Introduction
BigCircle Ventures Coöperatief U.A. and its affiliated entities (together “BigCircle Ventures”) are 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.
When Does This Privacy Statement Apply?
This Privacy Statement is applicable to any processing by BigCircle Ventures of all personal data of, investors, business partners, suppliers, experts, and other individuals (“Relations” and each a “Relation”).
What Is Personal Data and What Does Processing Mean?
Within BigCircle Ventures, 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 includes any actions that can be performed with personal data, such as gathering, storing, combining, transferring, or deleting data.
How Do We Collect Personal Data?
- We collect your personal data through a variety of sources:
- Directly from you, such as the information you provide when you opt-in for our mailings, contact us, or give us your business card;
- From others, such as your partner, colleague, or through a mutual connection/our network;
- From sources that are publicly available, such as LinkedIn or your company’s website;
- During our venture building process.
More specifically, we collect personal data in the following ways:
- News and publications – when you subscribe to our newsletter;
- Careers – when you (may) apply for a job or an internship;
- Events – when you (may) sign up for an event or show interest in being notified about events;
- Investments – when we ask you to fill out certain customer due diligence information in order for us to comply with applicable anti-money laundering laws and regulations when we are executing fundraising activities.
What Categories of Personal Data Do We Collect?
- Name, contact details, profession, and other identifying information required for payroll processing;
- When you subscribe to our newsletter, apply for a job or internship, sign an employment agreement, or contact us, we may record your name, title, profession, and contact details. Your contact details may include your address, telephone number, social media accounts, and/or email address;
- Job application details, including your name, Curriculum Vitae, motivation, contact details, and other information you share with us;
- Legal identification data, such as passport details, for compliance with anti-money laundering procedures;
- Communication records, such as emails and calls;
- Investors – when you (may) become involved as an investor;
- Experts – when you (may) become involved as an expert in a certain field;
- Partnerships – when we (may) enter into a collaboration with your organization;
- Photo and/or video content from events or for publicity purposes.
For What Purposes Do We Collect and Use Your Personal Data?
We may use your personal data for various purposes, including:
- Sending you our newsletter. When you sign up for our newsletter or if you have registered for one of our events or shared your contact details with us, we will send you regular updates. You have the right to unsubscribe at any time using the “unsubscribe” button at the bottom of the newsletter;
- Complying with laws and regulations, which may require us to disclose your personal data to government institutions or supervisory authorities;
- Onboarding new investors, where we request to fill out customer due diligence information to comply with anti-money laundering laws and regulations;
- Throughout the venture building process and when we consider doing investments in any ventures of BigCircle, for which we might ask for information like your personal data, passport copy, perform our CDD assessment, and do a management scan;
- Performing a contract, if we are (about to enter) in a contractual relationship, including an employment agreement;
- Interacting with you when you contact our team or vice versa, using personal information such as your name and contact history;
- Publicity purposes, if you participate in one of our events or are part of the management team of one of the ventures of BigCircle.
When You Enter into a Business Relationship with Us
You may provide personal information to BigCircle Ventures based on a contract or a broader business relationship and the preparatory stages to enter into a contract. We may process such personal data for:
- Processing the request for funding;
- The assessment and acceptance of a business partner;
- The conclusion and execution of agreements with business partners;
- Business process execution, including internal management, general management, and portfolio management.
Who Is Responsible for Your Personal Data?
BigCircle Ventures is responsible for the processing of all personal data that falls within the scope of this Privacy Statement. We may share your personal data with third parties, but if we do so, we will remain responsible for your personal data, unless your personal data has been summoned as part of a court order or another legal obligation.
Who Has Access to Your Personal Data?
Access to Your Personal Data within BigCircle Ventures
Personal data we collect may be transferred within BigCircle Ventures’s organization but only if we have a legitimate interest to do so. Your data may be exchanged within BigCircle Ventures for administrative purposes to create a complete overview of your contacts and contracts. Employees are authorized to access personal data only to the extent necessary to serve the applicable purpose and to perform their jobs.
Access to Your Personal Data by Third Parties
The following third parties may have access to your personal data:
- Service providers, such as due diligence providers, business partners, investors, experts, and similar parties.
- Bank payment system operators and credit card companies for the fulfillment of payments.
- Insurance companies.
- IT suppliers hosting our websites and technology service providers.
- Parties supporting our marketing activities.
- Debt collectors.
- Fraud bureaus or other organizations to identify, investigate, or prevent fraud or other misconduct.
- Regulatory bodies, government agencies, and law enforcement bodies.
Our financial advisors, legal advisors, and auditors.
When third parties are given access to your personal data, we will take the required contractual, technical, and organizational measures to ensure that your personal data is processed only to the extent necessary or within the scope of the consent we have received from you.
The Use of Your Personal Data by Data Processors
When a third party processes your personal data for or on behalf of BigCircle Ventures, 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.
How Is My Personal Data Secured?
BigCircle Ventures has taken adequate safeguards to ensure the confidentiality and security of your personal data. We have implemented appropriate technical, physical, and organizational measures to protect personal data against accidental or unlawful destruction, loss, damage, alteration, unauthorized disclosure or access, and other forms of unlawful processing.
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 as necessary for compliance with statutory obligations and for solving any disputes.
How Can I Exercise My Rights?
You can at all times request access, correction, restriction, portability, or removal of the data that BigCircle Ventures processes. If you have any questions regarding the processing of your personal data, send a request to info@bigcircle.ventures.
If you prefer to contact us by regular mail, please send your request to the following address:
BigCircle Ventures
Attn: Compliance
Joan Muyskenweg 22
1096 CJ Amsterdam
The Netherlands
We are very committed to working with you to 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.
When Was This Privacy Statement Last Amended?
This Privacy Statement was last amended on 5 June 2024.