will be kept for as long as it is legally required to be kept or for as long as the business has a legitimate need to keep the data for the purposes for which it is original collected.
Where we hold personal data to provide a product or a service to you we will hold the information for as long as it is required to fulfil the terms of that agreement with you and for a period of 10 years after the end of the customer relationship thereafter to ensure compliance with tax requirements.
Other information will be retained by us for no longer than is necessary for the purposes for which it was obtained or as required or permitted for legal, regulatory, fraud prevention and legitimate business purposes.
For further information on the period of time for which we retain your personal data please contact us using the details below. 

11. Personal Data Rights

The following is a summary of the rights available to you under data protection legislation. These rights may only apply in certain circumstances and may be subject to certain exemptions. Where you make an application for the exercise of your rights, this will be considered on a case by case basis. 

• Updating and correcting your personal data
  If we hold incorrect personal data on you, you have the right to have this data amended. While we use reasonable efforts to keep your personal data up to date, you will need to notify us where you require your details to be updated where we will be unaware of your change in circumstances.
• Right of Erasure
  You have the right in some circumstances to have your personal data erased i.e. where your personal data has been processed unlawfully or if you object to our processing of personal data on grounds relating to your particular situation and we have no overriding grounds to continue using it or where you have previously provided consent to the data processing you now wish to withdraw that consent.
  However, we will not be required to erase your data where to do so would prevent us from meeting our respective contractual obligations, or where we are required to process (including retaining) your personal data in order to comply with a legal obligation, or if the data is required to establish, exercise or defend our legal rights for the purposes of legal proceedings.
• Right of Access
  You have a right to be given a copy of your personal data on request, subject to certain exceptions which may apply. We have 30 days from the receipt of the request to provide you with a copy of this data. This period may be extended to a further period of 60 days in specific circumstances.
• Right to Restriction
  You also have the right, in certain circumstances, to request restriction on the use of your personal data, in each case subject to the restrictions set out in applicable data protection laws. 
  Right to withdraw Consent
• Where you have previously consented to the use of your personal data, you have the right to withdraw this consent and may notify us of you intention to do so.
  Where we rely on a legitimate interest of ours or a third party recipient of the personal data, in order to use or disclose personal data, you are entitled to object to such use or disclosure of your personal data and if you do so will cease to use and process your data for that purpose, unless we can demonstrate that there are compelling legitimate reasons for us to continue using the data or where we require the data for the purpose of legal claims.
• Right to Data Portability
  In limited circumstances, you may also have the right to receive your data saved onto a portable medium i.e. a structured, commonly used and machine-readable format, or transmit it to a third party where this technically feasible.
  Right to Lodge a Complaint
  You also have the right to lodge a complaint in respect of how your personal data has been processed by us with the Data Protection Commission in your home country or with the Federal Data Protection and Information Commissioner (‘FDPIC’) in Switzerland. 

12.  Contact information

Venture Valuation VV AG
Kasernenstrasse 11
CH-8004 Zurich
Switzerland

Phone: +41 (43) 321 86 60
Fax: +41 (43) 321 86 61 

E-mail: contact@venturevaluation.com

www.venturevaluation.com

13. Update history

This Privacy Policy (v2) was published on May 24th, 2018.