SURFnCODE’s Privacy Policy

Why are we providing this policy?

This Privacy Policy is intended to ensure that individuals outside our organisation with whom we interact, including visitors to our website, personnel of service providers or other suppliers and others who interact with us whether via our website or by corresponding with us by other means (e.g. by emailing or phoning us) are aware of the categories of personal data about them that SURFnCODE (“we”, “us” or “our”) may collect, how we collect it, what we use it for and with whom we share it.

“Personal data” means any information relating to you, such as your name and contact details, but does not include data where you can no longer be identified from it such as anonymised, aggregated data. SURFnCODE will be a data controller in respect of personal data about you that is collected through this website or that you otherwise provide to us. A data controller is responsible for deciding the ways in which and purposes for which personal data about you is processed. We may process your personal data ourselves or through others acting as data processors on our behalf.

What information may we process about you?

If you contact us

If you contact us through our website or otherwise, you may provide personal data to us in the course of your correspondence with us. This may include, but is not necessarily limited to, your name, address, place of business, email address, other contact details, job title, correspondence records and your opinions. We may also generate personal data about you in connection with the correspondence, such as correspondence records and opinions. The purposes for which we may collect, store and use such personal data about you and our ‘lawful basis’ for processing such data are set out in the table below. The GDPR specifies certain ‘lawful bases’ for which we are allowed to use your personal data where that processing is subject to the GDPR.

Purpose

To correspond with you, respond to your enquiry or address matters raised by your correspondence.

Lawful basis for processing

Our legitimate interests in responding to or addressing your enquiry or otherwise communicating with you in the course of our business.

If you sign up to the SURFnCODE Newsletter

If you sign up to our newsletter through our website, you will be required to provide your email address and name. The purposes for which we may collect, store and use such personal data about you and our ‘lawful basis’ for processing such data are set out in the table below.

Purpose

To raise the profile of our business, our portfolio companies and our industry. This may include direct electronic marketing.

Lawful basis for processing

Our legitimate interests in promoting our products and services and growing our business.

Other purposes

In addition to the uses above, we may also process your information where required by law to do so or if we reasonably believe that it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

We may also process personal data for purposes other than those for which the personal data was originally collected (provided that such new purposes are not incompatible with the original purposes). Where this is the case, we will provide you with information about that further processing.

What if you do not provide the personal data requested?

Unless and until you make a decision to engage in a business transaction with us you are not required to provide us with any information, although please note that our website may automatically collect certain technical data (further details information in this respect is set out in our Cookies Policy). We may not be able to grant you access to certain parts of our website if you do not provide certain personal data.

With whom will we share your information?

We may share your personal data with a third party where this is required by law or where we have another legitimate interest in doing so.

We may need to share your personal data with:

  • other entities within our group as part of our regular reporting activities in company performance, in the context of a business reorganisation or group restructuring exercise, for assistance in relation to marketing and business development or in connection with the operation of group-wide functions and services;

  • professional advisers, including lawyers, bankers, auditors and insurers to the extent such information is relevant to their performance of their services;

  • regulators and government bodies;

  • IT service providers (such as cloud services providers, IT consultants and software-as-a-service providers), including [The Rocket Science Group, LLC d/b/a MailChimp, which administers our marketing mailing lists]; and

  • any of our service providers where such information is relevant to their performance of such services.

We may share your personal data with third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with applicable law or judicial process or if we reasonably believe that disclosure is necessary to protection our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

Where your personal data may be processed.

We are established in Portugal.

The Rocket Science Group, LLC d/b/a MailChimp, which administers our marketing mailing lists, is based in the USA and personal data processed by MailChimp may be processed by Mailchimp in the USA. MailChimp participates in the EU-US Privacy Shield Framework. The European Commission has certified that it the EU-US Privacy Shield Framework ensures adequate level of protection in respect of personal data. We also use cloud based platforms to process personal data, such as Google Drive. These platforms may process personal data on our behalf on servers outside the EEA.

Where required by the GDPR, we will (or will require a processor to) put in place appropriate safeguards such as the standard contractual clauses approved by the European Commission. If you require further information about this you can request it using the details set out in the ‘Contact Us’ section below.

