Privacy Policy

FINDING STARTUPS LTD PRIVACY POLICY

Effective August 01, 2018

 

WHO WE ARE

Finding Startups Ltd. (the “Company” and/or “Controller”), registered in The Republic of Cyprus, under company registration number 383176, is committed to maintaining robust privacy protections for its users.  Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use and safeguard the information you provide to us and to assist you in making informed decisions when using our Service.

For purposes of this Agreement, “Site” refers to the Company’s website, which can be accessed at www.findingstartups.com. The terms “we,” “us,” and “our” refer to the Company. “You” refers to you, the “data subject”, as a user of our Site or our Service.  “Service” refers to the Company’s services accessed via the Site. Our main service is a listing platform for Startup businesses.

By accessing our Site or our Service, you accept our Privacy Policy, Terms of Use and our Cookie Policy. You consent to our collection, storage, use and disclosure of your Personal Data as described in this Privacy Policy.

 

PERSONAL DATA WE COLLECT

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

The processing of your personal data shall always be in line with the General Data Protection Regulation (GDPR). By means of this data protection declaration and in accordance with the country-specific data protection regulations applicable to Finding Startups Ltd., we would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, you are informed, of the rights to which you are entitled regarding the information you provide us.

We may collect the following categories of personal data:

Personal Data:

  • Login data: Username & Password
  • First and last name
  • E-mail address
  • Telephone number
  • Address / country of residence
  • Contact forms: any communication via contact form submissions is kept for customer service purposes, we do not use this information for marketing purposes.
  • Comments: when visitors leave comments on the Site we collect the data shown in the comments form and also the visitor’s IP address and browser user agent string to help spam detection.
  • IP address: The Site also collects a series of general data and information automatically that cannot be used to personally identify you. This general data and information are stored in the server log files, such as IP addresses, unique device IDs, language, regional settings, anonymous usage data, general demographic information, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks.

Company Data:

  • Company name and description
  • Logo and cover image
  • Address
  • Website URL
  • Contact details
  • Media Images: All uploaded files are usually publicly accessible. If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the Site can download and extract any location data from images on the Site.

Communication Data:

  • Emails: emails you send us voluntarily
  • Contact forms: any communication via contact form submissions is kept for customer service purposes, we do not use this information for marketing purposes.
  • Comments: when visitors leave comments on the Site we collect the data shown in the comments form and also the visitor’s IP address and browser user agent string to help spam detection.
  • Marketing preferences: your express consent to receiving marketing or promotional material from us.

Transactional Data:

  • Purchase information:
  • Upon checkout: First & Last Name, Company Name, Phone Number, E-Mail address, Billing Address, Country of Residence, EU VAT Number (Optional), credit card details
  • Purchase History

Technical Data:

  • Cookies*
  • Analytics**

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

 

HOW WE COLLECT YOUR DATA

  1. Upon Account Registration:
  • First and last name
  • Email address
  • Username and password
  • Financial details upon purchase of a subscription package.
  • Company listing: which includes, company name & description, company logo, contact details, company video & URL (optional).

By registering, you are authorizing us to collect, store and use the above data in accordance with this Privacy Policy. You may make changes or choose to cancel your account at any time.

  1. 2. *(We eat) Cookies (lots of them!)

In an effort to improve the quality of the Service, we also track information provided to us by your browser or by our software application when you view or use the Service, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the Service, the time and date of access, and other information that does not personally identify you. We track this information using cookies, or small text files which include an anonymous unique identifier. Cookies are sent to a user’s browser from our servers and are stored on the user’s computer hard drive. Sending a cookie to a user’s browser enables us to collect data about that user and keep a record of the user’s preferences when utilizing our services, both on an individual and aggregate basis. The Company may use both persistent and session cookies; persistent cookies remain on your computer after you close your session and until you delete them, while session cookies expire when you close your browser.  Please review our Cookie Policy for information on how the Company may use cookies to collect information.

You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some of our Service features may not function properly without cookies. Most browsers accept cookies automatically but allow you to disable them. We recommend that you leave cookies enabled so that we can offer you the best experience.

  1. Third-party processors

We may sometimes contract with the following third parties to supply certain services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold. We have processor agreements in place with said parties.

We also transfer your data to third parties, mentioned below, based in the United States that comply with the EU-US Privacy Shield Framework. This requires third parties to provide data protection to standards of European levels.

3.1 ** Google Analytics  

We use Google Analytics, a web analytics service, on this Site. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects data about the website from which a person has come (the so-called referrer), demographic data, which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.

You have the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this Site, as well as the processing of this data by Google. To prevent your data from being used by Google Analytics, click here for instructions.

