Introduction
Our website www.lakegenevaventures.com (the “Website”) is owned by EFI Lake Geneva Ventures ICAV, with registered office at 2nd Floor, Block 5, Irish Life Centre, Abbey Street Lower, Dublin 1, Ireland (referred to as “we”, “us”, “our” and “LGV”). By accessing and using the Website you agree to be bound by all terms and conditions which are set out on the Website from time to time, which govern such access and use (the “Privacy Policy”).
LGV may change, suspend or discontinue any aspect of its Website at any time. LGV may modify this Privacy Policy without notice, and such modified terms shall be effective upon posting. Please re-visit this page occasionally to ensure that you are happy with any changes.
Through this Privacy Policy we aim to inform you about the types of personal data we collect, the purposes for which we use the data and the ways in which the data is handled. We also aim to comply with all requirements and obligations of transparency under the EU General Data Protection Regulation 2016/679 (“GDPR“) and national laws implementing GDPR.
Why we may collect data about you
- To communicate with you;
- To provide you with further news and updates;
- To improve our services;
- For cybersecurity of the services; and
- For statistical and planning purposes.
Why we may collect data about you
- When you access and navigate through the Website;
- When you willingly and voluntarily submit personal data through web forms, by uploading user content on the Website or with your explicit consent by separate submission outside the Website;
- When you submit an inquiry about a start-up or entrepreneur or your interest;
- Through third-party plugins/websites; and
- Through cookies and other analytical tools.
What information we may collect and process
We collect and process various categories of personal information and data at the start of, and for the duration of, your business relationship with us. We will limit the collection and processing of data and information to that which is necessary to achieve one or more legitimate purposes as identified in this Privacy Policy.
- Full name, job title and company name;
- Contact information including email address, phone number and address;
- Know Your Client (KYC) data, such as Date of Birth, nationality, wealth, income, indebtedness capacity, education, past investment experience, entities controlled by you, portfolio data, certified ID copies, etc;
- IP address;
- Visiting date on the Website;
- List of the start-ups viewed on the Website;
- Your interaction with our services such as your navigation details on the Website, notably without limitation information about your web browser, webpages visited and saved, and log files; and
- Data collected from third-party plugins/websites such as without limitation Facebook, Google, LinkedIn, Twitter, XING, Keen IO, Intercom, Mailchimp, Sentry, Cloudflare, Amazon Cloudfront, that are provided when you submit your user information through our services.
Where permitted by law or to fulfil our regulatory requirements, we may process information about criminal convictions or offences and alleged offences for specific and limited activities and purposes, such as to perform checks to prevent and detect crime and to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions. It may involve investigating and gathering intelligence on suspected financial crimes, fraud and threats and sharing data between banks and with law enforcement and regulatory bodies.
How we use your information
- You can be assured that information you provide voluntarily will only be used in connection with your legitimate business relationship with us. We will hold, use and disclose your personally identifiable information and data for our legitimate business purposes including: administer, operate, facilitate and manage your relationship and/or account with LGV. This may include sharing such information internally as well as disclosing it to third parties.
- Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, etc., in connection with your relationship and/or account;
- Provide you with information relating to our products and services, including dealing with any enquires and any complaints;
- Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements;
- Administer our website, including keeping our website and systems secure and prevent fraud; and
- Where relevant, to meet legal, regulatory or compliance needs.
We do not sell or share your personal information and/or data to third parties for third party direct marketing purposes. We record telephone lines and other communications including mails, emails, or documentation concerning your business relationship with us. Copies of these recordings and/or other communications set out in this paragraph may be delivered to any court of or regulatory authority in a competent jurisdiction.
The Legal Basis for Processing your Personal Information
Under GDPR, the main grounds that we rely upon in order to process personal information of users of our Website, business contacts and clients are the following:
- Necessary for the purposes of legitimate interests – either we, or a third party, will need to process your personal data for the purposes of our (or a third party’s) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected. Our legitimate interests include: responding to requests and enquiries from you or a third party; optimising our Website; enhancing the information we provide to you; creating and developing the services we provide to our clients; informing you about our products and services and ensuring that our operations are conducted in an appropriate and efficient manner;
- Necessary for compliance with a legal obligation – we are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or a law enforcement agency;
- Necessary for entering into, or performing, a contract – in order to perform obligations that we undertake in providing a service to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data;
- Consent– in some circumstances, we may ask for your consent to process your personal data in a particular way.
You can withdraw at any time your consent for such specific data processing. Please note however that such withdrawal may lead to LGV not being able to provide and perform a business relationship with you. In such case, LGV may terminate your access and/or use to all or part of our services without incurring any liability whatsoever.
If your relationship with us ends, we will continue to treat your personal information, to the extent we retain it, as described in this Privacy Policy.
