Privacy Policy

1. PREAMBLE

 

We are responsible for ensuring that this website uses the Personal Data in compliance with data protection laws.

We respect the privacy of our clients, and we are committed to keeping all your Personal Data secure. This Privacy Policy governs the handling of Personal Data by ROCHELLE CAPITAL MANAGEMENT AEDAKES in the course of carrying on commercial/investment activities.

“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information, which is in the possession of, or is likely to come into our possession (or that of our representatives or service providers including but not limited to ROCHELLE CAPITAL MANAGEMENT AEDAKES). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of ROCHELLE CAPITAL MANAGEMENT AEDAKES or any other person in respect of an individual.

 

2. THE PRODUCTS AND SERVICES WE PROVIDE

 

This Privacy Policy concerns the following categories of information that we collect about you:

  • Information we receive through our website (“ROCHELLE CAPITAL MANAGEMENT AEDAKES Website”), as described in our Terms and Conditions, and
  • Information we receive through or in connection with our Portfolio Investment Activities and potential Investee Companies.

 

3. THE TYPES OF PERSONAL DATA WE COLLECT

 

Many Investment Activities of ROCHELLE CAPITAL MANAGEMENT AEDAKES require us to obtain Personal Data about you in order to evaluate the eligibility of Investee Companies in compliance with the current legislation and provide funding to our Portfolio Companies. In relation to the abovementioned, we will collect and process the following Personal Data about you:

  • Information that you provide to ROCHELLE CAPITAL MANAGEMENT AEDAKES: This includes information about you that you provide to us. The kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):
    1. Basic Personal Data (such as first name, family name, position in the company, company name, company email address, business phone number, business address, city, postcode, country),
    2. Project Data (such as financial forecasts, fundraising targets, business assumptions, pricing targets) describing a business that may or may not become incorporated in our eligible Investees,
    3. Any information that you choose to share with us (whether through our websites or otherwise) which may be considered Personal Data,
  • Information that we collect or generate about you: This includes (by way of a non-exhaustive list):
    1. Information about the website contact tools you use, your interests in our informative content and our interactions with you,
    2. When you visit ROCHELLE CAPITAL MANAGEMENT AEDAKES Website, cookies are used to collect technical information about the services that you use, and how you use them.
    3. Information we obtain from other sources.
    4. We may be supplied with CV of prospective candidates for roles at both ROCHELLE CAPITAL MANAGEMENT AEDAKES and our portfolio companies.
    5. We may from time to time use 3rd party public and private data sources.
  • Anonymized data: In addition to the categories of Personal Data described above, we will also process further anonymized information and data that is not processed by reference to a specific individual.

 

4. HOW WE USE YOUR INFORMATION

 

4.1 Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

  • for ongoing review and improvement of the information provided on or operation and security of ROCHELLE CAPITAL MANAGEMENT AEDAKES Website,
  • to comply with and to assess compliance with applicable laws, rules and regulations, and internal policies and procedures,
  • for the administration and maintenance of databases storing Personal Data, and / or
  • to process business communications traffic data sent and received by us for the purposes of evaluating our existing or prospective business relationship.

4.2 However, the way we use Personal Data, we make sure that the processing complies with respective privacy laws and the laws only permits and requires us to process Personal Data on specific legal basis. These include where:

  •  we need to do so in order to perform our contractual obligations,
  • we have obtained your consent,
  • we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings,

4.3 We will take steps to ensure that the Personal Data is accessed only by employees of ROCHELLE CAPITAL MANAGEMENT AEDAKES that have a need to do so for the purposes set out in this Privacy Policy.

 

5. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

 

5.1 We may share your Personal Data among BGW VCMF and ROCHELLE CAPITAL MANAGEMENT AEDAKES for the purposes described above.

5.2 We may also share your Personal Data outside of ROCHELLE CAPITAL MANAGEMENT AEDAKES for the following cases:

  • with our business partners. For example, this could include intermediaries that introduced you to us. Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation,
  • with third party agents and contractors for the purposes of providing services to us (for example, ROCHELLE CAPITAL MANAGEMENT AEDAKES accountants, professional advisors, IT and communications providers and debt collectors). These third parties will be subject to appropriate data protection obligations, and they will only use your Personal Data as described in this Privacy Policy
  • to the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend our legal rights,
  • if we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes, and
  • if we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third – party buyer.

 

6. INTERNATIONAL TRANSFERS OF PERSONAL DATA

 

6.1 We may transfer your Personal Data to locations outside of your country.

6.2 Where we transfer your Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of Europe, for example, this may be done in one of the following ways:

  • the country that we send the data to, might be approved by the European Commission as offering an adequate level of protection for Personal Data,
  • the recipients might have entered into a contract incorporating “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data
  • or in other circumstances whereby, the laws may permit us to otherwise transfer your Personal Data outside Europe.

 

7. HOW WE SAFEGUARD YOUR INFORMATION

 

We have extensive controls in place to maintain the security of our information and information systems. The information that we handle is protected with safeguards appropriate to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed, or stored is exclusively limited to authorized employees.

As a condition of employment, ROCHELLE CAPITAL MANAGEMENT AEDAKES employees are required to follow all applicable laws and regulations, including personal data protection laws. Access to sensitive Personal Data is limited only to those employees for whom it is essential in order to discharge their duties. Unauthorized processing or disclosure of confidential client information by a ROCHELLE CAPITAL MANAGEMENT AEDAKES employee is prohibited.

 

8. HOW LONG WE KEEP YOUR PERSONAL DATA

 

How long we will hold your Personal Data for will vary and be determined by the following criteria:

  • the purpose for which we are processing it – ROCHELLE CAPITAL MANAGEMENT AEDAKES will need to keep the data for as long as is necessary for that purpose, and
  • legal obligations – laws or regulations may set a minimum period for which we have to keep your Personal Data.

 

9. YOUR RIGHTS

9.1 In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:

  • the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you,
  • the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation,
  • in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to ROCHELLE CAPITAL MANAGEMENT AEDAKES,
  • the right to request that we rectify your Personal Data if it is inaccurate or incomplete,
  • the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it,
  • the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request, and
  • the right to lodge a complaint with the National Data Protection Authority if you think that any of your rights have been infringed by us.

9.2 You can exercise your rights by contacting us using the details listed in paragraph 11 below.

 

10. DESIGNATED REPRESENTATIVE

 

ROCHELLE CAPITAL MANAGEMENT AEDAKES registered office may be contacted using the following contact information:

ROCHELLE CAPITAL MANAGEMENT AEDAKES, 43 Mitropoleos Str. (METROPOLIS CENTER), Marousi, 15124, Greece

 

11. ENQUIRIES AND CONCERNS

 

If you have any questions or concerns about our processing of your Personal Data, or about this Policy, please contact us using the following contact information:

Via post: ROCHELLE CAPITAL MANAGEMENT AEDAKES, 43 Mitropoleos Str. (METROPOLIS CENTER), Marousi, 15124, Greece Via email: info@rcm.vc /or admin@rcm.vc

We are usually able to resolve privacy enquiries or concerns promptly and effectively. If you are not satisfied with the response you receive, you may lodge a complaint with the National Data Protection Authority at www.dpa.gr.