Privacy Policy

This Privacy Policy sets out how we, DataFund Llc., obtain, store and use your personal information. The effective date of this Privacy Policy is 7th Maj 2018.

By using our DataFund platform or website, under the domains datafund.io and  datafund.net (including but not limited to our website https://datafund.io and platform https://reclaim.datafund.io/ ), you agree to the use and treatment of your personal information in accordance with this Privacy Policy.

Please read this Privacy Policy carefully. We recommend that you print a copy of this Privacy Policy and any future versions in force from time to time for your records.


Contents

Our details?        4

How do we collect and use (process) personal information about you?        4

What type of personal information we collect or obtain about you?        4

How we use your personal information        6

Data storage and retention        8

Our use of cookies and similar technologies        10

Server log files        10

Registration on this website        11

Registration with Facebook Connect        11

Social media        12

Share content via plugins (Facebook, Google+1, Twitter, etc.)        12

Analytics and advertising        13

Google Analytics        13

Browser plugin        13

Objecting to the collection of data        13

Outsourced data processing        14

Demographic data collection by Google Analytics        14

Google Analytics Remarketing        15

Google AdWords and Google Conversion Tracking        15

Google reCAPTCHA        16

Hotjar web analytics:        17

Newsletter        19

SparkPost        19

IBM Watson Campaign Automation        20

Plugins and tools        22

YouTube        22

Google Web Fonts        22

Google Maps        23

Do not track        23

Transfers of your personal information to other countries and safeguards used        24

Your right to object to the processing of your personal information for certain purposes        26

Consequences of not providing your personal information to us        27

Changes to our Privacy Policy        27

Changes to your information        27

Children’s Privacy        28

Our use of automated decision-making, including profiling        28

Questions, concerns or complaints        28


Our details?

The data controller in respect of our DataFund platform or website is DataFund limited liability company (d.o.o.), the registered office of which is at Kopitarjeva ulica 2, 1000 Ljubljana. If you have any questions about this Privacy Policy, you can send an inquiry to [email protected].

How do we collect and use (process) personal information about you?

We collect personal information about you when you provide it to us, such as through your use of our DataFund platform or website and its features, when you contact us directly by email, phone, in writing, or via social media, when you order services, when you use any of our other websites or applications or any other means by which you provide personal information to us. Where permitted or authorised by law, we may also receive information about you from other sources, if so allowed by law and if such is necessary for the functioning of DataFund platform.

We also collect information about your use of our DataFund platform or website through cookies and similar technologies. Our cookies policy sets out more of the information on how we use cookies and similar technologies to collect information about you.

What type of personal information we collect or obtain about you?

The type of information we collect about you may include information such as:

We may also obtain personal information about you from certain publicly accessible sources, including (but not limited to) the electoral register, online customer databases, business directories, media publications, social media, websites and other publicly accessible sources.

In addition, where we obtain personal information about you from a source other than yourself, we are not required to provide you with certain information contained in this Privacy Policy if:

Where we obtain personal information about you from a source other than yourself, and we are required to provide you with that information, we will provide you with the information contained in this Privacy Policy at the following points in time:

How we use your personal information

We may use your personal information for one or more of the following purposes:

We may also collect or process your personal information for the following purposes:

Data storage and retention

Your personal data is stored on the servers of the Amazon Web Services, a subsidiary of Amazon.com that provides on-demand cloud computing platforms to individuals, companies and governments, which services the DataFund engages, located in one of its EU  data centers, Frankfurt am Main, Germany.

DataFund will store your information for no longer than necessary, taking into account the following:

For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact DataFund at [email protected]

How we secure your personal information

We take appropriate technical and organisational measures to secure your personal information and to protect it against unauthorised or unlawful use or processing as well as against the accidental loss or destruction of, or damage to, your personal information, including:

Transmission of information (including personal information) over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our DataFund platform or website or any other means), you do so entirely at your own risk. We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your transmission of information to us by such means.

Our use of cookies and similar technologies

We use cookies and similar technologies on or via our website. Cookies do not harm your computer and do not contain any viruses. Cookies help make our website more user-friendly, efficient, and secure. Cookies are small text files that are stored on your computer and saved by your browser.

Most of the cookies we use are so-called “session cookies.” They are automatically deleted after your visit. Other cookies remain in your device’s memory until you delete them. These cookies make it possible to recognize your browser when you next visit the site.

