PRIVACY POLICY

INTRODUCTION

The following Privacy Policy (“Privacy Policy”) is part of our Rules of Participation and Terms of Use and is designed to inform you (“you” or “user” or “your”) the types of personal data that we may gather about or collect from you in connection with your use our website https://creatella.ventures/edtech21, as well as other device or online applications related to or connected thereto (collectively, the “Sites”) and how it uses and discloses that information.  The Privacy Policy applies to data that personally identifies you (“personal data”) using information directly or indirectly associated with you, especially when you “Apply as a startup” or “Apply”  via the Sites to participate in the Programme.  

The Sites are hosted in the United States and are subject to U.S. state and federal law.   If you are accessing the Sites from other jurisdictions, please be advised that you are transferring your personal data to us in the United States.  Your use of this Site constitutes your agreement to this Privacy Policy.  You also agree to abide by the applicable laws of the State of New York and U.S. federal law concerning your use of the Sites and your agreements with us.  If your use of the Sites would be unlawful in your jurisdiction, please do not use the Sites.

COLLECTION OF PERSONAL INFORMATION

Your personal data may be collected directly from you or it may be supplied to us by another party.  We may also collect personal data from other publicly or commercially available sources.  By voluntarily providing us with your personal data, you are consenting to our use of it in accordance with this Privacy Policy.

As a data controller, we collect personal data to deliver our services.  This includes:

  • Personal information: name, gender, date of birth, age, passport details, government-issued numbers and identification documents, photos, signature, nationality, and professional credentials or background; 
  • Contact information
  • Business/employment information 
  • Communications and information 
  • Financial and screening information 
  • Information relating to compliance matters 
  • Special categories of personal data 
  • Technical information 
  • Information about your visit to our website, including domain name, your computer’s IP address 
  • Preferences and views 
  • Transaction-related information 

When you visit the Sites, we may use cookies and other technologies to collect personal data.  We process all data we obtain from you, other sources, or that we create in accordance with this Privacy Policy. 

Information We Collect Directly

You directly provide us with most of the data we collect.  We collect data and process data when you:

  • Register online through our “Apply as a startup” or “Apply”  to participate in the Programme.
  • Voluntarily complete a survey or provide feedback on any of our message boards or via email.
  • Use or view the Sites via your browser’s cookies.
  • Join us as an advisor, investor, mentor, facilitator, jury, and complete our on-boarding process.
  • Attend our events, including demo day, pre-acceleration programme, other online and offline events.

Information We Collect Automatically

When you interact with the Sites, certain information about your use is automatically collected.  This information includes your domain name and host for internet access, internet address of the site from which you came, date and time of your access, your computer’s IP address and information about its operating system, browser and host.  This information may be collected through cookies and other tracking technologies, as well as through your web browser or device (for example, IP address, browser version, etc.).  The tracking technologies employed when you use the Sites may be the first party or third-party.  We use cookies for the following purposes:

  • Performance/Analytics

We use cookies to analyse how the Sites is accessed, used or is performing.  We use the information to maintain, operate and continually improve the Sites.  We may also obtain information from our e-newsletters to learn whether you opened or forwarded the newsletter or clicked on any of the content.  This information will show us the effectiveness of our newsletters and help us to understand that we are delivering information that you find interesting.

  • Advertising/Marketing 

We may use internet-based advertising to collect data across different websites and/or different devices for the purpose of tailoring advertising based on the preferences or interests known or inferred from the data collected.  We may allow third party services, such as Google, Facebook, Instagram and Twitter, that assist us in advertising the Sites to collect or receive information from the Sites and elsewhere on the internet and use that information to provide measurement services and target ads.  

Third Party Service Providers, including Social Media

We may use a range of third party service providers to deliver our services and develop our products.  Third-party website analytics tools include Google Analytics, a web analytics service provided by Google, Inc., that collects automated information about visitor traffic on the Sites.  

When you interact with the Sites through a social media platform (such as by clicking on a social media icon linked from the Sites), we may collect the personal information that you make available to us on that page, including your account ID or username and other information included in your posts.  If you choose to log in to your account with or through a social networking service, we and that service may share certain information about you and your activities.

