2. Collected information
2.1 When Users access and use the Services, ELVIRIA collects the specific following personal data and information (“User Information”) are collected and managed for the purposes and within the times indicated in the table.
|Data||Mode of data acquisition||Purpose of the treatment||Legal basis of the treatment||Data retention time|
|Technical data, such as IP address, browser characteristics (type, language, installed plug-ins, etc.).||Automatic during the platform visit||Visit of the platform by the user||Predominant private interest||10 years|
|Data collected from third-party plugins/websites that are provided when users submit their user Information through the Services||Automatic once the user give its consent||Access to the platform by the user||Predominant private interest||Until cancellation request|
|Identity information such as name, address, company name, ID card, birthday, email address||Entered by the user when registering for the platform or using the contact forms||Registration of personal data for accounting reasons and AML requirements||Fulfilment of contractual obligations and compliance with Anti Money Laundering Act||10 years after termination of the relationship (legal requirement)|
|Information on services purchased, means of payment used and price paid.||Entered by the user during the use of the platform||Recording financial data for accounting reasons||Art. 958f Code of Obligations||10 years|
|Entered by the user||Newsletter registration||Predominant private interest||Until cancellation request|
3. Use of collected information
3.1 The User Information listed in Section 2.1 are strictly necessary for ELVIRIA’s core Services, to provide notably a meeting place for Entrepreneurs of early stage ventures and Investors and enabling Investors to invest within such early stage ventures. Users can withdraw at any time theirs consent for such specific data processing. Please note however that such data processing is strictly necessary to provide the Users the Services and that a withdrawal may lead to the drawback that ELVIRIA would not be able to provide and perform properly the Services any more. In such case, ELVIRIA may terminate the Users’ access and/or use to all or part of the Services without incurring any liability whatsoever.
3.2 In addition, ELVIRIA collects the User Information listed in Section 2.1 for the following specific purposes:
3.2.1 to provide Users email alerts on interesting investments;
3.2.2 to communicate with the Users;
3.2.3 to communicate with the Users;
3.2.4 to provide the Business Management Tools to the Users;
3.2.5 to fuel a jobs posting section on the Website;
3.2.6 the Users’ subscription to ELVIRIA’s newsletter, in order to provide them further news and updates such as new investments matching their interest;
3.2.7 to provide Users with targeted marketing and advertising tailored to their preferences;
3.2.8 to offer Users similar Services;
3.2.9 to re-engage Users accessing and using the Services;
3.2.10 to improve the Services;
3.2.11 for cybersecurity of the Services; and for statistical and planning purposes.
4. Third-party websites
5. Communication to third parties
5.1 ELVIRIA’s personnel;
5.2 Investors, with respect to Entrepreneurs and vice versa;
5.3 ELVIRIA’s service providers such as the companies listed under Section 4, in particular for targeted marketing and advertising;
5.4 competent courts or supervisory or regulatory bodies, when ELVIRIA shall compellingly disclose User Information, pursuant to any applicable law, regulation or order, e.g. in case of merger, sale or acquisition, or in case of bankruptcy and liquidation, if applicable.
5.5 ELVIRIA’s IT systems providers, cloud service providers, database providers and consultants;
5.6 business partners with whom ELVIRIA conducts business with, which is necessary to offer the Services jointly with ELVIRIA; and
5.7 any third-party to whom ELVIRIA assigns or transfers any of ELVIRIA’s rights or obligations.
6. International transfer
The data collected by the Company are stored in Switzerland. Should we transfer your data outside Switzerland, we will ensure that in the first instance the data is stored in countries that guarantee adequate protection of personal data, such as member states of the European Economic Area. If this is not possible, we will ensure that the provisions of the applicable legislation on the transfer of personal data to third countries are complied with in all cases.
9. Data security
ELVIRIA always strive to ensure security, integrity and privacy of the User Information. ELVIRIA has adopted and implemented technical and organizational measures to avoid unauthorized access or disclosure of any User Information.
10. Users’ rights
Users may exercise the following rights under the conditions and within the limits set forth under applicable law:
10.1 the right to access their User Information, as processed by ELVIRIA and, if Users believe that any information relating to them is incorrect, obsolete or incomplete, to request its correction or update;
10.2 the right to request the erasure of their User Information or the restriction thereof to specific categories of processing;
10.3 the right to object to a channel of communication used for direct marketing purposes;
10.4 the right (i) to be informed about any decision making, based the fully automated processing of their User Information, (ii) to express their view on such decision and (iii) to require that it be verified by a human being, except if (a) such decision is directly related to the conclusion of an agreement between ELVIRIA and their request is accepted or (b) if they have given their express consent to such automated decision making; and
10.5 the right to request their User Information’s portability, i.e. that the User Information Users have provided to ELVIRIA be returned to the concerned User or transferred to the person of their choice, in a structured, commonly used and machine-readable format without hinderance from ELVIRIA and subject to their confidentiality obligations.
11. Governing law and jurisdiction