Privacy Policy – Applicants and Members

WHO WE ARE

VentureWaves Innovation Network Inc. (“VentureWaves”) is dedicated to promoting rapid digital innovation through collaboration with venture studios, investors, corporates, governments, R&D centers, and universities. We aim to foster an environment where innovation thrives and economies prosper.

Our head office is located at 2261 Market Street STE 22021, San Francisco, CA 94114 US. You can contact us by email at data@venturewaves.org in relation to any matters pertaining to this Privacy Policy.

VentureWaves is a data controller of Personal Information (as defined below) collected for the Member Purpose (as defined below).

In this Privacy Policy, references to “we,” “us,” or “our” mean VentureWaves. References to “you” and “your” are to Applicants and Members (both as defined below).

APPLICATION

Personal Information is information relating to you, which can be used to personally identify you (either directly or indirectly).

This Privacy Policy describes how we collect, use, and otherwise handle Personal Information that you provide or make available to us, or that we collect from you, when:

  • Considering your application to become a registered and/or licensed company in the VentureWaves network (Applicants); and
  • Any subsequent formation and registration of a company and/or grant of a trade license permitting you to operate in the VentureWaves network is approved (Members), and explains the circumstances in which we may transfer this information to others.

COLLECTION AND USE OF PERSONAL INFORMATION

  1. Information that we collect The types of information that we may collect from you include:
    • Your name
    • Your email address
    • Your address (business and personal)
    • Your landline and mobile telephone numbers (business and personal)
    • Any other information that you choose to provide to us when filling out a contact form
    • Your geographic location (country/territory where you are living and/or working)
    • Your job title, role, and the name of your employer
    • The industry sector in which you work
    • The country or countries, industry sector(s), and area(s) of our services in respect of which you wish to receive communications (where you have registered on our user portals)
    • Personal Information in respect of other individuals associated with you
  2. How we use your Personal Information
    • Member Purpose: We collect your Personal Information, which you choose to provide as an Applicant for the purposes of assessing whether you meet suitable VentureWaves governance criteria in order for your application to be confirmed as a Member. On an ongoing basis (in the event that your application to become a Member is approved), we ensure our Members can avail of their rights, entitlements, and benefits as Members. We may use this Personal Information to respond to your queries, and/or provide the services and/or information that you have requested.
    • Our Business Purposes: We may also use your Personal Information for our business purposes such as:
      • Record keeping, statistical analysis, internal reporting, and research purposes
      • Ensuring network and information security
      • Notifying you about changes to our services
      • Investigating any complaint you make
      • Providing evidence in any dispute or anticipated dispute between you and us
      • Customizing various aspects of our services to improve your experience
      • Detecting and preventing fraud and other criminal offenses and for risk management purposes
      • Business and disaster recovery (e.g., creating back-ups)
      • Document retention/storage
      • Database management
      • Protecting the rights, property, and/or safety of VentureWaves, its personnel, and others
      • Ensuring the quality of the services we provide to our users
    In addition, we may use your Personal Information for additional specific purposes made clear at the point of collection. If you choose not to provide Personal Information requested by us, we may not be able to provide you with the information and/or services you have requested or otherwise fulfill the purpose(s) for which we have asked for the Personal Information.
  3. Legal grounds for collection and use of Personal Information: We rely upon your consent to process your Personal Information in relation to the Member Purpose. In other cases, we process your Personal Information where we need to do so:
    • To comply with our legal and regulatory obligations
    • For the performance of a public task
    • For our legitimate interests in:
      • Responding to your queries
      • Providing services and/or information to you
      • Our internal Business Purposes, as set out in section 2 above
    You can object to processing based on our legitimate interests at any time by contacting us at data@venturewaves.org. See also the “Your Rights” section below.We consider the risk to your rights of data protection in connection with personal data that we process on the basis of our legitimate interests is not excessive or overly intrusive. We have also put in place protections for your rights by ensuring proper retention periods and security controls.
  4. Information from other sources: Where permissible under applicable local laws, we may combine information that you have provided to us with other information that we already hold about you and which we have collected for a compatible purpose.

SHARING INFORMATION WITH THIRD PARTIES

Some services that we provide require the involvement of third parties. We have carefully selected these third parties and taken steps to ensure that your Personal Information is adequately protected.

