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Tomasz Freier

Head of Compliance
Angels Den

Dear User,

You may have heard about the new General Data Protection Regulation (“GDPR”), that comes into effect May 25, 2018.

We would like to ensure you that your personal data is safe with us. Please read the details regarding the processing of your personal data and if you agree with the processing as described below, please click the ‘I agree’ button.

Please be informed that you can withdraw this consent at any time.

1) What data are we talking about?

We are disclosing details regarding the processing of personal data that is collected within our calls and in connection with your use of Angels Den’s platform, Websites and other functionalities of Angels Den, including those saved in cookies files.

2) Who will be the controller of your data?

Angels Den Funding Limited (hereinafter referred to as AD) will be the controller of your data (Angels Den means all entities from the Angels Den capital group, which includes Angels Den Funding Limited with its registered office in London and all entities related to it and dependent on it) and only our Trusted Partners.

3) Why do we want to process your data?

We process this data for the purposes described in our Privacy Policy, including:
- compliance with any legal requirements and obligations,
- ensuring that content from our Website is presented in the most effective manner for you,
- marketing purposes,
- providing you with our services (including the completion and support of immediate activity required to provide you with information and deliver products and/or services that you request and to deliver any contracts entered into with you), or
- as otherwise explained in this privacy policy or by any communication by us.
Where you have explicitly consented to be contacted for such purposes, we use your personal data to provide information on our new and existing products and services.

4) To whom can we transfer data?

In accordance with applicable law, we may transfer your data to entities processing it at our request, e.g. marketing agencies, subcontractors of our services and entities authorized to obtain data under applicable law, e.g. courts or law enforcement agencies - of course only if they submit a request based on an applicable legal basis. Furthermore, we will transfer your data to Trusted Partners outside the European Union – to the USA – under the EU-U.S. Privacy Shield Framework.

5) What are your rights to your data?

You have the right to request access to, correct, delete your personal data. You can also withdraw consent to processing of personal data, raise objections and use other rights granted under GDPR (i.e. right to data portability).

6) Use of cookies

We use cookies to give you the best experience on our Website. This means that we have placed cookies on your device. If you continue without changing your cookie settings, we assume that you consent to our use of cookies on this device. You can change your cookie settings at any time but if you do, you may lose some functionality on our Website. More information can be found in our Privacy Policy.

In connection with the above, I agree to the processing of my personal data by Angels Den and its Trusted Partners. I confirm that I understand that my personal data is being collected as part of my phone calls, use of AD’s online platform, Websites, and other functionalities of AD, including the data saved in cookie files. I also consent to profiling in order to allow Angels Den and its Trusted Partners the provision of better services (including for analytical purposes). Your data will only be processed on a valid lawful basis in accordance with applicable data protection laws. The processing of your personal data for marketing purposes (including statistical analysis) by AD is based on the firm's legitimate interest. The processing for marketing purposes by our Trusted Partners is only possible if we receive your freely given consent. We will also process your personal data to fulfil our contractual obligations to you as contained in AD’s Terms and Conditions of the use of our Website and services. Therefore, this data will be processed on another lawful basis – ‘contract’. We will also process your data to comply with our legal obligations for our Service (such as anti money laundering and know your customer requirements), which is also a valid lawful basis in accordance with applicable data protection laws.

Expressing this consent is voluntary and you can withdraw at any time.

If you have any doubts or questions about the use of your personal data, please do not hesitate to contact me via email. I’m happy to assist.

Tomasz Freier

Head of Compliance
Angels Den
tom@angelsden.com

PRIVACY POLICY

The controller is Angels Den Funding Ltd, 34b York Way, London, England, N1 9AB, registered at the companies house under the company number 08384317, represented by the executive directors Marc Carena, Tanya Kopps, Angus Rankine, Chitraj Singh (“we/us/our” or “AngelsDen”) as well as further controllers (in form of a joint control as set forth in detail below. We offer services to our users’ (the “User/you/your”) on our website www.angelsden.com (“Website”) as well as related services (jointly the “Service”).


For any questions about data protection, you may contact our Compliance Department via email.

  

IN SHORT:


Controller / Data Protection Officer

Angels Den Funding Ltd

1-2 Faulkner's Alley, Clerkenwell, London, EC1M 6DD, registered at the companies house under the company number 08384317, represented by the executive director(s) Marc Carena, Tanya Kopps, Angus Rankine, Chitraj Singh.

Email: info@angelsden.com

Tel.: +44 0203 318 0230

If you register for our Service we and “Smartsearch” are joint controllers for complying with anti-money laundering obligations when you are using our Service (details: https://www.smartsearchsecure.com/dpa/dpajdc).

