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Privacy Statement

1 INTRODUCTION

Rockstart Enterprises B.V. and its affiliated entities (together “Rockstart”) want to give you the best Rockstart experience possible and are very committed to your privacy and keeping your personal data safe. We are bound by the General Data Protection Regulation (GDPR) and will protect your personal information in accordance with the principles set out therein.

This privacy statement (“Privacy Statement”) aims to give you a clear view of what personal data we collect and how we use it, our dedication to protecting it and your rights and options to control your personal data and protect your privacy.

2 WHEN DOES THIS PRIVACY STATEMENT APPLY?

This Privacy Statement is applicable to the processing by Rockstart of all personal data of startup founders, mentors, investors, business partners, suppliers, experts, community members and other individuals (“Customers” and each a “Customer”). This Privacy Statement does not address the processing of personal data of employees and/or interns in the context of their employment or internship relationship with Rockstart.

3 WHAT IS PERSONAL DATA AND WHAT DOES PROCESSING MEAN?

Within Rockstart, we consider all information that relates to you and identifies you personally, either alone or in combination with other personal information available to us as personal data. Processing of personal data is pretty much anything you can do with personal data. For example: gathering, storing, combining, transferring or deleting data.

4 HOW DO WE COLLECT PERSONAL DATA?

We collect your personal data through a variety of sources:

More specifically, we collect personal data in the following ways:

5 WHAT CATEGORIES OF PERSONAL DATA DO WE COLLECT?

6 FOR WHAT PURPOSES DO WE COLLECT AND USE YOUR PERSONAL DATA?

We may use your personal data for various purposes, all of which have been set-out below. This may be data that you provided to us explicitly, but also data that we collected ourselves (for example, data relating to your visits of our websites). Some information that we collect is mandated by law or otherwise necessary for the delivery of our services or products. Some information we collect is based on your consent. If you do not allow us to collect all the information we request, we may not be able to deliver all our services or products effectively.

6.1 To provide you with our programs, events, and services
We and our service providers collect, use, hold and disclose personal information to provide you with services and/or products that you have requested from us or we think is of interest to you. This includes personal data that directly relate to the fulfilment of our services and are required to:

 

6.2 To send you our newsletter
When you sign up for our newsletter or if you have registered for one of our events, programs or challenges, shared your contact details with us to stay in touch, or received other services or products in the past, we will send you regular updates on the activities of Rockstart which may be relevant for you. We can update you via e-mail, regular mail or our social media channels. You have the right to unsubscribe at any time from our newsletter by using the “unsubscribe” button at the bottom of the newsletter.

We process this personal information based on your consent if you have subscribed to our newsletter, or for our legitimate business purposes to communicate about our activities and to enhance, modify, personalise or otherwise improve our programs, challenges, events, products, services and communications towards our Customers, to better understand how people interact directly with us (through our communications or our websites) and to determine the effectiveness of promotional campaigns or advertising.

6.3 To send you personalised marketing messages
When you have visited our website, signed up for our newsletter, registered for one of our events, applied for one of our programs or challenges, or shared your contact details with us during one of our events or otherwise, we may send direct marketing communications to you, such as email, phone, or social media. We ask for your consent, where required by applicable law to send our personalised marketing communications.
The messages you receive will be personalised and tailored to your individual preferences and interests. We use analytics to generate such personalised messages. These analytics will process your personal information and place you in marketing segments, which determine the content of the messages and the offers you will receive from us.

We also undertake opinion research (such as to ask if you would like to participate in a survey) to learn about your experience and improve your experience with Rockstart, including by sending you personalised messages.

We process this personal information for legitimate business purposes, to send you relevant information about our programs, events, products and services or promotions and Rockstart news that might be of interest to you.

6.4 To combine and analyse your data
We will use your personal information to create a profile based on the information we hold about you, which is stored and processed in a central marketing database. This is necessary to ensure that we have all accurate information about you in one place. We create your profile in accordance with your preferences to provide you with the best personalised experience, to send you personalised marketing messages and newsletters and for opinion research purposes. Below you can find a more detailed description of the ways in which we will use your personal information for these purposes.

The way you and other Customers interact with our brand across all the different channels described above (e.g. our website, social media channels and marketing messages we send you) and the information we collect in that regard from each of these channels provides us valuable information about your interests and preferences and the interests and preferences of our Customers in general. If you consent thereto, we may combine the information we collect with information we lawfully obtain from third parties.

We process this personal information based on your consent where required, for example if we combine third party databases with ours. We also process this information based on our legitimate business purposes, which includes the ability to enhance, modify, personalise or otherwise improve our services and communications towards our Customers, to better understand how people interact directly with us (through our communications or our websites), determine the effectiveness of promotional campaigns or advertising, and/or to identify and prevent fraud.

6.5 To develop and improve our services
We use aggregated personal data to analyse customer behaviour and to adjust our services accordingly, to ensure that it is relevant to our Customers. We may also process your personal data to compile analytics reports. This means that we analyse how often you read our newsletters, how often you visit our website or apps and which pages you click to understand which services, products and topics you are interested in.
We also test the level of satisfaction of our Customers, using surveys. We use your responses to such surveys for quality assessments and to improve our services and products.

Only insofar as necessary for our legitimate business interest, we use the information above to adjust our services, products, newsletters or website to make these more relevant and attractive for our Customers.

6.6 To comply with the law
In some cases, Rockstart processes your personal data to comply with laws and regulations. This could, for example, be the case where tax or business conduct related obligations apply. To comply with relevant laws and regulations, we may need to disclose your personal data to government institutions or supervisory authorities.

6.7 To perform a contract
If we are (about to enter) in a contractual relationship, we will process your personal information if it is necessary for the performance of the contract or in order to create the respective contract. See chapter 7 for further information.