Who the information is shared with – Third party service providers and their delegates
We may, from time to time, use trusted third-party service providers and their delegates to help us ensure our business operations. We may, where necessary, share your personal information with trusted third parties where we have retained them to provide services that you or our clients have requested, or which are required in order to enable us to maintain our records. We will share your personal information for any or all of the following purposes:
- LGV’s personnel;
- Investors, with respect to entrepreneurs, and vice versa;
- LGV’s service providers, in particular for targeted marketing and advertising;
- Competent courts or supervisory or regulatory bodies, when LGV shall compellingly disclose personal data pursuant to any applicable law, regulation or order, e.g. in case of merger, sale or acquisition, or in case of bankruptcy and liquidation, if applicable;
- LGV’s IT systems providers, cloud service providers, database providers and consultants;
- Business partners with whom LGV conducts business with, which is necessary to offer the business services jointly with LGV; and
- Any third-party to whom LGV assigns or transfers any of LGV’s rights or obligations.
We may share some broader statistics and customer profiling information with third parties, but the information or data will be anonymised, so you will not be identifiable from that data. We will not rent or sell your data and/or information details to any other organisation or individual.
Storage of your Personal Data
All information you provide to us is stored on secure servers. Information may be transferred, stored and processed by third parties (see above). It may also be processed by staff operating outside the European Economic Area (“EEA”) who work for us or for one of our suppliers of services, such as data processors or providers of back up services.
You should be aware that in territories outside the EEA, laws and practices relating to the protection of personal data are likely to be different and, in some cases, may be weaker than those within the EEA. By submitting your personal data, you are agreeing to this transfer, storing or processing.
Such transfers outside the EEA will only take place where either (i) the Commission has decided that such third country ensures an adequate level of protection; or (ii) we have provided appropriate safeguards, and on the condition that enforceable rights and effective legal remedies are available for you.
If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services. By submitting your personal data, you agree to the potential transfer, storing and other processing described above. We will take all steps reasonably necessary to ensure that your personal data are treated securely and in accordance with this Privacy Policy.
Cookies
LGV also uses “cookies” to collect information. A cookie is a small data file that LGV transfers to your electronic device and is stored on it. When you access and use the Website, the cookie identifies your electronic device. LGV also uses cookies to measure the traffic to and usage of the Website, its different features, and other miscellaneous uses.
If you do not wish to have cookies placed on your electronic device, you should set your browser or electronic device to refuse cookies before using the Website, with the drawback that certain features of the Website may not function properly without the help of cookies.
Security
We will take all steps reasonably necessary to ensure that your information and/or data is treated securely and in accordance with this Privacy Policy.
We follow strict security procedures as to how your information and/or data is stored and used, and who sees it, to help stop any unauthorised third parties getting hold of it. Once we have received your information and/or data, we will use strict procedures and security features to prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure and although we will do our best to protect your information and/or personal data, we cannot guarantee its security completely. Accordingly, in the case of a security breach we do not accept any liability for the direct or indirect loss, theft or misuse of any information and/or data that you have provided to us and/or which you have registered on the Website.
Third party links
This Website may contain links to third-party advertisers, websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. LGV does not endorse, approve, certify, or control these external internet websites and does not guarantee or assume responsibility for the accuracy or security of information located at such websites. Use of, or reliance on, any information obtained from such websites is voluntary and at such user’s own risk. When you leave our Website, we encourage you to read the privacy notice of every website you visit. We do not accept any responsibility or liability for the privacy policies or notices on third-party websites.
How long we keep your information
If we collect your personal data, the length of time for which we retain it, is determined by a number of factors including the type of data, the purpose for which we use that data and our regulatory and legal obligations attached to the use of your personal data. We do not retain personal data in an identifiable format for longer than is necessary. You can always request that we stop processing or delete your personal information. The next section sets out more information on your rights.
Your rights
- Right of access: The right to ask us for copies of your personal information.
- Right to rectification: If you believe that any information relating to it is incorrect, inaccurate or incomplete, the right to request its rectification or update.
- Right to object: The right to object to certain processing of your personal data. We may be obliged to comply with your request unless we can demonstrate compelling legitimate grounds for further processing of such personal data.
- Right to erasure: The right to request that we delete your information and/or data or the restriction thereof to specific categories of processing.
- Restriction of processing: Under certain statutory situations, we may be obliged to restrict the processing of your personal data.
- Right to opt out of marketing communications: The right to object to a channel of communication used for direct marketing purposes.
- Right to withdraw your consent: In cases where we have been processing your personal data based on your consent, you have the right to withdraw your consent to such processing at any time.
- Data Access Portability: The right to request your personal data’s and/or information’s portability, i.e. that the personal data that you have provided to LGV be returned to you or transferred to the person of your choice, in a structured, commonly used and machine-readable format without hinderance from LGV and subject to their confidentiality obligations.
Contact Information
If you have any questions regarding this Privacy Policy, our privacy practices or would like to make a data access request, you can contact us via email at info@lakegenevaventures.com.
Complaints
If you have any complaints or concerns about the contents of this Privacy Policy or your personal data stored, processed and/or controlled by LGV, we would appreciate the chance to deal with your concerns before you approach the relevant supervisory authority, so please contact us at info@lakegenevaventures.com in the first instance.