You can configure your browser to inform you about the use of cookies so that you can decide on a case-by-case basis whether to accept or reject a cookie. Alternatively, your browser can be configured to automatically accept cookies under certain conditions or to always reject them, or to automatically delete cookies when closing your browser. Disabling cookies may limit the functionality of this website. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org

Cookies which are necessary to allow electronic communications or to provide certain functions you wish to use are stored pursuant to Art. 6 paragraph 1, letter f of GDPR. The website operator has a legitimate interest in the storage of cookies to ensure an optimized service provided free of technical errors. If other cookies (such as those used to analyze your surfing behavior) are also stored, they will be treated separately in this privacy policy.

Server log files

The website provider automatically collects and stores information that your browser automatically transmits to us in “server log files”. These are:

These data will not be combined with data from other sources.

The basis for data processing is Art. 6 (1) (b) GDPR, which allows the processing of data to fulfill a contract or for measures preliminary to a contract.

Additional basis is Art. 6 (1) (f) GDPR. DataFund as a website operator has the legitimate interest to protect his offers against misuse and unauthorized access. These log files are only accessible to system administrators and privileged programmers.

Registration on this website

You can register on our website in order to access additional functions offered here. The input data will only be used for the purpose of using the respective site or service for which you have registered. The mandatory information requested during registration must be provided in full. Otherwise, we will reject your registration.

To inform you about important changes such as those within the scope of our site or technical changes, we will use the email address specified during registration.

We will process the data provided during registration only based on your consent per Art. 6 (1)(a) GDPR. You may revoke your consent at any time with future effect. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.

We will continue to store the data collected during registration for as long as you remain registered on our website. Statutory retention periods remain unaffected.

Registration with Facebook Connect

Instead of registering directly on our website, you may also register using Facebook Connect. This service is provided by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.

If you decide to register with Facebook Connect and click on the “Login with Facebook” or “Connect with Facebook” buttons, you will be automatically redirected to the Facebook platform. There you can log in with your Facebook username and password. This will link your Facebook profile to our website or services. This link gives us access to your data stored on Facebook. Including especially your:

This data will be used to set up, provide, and personalize your account.

For more information, see Facebook’s Terms of Use and Privacy Policy. These can be found at https://de-de.facebook.com/about/privacy/ and https://www.facebook.com/legal/terms/.

Social media

Share content via plugins (Facebook, Google+1, Twitter, etc.)

The content on our pages can be shared on other social networks like Facebook, Twitter, or Google+. This page uses the eRecht24 Safe Sharing Tool. This tool establishes direct contact between the networks and users only after users click on one of these buttons.

This tool does not automatically transfer user data to the operators of these platforms. If users are logged into one or more of the social networks, the Like, +1, and Share buttons for Facebook, Google+1, Twitter, etc. will display an information window in which the user can edit the text before it is sent.

Our users can share the content of this page on social networks without their providers creating profiles of users’ surfing behavior.

Analytics and advertising

Google Analytics

This website uses Google Analytics, a web analytics service. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.

Google Analytics cookies are stored based on Art. 6 (1) (f) GDPR. DataFund as the website operator has a legitimate interest in analyzing user behavior to optimize both its website and its advertising.

Browser plugin

You can prevent these cookies being stored by selecting the appropriate settings in your browser. However, we wish to point out that doing so may mean you will not be able to enjoy the full functionality of this website. You can also prevent the data generated by cookies about your use of the website (incl. your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en

Objecting to the collection of data

You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie will be set to prevent your data from being collected on future visits to this site: Disable Google Analytics

For more information about how Google Analytics handles user data, see Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=en.

Outsourced data processing

We have entered into an agreement with Google for the outsourcing of our data processing and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

Demographic data collection by Google Analytics

This website uses Google Analytics’ demographic features. This allows reports to be generated containing statements about the age, gender, and interests of site visitors. This data comes from interest-based advertising from Google and third-party visitor data. This collected data cannot be attributed to any specific individual person. You can disable this feature at any time by adjusting the ads settings in your Google account or you can forbid the collection of your data by Google Analytics as described in the section “Refusal of data collection”.

Google Analytics Remarketing

Our websites use the features of Google Analytics Remarketing combined with the cross-device capabilities of Google AdWords and DoubleClick. This service is provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA.

