WHAT DOES THIS POLICY COVER?

We are Cupola XS B.V. (registered number 76514064), whose registered office is at Koepelplein 1E, 2031WL, Haarlem, the Netherlands (“our”, “us” and “we”). We will refer to you as “you” and “your”. This privacy policy applies to cupolaxs.nl owned and operated by Cupola XS B.V. and/or its affiliated businesses. This privacy policy also applies to webforms where explicit consent to this privacy policy is given. 

We take great care to treat the personal details of any person visiting a Cupola XS webpage or form prudently. Personal details are processed and protected in conformity with the General Data Protection Regulation. The purpose of this privacy statement is to inform you how we use and process any personal details obtained by us when you visit an Cupola XS website and/or do an application for any of our services.

PERSONAL DATA

We process the personal details within the meaning of Article 1, section a, of the General Data Protection Regulation. Personal details are defined as any details that could disclose information about an identified or identifiable natural person.

We use your name, address, telephone number and e-mail address in order to contact you if your personal details are used, or if we have questions about a report you may have made regarding a data leak on our part.

NON-PERSONAL DATA

We also process non-personal data, this is information that refers to a legal entity, which doesn’t relate to identifying a person. When you are an applicant to one of our websites or forms, we may collect this non-personal data. The policy used specifically for personal data does not apply to non-personal data.

RESPONSIBLE PARTY

Cupola XS B.V. is the responsible party within the meaning of the General Data Protection Regulation. This means that Cupola XS B.V. decides which personal details are processed, as well as the purpose for which and how they are processed. We are responsible for ensuring your personal details are processed correctly and prudently in accordance with provisions of the General Data Protection Regulation.

THE PERSONAL DATA THAT WE COLLECT

Examples of personally identifiable information you may provide to us:

We collect personal details that you provide to us such as your name, email address and phone number and information about your organisation, when you want to learn more about us or would like to participate in our activities. We also collect financial details from our paying customers in order to process payment for our services. We also collect non-personal data which includes information about the companies that would like to participate in our activities, this may contain data which is needed for the participating and/or selection process of these activities. You may choose to provide personal details in following examples:

  • Wanting to participate in events, opportunities, meetups, network or other related activities

  • Subscribe to newsletters

  • Submit job applications

  • Contact us for further information

  • Surveys/forms

  • Mailings or calls about relevant opportunities

Information we collect automatically

Automatically we collect certain technical information from you when you visit the Website. The technical information we may collect through cookies are your IP-address, browser types, the web pages you view on our website, whether you interact, how you interact on our website, and the date/time of your Application.

Information obtained from other sources

We could receive information from other sources, including third parties, such as organisers of Cupola XS events, partners, investors and other partners with whom we organise and co-host activities. We also may receive your information by interacting with our social media platforms online or by access to available databases.

We may collect information directly from you, use public record sources or create editorial content about you or the organisation you are linked to in order to identify opportunities for you or your organisation. For example, we may engage with you verbally, by e-mail or use other sources to get this information. As further examples, we may provide this information to third-parties to help them scout appropriate startups to accept into a program, identify potential partners, identify promising investment opportunities or other to engage with you.

Data of children

We understand the importance of protecting the privacy of children. It is our policy to never knowingly collect or maintain personal information of children under the age of 13. When a parent or legal guardians has reason to believe their child has provided personal details to us without their consent, please contact administratie@cupolaxs.nl and we will ensure that we delete this information from our databases.

PURPOSE OF THE PROCESSING OF PERSONAL AND NON-PERSONAL DATA

We process personal and non-personal details of applicants with the purpose of connecting applicants to resources such as corporates, governments, investors and other supporting organisations and persons to create business opportunities. We can use all of the personal and non-personal details provided by applicants to do so. Applicants will be informed how we process these details, and the purpose for which we are using or will use the details.