We may also receive your data indirectly through LinkedIn and Google Analytics. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policy.  We encourage you to read the privacy policies of any third parties upon disclosing your information to such parties or visiting such third party websites. 

USE OF PERSONAL DATA

We may use your personal data for the various purposes, including as follows:

  • Accepting Application/Selection of Startup Participants.  We collect personal data of people who apply as startup participants for the Programme. We process this data for accepting applications, and selection of startup participants and other things related to the Programme.  Please refer to the Collection and Use of personal data in the Participants section in the Rules of Participation.  The information you provide to us during this process is used, stored, and shared under the terms of this Privacy Policy, as if it was collected through this Sites.
  • Targeted Communication.  Data is collected through consensually disclosed information (to our team or at events) or publicly available sources such as LinkedIn and similar social media outlets, and may be used for occasional targeted communications. 

We use personal data to communicate with you, including to inform or update you on activities or events related to the Programme, respond to your inquiries and fulfil your requests, share with you the opportunities that we think you may be interested in pursuing with us, our advisor or venture partner or supporters.

  • Conducting Events.  By attending our events, you permit us to make on-site recordings in which you may be included, by any means, such as video recording and photography. The videos and photos may be used in marketing or editorial material, as long as they are related to the article subject. 
  • Marketing and Subscription.  We may use your personal data, such as names and email addresses in order to communicate with business contacts, build brand awareness, share updates, provide you with more relevant content in email bulletins to which you may be subscribed, publicise events, and fulfil other general marketing purposes.   We do so through occasional email communications, ensuring minimal privacy impact. 

You have the option at any time to stop us from contacting you of any marketing communications by clicking the unsubscribe links provided in the email.

  • Prevention Measure.  Detecting, investigating, and preventing activities that may violate Privacy Policies or be fraudulent or illegal.

SHARING OF PERSONAL DATA

We may share your personal data with third party service providers, affiliates and agents who use the information to help us respond to your requests and to perform services on our behalf.  We may also share information with third parties who we think have a similar mission to ours to enable them to reach you with a similar or related mission.  We do not rent or sell your personal data to third parties.

Sharing Data with Organizers, Investors, Advisors, Venture Partners, Mentors, Judges, and Supporters

We will seek your consent before sharing personal data with any of these third parties. You may find Organizers, investors, advisors, venture partners and supporters we potentially share your personal data with are all listed on the Sites. 

Sharing data with Authorized Third Party

The Sites may contain links to other websites.  These websites are governed by their own terms of use and privacy policies, which we encourage you to read.  We are not responsible for the security or privacy of any information collected by other websites or other services.  You should exercise caution, and read the third party privacy policies to understand how the third parties collect, process, share and store your information.

Sharing Data in Other Circumstances

There are certain situations in which we may share access to your personal data without your explicit consent; including, if required by law, to protect the life of an individual, to prevent fraud against us and/or our business partners, or to comply with any valid legal process, government request, rule or regulation.  Subject to applicable law, we reserve the right to use or disclose your personal data to third parties in a good faith belief that such disclosure is reasonably necessary to (a) take action regarding suspected illegal activities; (b) enforce or apply our Rules of Participation, Terms of Use and Privacy Policy; (c) comply with legal process, such as a search warrant, subpoena, statute, or court order; (d) protect our rights, reputation, personal safety and property, or those of our users, affiliates or the public; or (e) enable our consultants or service providers to help us operate or fulfil your requests more efficiently.

DATA STORAGE 

We store your data using a third party provider where such third parties implement a secure manner in a restricted-access database.  We may store, process and transfer the personal data in the United States or any other country in which we, Organizers, partners or service providers maintain facilities. We may transfer personal data outside of the United States, for example, if a third party we share data with has servers located in other countries.  

Data protection laws vary among countries, with some providing more protection than others.  We are relying on the policy of the cloud services provider to apply the same protections wherever the information is processed and their compliance warranty in relation to data transfer.  