You acknowledge that by using our Service you agree to the applicable data protection provisions of Google that may be retrieved here and under their terms here. Google Analytics is further explained under the following Link.

You may also see third party ads on our Service that are targeted to you based on previous data collection and online behavior, or you may see ads on third party websites based on your prior visits to our website Services. We do not have access to these cookies as only third-parties engage in online behavior profiling.

To opt out of Google behavioral advertising, click here to see your Google ad settings.

3.2 Mailchimp

We use Mailchimp, based in the US, as our third-party processor for Direct E-Mail Marketing. They are certified under the EU-US Privacy Shield and have provided measures to ensure your rights and consent are adhered to according to the new EU regulations. At no time will we send you marketing communication without your consent. By agreeing to this Privacy Policy, you acknowledge that the information we collect from you will be transferred to Mailchimp in accordance with their respective Privacy Policy. You have the right to object or opt-out at any time to processing of personal data concerning you for such marketing, as detailed under ‘Your rights’ section below.

3.3 Social Network Platforms

We use social network platforms such as Facebook, Instagram, Twitter and LinkedIn. Actions taken through these external social platforms are custom to their respective Terms & Conditions and Privacy Policies. For ease of reference, we have provided these below, under ‘Useful Links’.

This Site may use social sharing buttons which help share web content directly from web pages to the social media platform in question. You are advised before using such social sharing buttons to do so at your own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.

3.4 LiveChat

We use Smartsupp Live Chat to respond to any questions you might have. When the chat is online or offline, we may collect your name, email, message and IP address. You can check Smartsupp’s Privacy Policy here.

3.5 Payment Processors

Paypal

When signing up for our packages you will be required to provide payment details. Our payment plans are handled through our third-party payment processor, PayPal and are subject to the Terms & Conditions of their Privacy Policy, which you can find here.

PayPal is an online payment service provider. Payments are processed via so-called PayPal accounts, which represent virtual private or business accounts. PayPal is also able to process virtual payments through credit cards when a user does not have a PayPal account. We do not store your credit card details when processed through Paypal. 

The personal data transmitted to PayPal is usually first name, last name, address, email address, IP address, telephone number, mobile phone number, or other data necessary for payment processing. The processing of the purchase contract also requires such personal data, which are in connection with the respective order.

PayPal makes it possible to trigger online payments to third parties or to receive payments. PayPal also accepts trustee functions and offers buyer protection services.

Your data is encrypted before transmission to prevent misuse of the transmitted data by third parties. SSL (Secure Socket Layer) is a security technology which guarantees that your personal data, including credit card information, login data and payment method, are securely transferred via the Internet. The data is encrypted so that is only readable by the PayPal payment systems.

3.6 Accounting Software

We use Xero as our accounting software. Their headquarters are based in New Zealand but they operate and have offices all over the world. Xero automatically collects your name, e-mail address and purchase information when you make a purchase on our Site. You can find details of Xero’s Privacy Policy here.

  1. Embedded content from other websites

Articles on this site may include embedded content (i.e. videos, image, articles, etc.) Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged into that website.

 

OUR LEGAL GROUNDS FOR PROCESSING

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you (i.e providing our Site’s services), because you have explicitly consented to our use of your personal data, because it is in our legitimate business interests to use it or to comply with legal obligations.

Your personal data may be used for the following purposes and on the following grounds:

Performance of a contract with you (i.e providing our Site’s services):

  • Providing and managing your Account;
  • Providing and managing your access to our Site;
  • Personalising and tailoring your experience on our Site;
  • Personalising and tailoring our services for you.

Legitimate Interests:

  • Communicating with you. This may include responding to emails, calls, contact form messages or live chat.
  • Analysing your use of our Site and gathering feedback to enable us to continually improve our Site and your user experience.

Explicit Consent:

  • Supplying you with information by email that you have opted-in to.
  • Sending you marketing communication with information, news and offers on our products and services.

 

HOW WE USE AND SHARE YOUR DATA

Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent or otherwise share for marketing purposes your Personal Data with third parties without your consent. We do share Personal Data with integrated services, such as the servers for our email communications who are provided access to user’s email address for purposes of sending emails from us.

In general, the Personal Data you provide to us is used to help us communicate with you. For example, we use Personal Data to contact users in response to questions, solicit feedback from users, provide technical support, and inform users about promotional offers.

We may share Personal Data with outside parties if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable legal process or enforceable governmental request; to enforce applicable Terms of Use, including investigation of potential violations; address fraud, security or technical concerns; or to protect against harm to the rights, property, or safety of our users or the public as required or permitted by law.

The general data the Site collects is to track trends and analyze patterns on the Site, as well as improve the Service and customize the user experience. We reserve the right to use and disclose such data to our partners, advertisers and other third parties at our discretion.