This feature makes it possible to link target audiences for promotional marketing created with Google Analytics Remarketing to the cross-device capabilities of Google AdWords and Google DoubleClick. This allows advertising to be displayed based on your personal interests, identified based on your previous usage and surfing behavior on one device (e.g. your mobile phone), on other devices (such as a tablet or computer).

Once you have given your consent, Google will associate your web and app browsing history with your Google Account for this purpose. That way, any device that signs in to your Google Account can use the same personalized promotional messaging.

To support this feature, Google Analytics collects Google-authenticated IDs of users that are temporarily linked to our Google Analytics data to define and create audiences for cross-device ad promotion.

You can permanently opt out of cross-device remarketing/targeting by turning off personalized advertising in your Google Account; follow this link: https://www.google.com/settings/ads/onweb/ .

The aggregation of the data collected in your Google Account data is based solely on your consent, which you may give or withdraw from Google per Art. 6 (1) (a) GDPR. For data collection operations not merged into your Google Account (for example, because you do not have a Google Account or have objected to the merge), the collection of data is based on Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in analyzing anonymous user behavior for promotional purposes.

For more information and the Google Privacy Policy, go to: https://www.google.com/policies/technologies/ads/.

Google AdWords and Google Conversion Tracking

This website uses Google AdWords. AdWords is an online advertising program from Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, United States ("Google").

As part of Google AdWords, we use so-called conversion tracking. When you click on an ad served by Google, a conversion tracking cookie is set. Cookies are small text files that your internet browser stores on your computer. These cookies expire after 30 days and are not used for personal identification of the user. Should the user visit certain pages of the website and the cookie has not yet expired, Google and the website can tell that the user clicked on the ad and proceeded to that page.

Each Google AdWords advertiser has a different cookie. Thus, cookies cannot be tracked using the website of an AdWords advertiser. The information obtained using the conversion cookie is used to create conversion statistics for the AdWords advertisers who have opted for conversion tracking. Customers are told the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, advertisers do not obtain any information that can be used to personally identify users. If you do not want to participate in tracking, you can opt-out of this by easily disabling the Google Conversion Tracking cookie by changing your browser settings. In doing so, you will not be included in the conversion tracking statistics.

Conversion cookies are stored based on Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in analyzing user behavior to optimize both its website and its advertising.

For more information about Google AdWords and Google Conversion Tracking, see the Google Privacy Policy: https://www.google.de/policies/privacy/.

You can configure your browser to inform you about the use of cookies so that you can decide on a case-by-case basis whether to accept or reject a cookie. Alternatively, your browser can be configured to automatically accept cookies under certain conditions or to always reject them, or to automatically delete cookies when closing your browser. Disabling cookies may limit the functionality of this website.

Google reCAPTCHA

We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on our websites. This service is provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”).

reCAPTCHA is used to check whether the data entered on our website (such as on a contact form) has been entered by a human or by an automated program. To do this, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis starts automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, how long the visitor has been on the website, or mouse movements made by the user). The data collected during the analysis will be forwarded to Google.

The reCAPTCHA analyses take place completely in the background. Website visitors are not advised that such an analysis is taking place.

Data processing is based on Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in protecting its site from abusive automated crawling and spam.

For more information about Google reCAPTCHA and Google’s privacy policy, please visit the following links:
https://www.google.com/intl/en/policies/privacy/
and
 
https://www.google.com/recaptcha/intro/android.html
.

Hotjar web analytics:

This website uses Hotjar web analytics service to improve the user experience on our website (http://www.hotjar.com, 3 Lyons Range, 20 Bisazza Street, Sliema SLM 1640, Malta, Europe). Hotjar may record mouse clicks, mouse movements and scrolling activity where we use this information to improve user experience. Hotjar collects information regarding pages visited, actions which are taken, country, device used, operating system, and browser used. Hotjar does not collect personally identifiable information that you do not voluntarily enter in this website. Hotjar does not track your browsing habits across web sites which do not use Hotjar services.  You can find out more about Hotjar data processing here: https://www.hotjar.com/privacy.

If you do not want to be tracked by Hotjar on websites, you can turn it off with a “do not track” header. Hotjar does not collect form submissions or any personal information. You can find information about this on the following website https://www.hotjar.com/opt-out.

