Startup Wise Guys, along with its subsidiaries and affiliates (collectively referred to as “SWG”, “we”, “us” or “our”) recognizes the trust that individuals place in us when providing us with Personal Data and we are committed to safeguarding the privacy of Personal Data (as defined below) in line with applicable data protection laws, including but not limited to the European Union’s General Data Protection Regulation 2016/679 (“GDPR”), the United Kingdom’s Data Protection Act of 2018 along with the “UK GDPR” as retained as UK law by the European Union Withdrawal Act 2018 (collectively, the “UK GDPR”) and California Consumer Privacy Act as amended by the California Privacy Rights Act(collectively “CCPA”).
In this Privacy Statement, “Personal Data” means information that either in isolation or in combination with other information enables us to identify you as an individual. With respect to California residents, references to “Personal Data” in this Privacy Statement means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, subject to certain exceptions set forth in the CCPA.
The Privacy Statement applies to all websites that we own and operate, including the websites located at: https://startupwiseguys.com and https://theyoungentrepreneurs.co, (“Website”) and services, offerings, and other interactions (for example, customer service inquiries, or your participation in SWG accelerator programs, pre-revenue programs, accelerators, mentoring sessions, user conferences, community events, other programs etc.) you may have with us that are subject to this Privacy Statement (collectively referred to as our “Services“).
This Privacy Statement does not apply to any third party applications or software that integrate with the Services or any other third party products, services or businesses.
The terms outlined in any supplementary privacy statement provided to our partners, employees, and contractors shall prevail in the event of any discrepancies with this Privacy Statement. If you are unsure or would like to ask what policies we consider apply to your relationship with SWG, please do not hesitate to contact us at firstname.lastname@example.org.
This Privacy Statement aims to help you understand our Personal Data collection, usage and disclosure practices by explaining the following:
- Who we are
SWG is a global, vertical-focused accelerator specializing in B2B startups and helping talented founders to scale their startups.
If you have any questions about this Privacy Statement or how we process your Personal Data, please contact us by sending an email to email@example.com, or by writing to:
Wise Guys Holding OÜ
Harju county, Kesklinna district, A. Lauteri street 3
- Who is the data controller of your Personal Data
SWG is made up of a number of different subsidiaries. Depending on where you are located and the location from which legal or other services are provided, the data controller of your Personal Data processed by us under this Privacy Statement will be different. We shall indicate in prior notices upon processing activities as to which entity is the data controller. You may also contact us at firstname.lastname@example.org for details of which SWG entities will be data controllers in which countries.
- What Personal Data we collect about you
We may collect and process different types of Personal Data in the course of operating our business and providing our Services. These may include:
Identity Data such as your name, surname, date of birth, title, hoodie size, job responsibilities as a founder, professional qualifications, and similar information;
Contact data such as your telephone number, postal or email address and other identifiers used for communication;
Usage data such as details of your visits to our Website, computer Internet Protocol (IP) address, unique device identifier, cookies and other data linked to a device, the website you visited before browsing to our Website, pages you viewed, how long you spent on a page, access times and other technical data regarding usage of our Website, advertisement or applications;
Financial data such as payment related information or bank account details;
Marketing Data such as information about your marketing communication preferences, your engagement with SWG, and details about your demographics, individual participation in conferences and in-person seminars, credentials, associations, product interests, and preferences;
Special Categories of Data such as religious or other beliefs, racial or ethnic origin, sexual orientation and any other sensitive information you voluntarily provide to us in limited circumstances and subject to it being necessary for a specific service we are providing to you;
Compliance data: Government identifiers, passports or other identification documents, dates of birth, beneficial ownership data, and due diligence data;
Content data such as any Personal Data included in your content that you post on our Website, contact us forms, application forms or pitch decks provided to us;
Event Data that you may provide to us in course of registering for and attending Events hosted by SWG, including access and dietary requirements, event recordings such as audio files and records; and
Any other Personal Data relating to you that you may provide to us.
- How we obtain Personal Data about you
We may collect or receive your Personal Data from a number of sources:
Where you provide it to us directly, for example by corresponding with, registering for an Event or when you otherwise use our Services;
Where we collect Personal Data automatically, for example by monitoring use of, or interactions with our Website or marketing communication we may send to you.