However, no data transmitted over the Internet can be guaranteed to be 100% secure, and WE DO NOT REPRESENT OR GUARANTEE THE SECURITY OF PERSONAL INFORMATION OR OTHER INFORMATION IN ANY FORM.   Similarly, we disclaim liability for personal information submitted through the Sites and you provide us with this data at your own risk.  

We will retain your personal data for as long as is necessary or as permitted by applicable national rules.

Our databases are located in the United States.  If you are outside of the US, you may be located in a region with laws or regulations governing personal data collection, use or disclosure that differ from US laws, which do not have the same data protection laws as the EU and other regions.  By providing your data you consent to: (i) the use of your personal data for the uses identified above in accordance with the Privacy Policy; and (ii) the transfer of your personal data to the US as indicated above and the application of US laws to the collection, use and disclosure of your personal information. 

FOR USERS IN THE EEA AND SWITZERLAND

If you are a resident of the European Economic Area and Switzerland, we would like to inform you the following data protection rights applicable to you:

  • The right to access.  You have the right to request for copies of your personal data we store.  We may charge you an administrative fee for this service.
  • The right to rectification.  You have the right to request to update your personal data if its is inaccurate or incomplete.
  • The right to request data erasure.  You have the right to request to have your personal data erased from our file if the personal data.  This is not absolute and  shall only apply in certain circumstances, including if the personal data is no longer necessary for the purpose for which we originally collected or processed, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing, you object our processing the personal data for direct marketing purposes.
  • The right to restrict processing.  You have the right to request to restrict or object to our processing. This is not an absolute right and shall only apply in certain circumstances, including the following
    • You contest the accuracy of your personal data and we are verifying the data accuracy;
    • Personal data has been unlawfully processed (ie in breach of the lawfulness requirement of the first principle of the GDPR) and you oppose erasure and requests restriction instead;
    • We no longer need the personal data but you need us to keep it in order to establish, exercise or defend a legal claim; or
    • You have objected to you processing their data and we are considering whether our legitimate grounds override your grounds. 

This is not an absolute right and only applies in certain circumstances.  When processing is restricted, we are permitted to store the personal data, but not use it.

  • The right to data portability.  You have the right to receive the personal data you have provided to us in a structured, commonly used and machine readable format.  You may request us to transmit the personal data directly to another controller.  The right to data portability only applies when: our lawful basis for processing the personal data is consent or for the performance of a contract and we are carrying out the processing by automated means, i.e., excluding paper files.
  • Right to object.  You have object to the processing of your personal data at any time, only in certain circumstances, including object to the processing of your personal data if it is for direct marketing purposes, a task carried out in the public interest, the exercise of official authority vested in us; or our legitimate interests (or those of a third party).

If you make a request, we have one month to respond to you.  If you would like to exercise any of these rights, please contact us at hello@creatella.ventures.

INFORMATION YOU PROVIDE ABOUT OTHERS

You shall not provide or allow others to provide personal data about anyone unless you, on your own behalf and on behalf of anyone whose information you provide: (a) have reviewed and agree with this Privacy Policy, and (b) are authorized to and consent to have all data used and transferred internationally.  By submitting any personal data about others you represent and warrant that you have received such prior authorisation.

USE OF THE SITES BY CHILDREN

The Sites are not specifically targeted to children 13 years of age or under.  We do not actively solicit information from children, and we do not knowingly collect personal data from children without proper parental consent. 

GOVERNING LAW

Disputes over privacy issues contained in this Privacy Policy will be governed by the law of the State of New York, USA.  You also agree to abide by any limitation on damages contained in our Rules of Participation, Terms of Use, or other agreement that we have with you.

PRIVACY NOTICE CHANGES

We may make changes to this Privacy Policy from time to time.  We will post any changes, and such changes will become effective when they are posted.  Your continued use of the Sites following the posting of any changes shall constitute your acceptance to those changes.

We may change our ownership or corporate organization or Organizers while providing the Sites.  We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction.  We shall not be able to guarantee that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Privacy Policy.

INQUIRIES

Please contact us at hello@creatella.ventures with respect to any inquiries about our Privacy Policy.

 

Last Updated:  20 September 2021