PRIVACY POLICY

Last updated December 5, 2023

  1. INTRODUCTION

Deba Ventures (full legal name: DeBa Group S.A. SPF ) (also referred to below as the “DB” “we,” “us,” or “our“) is committed to safeguarding the privacy of visitors to https://debaventures.com (the “Website”), contacts for our clients and prospective clients, contacts for suppliers of goods and services, personal data of startup founders, candidates for employment or engagement, and any other individuals (collectively “you”) about whom the DV obtains personal data (described below).

In this Privacy Statement, “Personal Data” means information that (either in isolation or in combination with other information held by the DV) enables you to be identified as an individual or recognized directly or indirectly. With respect to California residents, references to “Personal Data” in this Privacy Statement means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, subject to certain exceptions set forth in the California Consumer Privacy Act.

Unless we specifically state otherwise, the DV is the data controller in relation to any Personal Data that the DV processes about you and is therefore responsible for ensuring that the systems and processes we use are compliant with data protection laws, to the extent applicable to us, including the, but not limited to, European Union General Data Protection Regulation, The Law on Protection of Personal Data, Law No. 6698 of Republic of Türkiye and the California Privacy Rights Act. 

This Privacy Statement sets out the principles governing the DV’s use of Personal Data that we may obtain about you, how the DV collects, uses, and otherwise processes your Personal Data as well as the rights that you have in relation to our processing of that information. 

  1. CATEGORIES OF PERSONAL DATA WE COLLECT

DV only collects personal data necessary for a specific purpose.  In the course of providing our services, we collect or receive your personal information in a few different ways. 

  • directly from you, for example, during registration or when placing an order; 
  • indirectly from you based on your activity and interaction with our services, or from the device or browser you use to access the Site.

In this section we outline the categories of personal data which we may collect, use, store, share and transfer. 

Usually the personal data we process falls into one or more of the following categories:

  • Contact Data – this includes information, such as your full name, email address, phone number;
  • Pitch Deck Data – this includes any information you include in a pitch deck that is submitted for our review, including the recorded 1-minute elevator pitch;
  • Job applicant data: Identification data and contact information, resumé and other data provided by you on our Website or online recruitment portal; 
  • Transaction data: Personal data contained in documents, correspondence or other materials provided by you or relating to transactions conducted by our clients;
  • Compliance data: Government identifiers, passports or other identification documents, dates of birth, beneficial ownership data, and due diligence data;
  • Aggregated Data – we also obtain and use aggregated data such as statistical or demographic data. Aggregated Data may be derived from your personal data but does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature on our Website.

We employ some third-party services to help us understand the usage of the services and these third parties may also deploy cookies, pixels, or other identifiers on the services. For example, we may use Google Analytics to understand, in a non-personally identifying way, how users interact with various portions of the services. You can learn more about information that Google may collect here.

  1. HOW WE USE YOUR PERSONAL DATA

We rely on a number of legal bases to use your information. We may collect and process your personal data for one or more of the following purposes:

Provide You Products and Services: We use your personal data to provide you feedback regarding your inquiry or whether we would like to invest in your company; 

Improve our Websites and our Product Offerings and Services: In order to improve your experience and provide you with products and services that you are interested in, we use your personal data to understand who is visiting our website, analyze how the website are being accessed and used, improve the functionality of our website and develop new product and service offerings.

Comply with Our Legal Obligations and Respond to Legal Proceedings: We use your personal data to comply with our legal, regulatory and risk management obligations, including confirming your identity for AML/KYC reasons.

  1. PERSONAL DATA SHARING

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.

Authorized third-party vendors and service providers. We share your information with third-party vendors and service providers that provide services to us for a variety of business purposes, such as billing, payment processing, customer service, email deployment, advertising and security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing.

Business transfers. We may share your information in connection with a substantial corporate transaction, such as a merger, consolidation, asset sale, initial public offering, or in the unlikely event of bankruptcy.

Legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of DV, our affiliates, users, or the public.

With your consent. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.

DV undertakes never to sell or rent your data or to cede access to.

  1. YOUR RIGHTS 

Certain privacy laws, including the law on Protection of Personal Data of the Republic of Armenia and European General Data Protection Regulation (GDPR) provide customers and users with certain rights related to their personal information. Consistent with those laws, DV gives you the choice of accessing, editing, or removing certain information, as well as choices about how we contact you.

In this section we have summarised the rights that you have under data protection laws that can be exercised against us if we process your personal data. Some of the rights are comprehensive, and not all of the details have been included in our summaries. Accordingly, you should read the applicable laws and guidance from the supervisory authorities for a full explanation of these rights.

  • Access: You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing that the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
  • Rectification: You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. Where you have created an account with us, you can rectify some of your personal data yourself via the account dashboard.
  • Erasure: In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing; the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. 
  • Restriction: In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
  • Object: You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that it is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
  • Data portability: To the extent that the legal basis for our processing of your personal data is either consent orthat the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others. 
  • Withdraw consent: To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

Please note that we may verify your identity before we are able to process any of your requests with regards to your personal data, and in our discretion, deny your request if we are unable to verify your identity.

6. DATA SECURITY

We endeavor to implement technical and organisational security measures in an effort to safeguard the Personal Data in our custody and control. Such measures include, for example, limiting access to Personal Data only to our staff and authorised service providers on a need-to-know basis for the purposes described in this Privacy Statement, as well as other administrative, technical, and physical safeguards.

  1. CHILDREN’S PRIVACY PROTECTION

We understand the importance of protecting children’s privacy in the interactive online world. This Website is not designed for or intentionally targeted at children 13 years of age or younger. It is not our policy to intentionally collect or maintain information about anyone under the age of 13.

8. DATA RETENTION

We will only retain your personal information for as long as necessary for the purposes for which that information was collected as set out in this Privacy Statement or for longer as required under any applicable legal, regulatory, accounting, or reporting requirements. 

9. THIRD PARTY SITES

Our Website may contain links to other sites which are controlled by third parties. We also use social media sites, such as LinkedIn and Facebook and third-party platform to host events, training and seminars. You should review these other sites’ privacy policies. We do not accept any responsibility for the information you provide on those sites or their collection and use of your personal information.

  1. PRIVACY POLICY UPDATES

It is likely that DV needs to amend or update this Privacy Policy from time to time. We’ll notify you of any material changes via email, but you’re welcome to come back and check it whenever you wish. 

We encourage our customers to frequently check for any changes to its Privacy Policy.

Your continued use of this Website after any change in this Privacy Policy will constitute your acknowledgement and understanding of such change.

CONTACT INFORMATION

Should you be concerned about a possible interference with your privacy or misuse of your personal data by DV, or if you have any questions or comments regarding this Privacy Policy, please do not hesitate to contact us.

  • Post: 7, rue Nicolas Van Werveke L-2725 Luxembourg
  • Email: info@debaventures.com