Owliko’s mission is to help startups fail or progress faster by offering equal decentralized access to services, such as analysis, testing, funding and scaling, as well as to enable investors to discover new verified investment opportunities. We do so through a Platform which offers solutions to technical and financial challenges of startups worldwide in order to level the playing field and help both the startups itself and any investors by increasing the chances of success and lowering chances of failure and loss of funds.
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
The Platform is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
This privacy notice is issued on behalf of Owliko so when we mention "Owliko", "we", "us" or "our" in this privacy notice, we are referring to ARCHIMEDES PRINCIPAL Ltd. acting as the controller and responsible entity for this Platform.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Full name of legal entity: ARCHIMEDES PRINCIPAL Ltd.
Name or title of data privacy manager: Matevž Smole
E-mail address: firstname.lastname@example.org
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 14 November 2018.
It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and we are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, username or similar identifier, title, date of birth.
Contact Data includes designated address, e-mail address and telephone numbers.
Verification Data includes any document, provided to us, for the purpose of verifying Identity Data and Contact Data, such as scan of personal documents, utility bills, selfie photos of the user with a document, recording of a video call with the user.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Startup Data includes information about the startup project, including the information on its legal entity, team members, advisors, their Identity, Contact, Verification, Technical and Profile Data.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data 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 website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract or any other form of business relationship we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Startup and Verification Data by filling in forms or by corresponding with us by post, phone, e-mail, internet, website or otherwise. This includes personal data you provide when you:
apply for our products or services;
create a user account on our website;
subscribe to our newsletter;
sign up as a Startup; or
give us some feedback.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
Technical Data from the following parties:
a) analytics providers such as Google based outside the EU,
The data that you publicly post and which can be accessed by linking your profile with information that is available through social and other networks.
To apply to our Platform as a Startup you have to submit the Startup Information. By submitting the Startup Information you provide us with information about your Startup. In case you provide us with Personal Information from third parties (e.g. your team members) you assure us that you are appropriately authorized by these persons and that you have their explicit consent or legal basis to do so. We may ask you to submit such written evidence without stating a reason. By providing us with Personal Information from third parties we will automatically consider you are authorized for such action and we cannot in any way be held liable for receiving such information. In case your Personal Information was provided to us through an authorized person but you no longer agree to it or the person has not been authorized to provide us your Personal Information, you can opt-out at any time by sending a removal request to email@example.com.
You are solely responsible to have legal basis for acting on behalf of such organization or entity or for acquiring authorization from such organization or entity and Startup Team Members. In case where you are providing information on behalf of organization or entity or Personal Information of Startup Team Members, it is automatically considered that you have acted as a duly authorized person to provide us with such information and we cannot in any way be held liable to you or any third person if you have acted without legal basis or authorisation. If you disagree with information being provided to us, please contact us at firstname.lastname@example.org.
In case you are under the age of 18 you are not allowed to use our services and please do not attempt to register for the Services or submit Startup Information or send any personal information about yourself to us. In case we will learn that we have collected personal information from a person under the age 18, we will delete that information as soon as possible. For more information please contact us at email@example.com.
You and others may include content that includes information about you (e.g. as a team member in a certain Startup). Unless you opt-out, we may collect public information about you, such as professional-related news and make them available as part of our Services. You may opt-out at any time by emailing us at firstname.lastname@example.org with a request for deletion of information.
Whenever you interact with our Platform, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, “cookie” information, the type of browser and/or device you’re using to access our services, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. We need such cookies to enable you to use our Platform (they are needed to deliver our Services to you) or are allowing us to improve your user experience. You may be able to change the preferences in your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features.
Information collected by cookies will be used to improve our services by knowing for example which features or Services are most popular for users and based on such information we can make the Services more interesting to more users.
4. HOW WE USE YOUR PERSONAL DATA
Where we need to perform the contract or any form of business relationship we are about to enter into or have entered into with you .
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
When we will contact you and/or provide you with general information as well as information about our products and services from time to time.
When we will contact you to participate in startup ratings and surveys.
To continuously improve and enhance our services.
Automated processing (profiling) - building your user profile based on your use of our Platform and our Services in connection to information we gather about you.