In more detail: We can provide details of applicants to third parties for the following purposes:

  • Where we need to send details to third parties that provide a service that is part of & relevant for our activities. Only the details that are needed to deliver the service, will be provided. (i.e.  creating a booklet at a third party printing company, with details about startups participating in Activities)

  • Where we need to send details to licensed or contracted partners of activities for the purpose of sending more information about the specific activity the Applicant applied for. These contacted and licensed partners include but are not limited to: corporates, governments, investors and other supporting organizations and persons.

  • Where we can add value to the Applicant based on the communicated needs of the Applicant provided in the application process. In this case, we can provide details of the Applicant to third parties.

  • Where a licensed or contracted partner will perform research based on an anonymized version of the Applicant’s data.

We will not provide the Applicant’s information to third parties for unrelated marketing and/or sales purposes such as but not limited to direct marketing, advertising, or other direct commercial purposes by third parties.

BASIS OF THE PROCESSING OF PERSONAL DATA

We must be able to justify the use of the personal details on the basis of one of the principles laid down in Article 6 of the General Data Protection Regulation. On the grounds of this Article, it is also permissible for these personal details to be processed if the responsible party is required to comply with a legal obligation (Article 6, section 1c of the General Data Protection Regulation).

Consent

When the applicant provides consent of processing his or her personal data for the purpose of connecting with business opportunities and send you updates about our Activities.

Performance of a contract

Your personal information can be necessary to perform the contract you have with us in order to take steps at the request of data subject prior to entering into a contract with us.

Legitimate interest

We may use your personal information for a legitimate interest we have in connecting you to (specific) future business opportunities or a legitimate interest based on the  application on the website for our activities.

To comply with law

Processing is necessary to comply with our legal obligations.

BASIS OF THE PROCESSING OF NON-PERSONAL DATA

We use the same basis of processing non-personal data as processing personal data as described above; consent, performance of a contract, legitimate interest, to comply with law.

PROTECTION OF PERSONAL DETAILS

We ensure that there are suitable technical and organisational measures in place to prevent the loss or unlawful processing of personal details. This means that (personal) details are encrypted when they are being sent, and that they are sent via a secure connection.

RETENTION PERIOD OF PERSONAL DETAILS

We do not retain personal details for any longer than is necessary for the purposes for which they are being processed (Article 5, section 1c of the General Data Protection Regulation).

REGISTER

As the responsible party, Cupola XS maintains a register of all the processing activities which fall within our sphere of responsibility (Article 30 of the General Data Protection Regulation).

YOUR PRIVACY RIGHTS

You are entitled to access your personal details, and also have the right to request that these details be corrected or deleted. If you wish to know which of your personal details Get in the Ring has processed, you should submit a written request to have access to these details. We will process your request within four weeks. If it appears that your details are incorrect, incomplete or irrelevant, you should submit an additional request to have these details removed or supplemented. You should send your written requests to administratie@cupolaxs.nl.

MODIFICATION OF PRIVACY POLICY

We reserve the right, in our sole discretion, at any time to modify or terminate the Website and services, or modify this Privacy Policy. When we make modifications to this Privacy Policy, it will be posted to the website cupolaxs.nl/privacypolicy and at the top of this Privacy Policy it will show the “Updated” date. If any modified terms are not acceptable to the Applicant, the Applicant can choose to cease using the Website and services, and send a written request to us asking it to delete all the details regarding Applicant stored by us. Upon receiving such written request, we will stop using and sharing the details provided by and directly linked to Applicant, but will not (be able to) delete such information provided to third parties earlier on or secluded by way of integration into anonymised datasets. Please review this Privacy Policy periodically, and especially before you  provide us with any personal data. By continuing to use the Website and services after we have notified of the changes, the Applicant agrees to be bound to such changes.

CONTACT DETAILS FOR FURTHER INFORMATION

For further questions or requests about the processing of your personal details: administratie@cupolaxs.nl

CONTACT ADDRESS:

Cupola XS B.V.

Koepelplein 1E

2031WL

Haarlem