  1. Sharing with Service Providers: When VentureWaves would like to use your Personal Information for a new purpose, we will let you know about this first. We share your Personal Information with our third-party service providers based both inside and outside of the United States who we engage to provide support services in relation to the Member Purpose. This includes for the purposes of: assessing certain corporate information and data provided by Applicants to confirm whether this information is accurate and to carry out the requisite compliance checks, in order to ensure that Applicants are fit and proper to be considered for the application process ahead of becoming a Member, and on an ongoing basis to ensure they are fit to remain a Member; providing data storage; assisting us with database management, and in order to assist us with related tasks or processes. All of our service providers are bound by written contracts to process personal data provided to them only for the purpose of providing the specific service to us and to maintain appropriate security measures to protect your Personal Information.
  2. Sharing with other third parties: We share your Personal Information with:
    • Our accountants, auditors, lawyers, or similar advisers when we ask them to provide us with professional advice
    • Any other third party if we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or to protect the rights, property, and/or safety of VentureWaves, our personnel, or others
    • Any other third party for the purposes of acting in accordance with the requirements of a court, regulator, or government agency, for example, complying with a search warrant or court order or acting in accordance with an applicable law or regulation
    • Investors and other relevant third parties in the event of an actual or potential sale or other corporate transaction related to VentureWaves

INTERNATIONAL TRANSFERS

The transfer of your Personal Information to third parties may involve your Personal Information being sent outside of the United States, to locations that may not provide the same level of protection as those where you first provided the information.

However, we will only transfer your Personal Information outside of the US:

  • Where the transfer is to a place or by a method or in circumstances that is regarded by the European Commission as providing adequate protection for your Personal Information
  • Where we have put in place standard data protection clauses adopted by the European Commission or a relevant data protection authority
  • Where none of the above apply but we are still legally permitted to do so, for example if the transfer is necessary for the establishment, exercise, or defense of legal claims

You can request further detail about the safeguards that we have in place in respect of transfers of Personal Information outside of the US by contacting us at data@venturewaves.org.

STORING PERSONAL INFORMATION

It is our policy to retain your Personal Information for the length of time required for the specific purpose or purposes for which it was collected. However, we may be obliged to store some Personal Information for a longer time, taking into account factors including:

  • Legal obligation(s) under applicable law to retain data for a certain period of time
  • Statute of limitations under applicable law(s)
  • (Potential) disputes
  • Guidelines issued by relevant data protection authorities

Whilst we continue to process your Personal Information, we will ensure that it is treated in accordance with this Privacy Policy. Otherwise, we securely erase your information once this is no longer needed.

If you would like to find out how long we keep your Personal Information for a particular purpose, you can contact us at data@venturewaves.org.

SECURITY

We employ appropriate security measures to help protect your Personal Information and guard against access by unauthorized persons. Information storage is on secure computers in a locked and certified information center. We undergo periodic reviews of our security policies and procedures to ensure that our systems are secure and protected. However, as the transmission of information via the Internet is not completely secure, we cannot guarantee the security of your information transmitted to us.

CONFIDENTIALITY

We acknowledge that the information you provide may be confidential. We do not sell, rent, distribute, or otherwise make Personal Information commercially available to any third party, except that we may share information with our service providers for the purposes set out in this Privacy Policy. We will maintain the confidentiality of and protect your information in accordance with our Privacy Policy and all applicable laws.

YOUR RIGHTS

The following section explains your rights. The various rightsare not absolute and each is subject to certain exceptions or qualifications. We will grant your request only to the extent that it follows from our assessment of your request that we are allowed and required to do so under data protection laws. Nothing in this Privacy Policy is intended to provide you with rights beyond or in addition to your rights as a data subject under data protection laws.

You have the right to request access to Personal Information that we may process about you. If you wish to exercise this right, you should:

  • Put your request in writing (an email sent to data@venturewaves.org is acceptable)
  • Include proof of your identity and address (e.g., a copy of your driving license or passport, and a recent utility or credit card bill)
  • Specify the Personal Information you want access to

You have the right to require us to correct any inaccuracies in your Personal Information free of charge. If you wish to exercise this right, you should:

  • Put your request in writing (an email sent to data@venturewaves.org is acceptable)
  • Provide us with enough information to identify you (for example, your name, include proof of your identity and address (e.g., a copy of your driving license or passport, and a recent utility or credit card bill))
  • Specify the information that is incorrect and what it should be replaced with

You also have the right to ask us to stop processing your personal data. However, if we do not hold all the data or are not able to process the data we need to administer the Member Purpose, we may not be able to provide you with the information and/or services you have requested or otherwise fulfill the purpose(s) for which we have asked for the Personal Information.

If you wish to exercise this right, you should:

  • Put your request in writing (an email sent to data@venturewaves.org with a header that says ‘Stop Processing’ is acceptable)
  • Provide us with enough information to identify you (for example, your name, include proof of your identity and address (e.g., a copy of your driving license or passport, and a recent utility or credit card bill))
  • Provide us with full details of the personal data that you wish us to stop processing

CHANGES TO THIS PRIVACY POLICY

This version was last updated in July 2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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