UAB Contrarian Ventures (legal entity code 304584559, registered address: Vingriu st. 3D-3D, LT-01118 Vilnius, Lithuania) (hereinafter referred to as the “Company” or “we”) commits to ensure the security of its Visitors’ personal data and protection of their rights when they use and navigate the Company’s website accessible at https://www.cventures.vc/ (hereinafter referred to as the “Website”).

This privacy policy (hereinafter referred to as the “Privacy Policy”) specifies the data collected by the Company, means and sources wherefrom this data is obtained, legal basis for processing of personal data as well as actions and measures, which have been taken by the Company to protect the collected data. By using the Company’s services and/or browsing the Website, Visitors agree to the terms of this Privacy Policy as well as the other general rules for using the site.All personal data are processed in accordance with the EU General Data Protection Regulation No. 2016/679 (hereinafter referred to as the “GDPR”), Law on the Legal Protection of Personal Data of the Republic of Lithuania and other applicable legal acts.For any questions regarding this Privacy Policy or any requests regarding the processing of personal data, please contact us at info@cventures.vc.

Personal data – any information from which directly or in combination with other data identification of a living individual is possible.

Data controller – an individual who manages personal data by determining purposes and means of the data processing. Within the scope of this Privacy Policy, the Company is a data controller of your personal data.

Data processor – any person (not an employee of a Data controller) who is processing the data on behalf of the data controller. Various external service providers may be used as data processors to ensure efficient handling of your data.

Data subject – an individual who is the subject of Personal Data.

Visitor or you – an individual who is using the Company’s services and/or browsing the Website, and who is the subject of Personal Data.

Specific personal information (“Personal Data”) that would allow us to identify and/or contact you may be required when using our Website and services.

Start-up “Check the fit”

In case the Visitor represents a start-up company and is interested in funding by the Company, and submits an application, we collect and process Personal Data provided in the respective application, including names, surnames of the founders or other representatives, contact details of the applicant, other data indicated in the submitted documents (including presentation of the start-up, etc.).

Conferences and other events

In case the Visitor registers for the conference or other event organized by the Company, we collect and process Personal Data necessary for organizing that event, including:

1. a) name, surname, workplace;
   b) e-mail address, telephone number;
   c) information regarding payment for the tickets.

For the processing of such data the Company engages data processors. Therefore, we strongly recommend familiarising yourself with their privacy policies or notices, cookie policies and/or other documents.

Newsletters

If you register for the Company’s newsletters, we shall use your e-mail address to send you news, information about special offers and/or other information related to the Company’s services.

You may unsubscribe from the Company’s newsletters at any time without giving any reason by following the instructions in each newsletter or by contacting us at info@cventures.vc.

Handling of Requests

When you contact us by any means such as telephone, e-mail or contact form available on the Website, you may submit inquiries, complaints, requests or feedback to the Company (hereinafter referred to as the “Request”). This way, you provide the personal data specified in the Request to the Company, also – your name, surname, e-mail address, telephone number.

We use the personal data you provide when submitting a Request in order to properly and objectively examine your Request, provide you with the necessary information, and answer your questions, requests or complaints. Request data may also be used to protect our legal interests (in the event of a dispute). The Company may also analyze the Request data in order to improve the quality of its services.

Please observe at least the following minimum requirements for the protection of your personal information: do not provide your personal identification code, provide only a minimum amount of personal data.

Technical information and cookies

The Company also collects cookies and other technical data (for more information, see our Cookie Policy).

The main purpose of the processing of personal data is to enable efficient, optimal and adapted use of the Website and services. The Company uses the collected data for a number of purposes including the following:

1. a) to deliver and maintain its services (assess applications of start-ups, organize events);
   b) to ensure timely and appropriate handling of Requests;
   c) to ensure smooth administration, functionality of the Website;
   d) to enable the Company to perform statistical and other analysis by continuously improving the content of the Website and the services provided by the Company;
   e) to detect, diagnose and address technical problems of the Website;
   f) for other purposes disclosed to the Visitor at the time of submitting personal data.

In case you sign up for receiving newsletters from us, your Personal Data may be utilised to provide you with news and other information related to Company’s services.

The Company processes your personal data on following grounds:

1. a) consent, given when the Visitor accepts cookies, register for the Company’s newsletters;
   b) when applicable, contract concluded with the Visitor regarding Company’s services;
   c) legal obligations to which the Company is subject;
   d) our legitimate interests to ensure and improve the quality of Company’s services and to protect our rights.

Visitors may revoke their consent to process their personal data at any time. If the Company has no other legal basis for the processing of personal data, the Company will cease processing of personal data immediately (subject to technical feasibility) after the cancellation/revocation of the consent provided by the Visitor.

In cases where the data retention period is not specified in this Privacy Policy, your data is stored for no longer than is necessary to achieve the purposes (specified in this Privacy Policy) for which the data was collected, or for such period of time as required by law. We would like to inform you that your personal data in back-up copies, which are made to ensure the security and integrity of the information, may be stored for some time after the end of the storage period specified in this Privacy Policy and then deleted.

