Adara Privacy Policy

1. PARTY RESPONSIBLE FOR THE WEBSITE

This website is the responsibility of the following companies:

Adara Venture Partners III S.à.r.l., a company incorporated in Luxembourg, established at 15 Boulevard F.W. Raiffeisen, Luxembourg, L-2411, registered with the Luxembourg Trade & Companies Register under number B 177954.
Adara Ventures Partners II S.a.r.l a company incorporated in Luxembourg, established at 15 Boulevard F.W. Raiffeisen, Luxembourg, L-2411, registered with the Luxembourg Trade & Companies Register under number B177954
Adara Venture Partners S.a.r.l. a company incorporated in Luxembourg, established at 4, rue Robert Stumper; L-2557 Luxembourg, registered with the Luxembourg Trade & Companies Register under number B108805
Adara Advisors, S.L., a company incorporated in Spain, established at Calle Jose Abascal, 58 - 4º derecha, 28003 , Madrid, registered under number B83439778.
Adara Ventures S.G.E.I.C., S.A., a company incorporated in Spain, established at Calle Jose Abascal, 58 - 4º derecha, 28003 , Madrid, registered under number A72763295.

These companies will be considered as independent Data Controllers, according to the legislation in force.

Each company process the personal data collected by them or transferred from the other companies.

All these companies are hereinafter referred to as "ADARA".

For any request, you can reach us at gdpr@adara.vc

2. MOTIVATION

ADARA respects the privacy rights of its Users and acknowledges the importance of protection of the personal data gathered by ADARA concerning its Users.

This document sets out to inform Users of the website concerning the processing of personal data on this website.

3. PROCESSING OF PERSONAL DATA

3.2. Website forms

ADARA has the following forms on its website through which personal data are collected.

3.2.1. Type form to submit Investment Pitches

ADARA shall process the data furnished through the type form to address the investment request.

Legal basis: The legal basis legitimising the processing is the need to manage the transaction and therefore apply pre-contractual measures.
Conservation period: Data shall be processed for the period necessary to resolve the user’s contact request. Subsequently, they shall be locked and kept for 10 years in order to cover any liabilities arising from processing.
Mandatory data shall be identified as such whenever they are requested. Refusal to furnish this information may prevent the recruitment process from being carried out properly, and your application must be discarded. The consent you have granted may be withdrawn at any time, as stated in the section concerning the rights of the parties concerned in this Privacy Policy, although this shall entail your exclusion from the selection processes since your data cannot be processed.

3.2.2. Newsletter sign up form

ADARA shall process the data provided through the subscription form in order to send you the newsletter and keep you informed about ADARA's products, services, events or news.

Legal basis: The legal basis legitimising this processing is your consent expressed at the time of sending your newsletter subscription request.
Conservation period: The data will be processed indefinitely until you revoke your consent or request deletion of your data.

3.2. Cookies and similar

ADARA uses cookies and other similar data storage and retrieval mechanisms on terminal equipment (“cookies”).

Cookies are files that are downloaded to the User’s browser and can be read later by ADARA. In this way, the cookies allow various functions, such as recognizing a User who has already accessed the website previously and being able to make analyses on the use of the web service that allow it to be improved.

However, it is not possible to find out the identity of the User from the cookies used by ADARA, unless the User provides additional information through other means and these could be linked to the cookies it has downloaded. For more information, see the Cookie Policy.

4. RECIPIENTS OF DATA

ADARA does not disclose this information to any third parties other than ADARA entities unless it is obliged to do so by legislation in force (for example, an official request as part of a police force investigation).

In addition, for the provision of services by ADARA, we inform you that the data shared with us will be hosted by TypeForm, Mailchimp, and Google, located in the US. Therefore, your data may be transferred outside the European Economic Area. However, we inform you that these entities offer adequate data protection guarantees through their adherence to the EU-USA Data Privacy Framework which declares an adequate level of protection by the European Commission or by signing the Standard Contractual Clauses approved by the European Commission.‍

5. USER’S RIGHTS AND HOW TO EXERCISE THEM‍

Data protection regulations guarantee Users the following rights:

Access: This informs the User as to which information is held, where it was obtained, who it has been disclosed to, and the purposes for which it was processed.
Rectification: This enables the User to rectify any erroneous data or data that are no longer current.
Erasure: This enables the User to stop the processing of his/her data.

Opposition: This enables the User to stop his/her data being used for a specific purpose.
Limitation: This enables the User to restrict the processing of his/her data, albeit in such a way that they are kept for a subsequent purpose.
Portability: This enables the User to obtain a copy of his/her data in electronic format and, in certain circumstances, issue a request for them to be sent to another service provider. This is only applicable to computerised processing carried out with the consent of the User or for performance of a contract.
Withdrawal of consent: This enables the User to withdraw any consent he/she may have granted to process his/her data.
Users are informed that they may exercise these rights, and withdraw any consent they may have granted for processing, by post to the above addresses, or by e-mail to gdpr@adara.vc. If Users wish to obtain further information in this regard or believe that their right to data protection has been breached, they may contact the Luxembourg National Commission for Data Protection (https://cnpd.public.lu/en.html), the Spanish Data Protection Authority (www.aepd.es) or with the Data Protection Officer dpo@adara.vc.

6. SENDING OF COMMERCIAL COMMUNICATIONS

ADARA informs the user that the commercial communications requested by the user or if the user has not objected to their reception by checking the corresponding boxes on the forms, will be sent by means of the tool Mailchimp, managed by the company The Rocket Science Group LLC.

The tool used for sending commercial communications by e-mail will include links and tiny, transparent images that will be associated with your e-mail address. In this way, when you download one of these images or access the links contained in the e-mail, ADARA can know for statistical purposes if the e-mail has been opened or if any link has been accessed from the e-mail. You can prevent these uses by configuring your manager or e-mail program to prevent automated downloading of images, as well as by not accessing the links included in the e-mails you receive.

In each communication, the user may oppose to receive this type of information through the specific mechanisms to process the cancellation, as well as request in its case the right to revoke consent, opposition or deletion.

7. DATA OF THIRD PARTIES FURNISHED BY THE USER

In the event the user furnishes personal data of third parties for any reason, he/she guarantees that he/she has notified these parties before hand, and has obtained their consent for disclosure of their data to the company.

If any liabilities arise due to non-compliance with these conditions by the user, he/she must take responsibility for the consequences of such non-compliance.

8. SECURITY MEASURES

ADARA guarantees that it has adopted and applied the necessary technical and organisational measures to guarantee the security of personal data and prevent any alteration, loss, processing or unauthorised access, in due consideration of the status of technology, the nature of the data stored and the risks to which they may be exposed, either by human actions or the physical or natural environment.

However, users must be aware that security measures on Internet are not impregnable.

9. WEBSITE IMAGES

All images used on this site are self-produced or royalty-free. Some of them require the cite of the authors. Photos by: Bady Abbas, Christian Perner, Daniel Von Appen, David Jorre, Drew Beamer, Erik Eastman, Haydn Golden, Jean Philippe, JJ Ying, Joel Filipe, Lucian Aalexe, Mathew Schwartz, Niclas Illg, Omar Flores, Robert Katzki, Ross Parmly, Ryan Quintal, Shahadat Rahman, Shapelined, Scott Webb and William Daigneault on Unsplash. Photo by Natana Elginting on freepik.

10. FURTHER INFORMATION

If users have any queries concerning the information in our Privacy Policy, they may send an e-mail to: gdpr@adara.vc.