This Privacy Policy ("Policy") sets out the basis on which VCEL Global (hereinafter referred to as "VCEL", "we", "us" or "our") processes Personal Data in connection with the use of the website https://www.vcelglobal.com (the "Website") and any related online or offline interactions with VCEL in the course of its venture capital and related activities (collectively, the "Services").
By accessing or using the Website or otherwise providing Personal Data to VCEL, you acknowledge that you have read, understood and agree to the terms of this Policy.
1. DEFINITIONS
For the purposes of this Policy:
- 1.1 "Applicable Data Protection Laws" means all applicable data protection, privacy and electronic marketing laws, regulations and rules in force from time to time, including, where applicable, the data protection laws of the United Arab Emirates, any relevant free zone regulations (including DIFC/ADGM data protection regulations, if applicable), the EU General Data Protection Regulation (EU) 2016/679 ("GDPR"), the UK GDPR, and any corresponding or equivalent laws, regulations or rules in any relevant jurisdiction.
- 1.2 "Personal Data" means any information relating to an identified or identifiable natural person, as defined under Applicable Data Protection Laws.
- 1.3 "Processing" (and its grammatical variations) means any operation or set of operations performed on Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, alignment, combination, restriction, erasure or destruction.
- 1.4 "You" / "Data Subject" means any individual who visits or uses the Website, submits information to VCEL (including founders, investors, partners, job applicants, and representatives of corporate entities), or otherwise interacts with VCEL in circumstances where VCEL is acting as a data controller.
2. CONTROLLER IDENTITY AND CONTACT DETAILS
- 2.1 The entity responsible for the Processing of your Personal Data under this Policy is:
VCEL Global
A venture capital firm incorporated under the laws of the Emirate of Dubai, United Arab Emirates. - 2.2 For any queries, requests, or concerns regarding this Policy or our Processing of Personal Data, you may contact us at:
Email: privacy@vcelglobal.com
Attention: Data Protection Contact / Compliance Officer
3. SCOPE AND APPLICATION
3.1 This Policy applies to the Processing of Personal Data:
- when you access or use the Website;
- when you communicate with us by email, telephone, online forms or otherwise;
- when you submit pitch decks, business plans, investment proposals, or any other materials;
- when you participate in events, meetings, or calls arranged by VCEL; and
- when you apply for employment, internships or consultancy engagements with VCEL.
3.2 This Policy does not apply to:
- third-party websites, applications or services which may be linked from the Website; or
- Processing carried out by VCEL solely in a processor capacity on behalf of another controller (if applicable), which will be subject to that controller's privacy terms.
4. CATEGORIES OF PERSONAL DATA COLLECTED
VCEL may collect and Process the following categories of Personal Data:
4.1 Information you provide directly:
- Identification and contact details (e.g. name, email address, telephone number, job title, company name, country, city).
- Professional data (e.g. CV/resumé, LinkedIn profile, work history, skills, references).
- Startup and business information (e.g. pitch deck, business model, financials, cap table, team details, product information, market data, strategy).
- Investor and partner information (e.g. organisation, role, investment focus, preferences, ticket size).
- Any content you provide in message fields, free text boxes or attachments.
4.2 Information collected automatically:
When you access the Website, we may automatically collect technical information including, without limitation:
- IP address, approximate geographic location (country / city level);
- device type, operating system, browser type and version;
- pages accessed, date and time of access, time spent on pages, referring URL;
- Website interaction data (clicks, scrolls and similar usage data), via cookies and similar technologies.
4.3 Information from third parties:
We may receive Personal Data about you from:
- publicly available sources (e.g. LinkedIn, company websites, press articles);
- our investors, partners, advisors and professional contacts;
- event organisers, conference platforms and networking tools.
We will Process such information in accordance with this Policy and Applicable Data Protection Laws.
5. PURPOSES OF PROCESSING AND LEGAL BASES
VCEL Processes Personal Data for the purposes and on the legal bases described below:
5.1 Provision and operation of the Website
To operate, administer, maintain, secure and improve the Website.
Legal basis: legitimate interests (to provide and improve our Website, ensure security and functionality).
5.2 Evaluation of investment opportunities
- To review pitch decks, proposals and business plans;
- To conduct initial and ongoing due diligence on founders, teams and companies;
- To schedule and manage meetings and communications with founders.
Legal basis: legitimate interests (to assess potential investments and manage our venture capital activities); contract (taking steps at your request prior to entering into an agreement).