6.8 To interact with you
If you contact our team (or vice versa), we will use personal information such as your name and contact history to process your request and provide you with the best service possible.

6.9 For publicity purposes
If you participate in one of our events, programs or challenges, your image and/or voice may be recorded and used for promotional purposes. If you don’t want to be recorded, please contact the photographer or cameraman.

7 WHEN YOU ENTER INTO A BUSINESS RELATIONSHIP WITH US

You may provide personal information to Rockstart based on a contract or a broader business relationship and the preparatory stages to enter into a contract. In this part of the policy, we set out how we may process such personal data.

7.1 To process your application for and your entry in an accelerator program
This includes personal data that directly relates to your application for or participation in an accelerator program and is required to:

7.2 For the assessment and acceptance of a business partner
When you get in contact with Rockstart, we process your personal data for assessment and acceptance purposes, for example to confirm and verify your identity. Rockstart further processes personal data of business partners for other administrative purposes such as due diligence and screening against publicly available government and/or law enforcement agency sanctions lists.

7.3 For the conclusion and execution of agreements with business partners
We process your personal data for administrative purposes such as sending invoices and making payments. We also use your personal data to deliver or receive and administer our or your services or products. Rockstart will process your personal data to further execute our agreement, including for the delivery of services and communications.

7.4 For relationship management and marketing
Rockstart uses the information stored in its central marketing database to send you suitable offers and newsletters, keep you updated on our events and to provide services and perform account management. We also use your personal data for the development, execution and analysis of market surveys and marketing strategies.

7.5 For business process execution
We process your personal data in the performance and organisation of our business. This includes internal management, general management and portfolio management. We provide central processing facilities to work more efficiently. We conduct audits and investigations, implement business controls, and manage and use various directories. Also, we process your personal data for finance and accounting, archiving and insurance purposes, legal and business consulting and in the context of dispute resolution.

7.6 To monitor compliance
Rockstart monitors its IT systems to check compliance with Rockstart’s internal policies and regulations, such as the Privacy Policy and the Information Security Policy. During monitoring activities, your personal data may be accessed and viewed.

8 WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?

Rockstart is responsible for the processing of all personal data that falls within the scope of this Privacy Statement. Rockstart may share your personal data with third parties, but if it does so, it will remain responsible for your personal data, unless your personal data has been summoned as part of a court order or another legal obligation to share this data rests on Rockstart.

9 WHO HAS ACCESS TO YOUR PERSONAL DATA?

9.1 Access to your personal data within Rockstart
As a global organisation, all the personal data we collect may be transferred internationally throughout Rockstart’s organisation, but only if Rockstart has a legitimate interest to do so. Based on such legitimate business interest, your personal data may be exchanged with the Rockstart group and with companies working under the Rockstart brand. We exchange your data within the Rockstart group for administrative purposes to create a complete overview of your contacts and contracts. We may also exchange your data to offer you a complete package of services.

Rockstart employees are authorised to access personal data only to the extent necessary to serve the applicable purpose and to perform their jobs.

9.2 Access to your personal data by third parties
The following third parties may have access to your personal data, where relevant, for the provisioning of their products or services to Rockstart or to you:

We may also disclose your personal information to others outside the Rockstart group where:

When such third parties are given access to your personal data, we will take the required contractual, technical and organisational measures to ensure that your personal data is only processed to the extent that such processing is necessary or within the scope of the consent we have received from you. We will ensure that third parties will only process your personal data in accordance with applicable (local) law.

We may need to transfer your personal information outside of the European Economic Area (“EEA”) to a country that is not regarded under European Law as providing the same level of data protection as the country in which you normally use our services. For example, if you register for a Rockstart event outside the EU or participate in an accelerator program outside the EU.

In these circumstances we will take appropriate steps to ensure that your personal information is adequately protected. Typically, such steps include carrying out data security reviews of any recipients and putting in place contracts with such recipients to ensure they employ the same or similar appropriate technical and organisational measures as Rockstart, so your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the contact details below.

We will not sell, distribute or lease your personal information to third parties other than as set out above, unless we have your permission or are required by law to do so.

9.3 The use of your personal data by data processors
When a third party processes your personal data for or on behalf of Rockstart we will enter into an agreement with such third party to agree on appropriate conditions subject to which the processing of personal data is allowed. In this agreement we include obligations to ensure that your personal data is processed by the data processor solely to provide services to us.

10 HOW IS MY PERSONAL DATA SECURED?

Rockstart has taken adequate safeguards to ensure the confidentiality and security of your personal data. We have implemented appropriate technical, physical and organisational measures to protect personal data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing. Examples are our internal Privacy and Information Security policies that all staff must comply with, staff training and secure servers.

11 HOW LONG DO YOU RETAIN MY PERSONAL DATA?

Your personal data will be retained for as long as required for the purposes described in this Privacy Statement or in so far as such is necessary for compliance with statutory obligations and for solving any disputes.

12 HOW CAN I EXERCISE MY RIGHTS?

You can at all times request access, correction, restriction, portability or removal of the data that Rockstart processes or if you have any questions regarding the processing of your personal data by sending a request to compliance@rockstart.com.
if you prefer to contact us by regular mail, please send your request to the following address:

Rockstart Enterprises B.V.
Compliance
Rigakade 10
1013 BC Amsterdam

We are very committed to working with you to always obtain a fair resolution of any complaint or concern you might have in relation to our processing of your personal data. If, however, you feel that we have not been able to assist you adequately and do not comply with applicable privacy rules you have the right to lodge a complaint with the data protection authority using their website.

13 WHEN WAS THIS PRIVACY STATEMENT LAST AMENDED?

This Privacy Statement was lastly amended on 22 May 2018.