How long will we retain your information?

We will retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and our legitimate interests in maintaining such personal information in our records.

In some circumstances your personal data may be anonymised so that it can no longer be associated with you, in which case it is no longer personal data.

Once we no longer require your personal data for the purposes for which it was collected, we will securely destroy your personal data in accordance with applicable laws and regulations.

Accuracy of information

It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data which we hold changes during your relationship with us.

Your rights in relation to your information

Where the processing of your personal data is within the scope of the GDPR, you have rights as an individual which you can exercise in relation to the information we hold about you under certain circumstances. These rights are to:

  • request access to your personal data (commonly known as a “data subject access request”) and request certain information in relation to its processing;

  • request rectification of your personal data;

  • request the erasure of your personal data;

  • request the restriction of processing of your personal data;

  • object to the processing of your personal data;

  • request the transfer of your personal data to another party.

If you want to exercise one of these rights please use the contact details set out in the ‘Contact Us’ section below.

You also have the right to make a complaint at any time to a supervisory authority for data protection issues.

What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where we may require your consent to process your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us using the contact details listed below. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless we now have an alternative legal basis for doing so.

Changes to this Privacy Notice

Our practices with respect to personal data may vary from time to time and we may update this Privacy Notice at any time. The latest version of this Privacy Notice will be made available to you on our website. If we intend to process your personal data for a purpose other than the purposes referred to above, we will provide you with additional information about that purpose.”

Contact us

This Privacy Notice was written with brevity and clarity in mind and is not an exhaustive account of all aspects of our collection and use of personal data. If you require any further information, please do not hesitate to contact us using the following contact details: hello@surfncode.io.

Legal

You agree that all use of this website and all submissions that you make to us whether through the website or otherwise are subject to the following terms and conditions (as may be modified by SURFnCODE from time to time and posted on this website) Submitting a business plan or other confidential information You may send us messages, your ideas or other information (a “Submission”) using the email addresses listed on the Website. You undertake that you have all necessary rights and consents to send any Submission to us and you agree that we will be entitled to assume that any information, ideas or other materials that you provide to us as part of any Submission will not be confidential or proprietary. Due to the large number of business plans and related materials that we review or develop ourselves, and the similarity of many such plans and materials, we cannot accept responsibility for protecting against or have any liability or obligation in respect of any use or disclosure of any information, ideas or materials that you provide in the absence of our express written agreement to do so. If you send a Submission to us whether via this Website or otherwise, you grant to us the right to read, use, distribute, disclose and otherwise handle the Submission and any related information as we deem appropriate in our sole judgment. Without prejudice to the foregoing, we may disclose any such Submission and any related information, whether in whole or in part, to any of our investors or partners who shall be entitled to read, use, distribute, disclose or otherwise handle the same as they see fit in their sole discretion.

Intellectual property

Except as otherwise noted in this website, the content on this website – (including, without limitation, trademarks, logos, photos, descriptions, graphics, icons, other original material and the overall appearance of this website) is our property and should not be reproduced or used without our prior written consent. All our rights in and to the website and its content are hereby expressly reserved.

Disclaimer

This Website and all the content of this Website is provided “as is” and for information only and without warranty of any kind, either express or implied (whether by common law, custom, statute or otherwise) and all other conditions, statements and warranties are hereby excluded to the fullest amount permissible by law. Without prejudice to the foregoing, we do not give and hereby expressly exclude any and all warranties, representations, undertakings, guarantees or other terms relating to the accuracy, completeness, currency, reliability or fitness for a particular purpose of any materials or information contained on the Website.

Third-party websites

This site may include links to other websites as a convenience. We do not make any express or implied warranties in respect of and we will have no liability arising out of or related to any operators of linked sites or any information, material, products, or services that are contained on or accessible through linked sites. Without limiting the foregoing, these sites are in no way approved, vetted, checked or endorsed by us. If you choose to access a website beyond our control, you do so at your own risk.

Privacy

Unless you send a Submission to us we will not normally collect any personal data about you through the Site. However, any personal data that we do collect will only be used in accordance with our Privacy Statement.