LAST UPDATED: February 19, 2024

1. OWNER

The owner of investory.io (hereinafter referred to as the "Website") is Investory Onlineplattform GmbH, Commercial register No. 454326b, with registered office at Hintere Achmühlerstr. 1a, 6850 Dornbirn, Austria (hereinafter referred to as “Investory” or “the entity”).

Contact: support@investory.io

2. MOTIVATION

The entity respects the privacy rights of its Users and recognizes the importance of protecting the personal data that the entity collects about its Users.

The purpose of this document is to inform the Users of the website about the processing of personal data carried out on this website.

3. PERSONAL DATA PROCESSED BY THE MERE ACCESS TO THE WEBSITE

3.1. What data is processed

When you access the website or use any of our services, we may collect and process all or a part of the following types of personally identifiable information about you or your business (the “Personal Data”), including: company information, company documents financial metrics and cap table details, all together the company data (the “Company Data”), and identity and contact date, financial payment data, profile, usage and website interaction, and technical data, all together the general user data (the “General User Data”)

This compilation will assist you in comprehending the types of data we manage and the roles associated with them

By simply accessing the website, the entity collects the General User Data, such as IP address and other data relating to the connection and its origin.

The IP address is a code that identifies the user's internet connection at a specific time.

Only the user's internet access provider can identify the subscriber who was assigned an IP address at a particular time.

By the very nature of the server that supports the website, the User's IP address is automatically recorded along with the date and time of access.
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3.2. What is this data used for?

General User Data is used only to manage the normal use of the website and to perform statistical analysis on the use of the website.
Company Data is used only to provide you with our Services.

3.3. Lawful treatment

We retain your Personal Data only as long as necessary for the purposes outlined in this Privacy Policy or as required by law. Our processing is based on the following legal grounds:

Contract:

3.4. Data Recipients

The entity does not provide Personal Data to any third party, unless required to do so by applicable law (e.g., an official request in the context of a police investigation) or users provide their consent or request to share data to a third party.

However, we may share Personal Data with third party companies or individuals that we engage as service providers to process information and support our business and services (subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions). Examples include providers of cloud hosting and storage services, analytics, services, email delivery services and customer support services.
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We may also share General User Data with acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Investory (including, in connection with a bankruptcy or similar proceedings).

If Investory is sold, makes a sale, or undergoes a transfer, we reserve the right to, at our discretion, transfer, sell, or assign your Personal Data to a third party in relation to that transaction. Following such transfer, the Privacy Policy of the acquiring entity may dictate the subsequent use of your Personal Data. In all other scenarios, your data will continue to be safeguarded in accordance with this Privacy Policy (subject to periodic amendments).

3.5 Retention period

We will retain your information or data for the period your account is active to perform our duties unless you have unsubscribed or requested us via the dashboard or an email to remove your information permanently from our database.

When your account is inactive or you stop using our services without an intimation of data removal, we will either delete or anonymize it with no ability to access the information or process it in any way.

4. USER RIGHTS

Data protection regulations guarantee Users the following rights:

· Access: Allows the User to know what information is held, from where it has been obtained, to whom it has been provided and with what uses it has been treated.

· Rectification: Allows the User to rectify any erroneous or outdated data.

· Suppression: Allows the User to stop the processing of his/her data.

· Deletion: Allows the User to delete his/her data through the platform.

· Opposition: Allows the User to stop the use of his/her data for a specific purpose.

· Limitation: Allows the user to restrict the processing of their data, but so that they are retained for a later purpose.

· Portability: Allows the User to obtain a copy of his/her data in electronic format and, under certain circumstances, to request that they be communicated to another service provider. It is only applicable for computerized processing carried out with the consent of the User or for the fulfillment of a contract.

· Revocation of consent: Allows the User to withdraw the consent that, where appropriate, has been given for the processing of their data.

These rights require the possibility of identifying the User requesting them and linking his identity with the data processed by the entity.

However, the entity cannot establish this link with any of the data processed by the mere access to the website, unless the User could provide certain documentation that allows its identification (for example, a certificate from its Internet access provider indicating the IP address that the User had assigned on a specific date and time).

Users are informed that they may exercise the aforementioned rights before the entity, as well as revoke their consent for the treatments that they had given it, by mail to the above address or by e-mail to support@investory.io

If Users wish further information in this regard or consider that their right to data protection has been violated, they may contact the relevant Data Protection Authority.

5. OTHER PROCESSING OF PERSONAL DATA

5.1. Cookies

The entity uses cookies and other similar mechanisms for storing and retrieving data on terminal equipment (hereinafter, cookies).

Cookies are files that are downloaded to the User's browser and can be read later by the entity. In this way, cookies allow various functionalities, such as, for example, recognizing a User who has previously accessed the website and being able to analyze the use of the web service in order to improve it.