We may send you marketing communications via e-mail relating to our business which may be of interest to you. You can choose the types of communications you want to receive at any time by updating your email preferences. You may also unsubscribe at any time.
Consent: We will not use your personal data for advertising purposes unless you have freely given your explicit and prior consent.
However, for existing customers, we may use your email address that we obtained from you in the context of our existing customer relationship to provide you with marketing materials relating to similar products or services that you have previously requested, used or participated in. You may, however, object to such use at the time of collection and each time a message is sent. To opt-out of email marketing, follow the instructions within the email that you receive.
For Recommendation of our Services so that we adjust our Services to your user profile.
When we will share your personal data with agents, contractors or our partners in connection with services that these individuals or entities perform for or with us. These agents, contractors or partners are restricted from using Personal Data in any way other than to provide services for us. We may, for example, provide Personal Data to agents, contractors or partners for hosting our databases, for data processing services, or to send you information that you requested, but those parties cannot use your Personal Data for their own purposes unrelated to the work they are doing for us.
When we will have to investigate suspected fraudulent activity in connection with the website or violation of another party’s rights.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new user (when you create a user account on our Platform)||
|To sign up as a Startup by Submitting product-related Startup Information||
|To sign up as a Startup for any funding-related Services||
|Participating in Owliko surveys||
|Automated processing (profiling)||
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
|To administer and protect our business and this Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
||Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)|
|Application for funding||
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Public availability of your personal data on our Platform
We may use your Identity and Startup Data across all of the Services we offer, including but not limited to publishing the provided information on our Platform where it will be visible to other users of our Platform. We may also display your Identity and Contact Data to a certain extent in your profile, which will be visible to other users of our Platform.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive communications from us if you have requested information from us or used our services and, in each case, you have not opted out of receiving that communications.
You can ask us to stop sending you messages at any time.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We ensure your personal data is protected by requiring companies acting as data processors to follow the same rules when processing your personal data. These rules are called "binding corporate rules". For further details, see European Commission: Binding corporate rules.
Since some of our external third parties are based outside the European Economic Area (EEA) processing of your personal data may sometimes later involve a transfer of data outside the EEA. In such case we ensure your personal data will be protected by requiring our data processor to follow same rules as are applicable to us.
In case we might transfer your personal data out of the EEA, we will ensure a similar degree of protection will be afforded to it by ensuring at least one of the following safeguards is implemented:
We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers or partners, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. SECURITY OF YOUR PERSONAL INFORMATION
We have put in place reasonable physical, electronic, and administrative procedures to safeguard the information we collect to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We cannot guarantee, however, that all communications between us or information stored on our servers will be free from unauthorized access by third parties such as hackers. Your use of our services demonstrates your assumption of this risk.
8. DATA RETENTION
Data retention time
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep information about our customers for at least 10 years after they cease being customers for tax, accounting and other legally binding purposes.
We will not keep your data beyond reasonable time but this will not limit us anyhow to keep your personal data for indefinite period of time under our sole discretion to which you consent.
Nevertheless, you can ask to delete your data in some circumstances. For such request contact us at email@example.com.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. We may use such information even if you have instructed us to delete your personal information under condition such information have been de-identified and are only used in aggregated manner.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Bellow you will find overview of your rights under data protection law (you will find more detailed explanation in section 10. Glossary). For full understanding of relevant rights you should read the relevant laws from regulatory authorities.
Your rights under data protection law are:
Request access to your personal data
Request correction of your personal data
Request erasure of your personal data
Object to processing of your personal data
Request restriction of processing your personal data
Request transfer of your personal data
Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External Third Parties
Service providers acting as processors based in the EU who provide IT and system administration services and identification services.
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Banks, which provide us access to banking services, such as bank account, for compliance with anti money laundering regulation, and crypto exchanges and brokers, which enable us conversion between cryptographic tokens and fiat money.
Tax Authority, regulators and other authorities based in the British Virgin Islands and Slovenia who require reporting of processing activities in certain circumstances.
Digital asset offering provider, only in case user will desire to participate in the purchase of digital assets from such provider, and subject to the user giving explicit consent for its Identification and Verification Data to be transmitted to the digital asset offering provider.
Your legal rights
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.