We are a social network and online platform for professionals. People use the AngelFunder application to find and be found for business opportunities, to connect with others and find information.
When you use the AngelFunder application, AngelFunder Limited and our technology partners collect, use and are responsible for certain personal information about you. When we do so, we are required to comply with applicable GDPR regulations as a data processor and/or data controller.
- What information and data we collect, and why we collect it.
- How we use that information and data, and how we secure it.
- Any third parties with access to your personal information that we collect; and
- the choices you have with regard to the use of your personal information and data, and how to contact us about our use of your personal information and data.
How to contact us
If you have any requests concerning your personal information or any queries about our privacy practices, please contact AngelFunder Limited at firstname.lastname@example.org.
If you are resident in the European Economic Area (EEA), you may alternatively address privacy-related enquires to our EU representative appointed pursuant to Art. 27 of the EU GDPR at EUPrivacy@angelfunder.io.
You have the right to make a complaint at any time regarding data protection issues to the relevant supervisory authority. The UK supervisory authority is the Information Commissioner’s Office (“ICO”), whose website is at www.ico.org.uk. If you are resident in the European Economic Area (EEA), you may bring a complaint to your national supervisory authority. We would appreciate the opportunity to deal with your concerns before you approach any supervisory authority, so please contact us in the first instance using the above contact details.
Depending on the type of services you use, the information we collect about you may include:
- Contact information (such as your name, date of birth, email and postal address, telephone number, and country of residence).
- Information permitting us to offer services to you, including details relating to your personal bank accounts, financial sophistication, occupation, investment objectives.
- Details about your finances that you provide to us or permit us to collect through third-party service providers.
- Your login and password details.
- Information about your activity on the AngelFunder application, such as your IP address, the pages you have visited and the device or browser you use.
- Information provided via your mobile devices, such as your location, phone ID, mobile username, password, location.
- Communications with us (for example, when you ask for support, send us requests, questions, or comments, or report a problem).
- Information that you submit through the AngelFunder application, including in the form of comments, contributions to discussions, or messages to other users.
- Demographic information.
- Geolocation information; and
- data mining and financial profiling.
When you opt in for our marketing materials, we collect your email address and name. For more about marketing communications, please see section heading “Marketing” below.
As is true of most applications, but subject to your browser settings, we automatically gather information about your computer such as your IP address, browser type, referring/exit pages, and operating system.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal details change during your relationship with us.
How we use your personal information
We will only use your personal data when the law allows us to. There are various lawful bases on which we may rely to process your personal information, depending on what personal information we process and why. The lawful bases we generally rely on are as follows:
- When we need to perform a contract, we are about to enter or have entered with you (“Contract Performance”).
- 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 (“Legitimate Interests”). If we rely on Legitimate Interests, then the relevant Legitimate Interest is stated below.
- Where we need to comply with a legal obligation (“Legal Obligation”).
We have set out below our reasons for processing your data and have stated the relevant lawful basis on which we rely in order to undertake that processing for each.
We need to use the personal information described below in order to offer our services to you, including for the following purposes:
- Ascertaining whether to approve you for use of the services when you apply to use our services (Contract Performance).
- Identifying you when you sign-in to your account (Contract Performance).
- Detection of suspicious transactions, including transactions involving fraud, money laundering or terrorist financing activities (Legal Obligation; Legitimate Interests).
- Managing invoicing, accounting and information security services related to our transactions with you (Contract Performance).
- Protecting against harm to the rights, property, or safety of AngelFunder, its clients, employees, service providers, or the public (Legal Obligation; Legitimate Interests).
- Internal management purposes, including planning, resource allocation, policy development, quality improvement, compliance, monitoring, audit, evaluation, and reporting (Legitimate Interests).
- Asking you to complete surveys to help us improve our services (Legitimate Interests).
- Managing your communications preferences (Legitimate Interests).
- Maintaining ownership records (Contract Performance); and
- keeping a record of our communications with you to assist us in ensuring you get the best from our services (Contract Performance; Legitimate Interests).
In certain circumstances, a user of the AngelFunder application may wish to contact another user of the AngelFunder application, for example when an angel investor has demonstrated an interest in an entrepreneur’s capital raise pitch and that entrepreneur wishes to make direct contact with that angel investor with a view to follow up.
To protect all concerned, we will not disclose the angel investor’s details save for providing the entrepreneur with the angel investor’s first name, job title and region. Thereafter it is up to the angel investor to decide whether it wishes to follow up with the entrepreneur and/or disclose more information to the entrepreneur whether through the facilities provided by the AngelFunder application, or otherwise.
We would, from time to time, like to send to you information electronically about news, promotions, special offers and other information from us, regarding either our or our selected partners, which may be of interest to you. We will only send you such marketing messages if you actively consent to this (for example, by ticking the relevant box in your application form). Our lawful basis for processing your personal information in order to send you such marketing communications is therefore your consent, which you can withdraw at any time (see section heading below for more information about your legal rights).
If you wish to unsubscribe to marketing emails from us, please contact email@example.com. We will strive to honour your request as soon as possible, and in any event within the next 10 business days. Please note, however, that this request will apply only to marketing emails and not to certain account-based information emails which will continue to be sent to account holders. We are not responsible for any additional information you provide directly to our partners, and we encourage you to become familiar with their privacy and security practices and policies before disclosing information to them.
Information security, storage, and retention
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We will retain your information for as long as you have an account with us or as is needed to provide you with our services. If you wish to terminate your agreement with AngelFunder or request that we no longer use your information to provide you services, please contact us on firstname.lastname@example.org. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 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, regulatory, tax, accounting or other requirements. In some circumstances we will 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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. In summary, these include rights to:
- Require us to correct any mistakes in your information which we hold.
- Require the erasure of personal information concerning you in certain situations.
- Receive the personal information concerning you which you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit that data to a third party in certain situations.
- Object at any time to processing of personal information concerning you for direct marketing.
- Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.
- Object in certain other situations to our continued processing of your personal information; and/or
- otherwise restrict our processing of your personal information in certain circumstances.
If you wish to exercise any of the rights set out above, please contact us using the contact details given above. 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 could refuse to comply with your request in these circumstances. 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. We try to respond to all legitimate requests within one month. Occasionally it could 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.
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