Privacy Policy.

This Privacy Policy is meant to help you understand what personal data we collect, why we collect them and what we do with them. Please take time to read our Privacy policy carefully. We want you to be aware of how we use your information and how you can exercise your rights.

This Privacy Policy applies to your Personal Data when you visit https://sofiaventures.eu/ (the “Website”) or use our services through this Website and does not apply to online websites or services that we do not own or control. By using any of our services through the Website you agree to have read and understood this Privacy Policy.

WHO WE ARE

The company providing you services in the capacity as Personal Data Controller is Sofia Angels Ventures KDA, UIC 206288077, with seat and registered office: Sofia, 1463, 90 Vitosha Blvd., 5th floor, office 6, email: milen@sofiaventures.eu

Data protection officer: Milen Ivanov, email: milen@sofiaventures.eu, tel: +359 2 9515132

We take your right to privacy seriously and work continuously to keep the data we process minimized. Nevertheless, in order to be able to provide you with our services, we need to process some personal data.

PERSONAL DATA RECEIVED THROUGH THE APPLICATION FORM (“APPLY FOR FUNDING”)

Categories of data subjects

For the performance of its main activity Sofia Angels Ventures KDA processes personal data of the following categories of data subjects:

1. a) individuals – applicants for funding;
2. b) legal representatives of legal entities – applicants for funding;
3. c) employees or team of the applicants for funding;
4. d) contact persons of applicants for funding;
5. e) investors of the applicants for financing;
6. f) competitors of the applicants for funding.

Categories of personal data

When you use our Website platform to apply for funding for your project we may process the following personal data:

1. a) General personal data of the natural persons – incl. names;
2. b) Personal data related to the application for funding – education and qualification, work experience, skills, place of development of the project, as well as any other information that applicants may choose to include in their CV or accompanying documentation, such as diplomas, certificates, videos, photos, etc. ;
3. c) Contact details – email address, telephone number, LinkedIn profile.

Purpose for processing and legal basis

We may process your personal data for the following purposes:

1. a) identifying the person as an applicant for funding;
2. b) completing and maintaining the relevant documentation related to the funding project;
3. c) evaluation of the project, provision of assistance by Sofia Angels Ventures KDA and selection of appropriate funding;
4. d) liaising with applicants and providing feedback, support, news and notices on the development and financing of their projects.

The legal basis for this processing is the performance of pre-contractual and contractual obligations of Sofia Angels Ventures KDA in relation to the Application for funding and the evaluation of the project.

Terms of storage

We will store the personal data received through our platform up to 10 (ten) years from the submission of your Application for funding. In case that your Application for funding is approved we store the personal data for 7 more years after termination of Sofia Angels Ventures KDA (pursuant to the requirements of the European Investment Fund).

Third party recipients

We may share the personal data contained in your Application for funding with the following third parties:

1. a) the shareholders and the general partner of Sofia Angels Ventures KDA;
2. b) tax and accounting services providers and expert auditors;
3. c) legal advisers;
4. d) service providers supporting the e-mail system used by Sofia Angels Ventures KDA;
5. e) service providers supporting software systems used by Sofia Angels Ventures KDA;
6. f) other IT service providers;
7. g) the European Investment Fund (EIF)*;
8. h) co-investors**.

*For the performance of our investment services and in order to be able to provide you with funding for your project we are strongly backed up by the European Investment Fund (EIF) as our main shareholder. Pursuant to the contractual relations established between Sofia Angels Ventures KDA and EIF we shall provide EIF with the personal data you disclosed to us via your Application for funding.

You shall be aware that your personal data are processed by the European Investment Fund (in its capacity as independant “Controller”) in accordance with Regulation (EU) 2018/1725 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data, as such regulation may be amended from time to time and with EIF Privacy Notice.

You can learn more about the EIF Privacy Notice and manner of such processing available at:

http://www.eif.org/attachments/processing-of-final-recipients-personal-data.pdf, as may be updated from time to time and

https://www.eif.org/attachments/eif_data_protection_statement_financial_intermediaries_due_diligence_en.pdf, as may be updated from time to time.

It is your sole responsibility to follow up with the amendments and supplements of the documents above and to undertake all necessary actions for the implementation of their personal data requirements.