Information third parties provide to us. We sometimes receive information about you from other parties such as databases, third party data providers, and those in the SWG network. This information may include Contact Data, Identity Data, and other Personal Data regarding individuals who may be interested in our Event and Services. We may also obtain information from event organizers, contractors, and local representatives in our network. Third-party sources may include information collected for “know your client” checks.
Where we collect Personal Data from publicly available sources, for example, use such sources to help us keep the contact details we already hold for you accurate and up to date or for professional networking purposes, e.g. LinkedIn, Crunchbase.
- How we use your Personal Data
We will only use your Personal Data where we are permitted to do so by applicable law. If you are located in the European Economic Area or the UK we only process your Personal Data when we can rely on a valid legal basis. The principal legal grounds that justify our use of your Personal Data are:
Contract performance. Where we need your Personal Data to enter into or perform our contract, including to provide our Service, to operate our Website, or to otherwise respond to your queries.
Compliance with a legal obligation. Where we are required or allowed to collect and use your Personal Data to comply with a legal obligation, for example to detect fraud or to comply with our tax, accounting and anti-money laundering obligations.
Legitimate interest. Where we or a third party, have a legitimate interest in processing your Personal Data and our reasons for using it outweigh any prejudice to your data protection rights. For example, we have a legitimate interest in using your Personal Data to process Device Data or to improve the safety, security and performance of our Service.
Consent. Where you have consented to our use of your Personal Data, for example to send you SWG newsletters or for the use of certain cookies. (you will have been presented with a consent form or facility in relation to any such use and may withdraw your consent through an unsubscribe or similar facility).
We may use your Personal Data in various ways based on your interaction with us such as:
- When you visit our Website
For example, each time you visit the Website, we may automatically collect your Usage Data. In some cases, we may collect Content Data which you provide to us in the form of messages submitted through our Website.
Legal grounds: legitimate interests and consent. It is necessary for our legitimate interests to monitor how our Website are used to help us ensure that content from our Website is presented in the most effective manner for you. We rely on consent for certain cookies which are part of Usage Data. Please refer to our Cookies Policy here for further information.
Retention: We retain this data for as long as reasonably needed to fulfill the purpose for which it was collected.
- When you opt in to SWG marketing communication
If you request information from us, submit a contact us form, subscribe to SWG newsletter or participate in our surveys, promotions or workshops, where allowed by law, we or our processors may use your Personal Data, such as Identity Data, Contact Data or Content Data, to send you updates, newsletters, surveys, offers, and other promotional materials. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us at email@example.com. We may process your Contact Data, Identity Data and Content Data to respond to your request submitted through a contact us form, and communicate with you, as appropriate.
Legal grounds: legitimate interests and consent. It is necessary for our legitimate interests to process this information in order to provide you with tailored and relevant marketing, updates, invitations and to provide you with the opportunity to participate in on-demand learning, promotional campaigns, and publications.
Retention: We retain this data for as long as reasonably needed to fulfill the purpose for which it was collected. It must be noted that you have the right at any time to unsubscribe from the newsletter and withdraw your consent by clicking on the appropriate link assigned for unsubscribing in SWG’s newsletter email (it is situated at the bottom of the email), and/or by contacting us at firstname.lastname@example.org with the request of unsubscribing your email address from the listed subscribers of SWG newsletters.
- When you attend events hosted by SWG
You may provide us with Identity Data, Contact Data, Financial Data and Events Data when you apply to participate in an Event organized, hosted, coordinated and operated by SWG such as “Teach us something” workshops, bootcamps, Red Hoodie ceremonies, demo days, mentor sessions, graduation days, and other public or private events (“Events”).
In certain cases and subject to prior notice in writing, we may create audio or visual recordings of these events, take photographs, conduct interviews or surveys, or conduct similar activities at these Events (“Event Recordings”), and we will collect Event Data and process, audio files and records, including voice mails, face and other data comprising these Event Recordings.
Legal grounds: Legitimate interest, contract performance or consent.