In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Data may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your Personal Data as set forth in this Privacy Policy.

If our information practices change at any time in the future, we will post the policy changes to the Site so that you may opt out of the new information practices. We suggest that you check the Site periodically if you are concerned about how your information is used.

 

 

HOW WE PROTECT YOUR DATA

We implement security measures designed to protect your information from unauthorized access. Your account is protected by your account password and we urge you to take steps to keep your Personal Data safe by not disclosing your password and by logging out of your account after each use. We further protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.

Only specific employees have access to your data on a need to know basis. They will only process your data according to our Policies and instructions.

By using our Service, you acknowledge that you understand and agree to assume these risks.

 

HOW LONG WE RETAIN YOUR DATA

We will retain your data as long as your account is active. We will not keep your personal data for any period longer than is necessary in light of the reason(s) for which it was first collected (i.e to provide you with our services) and our legal grounds for processing.

To note: if you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

 

YOUR RIGHTS REGARDING THE USE OF YOUR PERSONAL DATA

a) Right to be informed

You have the right to obtain from us the confirmation as to whether or not your personal data is being processed, how it is being processed and the purposes for the processing.

b) Right to access

Subject to any exemptions provided by law, and at no cost to you, you have the right to request access to Information we hold about you, as well as to seek to update, delete or correct this information. You can do so by sending us a ‘Subject Access Request’ at support@findingstartups.com. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

We reserve the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

c) Right to object

If we process personal data for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing. When we send a promotional communication to you, you can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional e-mail. You can also e-mail us a request that you do not wish to receive marketing communications from us at support@findingstartups.com. Please note that we may continue to send you administrative emails including, for example, periodic updates to our Privacy Policy.

We shall no longer process your personal data in the event of the objection, unless we can demonstrate compelling legitimate or legal grounds for the processing.

d) Right to rectification

You have the right to rectify inaccurate personal data concerning yourself and to have incomplete personal data completed, including by means of providing a supplementary statement.

In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.

e) Right to erasure (Right to be forgotten)

You have the right to obtain the erasure of personal data concerning yourself without undue delay, and we have the obligation to erase your personal data without undue delay. In accordance with GDPR regulations, please allow us a period of up to 30 days to ensure your request is carried out. At times, due to either technical reasons or complex requests, it may take longer, please bear with us. We may also retain Personal Data, under statutory regulations, in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.

f) Right to restrict processing

You have the right to request the restriction or suppression of your personal data, thereby limiting the way we use your data.

g) Right to data portability

You have the right to receive your personal data in a structured, commonly used and machine-readable format. Furthermore, you have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

h) Right to withdraw consent

Additionally, if we rely on consent for the processing of your personal data, you have the right to withdraw it at any time. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.

i) Data Breaches

We work hard to ensure any personal information entrusted with us is kept secure, and have systems in place to monitor security 24/7. If a data breach occurs, we will inform you within 72 hours of us identifying the data breach.

We shall implement appropriate technical and organizational measures, in an effective way, in order to meet the requirements of this Regulation and protect your rights. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Data Protection Commissioner’s office in Nicosia, Cyprus: commissioner@dataprotection.gov.cy

 

LINKS TO OTHER WEBSITES

As part of the Service, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Site and the Service. Therefore, this Privacy Policy does not apply to your use of a third party website accessed by selecting a link on our Site or via our Service. To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

 

CHANGES TO OUR PRIVACY POLICY

The Company reserves the right to change this policy and our Terms of Use at any time.  We will notify you of significant changes to our Privacy Policy by sending a notice to the primary email address specified in your account or by placing a prominent notice on our site. Significant changes will go into effect 30 days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the Site and this privacy page for updates.

 

LEGAL AGE

The use of this site is intended for people of 18 years or above. If you believe that a child has provided us with personal information, please contact us at: support@findingstartups.com. Unless we are legally required to retain the data, we will promptly delete it.

 

CONTACT US

If you have any questions regarding this Privacy Policy or the practices of this Site, please contact us by sending an email to support@findingstartups.com

 

Other Information

Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

Finding Startups Ltd.

Cyhub Paphos, Gladstonos 12-14

8046 Paphos

Cyprus

Phone: 0035797768903

Email: hello@findingstartups.com

Website: www.findingstartups.com

 

Name and Address of the Data Protection Officer

The Data Protection Officer of the controller is:

Samantha Gargour

Finding Startups Ltd.

Cyhub Paphos, Gladstonos 12-14

8046 Paphos

Cyprus

Phone: 0035797768903

Email: support@findingstartups.com

Website: www.findingstartups.com

You may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection.

 

Useful links

Last Updated: This Privacy Policy was last updated on August 01, 2018