1. PARTY RESPONSIBLE FOR THE WEBSITE
This website is the responsibility of Adara Venture Partners III S.à.r.l. (hereinafter “ADARA”), 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.
For any request, you can reach us at email@example.com
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. PERSONAL DATA PROCESSED
3.1. What this data is used for
This data is only used to manage the normal use of the website and to perform statistical analysis on the use of the website.
3.2. Recipients of the data
ADARA does not provide this information to any third party, unless it is obliged to do so by law (e.g. an official request in the framework of a police investigation).
3.3. Lawful processing
The legal basis that legitimizes the treatment of the IP address is the technological need to enable the provision of the site and guarantee the security of the website.
3.4. Data processing time
IP addresses will be kept for a period of 1 month.
4. OTHER PROCESSING OF PERSONAL DATA
4.1. Cookies and similar
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.
4.2. Website forms
ADARA does not use its own forms on its website, through which personal data is collected. All form data is collected by third party actors such as Typeform or Mailchimp.
4.2.1. 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 for the performance of a contract or in order to take steps at your request prior to entering into a contract.
- 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 5 years in order to cover any liabilities arising from processing.
- All personal data is handled with care and will be transferred to other Adara entities (Adara Advisors SL, Adara Venture Partners Sarl and Adara Ventures Partner II Sarl) for the same purposes. However, we will not give, sell or rent your personal data to third parties so they can market their services to you.
- All personal data and other files shared with us are stored on TypeForm, Mailchimp, and Google Analytics, which may involve international transfers of data to the US, a country whose legislation does not offer a level of data protection equivalent to the European legislation. Nevertheless, adequate data protection guarantees have been adopted by signing standard contractual clauses approved by the European Data Protection Commission.
4.3. 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).
4.4. The 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 address, or by e-mail to firstname.lastname@example.org 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 National Commission for Data Protection (https://cnpd.public.lu/en.html).
5. 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 whose servers are located in the USA, a country whose legislation does not offer a level of data protection equivalent to the European legislation. Nevertheless, adequate data protection guarantees have been adopted by signing standard contractual clauses approved by the European Data Protection Commission.
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.
6. 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 beforehand, 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.
6. 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.
7. 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.