We process Identity Data, Contact Data and Financial Data to operate our Events, perform or initiate a transaction with you, to respond to guest requests/concerns, for our legitimate interests, such as analyzing participants’ experiences of satisfaction and to allow our Events partners to communicate with participants.
We may use Event Recordings and related Personal Data as part of our marketing and promotional activities and for our legitimate interests. Further, we may also publish the Event Recordings, Events Data or Identity Data, in connection with our documentation of those Events, for example, on the SWG website or a relevant Event-specific page.
In connection with Events, we may process Special Categories of Data (i.e, race, nationality) only with your consent, and allow you to limit use or disclosure as required by law. You may revoke your consent to the processing of a special category of data at any time.
Retention: We retain this data for as long as reasonably needed to fulfill the purpose for which it was collected. In cases where we relied on consent we shall retain this data for as long as reasonably needed to fulfill the purpose or until you withdraw your consent.
- When your Personal Data or your company’s data is displayed on the Website or social media posts
We may use or disclose your Identity Data and Contact Data on our Website with your consent, such as when you let us post your testimonials or endorsements on our Website.
Legal grounds: This processing is done on the basis of your consent which you may withdraw at any time.
Retention: We retain this data for as long as reasonably needed to fulfill the purpose for which it was collected or until you withdraw your consent.
- When you apply to a SWG Accelerator Program and/or Services
To provide Services to you and to conduct our business we may process your Identity Data, Contact Data and Financial Data to administer and perform our Services, including to carry out our obligations arising from any agreements entered into between you and us.
When you are accepted to participate in any of the SWG Accelerator Programs, Pre-revenue programs or other programs you are asked to fill out an application on a third-party sites, such as on Dealum or Airtable (please see their privacy policies at https://app.dealum.com/privacy.html and at https://www.airtable.com/privacy). In these applications, you may be asked to provide your Identity Data and Contact Data. Please note, we may also process Content Data included in the pitch deck you submit for our review.
We may additionally ask you to voluntarily provide Special Categories of Data, such as gender and country of origin in order to use it for our statistical and analytical purposes on the basis of your explicit consent. You may withdraw your consent at any time.
Legal grounds: We shall process your Identity Data, Contact Data and Financial Data for the purpose of performing contractual obligations between SWG and you and for our legitimate interests (to enable us to perform our obligations, improve and analyze our Services) and on the basis of your consent (to provide your Special Categories of Data for our statistical purposes).
Retention: We retain this data for as long as reasonably needed to fulfill the purpose for which it was collected. In cases where we relied on consent we shall retain this data for as long as reasonably needed to fulfill the purpose or until you withdraw your consent.
- When we have to fulfil our legal, regulatory, or risk management obligations
We may process Identity Data and Compliance Data to comply with our legal obligations. More specifically to perform due diligence/ ”know your client”, anti-money laundering, anti-bribery, sanctions or reputational risk screening, to prevent fraud and/or other relevant background checks as may be required by applicable law and regulation, to enforce our legal rights, to comply with our legal or regulatory reporting obligations and/or to protect the rights of third parties.
Legal grounds: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities, to ensure that you fall within our acceptable risk profile and to assist with the prevention of crime and fraud).
Retention: We retain this data for as long as reasonably needed to fulfill the purpose for which it was collected and up until a period prescribed by law.
SWG does not intentionally process Personal Data from minors under the age of 16 nor our Services are directed to children under the age of 13, and we do not intentionally gather Personal Data from visitors who are under the age of 16, without their parental or guardian’s consent. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at email@example.com. We will delete such information from our files as soon as reasonably practicable.
- How we retain data and why
We will retain your Personal Data for as long as is necessary to fulfil the purpose for which this data was collected and any other permitted linked purpose (for example certain transaction details and correspondence related to any Services we provide may be retained until the time limit for claims in respect of the transaction has expired or in order to comply with regulatory requirements regarding the retention of such data).
If your Personal Data is used for two purposes we will retain it until the purpose with the latest period expires; but we will stop using it for the purpose with a shorter period once that period expires. Our retention periods are also based on our business needs and good practice.