Hotjar data processing is based on Art. 6 (1) (f) GDPR. DataFund as the website operator has a legitimate interest in analyzing user behavior to optimize both its website and its advertising.

Newsletter

SparkPost

This website uses the services of SparkPost to send newsletters. This service is provided by SparkPost Message Systems, Inc., 9130 Guilford Road, Columbia, MD 21046, USA.

SparkPost is a service which organizes and analyzes the distribution of newsletters. If you provide data (e.g. your email address) to subscribe to our newsletter, it will be stored on SparkPost servers in the USA.

SparkPost is certified under the EU-US Privacy Shield. The Privacy Shield is an agreement between the European Union (EU) and the US to ensure compliance with European privacy standards in the United States.

We use SparkPost to analyze our newsletter campaigns. When you open an email sent by SparkPost, a file included in the email (called a web beacon) connects to SparkPost’s servers in the United States. This allows us to determine if a newsletter message has been opened and which links you click on. In addition, technical information is collected (e.g. time of retrieval, IP address, browser type, and operating system). This information cannot be assigned to a specific recipient. It is used exclusively for the statistical analysis of our newsletter campaigns. The results of these analyses can be used to better tailor future newsletters to your interests.

If you do not want your usage of the newsletter to be analyzed by SparkPost, you will have to unsubscribe from the newsletter. For this purpose, we provide a link in every newsletter we send. You can also unsubscribe from the newsletter directly on the website.

Data processing is based on Art. 6 (1) (a) GDPR. You may revoke your consent at any time by unsubscribing to the newsletter. The data processed before we receive your request may still be legally processed.

The data provided when registering for the newsletter will be used to distribute the newsletter until you cancel your subscription when said data will be deleted from our servers and those of SparkPost. Data we have stored for other purposes (e.g. email addresses for the members area) remains unaffected.

For details, see the SparkPost privacy policy at:
https://www.sparkpost.com/policies/privacy/

Completion of a data processing agreement

We have entered into a data processing agreement with  SparkPost, in which we require  SparkPost to protect the data of our customers and not to disclose said data to third parties. This agreement may be viewed at the following link: https://www.sparkpost.com/policies/dpa/

IBM Watson Campaign Automation

IBM Watson Campaign Automation (hereinafter: IBM Watson)  is the platform for sending newsletters of US provider IBM we use for e-mailing our customers and prospects. These cookies let us know what content on our website is of most interest to those who have opted in.   also allows us to centrally block any further communication to people who opt out. The data stored by these cookies can be seen only by the relevant teams at Countrywide and IBM Watson and never shows any confidential information.

Email addresses of our newsletter recipients are stored on the servers of IBM in Germany. IBM Watson will use this information to send and evaluate the newsletters on our behalf. However, IBM Watson will not use the information of our newsletter recipients to address them or to transfer them to third parties.

You can find more information about the data collected on the IBM Watson  Privacy Policy.

We trust to the reliability and IT and data security of IBM. IBM Watson is certified under the EU-US Privacy Shield. The Privacy Shield is an agreement between the European Union (EU) and the US to ensure compliance with European privacy standards in the United States. IBM Watson is also certified under ISO/IEC 27001:2013 and thus satisfies the highest IT security requirements. We have concluded a data processing agreement witj IBM. It’s an agreement under which the IBM is obliged to protect the data of our customers in accordance with its data protection provisions and our instructions and especially not transfer them to third parties. The data protection provisions of IBM are available here.

IBM Watson data processing is based on Art. 6 (1) (f) GDPR. DataFund as the website operator has a legitimate interest in analyzing user behavior to optimize both its website and its advertising.

Plugins and tools

YouTube

Our website uses plugins from YouTube, which is operated by Google. The operator of the pages is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.

If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers is established. Here the YouTube server is informed about which of our pages you have visited.

If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account.

YouTube is used to help make our website appealing. This constitutes a legitmate interest pursuant to Art. 6 (1) (f) GDPR.

Further information about handling user data, can be found in the data protection declaration of YouTube under https://www.google.de/intl/en/policies/privacy.

Google Web Fonts

For uniform representation of fonts, this page uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.

When you call up a page of our website that contains a social plugin, your browser makes a direct connection with Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our website. This constitutes a legitimate interest pursuant to Art. 6 (1) (f) GDPR.

If your browser does not support web fonts, a standard font is used by your computer.

