Overview, Objective and the Scope of the Policy

This Privacy Policy explains how information is collected, used, and disclosed by Start in Europe. (“Start in Europe”) and applies to information collected when you use or access Start in Europe’s website at (the “Website”) and its subdomains or when your information is submitted to Start in Europe to receive services (collectively, the “Start in Europe Service”). We respect the privacy rights of users and recognize the importance of protecting information collected about you.

Our goal is to collect, use and disclose only that personal information reasonably required to enable us to provide the particular product or service that you have requested, to maintain our customer/visitor lists and/or to respond to your inquiries or feedback and for other purposes further described in this Policy. If you have provided us with contact information, we will maintain the confidentiality of your contact information and use it only for the purposes for which we have collected it, unless you agree that we may disclose it to other third parties.

Changing Our Policy

We may change this Privacy Policy from time to time. If we make any changes, we will revise the "Last Updated" date at the end of this Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you an email notification). If there are material changes to this Privacy Policy, we will notify you more directly by email or means of a notice on the home page prior to the change becoming effective. We encourage you to review our Privacy Policy whenever you access the Start in Europe Service to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this Privacy Policy and do not wish your information to be subject to the revised Privacy Policy, you will need to deactivate your account with us and stop using the Start in Europe Service. Your use of the Start in Europe Service after the posting of such changes shall constitute your consent to such changes.

Information Collection and Use

When registering a user account and using our Services we may collect or ask you to provide certain personal information such as contact details of you and/or your organisation.

If you register on our Website as a Company we collect your name and email address as well as other information you provide by filling in the registration form.

If you register on our Website as an Investor we collect your name and email address as well as other information you provide by filling in the registration form, e.g. location, investment history and investment strategy overview.

When subscribing to a paid plan we collect billing information (including credit card and payment information).

In course of using our Services you may provide additional information and/or content by filling out your user profile (e.g. your photo, biography, phone number, etc.), due diligence questionnaire (e.g. company business model, sales channels, milestones, etc). reporting or communicating with other users on the Website (e.g. comments, votes when participating in voting as a jury member, etc). Please read our Terms and Conditions to find out more about different Services and in order to better understand the purposes of the processing of your personal data.

We use the personal information you have provided for creating and managing your user account, managing your subscriptions and to provide and improve the chat, matchmaking, deal room, investment syndicate, reporting and other Services that are available on the Website. Such processing is necessary for the performance of the contract to which you are a party when you are using our Services or in order to take steps prior to entering into the contract.

We may send you e-mails for marketing purposes but only with your explicit consent. You have the right to withdraw your consent at any time. In case you wish to stop receiving e-mails for marketing purposes, please click the unsubscribe button, which can be found at the end of such e-mails.

Sharing and Disclosure of Information

We will not share personal information about you or any Content with any third parties except as described in this Privacy Policy, or as defined in an agreement with us, in

connection with the Start in Europe Service. For example, we may share personal information about you:

To Vendors, Consultants, Solution Partners and Other Service Providers: We may share your information with third-party vendors, consultants, solution partners and other service providers who are working on our behalf and require access to your information to carry out that work, such as to process billing or as it relates to a Product feature. These service providers are authorized to use your personal information only as necessary to provide services to Start in Europe.

In Compliance with Laws: We may disclose your information to a third party: (a) if we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request; (b) to enforce our agreements and policies; (c) to protect the security or integrity of the Start in Europe Service; (d) to protect Start in Europe, our customers, or the public from harm or illegal activities; (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person; or (f) as otherwise directed by you.

We may process your personal information on the basis of consent also in other cases. For example, if you contact us via our Webpage to require information about a custom solution of pricing, we ask you to provide us your name, email, phone number and organization name.

Furthermore, the processing might be necessary for compliance with legal obligations to which Start in Europe is subject. For example, Start in Europe is required to organise the accounting, financial reporting and submit product developmet for evaluation.

We may also use or share the information collected with others, in aggregated, anonymous form, which means that the information will not contain any personally-identifiable information about you or any other person.

As Aggregated and/or Anonymized Data: We may also share aggregated and/or anonymized information with third parties that does not directly identify you.