When determining the retention period, we take into account various criteria, such as the nature and length of our relationship with you, mandatory retention periods provided by law and the statute of limitations, the type of Services requested by or provided to you, the impact on our Services if we delete some information and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, applicable legal requirements.
Our Personal Data Retention Policy determines the appropriate retention period based on factors such as the nature and length of our relationship with you, mandatory retention periods provided by law and the statute of limitations, the type of Services requested by or provided to you, the impact on our Services if we delete some information and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, applicable legal requirements.
In certain circumstances, we may anonymize your Personal Data so that it can no longer identify you in which case we may use this information indefinitely without further notice to you.
- Who we share your Personal Data with
SWG is a global accelerator and as such any Personal Data that we collect or you provide to us may be shared with and processed by other SWG affiliate entities, offices and representatives around the world.
We may also share Personal Data with the following categories of third-party recipients and/or for the following reasons:
With third party contractors: We may disclose your Personal Data to professional advisors engaged by SWG in the course of business such as external legal counsel and other professional experts, advisors and/or consultants subject to binding contractual obligations of confidentiality;
Partners, coaches and mentor: We may disclose your Personal Data to our partners, coaches and mentors, and other groups with whom we have collaborated to deliver SWG accelerator and other programs for which you are registered. Also, when you register for an Event we may share your Personal Data with the Event organizers and sponsors in order to deliver the Event and communicate with you.
Mandatory disclosures and legal claims: We may disclose your Personal Data to government or law enforcement officials or private parties as required by law to comply with a request from our regulators, governmental request or any other legally enforceable demand. We also share Personal Data to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.
Business sale: We may sell, transfer or otherwise share some or all of our business or assets, which may include your Personal Data, in connection with a business deal such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy or liquidation where your Personal Data may be transferred as part of such a transaction as permitted by law and/or contract.
You can contact me by emailing to firstname.lastname@example.org to receive a list of processors for your specific situation, and what it is that they do, whether or not they have any access to your Personal Data, or if they only handle your data in its encrypted form.
- What rights you have in relation to your Personal Data
If you are in the European Economic Area (EEA) and the UK you have the following rights under the GDPR and the UK GDPR:
Access. Subject to certain exceptions, you have the right to request a copy of the Personal Data we are processing about you, which we will provide to you in electronic form.
Rectification. You have the right to require that any incomplete, inaccurate or outdated Personal Data that we process about you is rectified.
Deletion. You have the right to request that we delete Personal Data that we process about you, unless we are required to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
Restriction. You have the right to request that we restrict our processing of your Personal Data whilst a complaint is being investigated where:
- you believe such data to be inaccurate;
- our processing is unlawful; or
- we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not want us to delete it.
Portability. You have the right to request that we transmit the Personal Data we hold in respect of you to another data controller. At your request, we’ll provide you with a transferable copy of your data or send it directly (if possible) to your designated recipient. Please note this only applies where the lawful basis was either consent or performance of a contract and processing was automated.
Objection. Where the legal basis for our processing of your Personal Data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.
Withdrawing Consent. If you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time, free of charge This includes cases where you wish to opt out from marketing messages that you receive from us. For any processing that is based on your consent, you can withdraw that consent at any time. This means that we will stop that processing, unless there is another basis to continue processing, such as a legal obligation. Withdrawing consent does not affect any processing that has already taken place.
Right to Avoid Automated Individual Decision-Making: At SWG, all decisions that could affect your rights are made by humans. While we use computers to help us in our work, all decisions are made by real individuals.
If you are in the EEA you also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. Access a list of local data protection authorities in EEA countries here.
Under the CCPA and other state privacy laws, residents of certain US states may have the following rights, subject to regional requirements, exceptions, and limitations.
Confirm: Right to confirm whether we process your Personal Data.
Access/Know: Right to request any of following: (1) the categories of Personal Data we have collected, sold/shared, or disclosed for a commercial purpose; (2) the categories of sources from which your Personal Data was collected; (3) the purposes for which we collected or sold/shared your Personal Data; (4) the categories of third parties to whom we have sold/shared your Personal Data, or disclosed it for a business purpose; and (5) the specific pieces of Personal Data we have collected about you.