**In connection with the conditions for provision of funding of applicants, according to which Sofia Angels Ventures KDA will provide funding to applicants only if such applicant receives simultaneous funding by a third party – a private investor (co-investor) and in view of the need for the co-investor to receive sufficient information, on the basis of which to make an independent and informed decision regarding the investment, Sofia Angels Ventures KDA shall provide the co-investor with some of your personal data, contained in your Application for funding. Sofia Angels Ventures KDA shall, as appropriate, notify you of the said disclosure of personal data to the respective co-investor.

PERSONAL DATA RECEIVED THROUGH THE CONTACT FORM (“CONTACT US”)

When we receive an inquiry by a person through one of our contact forms, we will use the contact information (name and email address) provided by him / her to contact and provide the information or assistance he/she needs.

We store the data received through our contact form up to 2 (two) years in order to respond to inquiries, create and settle contractual relationships.

METHOD OF COLLECTION

We shall not use any personal data, unless it has been voluntarily provided, entered or uploaded by you personally. You are not allowed to enter third party personal data without due authorization by such third party. It is your sole responsibility to provide and guarantee that the processing personal data activities performed and the provision of third party personal data are compliant with the requirements of the applicable data protection legislation.

Sofia Angel Ventures KDA cannot monitor or control the content, entered or uploaded by the applicants for funding or the users of the website and its compliance with the data protection legislation.

It is your responsibility (personally and/or as a representative of the company-applicant for funding) to provide and guarantee that the processing personal data activities, performed by you and the company-applicant for funding are compliant with the requirements of the applicable data protection legislation, as well as that Sofia Angel Ventures KDA shall have all legal rights for processing the provided personal data. In the event of a Data Subject claim or sanctions by a competent authority for violation of applicable data protection legislation, resulting from your  noncompliance of obligations listed herein, you shall (personally and/or as a representative of the company-applicant for funding) compensate Sofia Angel Ventures KDA for all sustained damages, including any compensations, administrative penalties and sanctions, reasonable lawyer fees, expenses, etc.

HOW WE PROTECT YOUR INFORMATION

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential and that they are properly trained and authorised. We also take appropriate technical and organisational measures to protect your personal data against loss or other forms of unlawful processing.

MINORS

We allow our network to be used only by persons aged 18 and over. If we obtain actual knowledge that we have collected personal data from a person under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. Please, contact us, if you believe that we have mistakenly or unintentionally collected information from a person under the age of 18.

YOUR RIGHTS

You have the right to request a copy of your personal details at any time, to check the accuracy of the information held and/or to correct or update this information. You may ask your personal information to be deleted completely, if no enquiry from you is in progress. You also have the right to complain when your personal data protection rights have been violated. We will make commercially reasonable efforts to provide you with reasonable access to any of your personal information we maintain or correct it within 30 days as of receipt of your request. We will comply with your instructions for deletion of personal data as soon as reasonably practicable and within a maximum period of 30 days, unless EU or Bulgarian law requires further storage. Please, note that we may keep that information for legitimate business or legal purposes or be required (including by contract or GDPR) to keep certain of information and not delete it (or to keep this information for a certain time, in which case we will comply with the deletion request only after we have fulfilled such requirements). Please, note that after deleting your information, you shall not be able to use our network anymore.

If you wish to access, delete (when applicable) or correct your personal information please, address your requests and complaints to: Sofia, 1463, 90 Vitosha Blvd., 5th floor, office 6, or to email: milen@sofiaventures.eu.  Please state clearly in the subject that your request concerns a privacy matter, and more specifically whether it is a request to access, correction, deletion or else. Bear in mind that we may ask for additional information to determine your identity.

We may reject requests that are unreasonably repetitive, require disproportionate technical effort, risk the privacy of others, or would be extremely. Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort.

SUPERVISORY AUTHORITY

If you think we have infringed your privacy rights, you can lodge a complaint with the supervisory authority of Bulgaria, which is the Commission for personal data protection. More information can be found at: www.cpdp.bg. You can also lodge your complaint in particular in the country where you live, your place of work or place where you believe we infringed your right(s).