Further information about handling user data, can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy at https://www.google.com/policies/privacy/.

Google Maps

This site uses the Google Maps map service via an API. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

To use Google Maps, it is necessary to save your IP address. This information is generally transmitted to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer.

The use of Google Maps is in the interest of making our website appealing and to facilitate the location of places specified by us on the website. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.

Further information about handling user data, can be found in the data protection declaration of Google at https://www.google.de/intl/en/policies/privacy/.

Do not track

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org

At this time, we do not respond to Do Not Track browser settings or signals. In addition, we may use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the website, or one of the affiliated pages. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.

Transfers of your personal information to other countries and safeguards used

We don’t intend to transfer your data outside the European Economic Area but it may be necessary for us to do so from time to time. Where we transfer your personal information outside the European Economic Area, the country to which it is transferred will either be subject to an adequacy decision by the European Commission, or if not (or if we transfer your personal information to an international organisation), we will ensure that the transfer takes place on the basis of one or more of the following safeguards:

Your rights in relation to your personal information

You have the following rights in relation to your personal information, which you can exercise by an email to [email protected].

If there has been a breach of data protection legislation, you also have the right to lodge a complaint with a supervisory authority, which, for the purposes of Slovenia, the Information Commissioner, the contact details of which are available here:  https://www.ip-rs.si/kazalo-kontakt-iskalnik/kontakt/

For further information about your rights in relation to your personal information, including certain limitations which apply to some of those rights, please see Articles 12 to 23 of the General Data Protection Regulation (GDPR), which is available here: 
http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

Where you request access to personal information, we are required by law to use reasonable means to verify your identity before doing so. In order for us to verify your identity, we require you to provide us with an original or certified copy of a document from each of the following two categories of documents:

Where you provide a certified copy of these documents, these must be certified by an appropriate professional such as a notary public.

We will not be able to provide you with access to your personal information until you provide us with your proof of identity as set out above and we have been able to successfully verify your identity.

Your right to object to the processing of your personal information for certain purposes

You have the following rights in relation to your personal information, which you may exercise in the same way as you may exercise the rights in the preceding section (Your rights in relation to your personal information):

You may also exercise your right to object to us using or processing your personal information for direct marketing purposes by:

Whenever you object to direct marketing from us by a different communication method to that of the marketing communications you have received from us, you must provide us with your name and sufficient information to enable us to identify you in relation to the communications you have received (for example, if you have received text messages from us and you wish to unsubscribe by email, we may need you to provide us with your phone number in that email).

Consequences of not providing your personal information to us

Where you wish to purchase goods or services from us, we require your personal information in order to enter into a contract with you. We may also require your personal information pursuant to a statutory obligation (in order to be able to send you an invoice for products and services you wish to order from us, for example).

If you do not provide your personal information, we will not be able to enter into a contract with you or to provide you with those products or services.

Changes to our Privacy Policy

We may change our Privacy Policy from time to time without providing prior notice to you. If required by law, we will make such changes to our Privacy Policy known to you by posting a notice on the website and/or by us posting an updated version of our Privacy Policy on our website with a new effective date stated at the beginning of it. By continuing to access our website on or after that effective date, you agree to be bound by that new version of our Privacy Policy.

Where we intend to use your personal information for a new purpose other than the purpose(s) for which we originally collected it, we will provide you with information about that purpose and any other relevant information before we use your personal information for that new purpose and obtain your consent if required.

Changes to your information

Please inform us of any changes to any information (including personal information) which we hold about you so we can keep the information we hold about you accurate and up-to-date.

The accuracy of your information is important to us. We’re working on ways to make it easier for you to review and correct the information that we hold about you.

We offer a ‘My details’ page (also known as Dashboard), where you can update your personal information at any time, and change your marketing preferences.

You have the right to ask for a copy of the information DataFund hold about you (we may charge for information requests to cover our costs).

Children’s Privacy

We do not knowingly contact or collect personal information from children under the age of 13. The website is not intended to solicit information of any kind from children under the age of 13.

It is possible that we may receive information pertaining to children under the age of 13 by fraud or deception. If we are notified of this, as soon as we verify the information, we will immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about children under the age of 13, please do so by sending an email to [email protected].  

Our use of automated decision-making, including profiling

We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and reduce fraud and credit risk.

Questions, concerns or complaints

Please contact DataFund by sending an email to [email protected] .