Privacy policy

ARISTAGORA VC ISRAEL MANAGEMENT LTD

PRIVACY POLICY

[Last updated: October 11, 2020]

This website is operated by Aristagora VC Israel Management Ltd., a management company of Aristagora VC Israel Technology L.P., a venture capital fund investing primarily in equity and equity like securities mainly in Israeli and Israeli related early stage technology startups, through privately-negotiated transactions (“Aristagora”, “we” or “us”).

This privacy policy (“Privacy Policy”) governs the data collection, processing and usage with respect to: (i) individuals who visit our website at: https://aristagoravc.com/ (“Visitor“); (ii) individuals who wish to qualify as investors in our fund (“Investor“) and (iii) individuals who wish to interest us in a potential investment (“Targets”) (all, collectively, shall be defined as “you“).

This Privacy Policy explains what information we may collect from you, how such information may be used or shared with others, how we safeguard it and how each of the aforementioned individuals may exercise their rights associated with their Personal Data (as such term is defined below), but before we get into that, we would like to explain the lawful basis for which we process data:

1. We process Visitors online identifiers subject to our legitimate interest;
2. We process and share Investors’ Personal data subject to either the Investors’ consent or on the basis of performing our contract with them. Please note that as an investor additional provisions may apply to with respect to privacy and data protection, including any privacy notices which were incorporated to your applicable subscription agreement.
3. When we send you direct marketing emails, we process data which we have a legitimate interest in processing; and
4. In the event you contact us, we will process your contact details and other information you choose to provide us with in order to perform our contract with you.

Subject to applicable data protection regulations such as the Regulation (EU) 2016/679 (General Data Protection Regulation) (GDPR) and the Cayman Islands Data Protection Law (DPL), it shall be clarified that we process certain data as a “Controller” and share certain data with service providers, as a “Processors”, all as explained below. If you have any questions about this Privacy Policy or with respect to information we collect or process, please contact us at: info@aristagoravc.com

We reserve the right to periodically amend or revise the Privacy Policy which will go into effect immediately upon the implementation of the revised Privacy Policy on our website. The last revision date will be reflected in the “Last updated” heading located at the top of the Privacy Policy. We will make a reasonable effort to notify you in the event that we implement any changes that substantially change our privacy practices. We recommend that you review this Privacy Policy periodically to ensure that you understand our privacy practices and to check for any amendments.

Our website is a general audience website, which is not directed to persons under 18 years old. We do not knowingly collect or solicit Personal Data from people under 18 years old. If we become aware that a person under 18 years old has provided us with Personal Data, we will delete such data from our databases.

TYPES OF DATA WE COLLECT

We may collect aggregated, non-personal non-identifiable information which may be made available or gathered via your use of our website (“Non-Personal Data”). We are not aware of the identity of the individual from which the Non-Personal Data is collected. We may also collect identifying and personal information from you, specifically through the investor forms you provide us offline through applicable agreements. Such information may include your contact details, banking details, etc. (“Personal Data”). The types of data that we collect as well as the purpose for processing such data are specified in the table below.

Further, in addition to the non-public Personal Data we process, as set forth above, we may process, obtain or receive public Personal Data about you which we will use to profile you together with the non-public Personal Data.

PERSONAL DATA COLLECTED AND PROCESSED

HOW WE COLLECT DATA

Depending on the nature of your interaction with us, including via website, the above detailed data is collected as follows:

• In the event you voluntarily choose to provide us with information, e.g., when you contact us or if you are an Investor and as explained broadly in the privacy notice attached to your subscription agreement.
• Through publicly available database.
• Through third parties (such as, banks).

We will ask for your consent to collect Personal Data and offer you the choice to opt-out of such collection if we are required to do so in accordance with applicable law.

SHARING DATA WITH THIRD PARTIES

We may share Personal Data solely as follows:

• Our affiliates and service providers (e.g., our attorneys, lenders, fund management services and accountants).
• To complete certain transactions or account changes that you request, it may be necessary to provide identifying information to nonaffiliated third party service providers.
• In certain instances, we may contract with nonaffiliated third parties (such as brokers, banks, custodians, tax accountants and others) to perform services for us and, where necessary, disclose your information (described above) to them. In all such cases, we provide the third party with only the information necessary to carry out its assigned responsibilities and only for that purpose. Further, we require these third parties to treat your Personal Data confidentially; however, it should be noted that certain third parties may be required under law to disclose such information to tax and other governmental authorities in varying jurisdictions.
• If you direct us to do so, if you consent and if we are required by law to do so or in other limited circumstances permitted by law – for example, to protect you from fraud.
• In order to comply with applicable laws, we may disclose your nonpublic information to tax and other governmental authorities in varying jurisdictions.
• We may share your information with our related entities, or other companies that are under common control with Aristagora (“Affiliated Companies”) solely if and when applicable or necessary for the purposes described in this Privacy Policy, as well as in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, we will make our best efforts to ensure that our Affiliated Companies or acquiring company assumes the rights and obligations as described in this Privacy Policy.

YOUR RIGHTS

Data protection and privacy laws may provide you with some of the following principal rights (depending on your jurisdiction) with respect to your Personal Data, which you may exercise:

• The right to access your Personal Data;
• The right to ensure your Personal Data is accurate, complete and up to date;
• The right to have your Personal Data amended (by correcting, deleting or adding information);
• The right to object to the processing of your Personal Data;
• The right to lodge a complaint with the appropriate supervisory authority in connection with concerns you may have with regards to your privacy and Personal Data;
• The right to stop the processing your personal data for direct marketing purposes;
• The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice.

In the event that you contact us and request to exercise any of your rights detailed above, we may request that you provide us with certain information in order to verify your identity and locate your data. Please note that, you may have different rights then those which we listed above subject to privacy protections laws in your jurisdiction.

If you wish to exercise any or all of the above rights, or would like to receive more information, or in the event that you have any additional complaints about your privacy rights, you may also send us a request in connection with reviewing your Personal Data to: info@aristagoravc.com

DATA RETENTION

Unless you instruct us otherwise and subject to applicable laws, we retain the information we collect for as long as needed to provide our services and to comply with our legal obligations, resolve disputes and enforce our agreements if applicable.

SECURITY

We use physical, technical and administrative security measures for the services that we believe are in compliance with applicable laws and industry standards in order to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed or accidentally lost. It is important for you to remember however, that unfortunately, the transmission of information via the internet cannot be 100% secure. As such, although we will do our best to protect your Personal Data, we cannot guarantee the security of data transmitted via our website or our services.

Please contact us at: if you feel that your privacy was not dealt with properly or was dealt with in a way that was in breach of our Privacy Policy or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data.

TRANSFER OF YOUR DATA

We may store or process your Personal Data in a variety of countries, including Israel. Please note, that if you are a resident of the EEA we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection when it is being transferred out of the EEA. If you are a resident of a jurisdiction where the transferring of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.

CONTACT US

Aristagora VC Israel Management Ltd.

Email: info@aristagoravc.com

Tel: +972-3-3761005