If you attend an event or webinar organized by us, or download or access an asset on our website, we may share your Personal Data with partners or sponsors of the event so that they may contact you and offer your discounts or other offerings of their services. Where required by applicable law, we will obtain your consent to such sharing when you register to the event or by asking you to scan your attendee badge at a sponsor booth. In these

circumstances, your information will be processed in accordance with the sponsors’ privacy statements. If you do not wish for your information to be shared, you may choose to not opt-in to such sharing when signing up as a member. You may also elect to not have your badge scanned when at an event.

Data Retention

We will retain your personal data only for so long as it is required for the purposes it was collected. This period may extend beyond the end of your relationship with us, but it will be only for so long as it is reasonably necessary for us to have sufficient information to respond to any issues that may arise after the end of your relationship with us. When your personal information is no longer required, we will destroy, delete or convert it into an anonymous form.

As a general rule Start in Europe will keep your personal information for as long as your profile is active. If you delete your profile, we keep your data for the limitation period (3 years by default) of possible claims. If you have not logged into your profile for 6 months, your profile is considered to be inactive; however, your personal data will be retained for the maximal limitation period of 5 years beginning from your last login. If you use your account again during that period, it will be reactivated (considered active again).

Please note that by derogation from the previous your data may be retained longer if other users of the Start in Europe’s Services have the right to process your data. The data will be retained as long as the other user continues using Startup Includer’s Services. Your communication on the Website, including any information you have provided to other users in course of private or group conversations, investment negotiations, investment syndicate or via other means available on the Website, shall remain accessible to such users as long as their user account is not deleted. For example, if an Investor uses the Services to manage his/her portfolio, the Investor has the right to process your data and as long as the Investor uses Start in Europe for these purposes, Startup Includer will retain all the relevant data.

The information contained in the accounting records will be retained for seven years in accordance with the law.

Credit card information is stored on certified credit card service provider servers. We do not retain any credit card information on our servers.

If the data are transferred to a third country, we implement appropriate safeguards and means depending on the circumstances of each transfer (e.g. the standard data protection clauses adopted by the European Commission; the EU-U.S. Privacy Shield Framework:, etc.). We will use technical and organisational measures to safeguard your personal data.

Your Rights As A Subject

You may at any time request to see, update or remove the profile information you have posted on the Website. However, please note that certain Services cannot be provided after you wish to remove your profile information.

You always have the opportunity to opt out of receiving promotional communications any time by following the instructions in those communications. If you opt out, we may still send you non-promotional communications, such as technical notices, support or administrative notifications or information about your account.

You have the right to receive information about the personal data processed by Start in Europe, including the categories of data processed, the sources of the data, purposes of processing etc. You are also entitled to receive copies and extracts of personal data processed. You have the right to request the correction or updating of data if it turns out that the personal data being processed is inaccurate.

You have the right on to object to processing, on grounds relating to your particular situation, at any time to processing of personal data concerning you if such processing is only necessary for the purposes of the legitimate interests pursued by Start in Europe.

You have the right to obtain from Start in Europe restriction of processing or the erasure of your personal data. Startup Includer will erase your data or implement other measures that result in the data becoming permanently anonymous if:

I. your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

II. you withdraw the consent on which the processing is based and there is no other legal ground for the processing;

III. you object to the processing and there are no overriding legitimate grounds for the processing;

IV.your personal data have been unlawfully processed;

V. your personal data have to be erased for compliance with a legal obligation to which Start in Europe is subject.

VI.Start in Europe will fulfil your request within a reasonable time, but no later than one month after receiving the request.

Links to Third-Party Websites

We may place links on the Start in Europe Service, including the Start in Eurpğe blog. When you click on a link to a third-party website from our Website, your activity and use on the linked website is governed by that website’s policies, not by those of Start in Europe. We encourage you to review their privacy and user policies.

Protection of Personal Information

We endeavour to maintain appropriate physical, procedural and technical safeguards with respect to our offices and information storage facilities in order to prevent any loss, misuse, or unauthorized access, disclosure, or modification of your personal information.

We further protect personal information by restricting its access to those employees, contractors, advisers, affiliates and service providers that we determine to reasonably require access to such information for any of the purposes stated in this Privacy Policy.


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