Portability: Right to request that we provide certain Personal Data in a common, portable format.
Deletion: Right to delete certain Personal Data that we hold about you.
Correction: Right to correct certain Personal Data that we hold about you.
Opt-out or Limit Use and Disclosure of sensitive Personal Data: Right to opt-out of the processing of certain Sensitive Data, or request that we limit certain uses of sensitive Personal Data. This right does not apply in cases where we only use sensitive Personal Data where necessary, or for certain business purposes authorized by applicable law.
Opt-in/Opt-out of Sale/Sharing of Minors’ Personal Data: To the extent we have actual knowledge that we collect or maintain Personal Data of a minor under age 16 in California, those minors must opt in to any sales/sharing of Personal Data (as defined under CCPA), and minors under the age of 13 must have a parent consent to sales/sharing of Personal Data. All minors have the right to opt-out later at any time. We do not have actual knowledge that we process the Personal Data of minors under age 16.
Non-Discrimination: California residents have the right to not to receive discriminatory treatment as a result of your exercise of rights conferred by the CCPA.
List of Direct Marketers: California residents may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year.
We may have disclosed your information as described above during the preceding 12 months, but we do not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate in any way your Personal Data to third parties in exchange for monetary or other valuable consideration.
- How you can exercise your rights
If you contact us to exercise any of these rights we will check your entitlement and respond in most cases within 1 month.
While it is our policy to respect the rights of individuals, please be aware that your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime), our interests and some of these rights may be limited (for example the right to withdraw consent) where we are required or permitted by law to continue processing your Personal Data to defend our legal rights or meet our legal and regulatory obligations.
We are also required to take reasonable steps to ensure that your Personal Data remains accurate. In order to assist us with this, please let us know of any changes to the Personal Data that you have provided to us by contacting us at email@example.com.
There is no fee for facilitating a request unless it is manifestly unfounded or excessive, in which administrative costs can be recovered. This shall be determined on a case by case basis.
Requests that are manifestly unfounded or excessive can be refused. If SWG was to refuse such a request, it shall provide a reasoning for such denial, within 1 month of receiving such a request, in the same format as the request was communicated to SWG.
- Third party sites and services
- How we protect your Personal Data
We recognise that information security is an integral element of data protection and to prevent loss, misuse, unauthorized access, disclosure, alteration, or destruction of your Personal Data we have taken commercially reasonable technical, administrative, and organizational measures to ensure its security both online and offline.
These measures include, for example limiting access to authorized personnel only, staff training on data protection, using a secure TLS encryption on our website as well as other safeguards.
However, we cannot guarantee complete security of your Personal Data as no security safeguards are 100% secure especially online. Therefore, please take special care in deciding what information you send to us via online means. We aim to continuously improve our security strategy to ensure security of the Personal Data.
- International data transfers
As a global accelerator, we cannot limit our processing of an individual’s Personal Data to the country in which that individual is based. In the course of providing our services, we will likely need to transfer Personal Data to locations outside the jurisdiction in which you provide it or where you are viewing our website. If you are based in the EEA, this will mean that your Personal Data may be transferred to, accessible from, and/or stored at, a destination outside the EEA such as the United Kingdom or United State and other countries in which data protection laws may not be as comprehensive as in the EEA.
Regardless of the location of our processing, we will impose the same data protection safeguards that we deploy inside the EEA and implement appropriate measures to ensure that your Personal Data is protected in accordance with applicable data protection laws. Where a third party service provider processes the Personal Data of EEA residents on our behalf, we will ensure that appropriate measures are in place to ensure an adequate level of protection for your Personal Data, usually by including EU standard contractual clauses in our agreements with such third party service providers (alongside other supplementary technical or contractual measures where necessary).
- How we may update this Privacy Statement
Startup Wise Guys reserves the right to amend this Privacy Statement. If the Privacy Statement is amended, a notification on our Website shall be displayed in a clear, easily accessible manner and additionally the content of the amendment will be reflected in SWG Newsletter
Last updated: February 15, 2023