Privacy Policy
This privacy policy (“Privacy Policy”) is applicable to the processing of personal data of individuals (“Users”) collected by FOV Partners GP I Ltd as the general partner of FOV Ventures Fund I Ltd (the “Partnership”) and/or FOV Fund Management Ltd as the AIFM of the Partnership (FOV Partners GP I Ltd, FOV Fund Management Ltd and the Partnership together “FOV”) in connection with using FOV’s online services, website or web-based applications (“Services”).
This Privacy Policy discusses the information FOV collects about users of FOV’s Services, how FOV treats such information, with whom FOV may share it, and how FOV protects it.
This Privacy Policy may be updated if so required to reflect the changes in data processing practices or otherwise. FOV will not make substantial changes to this Privacy Policy or reduce the rights of Data Subjects without providing a notice thereof.
Please note that this Privacy Policy only applies to processing of personal data where FOV acts as a data controller. This Privacy Policy does not address, and FOV is not responsible for, the privacy and data processing practices of any third parties.
CONTACT DETAILS
Questions and requests for personal data related to this Privacy Policy should be addressed to the contact person identified below:
Contact person:
Petri Rajahalme
+358 50 583 6379
petri@fov.ventures
Data Controllers under this Privacy Policy
Name: FOV Partners GP I Ltd
Business ID: 3213686-9
Address: Makslahdentie 14 C, 02140 Espoo, Finland
Name: FOV Fund Management Ltd
Business ID: 3177714-6
Address: Makslahdentie 14 C, 02140 Espoo, Finland
PERSONAL DATA PROCESSED AND SOURCES OF DATA
FOV may collect and process two types of information from the Users in connection with the use of the Services: i) User data; and ii) Technical data. Although we do not normally use Technical Data to identify you as an individual, you can sometimes be recognized from it. In such situations, Technical Data can also be considered personal data under applicable laws.
FOV may collect and process the following Users’ personal information: (a) personal details, including name, email and telephone/fax numbers; (b) with respect to customers who are private entities/institutions/foundations, primary contact person of such entity and contact details including phone and email; (c) information that Users provide when rating our Services or giving feedback on our Services; (d) any other personal data Users may provide themselves.
Technical Data may include for example (a) User’s IP address; (b) browser type and version; (c) preferred language; (d) time and date; (e) operating system and computer platform; (f) the URL of the website visited before and after the Services; and (g) interaction within the Services and other similar Technical Data.
COOKIES
FOV use various technologies to collect and store Technical Data and other information when Users visit FOV’s Services, including cookies. Cookies allow to calculate the aggregate number of people visiting the Services and monitor the use of the Services. This helps to improve the Services and better serve the Users. FOV may also use cookies that make the use of the Services easier, for example by remembering usernames, passwords and preferences. FOV may use tracking and analytics cookies to see how well the Services are being received by the Users, and use unique cookie identifiers for tracking purposes.
Users may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. This can usually be done through Internet browser’s settings. Information about how to manage cookies can be found online. Please note that some parts of the Services may not function properly if use of cookies is refused.
PURPOSES AND LEGAL GROUNDS FOR PROCESSING
Purposes of processing
FOV processes personal data for several purposes: (a) to provide the Services properly and to further develop FOV’s business; (b) for the purpose of contacting Users regarding the Services and to inform Users of changes in the Services; and (c) for other legitimate purposes such as sending of newsletters or similar marketing material, provided that the User has given consent to that or other legitimate grounds for such marketing communication exists.
INTERNATIONAL TRANSFERS
FOV processes personal data primarily within the European Economic Area. However, FOV and/or its service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area or outside of Data Subject’s domicile.
FOV will take steps to ensure that Users’ personal data receives an adequate level of protection in the jurisdictions in which it is processed. FOV provides adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with its service providers based on the Standard Contractual Clauses or through other appropriate safeguards.
More information regarding the transfers of personal data may be obtained by contacting FOV on addresses mentioned in this Privacy Policy.
PERSONAL DATA RECIPIENTS
FOV shares personal data inside its organisation only to the extent it is reasonably necessary for the purposes of this Privacy Policy.
FOV does not share personal data with third parties outside of its organisation unless one of the following circumstances applies:
It is necessary for the purposes set out in this Privacy Policy and to authorised service providers
To the extent that third parties need access to personal data to ensure the performance of the Services, FOV provides such third parties with Users’ personal data. Furthermore, FOV may provide Users’ personal data to authorised service providers who perform services for FOV (including subcontractors providing data storage, marketing and other support services).
When data is processed by third parties on behalf of FOV, FOV has taken the appropriate contractual and organisational measures to ensure that Users’ personal data are processed exclusively for the purposes specified in this Privacy Policy and in accordance with all applicable laws and regulations and subject to FOV’s instructions and appropriate obligations of confidentiality and security measures.
For legal reasons and legal processes
FOV may share personal data with third parties outside of FOV’s organisation if it has a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address criminal, security or technical issues; and/or (iii) protect the interests, properties or safety of FOV, Users or the public in accordance with the law. When possible, FOV will inform Users about such transfer and processing.
With Data Subject’s explicit consent
FOV may share Users’ personal data with third parties outside FOV’s organisation when it has the User’s explicit consent to do so. Users have the right to withdraw the consent they have given at any time.
STORAGE PERIOD
FOV does not store personal data longer than is legally permitted and necessary for the purposes of this Privacy Policy. The storage period depends on the nature of the information and on the purposes of processing. The maximum period may therefore vary per use. However, the retention of personal data shall always follow FOV’s own retention policies.
USERS’ RIGHTS
Right to access
Users have the right to access and be informed about personal data of the User processed by FOV. The User may request a copy of personal data of the User processed by FOV.
Right to withdraw consent
In case the processing is based on a consent granted by the User, the User may withdraw the consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to rectify
The User has the right to have incorrect or incomplete personal data FOV has stored about the User corrected or completed by contacting FOV.
Right to erasure
The User may also ask FOV to erase personal data of the User from FOV’s systems. FOV will comply with such request unless it have a legitimate ground to not delete the data.
Right to object
The User may have the right to object to certain use of personal data of the User if such data are processed for other purposes than necessary for the purposes of this Privacy Policy. If the User objects to the further processing of personal data, this may lead to fewer possibilities to use FOV’s Services.
Right to restriction of processing
The User may request FOV to restrict processing of personal data, for example, when the User’s data erasure, rectification or objection requests are pending and/or when FOV does not have legitimate grounds to process the User’s data. However, this may lead to fewer possibilities to use FOV’s Services.
Right to data portability
The User has the right to receive personal data of the User from FOV in a structured and commonly used format and to independently transmit those data to a third party.
How to use the rights
The above-mentioned rights may be used by sending a letter or an e-mail to FOV on the addresses set out above, including the following information: the full name, address, e-mail address and a phone number. FOV may request the provision of additional information necessary to confirm the identity of the User. Furthermore, FOV may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.
INFORMATION SECURITY
FOV uses administrative, organisational, technical, and physical safeguards to protect the personal data FOV collects and processes. These measures may include where appropriate, for example, encryption, pseudonymization, firewalls, secure facilities and access right systems. FOV’s security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability to restore the data. FOV regularly tests its systems and other assets for security vulnerabilities.
Should a security breach occur that is likely to have negative effects to the privacy of the Users despite of the security measures taken by FOV, FOV will inform the relevant User and other affected parties as well as relevant authorities when required by applicable data protection laws about the breach as soon as possible.
LODGING A COMPLAINT
In case the User considers FOV’s processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection. In Finland, the local supervisory authority is the Data Protection Ombudsman (https://www.tietosuoja.fi).