However, it is not possible to find out the identity of the User from the cookies used by the entity, unless the User provides additional information through other means and these could be linked to the cookies downloaded.

For more information, please consult the Cookie Policy.

5.2. Contact Form:

Investory will process the data provided through the contact form, in order to respond to the contact request.

· Legal basis: The legal basis that legitimizes the treatment, is the consent of the user expressed at the time of sending your request for contact.

· Retention period: The data will be processed for the time necessary to resolve the user's request for contact. Refer to Section 3.5 Retention for information relevant to this.

You may withdraw your consent and exercise your rights at any time, as indicated in the section on the rights of data subjects in this Privacy Policy.

5.2.1. Registration Form:

Investory will process the data provided through the registration form, in order to manage the user's registration and access to the website.

· Legal basis: The legal basis that legitimizes the processing is the need to manage the registration and access to the website.

· Retention period: The data will be processed for this purpose indefinitely in time until the user decides to unsubscribe from the platform of or by exercising their right of opposition or deletion. Refer to Section 3.5 Retention for information relevant to this.

Investory informs the user that in order to verify the data provided, a first email will be sent without commercial content in which the user will be asked to verify the data provided.

Also, in the event that the user has not objected to this by checking the appropriate box, the user will receive commercial communications about Investory services, products, news or events that may be of interest. You may obtain more information about commercial communications in the communications section of this Privacy Policy.

You may exercise your rights at any time, as indicated in the data subjects' rights section of this Privacy Policy.

5.2.2. Application Form:

Investory will process the personal data of the candidate for the purpose of managing their candidacy in current or future personnel selection processes.

· Legal basis: The legal basis that legitimizes this processing is the consent given by the candidate for the processing of their data in the selection processes. Mandatory data will be identified as such at each time they are requested. Refusal to provide this information may prevent the selection process from running smoothly and your application may be rejected.

· Retention period: In our database, he/she may exercise his/her right of deletion or revoke his/her consent through the procedure described above. Refer to Section 3.5 Retention for information relevant to this.

The candidate may revoke their consent at any time and may exercise their rights of access, rectification, deletion, opposition, limitation or portability by means of written communication by e-mail addressed to support@investory.io, identifying themselves as a candidate of Investory, accrediting their identity and specifying their request. Likewise, if you consider that your right to personal data protection has been violated, you may file a complaint with the corresponding Data Protection Agency.

5.2.3. Anonymized data

We may create, use and share aggregated or anonymized data for any lawful purpose, such as marketing, analytics or research purposes permitted by law.

Data of third parties provided by the user

If the User provides personal data of third parties for any purpose, he/she guarantees that he/she has previously informed the affected parties and obtained their consent for the communication of their data to Investory. The User guarantees that the persons concerned are over 18 years of age.

6. COMMERCIAL COMMUNICATIONS

Investory informs the user that the commercial communications requested by the user or if the user has not objected to receiving them by ticking the corresponding boxes on the forms, will be sent using the tool Mailchimp, managed by the company The Rocket Science Group LLC, whose servers are located in the United States, a country whose legislation does not offer a level of data protection equivalent to that of Europe; however, adequate guarantees of data protection are provided by signing the Standard Contractual Clauses approved by Decision 2021/914/EU of the European Commission.

Newsletters may also be sent by the customer relationship service Intercom and/ or HubSpot, Inc, whose servers are located in the United States, a country whose legislation does not offer a level of data protection equivalent to that of Europe; however, adequate guarantees of data protection are provided. [We also send out newsletters from HubSpot or other similar system that we may use from time to time.

Bugs and general errors are automatically collected and sent to Bugsnag, managed by the company SmartBear Software, Inc., whose servers are located in the United States, a country whose legislation does not offer a level of data protection equivalent to that of Europe; however, adequate guarantees of data protection are provided by signing the Standard Contractual Clauses approved by Decision 2021/914/EU of the European Commission.

The tool used for sending commercial communications by e-mail will include links and tiny, transparent images that will be associated with your e-mail address. Thus, when you download one of these images or access the links contained in the e-mail, Investory may know for statistical purposes whether the e-mail has been opened or whether a link has been accessed from the e-mail. You can prevent these uses by configuring your e-mail manager or program to prevent automated downloading of images, as well as by not accessing the links included in the e-mails you receive.

In each communication, the user will be able to oppose to receive this type of information through the specific mechanisms to process the unsubscribe, as well as to request in its case its right of revocation of consent, opposition or suppression.

We recognize the importance of maintaining the confidentiality and integrity of personal data entrusted to us. Specifically, we affirm that we do not engage in the following practices:

7. MORE INFORMATION

If the user has any questions about the information collected in our Privacy Policy, he/she can send an e-mail message to: support@investory.io.