Syndicates Privacy Policy

1. Generalities

Seedblink S.A., a joint-stock company registered with the Registry of Commerce under number J40/722/2020, with the unique registration code 42141358, with its legal office at 43 Pipera Road, Floreasca Park, Building B, 1st floor, District 2, Bucharest, postal code 014254, Romania (“Seedblink”, “we”, “our”, or “ours”), acting as a controller of personal data, is committed to protecting and respecting your confidentiality. This document (“Privacy Notice”) is designed to present to you our practices regarding the collection, use, and disclosure of the information which you can provide through the use of the services available on the platform www.seedblink.com (“The Platform”).

We collect personal data from and about you via the Platform, or, where appropriate, through other types of interactions which we have with you, such as those in the context of the facilitation and provision of Seedblink services and of the interactions with these services, or in the context of marketing activities.

This Privacy Notice (along with our Terms and Conditions and any other documents referenced within them) represents the basis on which any personal data collected from you, or which you provide to us, will be processed by us. We ask you to read the following information carefully to understand our points of view and practices regarding your personal data and the way it is treated.

2. What kind of information do we collect from you, and for what period?

We can collect and process the following personal data about you:

2.1 Information which you provide to us

You can give us information, including information which can identify you (“Personal data”) when you use our platform, when you contract our services (including when used with a view to the execution of contracts), when you use our services, when you participate in any of our contests, promotions or surveys, when you speak with us by phone, e-mail, or otherwise, as well as when you report a problem with our Platform.

Information which you can provide includes:

2.1.1 Information necessary to create a user account on our Platform: First name, last name, email address;

2.1.2 Information necessary to validate the user’s account (with the purpose of accessing all information available on the Platform) – in addition to the information from clause 2.1.1: a picture of your identification document, a “selfie”-style picture, your first name, last name, your home and/or residence address, tax residence, identification data from the provided identification document (the document series and number, date of issue, date of expiration, TIN or equivalent);

2.1.3 Information necessary for contracting the services we offer via our Platform (e.g. in order to invest in a crowdfunding campaign in progress) – in addition to the information in clause 2.1.2: the amount invested, information regarding the type of investor and phone number.

Seedblink will not be able to provide the services offered by our Platform if the necessary information is not provided;

2.1.4 Details of your visit on our Platform;

2.2 Information which we collect automatically

2.2.1 With regards to each of your visits on our Platform, we can collect, according to the applicable laws and, when it is necessary, with your permission, information about the devices which you use and the networks to which you are connected when you use our services. This can include the following information: the user’s address, login information, operating system and platform, and advertising identifier.

2.3 Data retention

2.3.1 We keep your data only while it is necessary for the purposes presented in this Privacy Notice.

3. How do we use the information which we collect from you?

We will use the information which we collect:

collected information

Seedblink will never process your personal data for the purpose of big data analysis or in any other manner than what is extensively described in the present Privacy Notice.

4. Who are the beneficiaries of the information we collect from you, and to what end?

4.1 When you use our services, your identification data is disclosed to co-investors in the project concerned. Given that the investment in the project is achieved through an SPV company (incorporated by us on the basis of the contract concluded with you), identification data (as previously mentioned in clause 2.1.3) of everyone who invests in that project are found in the articles of incorporation of the SPV, as well as in other corporate documents (for example, decisions of the General Meeting of the Shareholders).

4.2 Not least, we may disclose your name to the owners of the projects you invest in, in order for the latter to identify potential conflicts of interest.

4.3 In addition, we work closely with third parties which have access to your personal data, such as:

• Our partners who offer services for the completion formalities of founding SPVs with the Trade Register ;

• Our partners who offer the electronic identification service (for example, Onfido);

• Our partners who offer the service of sending marketing materials;

• Our partners who offer the service of direct communication with you;

• Our partners who offer electronic document signing services (for example, DocuSign);

4.4 We do not disclose any of the information which you provide, including your personal data, to any third party, with the following exceptions:

• Seedblink may disclose your information if it is required by law or if, in good faith, it considers that such access or disclosure is reasonably necessary to (i) respond to a complaint against Seedblink, (ii) to comply with legal procedures, (iii) to implement any agreement with our users, such as our Terms and Conditions, as well as the Privacy Notice, (iv) in an investigation or (v) to protect the rights of Seedblink, our partners, or other parties;

• If we sell a business or assets, we may disclose your personal data to the possible buyer or seller of such a business or asset; and

• If Seedblink is acquired, in part or in full, by a third party, the personal data held by Seedblink of its members will represent one of the assets transferred.