The storage of your personal data for longer than specified in this Privacy Policy may be carried out only in exceptional cases when:

1. a) it is necessary for the Company to be able to defend itself against existing or threatened claims or to exercise its rights, or for the proper resolution of dispute, complaint or claim;
   b) there is a suspicion of illegal activity;
   c) it is necessary for back-up copies or related purposes of functioning of information systems of the Company;
   d) it is mandatorily required by applicable laws.

The Company also reserves the right to retain Usage Data for the purposes of internal analysis. Though Usage Data is generally retained for a shorter length of time, in cases such as improving the effectiveness and quality of our services or strengthening its security your data may be retained for an extended duration.

Upon expiration of the term of processing and storage of your data set forth in this Privacy Policy, we will destroy and/or reliably and irrevocably depersonalize your data as soon as possible, within a reasonable time required to perform such action.

The information that we collect, including your Personal Data, may be transferred to and stored on devices located outside your place of residence. The laws on data protection in these localities may differ from those of your jurisdiction, thus by choosing to provide information to us you also agree to allow your information to be processed outside your country.

We may also use various data recipients (data processors) which provide us with services necessary to ensure that our Website and services runs smoothly. Such recipients may include providers of databases, software, database administration services, providers of communications, data centers, hosting and cloud services, advertising (including online advertising), direct marketing, messaging, administration services providers, providers of statistics, market research or business analytics, other services. In each case, we provide the data processor with only as much data as is necessary to provide their services. The data processors used by us may process your personal data only in accordance with our instructions and may not use them for other purposes.

The data may also be provided to the competent authorities, in cases and under procedures provided for by legal acts, such as the police or supervisory authorities, but only upon request and only when required by applicable law or in cases and under procedures provided for by law, to assert, submit and defend legal claims to ensure our rights, the safety of our customers, employees and resources.

In addition, particular technical data pertaining to your visits on the Website (such as IP address, data collected or placed on the devices of the Visitor by means of cookies, technical information of the browser, other information related to Visitor’s browsing activities, etc.) may be transferred or made available to the entities in the EEA, as well as outside the EEA (e.g., Google Analytics may be used), for statistical, analytical and related purposes. You can find more information in our Cookie Policy.

We remind you that in non-EEA countries personal data may have less protection than in the EEA, but we will carefully assess the conditions under which your data will be processed and stored after transfer to the non-EEA countries. We will also apply the safeguards provided for in the GDPR to ensure the legality of such transfers, e. g. standard contractual clauses approved by the European Commission.

Data security and proper treatment of your personal data are the key priorities for the Company. By implementing appropriate technical and organizational measures, the Company protects Visitors’ personal data from loss, misuse, unauthorized access, disclosure or alteration.

Nevertheless, it must be taken into account that complete control of information transfered via electronic protocols cannot be exercised. For this reason, users of the Company’s services are advised to protect their devices by using secure channels when connecting to the Internet, and to follow minimum safeguards for their personal data protection: do not visit suspicious websites, update their software and anti-virus protection as recommended by software providers and vendors.

Visitors have certain rights related to the protection of their personal data.

As a Data Subject, you have the following rights, subject to the requirements and conditions prescribed by applicable legal acts:

1. a) the right of access to your personal data;
   b) the right to request the rectification of your personal data;
   c) the right to request the deletion of personal data (“right to be forgotten”) or to restrict the processing of personal data;
   d) the right to data portability;
   e) the right to object to the processing of your personal data (when your personal data is processed on the basis of legitimate interests);
   f) the right to withdraw your consent at any time (when your personal data is processed on the basis of consent);
   g) the right to lodge a complaint with the data protection authority of the country that you reside in. The lead supervisory authority of the Company is State Data Protection Inspectorate of the Republic of Lithuania (address: Sapiegos St. 17, LT-10312 Vilnius, phone No.: +370 5 271 2804 / 279 1445, e-mail address: ada@ada.lt, for more information, visit https://vdai.lrv.lt/en/).

Requests for the exercise of the above rights (including the withdrawal of your consent or disagreement with the use of your data), as well as complaints, notifications or requests may be submitted to us by e-mail: info@cventures.vc. All data subject requests are executed and exercised subject to the conditions, limitations and exceptions provided for in applicable legal acts.

The Website may contain links to other sites which are not operated by the Company. When you decide to click on these links and be led to such sites, we recommend familiarising yourself with their privacy policies or notices, cookie policies and/or other documents. The Company assumes no responsibility for the content, policies or practices of such third-party websites or services.

This version of Privacy Policy is valid from [1 March 2021].

The Privacy Policy may be updated by the Company from time to time. The Company will inform its Visitors about the updates by submitting a new version of the Privacy Policy along with the dates of the corrections made. Therefore, you are recommended to review our Privacy Policy periodically to be fully acquainted with how your data is being handled.

Visitors understand and accept that by continuing to use the Website, they agree to any changes or updates to the Privacy Policy. If any provision of the Privacy Policy is deemed void or inapplicable, such provision shall not affect the legality and validity of the remaining provisions of the Privacy Policy.

In cases where you have any questions related to our Privacy Policy be sure to contact us by e-mail: info@cventures.vc.