5.3 Investor and partner relationship management
- To build and maintain relationships with current and prospective investors, co-investors and partners;
- To share appropriate information relating to opportunities and portfolio companies.
Legal basis: legitimate interests (to operate our investment business and manage relationships); contract where applicable.
5.4 Handling enquiries and communications
- To respond to queries, requests and feedback submitted through the Website or other channels;
- To provide information about VCEL, our investment thesis and Services.
Legal basis: legitimate interests (to respond to enquiries and manage relationships); contract where applicable.
5.5 Marketing and information updates
- To send newsletters, event invitations, updates on portfolio companies, and other communications which may be of interest to you;
- You may opt out of such communications at any time.
Legal basis: consent (where required under Applicable Data Protection Laws) and/or legitimate interests (for business-to-business communications).
5.6 Recruitment and talent management
- To receive and evaluate job applications and candidate profiles;
- To conduct interviews and manage the hiring process;
- To maintain talent pools for future opportunities.
Legal basis: contract (taking steps at your request prior to entering into an employment or consultancy contract); legitimate interests.
5.7 Compliance with legal and regulatory obligations
- To comply with obligations relating to anti-money laundering (AML), know-your-customer (KYC), sanctions and other regulatory checks, where applicable;
- To respond to lawful requests by public, regulatory or governmental authorities.
Legal basis: legal obligation; legitimate interests (where needed to protect our business and stakeholders).
5.8 Protection of rights and interests
- To prevent and detect fraud, misuse or unauthorised use of the Website or Services;
- To protect the security, property and rights of VCEL, our portfolio companies, investors and other stakeholders;
- To establish, exercise or defend legal claims.
Legal basis: legitimate interests.
7. DISCLOSURE OF PERSONAL DATA
VCEL may disclose Personal Data to the following categories of recipients, strictly on a need-to-know basis:
- 7.1 Internal recipients
Partners, management and authorised staff of VCEL and any affiliated entities involved in our investment and operational activities. - 7.2 Service providers (processors)
Third-party service providers engaged to provide services such as IT hosting, cloud storage, email services, customer relationship management systems, analytics, professional services and other support functions, subject to appropriate contractual and confidentiality safeguards. - 7.3 Co-investors, advisors and business partners
Co-investors, limited partners, advisors and strategic partners in the context of assessing or executing investment opportunities and for related reporting, subject to appropriate confidentiality undertakings where reasonable and applicable. - 7.4 Professional advisers
Legal advisers, auditors, accountants, consultants and other professional advisers, where necessary for our legitimate business purposes and compliance with legal obligations. - 7.5 Regulatory and governmental authorities
Law enforcement agencies, courts, regulators and other public authorities when required to do so by law or when we reasonably believe it is necessary to comply with a legal obligation or protect our rights or the rights of others. - 7.6 Corporate transactions
In the event of any prospective or actual merger, acquisition, reorganisation, restructuring or sale of assets, Personal Data may be disclosed to relevant counterparties and their advisers, subject to appropriate safeguards.
VCEL does not sell Personal Data.
8. INTERNATIONAL TRANSFERS
- 8.1 In the course of our operations, Personal Data may be transferred to and processed in jurisdictions outside your country of residence, including but not limited to the United Arab Emirates, the European Economic Area (EEA), the United Kingdom, and other countries where our service providers, advisors or counterparties are located.
- 8.2 Where such transfers involve a country that does not offer an equivalent level of data protection, VCEL shall implement appropriate safeguards as required under Applicable Data Protection Laws, which may include:
- entering into data transfer agreements incorporating standard contractual clauses or similar mechanisms;
- applying additional technical and organisational protections; or
- relying on other valid transfer mechanisms recognised by Applicable Data Protection Laws.
9. DATA RETENTION
- 9.1 VCEL shall retain Personal Data only for as long as is necessary for the purposes for which it was collected, including for the purposes of:
- evaluating and maintaining records of investment opportunities and decisions;
- managing relationships with investors, partners, founders and candidates;
- complying with legal, regulatory and tax requirements;
- resolving disputes and enforcing agreements.
- 9.2 Retention periods may vary depending on the nature of the data, the purpose of Processing and applicable legal requirements. Where Personal Data is no longer required, VCEL shall take reasonable steps to securely delete or anonymise such data.
10. DATA SECURITY
- 10.1 VCEL implements reasonable and appropriate technical and organisational measures designed to protect Personal Data against unauthorised or unlawful Processing and against accidental loss, destruction or damage. Such measures may include, without limitation:
- access controls and role-based permissions;
- use of secure servers and encryption technologies where appropriate;
- regular backup and system monitoring;
- confidentiality obligations for staff and contractors.