5. Targeted announcements on social media platforms and our e-mail or text message communications

In accordance with the legislation in force and with your permission, we may use the information which you give us on our Platform for direct electronic marketing (for example (i) sending our informative bulletins, invitations to events organized by us, or other communications that we consider of interest for you or (ii) showing you targeted advertisements on social media platforms.

For electronic marketing communications (newsletters): You can withdraw your consent at any time by (i) unchecking the appropriate box in your member account, (ii) clicking on the unsubscribe button available in every Seedblink communication or (iii) contacting us on the basis of the contact details provided in section 10 further down.

6. Is your information transferred? How, and to where?

In principle, we keep your personal data in the European Union (“EU”). However, because, for example, some of our service providers are located in countries outside of the European Union (i.e., the United States of America) (“Third countries”), we transfer some of your data to these Third countries. We always make sure that the transfer is made in accordance with the applicable laws and that there are adequate guarantees (especially standard contractual clauses, as they have been issued by the European Commission) to guarantee a sufficient level of protection for the private lives and fundamental rights of individuals.

By sending a request towards the person responsible for data protection (mailto:data.protection@seedblink.com), we can provide you with details concerning these adequate guarantees (for example, the standard contractual clauses issued by the European Commission).

7. What are your rights regarding your personal data?

7.1 You have the right to receive a copy of the personal data in our possession (your right of access to data).

7.2 You can request the erasing of your personal data or the correction of inaccurate personal data (your right of erasing and rectification). We remind you that we may keep certain information that concerns you, as the law provides or when we have a legal basis for proceeding as such.

7.3 You have the right to oppose, at any time, (i) the processing of your personal data with the purpose of direct marketing, or (ii) the processing of your personal data with reasons tied to your specific situation or with other purposes (your right to oppose processing). We remind you that in this latter case, the right is applicable only if the processing of your personal data is based on our legitimate interest.

7.4 You have the right to limit the processing of your personal data (your right to limit processing). We remind you that this only applies if (i) you have contested the accuracy of your personal data, and we are verifying the accuracy of your personal data, (ii) you have exercised your right of opposition, but we are still analyzing, as provided by the applicable laws, if our legitimate reasons for processing your personal data in this case overrides your interests, rights, and freedoms; or (iii) your personal data have been processed illegally, but you oppose the erasing of your personal data, or you wish for us to keep your personal data to formulate, exercise, or protect you against a legal action.

7.5 You have the right to receive, and/or for us to transfer to another data controller, a part of the personal information which concerns you and which you provided to us, which we process with the purpose of executing our contract, or because you consented beforehand to this, in a commonly used and electronically readable structured format (your right to portability of data).

7.6 You have the right to withdraw your consent at any time, without the legality of the processing performed based on your consent before this withdrawal being affected (your right to withdraw consent).

7.7 To exercise your rights, we ask you to contact the person responsible for data protection (mailto:data.protection@seedblink.com).

7.8 You also have the right to make a complaint to the relevant data protection authority or to find a solution through the courts if you feel that your rights have been violated.

8. The confidentiality of your password

The moment you must choose a password to gain access to our Platform, you are responsible to keep this password secret. We ask you to not share this password with anyone. Seedblink will never ask you for your password.

9. Amendment of the Privacy Notice

Any amendment which we may make in the future in the Privacy Notice will be posted on this page and we will notify you in this respect.

10. Contact

If you wish, at any time, to contact us, with your points of view about our confidentiality practices or any request concerning your personal data, we ask you to contact us by e-mail at the address: mailto:data.protection@seedblink.com, or by mail at the address mentioned at point 1.