- 10.2 Notwithstanding the foregoing, no method of transmission over the internet or method of electronic storage is completely secure. While VCEL strives to protect Personal Data, VCEL cannot guarantee absolute security.
11. DATA SUBJECT RIGHTS
- 11.1 Subject to Applicable Data Protection Laws and certain limitations, you may have the following rights in relation to your Personal Data:
- Right of access – to obtain confirmation as to whether we Process your Personal Data and to request a copy of such data.
- Right to rectification – to request correction of inaccurate or incomplete Personal Data.
- Right to erasure – to request deletion of Personal Data in certain circumstances (e.g. where the data is no longer necessary for the purposes for which it was collected).
- Right to restriction of Processing – to request the restriction of Processing in certain circumstances.
- Right to object – to object to Processing based on legitimate interests, including profiling, and to object at any time to Processing for direct marketing purposes.
- Right to data portability – where applicable, to receive Personal Data you provided to us in a structured, commonly used and machine-readable format and to transmit it to another controller.
- Right to withdraw consent – where Processing is based on your consent, you may withdraw such consent at any time, without affecting the lawfulness of Processing based on consent before its withdrawal.
- 11.2 To exercise any of the above rights, please contact us using the details in Section 2. We may request additional information to verify your identity and to process your request.
- 11.3 You may also have the right to lodge a complaint with a competent data protection authority in your jurisdiction if you consider that your rights have been infringed.
12. FOUNDERS, STARTUPS AND INVESTMENT MATERIALS
- 12.1 When founders or their representatives provide VCEL with pitch decks, business plans, financial models and other materials which may contain Personal Data:
- VCEL shall Process such information for the purposes of evaluating and conducting due diligence on investment opportunities, as described in this Policy;
- VCEL may share such information with its partners, authorised staff, co-investors and advisors on a confidential basis, where reasonably necessary for the evaluation of the opportunity.
- 12.2 The founder or entity providing such materials is responsible for ensuring that:
- any Personal Data included therein has been collected and disclosed in compliance with Applicable Data Protection Laws; and
- VCEL's receipt and Processing of such Personal Data as described in this Policy is lawful.
- 12.3 If you wish VCEL to cease consideration of your startup or to restrict or delete certain materials, you may contact us. VCEL may, however, retain limited records where required by law or where necessary for legitimate interests (e.g. audit trail of investment decisions).
13. DIRECT MARKETING
- 13.1 VCEL may Process Personal Data to send you communications (including emails and newsletters) relating to:
- VCEL's investment focus, activities and portfolio;
- market insights, articles or reports;
- invitations to events, webinars or meetings.
- 13.2 Where required by Applicable Data Protection Laws, such communications will be sent based on your consent. You may withdraw consent or opt out of marketing communications at any time by:
- clicking the "unsubscribe" link in any marketing email; or
- contacting us using the details in Section 2.
14. THIRD-PARTY WEBSITES
- 14.1 The Website may contain links to third-party websites, applications or services which are not operated or controlled by VCEL. VCEL is not responsible for the privacy practices or content of such third parties.
- 14.2 You are encouraged to review the privacy policies of any third-party websites or services prior to providing them with any Personal Data.
15. CHILDREN'S PRIVACY
- 15.1 The Website and Services are not directed to, and VCEL does not knowingly collect Personal Data from, individuals under the age of eighteen (18) years.
- 15.2 If VCEL becomes aware that it has collected Personal Data from a child under the age of 18 without appropriate consent, VCEL will take reasonable steps to delete such data.
16. CHANGES TO THIS POLICY
- 16.1 VCEL reserves the right to amend or update this Policy from time to time to reflect changes in our practices, legal requirements or other factors.
- 16.2 Any material changes will be posted on the Website with an updated "Last Updated" date. Your continued use of the Website or interaction with VCEL after such changes shall constitute your acknowledgement and acceptance of the revised Policy.
17. CONTACT AND COMPLAINTS
17.1 If you have any questions, concerns or requests regarding this Policy or our Processing of your Personal Data, please contact:
VCEL Global
Email: privacy@vcelglobal.com
Subject Line: "Privacy – Data Protection Request"
17.2 Depending on your jurisdiction, you may also have the right to lodge a complaint with the relevant data protection authority if you consider that your rights under Applicable Data Protection Laws have been infringed.
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