Smartsearch is offered by SmartCredit Limited T/As SmartSearch, a company registered in England and Wales under registered number 05534508, registered office is at Mayfield House, Lower Railway Road, Ilkley, Leeds, LS29 8FL

Contact: clientservices@smartsearchuk.com

Purpose and Legal Basis of Processing Data; Provision and Recipients of Data

Your data will be used for the following purposes:

  • - to provide the functioning Website,
  • - to implement this privacy policy and carrying out the contractual relationship and our Service (including the completion and support of immediate activity required to provide you with information and deliver products and/or services that you request and to deliver any contracts entered into with you),
  • - to comply with our legal obligations for our Service (such as anti money laundering and know your customer requirements),
  • - to analyze your use of our Service and improve our Service with our legitimate interests of marketing and fraud prevention,
    - for marketing purposes, whereby the processing of your personal data for marketing purposes by AngelsDen is based on the firm's legitimate interest and the processing by our third parties for marketing purposes is only possible if we receive your freely given consent, 
    - as otherwise explained in this privacy policy or by any communication by us. 

    Where you have explicitly consented to be contacted for such purposes, we use your personal data to provide information on our new and existing products and services.

    Applicable legal provisions are in particular those of the regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016, repealing the Directive 95/46/EC, on the protection of individuals with regard to the processing of personal data, on the free movement of such data (“General Data Protection Regulation”, GDPR) as well as national laws and regulations.

    We as well as our external service partners receive your data for processing those for the purpose of providing our Service. You provide data if this is necessary for the aforementioned purposes. In the event you refrain from providing such data you may face legal disadvantages, for example, limited or no possibility of using our Service.

    Transfer of Data 

    outside of the EU

    In course of data processing by us, data may be transferred to third countries, i.e. countries outside the EU. This may happen via implementation of third party providers which process data on our behalf.

    Your Rights

    You have the right to withdraw your consent relating to the use of data any time with effect for the future when such data processing is based on your consent.

    You are entitled to access the data stored by us and are also entitled to amend or rectify your data if such data are incorrect.

    You are entitled to request the erasure of your data.

    You are entitled to receive information about the stored data (in a structured, current and machine-readable format) at any time and to request the correction or deletion of the data in case of incorrect data storage.

    You have also the right to lodge a complaint with a supervisory authority at your choice. An overview of the European National Data Protection Authorities may be found here .

    Period for Storing Data; Deletion

    The data are deleted if such data are no longer necessary for the purpose of processing.

    Profiling/Automated Decision-making

    Profiling are procedures, which may involve a series of statistical deductions often used to make predictions about people.

    There are basically 3 characteristics of profiling:

    - An automated form of processing,

    - Carried out on personal data,

    - For the objective of evaluating personal aspects about a natural person.

    AngelsDen is profiling the Service users as the automated processing of personal data by our Website allows us to analyze and to make predictions about individuals within our internal scoring system.

    This, however, is only possible, if we will receive your explicit consent.

    Furthermore, such profiling may happen by third-party providers through the Website or Service. We will inform you about such fact if possible.

    Currently, the automated processing by us does not lead to automated decision-making.

    For more information, please contact our Compliance Department via email .

    Data Security

    We have implemented sufficient measures to ensure data and IT security. The Website is operated through a safe SSL-connection. If an SSL-connection is activated third parties are prevented from reading any data that are transferred by you to us.


    MORE DETAILED INFORMATION:

    Personal data is any information relating to an identified or identifiable natural person. Personal data includes e.g. name, email address or telephone number. Personal data also includes information about hobbies, memberships or websites viewed. We will only collect, use and/or pass on personal data if this is permitted by law or if the User consents to the data processing.

    Visiting the Website

    If you browse our website www.angelsden.com the provider of the website collects and stores information automatically in so-called “server-log-files” that your browser transfers to us. These are:

    type/version of the browser, system software used, referrer URL, hostname of the device, time of the server request, IP-address or other unique device identifier


    If you are using a mobile device the following data are collected additionally through the Website:

    country code, language, hostname of the device, name and version of the operational system


    We use these data only for statistical analysis for the purpose of operation, security and optimization of our Website. However, we reserve the right to check these data retrospectively if there is a justified suspicion of illegal use based on concrete indications. This data is then stored because this is the only way to prevent the misuse of our Website and, if necessary, allow us to investigate any crimes committed. The storage of these data is necessary in order to protect us as the person responsible for processing the data. As a matter of principle, these data will not be passed on to third parties unless there is a legal obligation to pass it on or the transfer of data serves criminal prosecution purposes.

    This data processing is based on Art. 6 (1) f. GDPR and we wish to achieve the legitimate interests of stabilizing and improving our Website, quality insurance, and fraud prevention.


    Contacting us

    When contacting us via email, the User’s details are stored for the purpose of processing the enquiry and, if applicable, follow-up questions based on your consent based on the legal basis of Art. 6 (1) a. GDPR.


    Newsletter

    With the newsletter we inform the user about the Website, our Service and us.

    When registering for the newsletter, you have to provide an email address. This email address will be transmitted to and stored by us (or a provider as specified below).

    After registration, the user will receive an email to confirm the registration (“double opt-in”). Via clicking the registration link you have given your consent to the processing of your personal data for receiving our newsletter according to Art. 6 (1) a. GDPR and we may process such data accordingly.

    In case of registration for the newsletter, we (or our provider as specified below) also store the IP address, the device name, the mail provider as well as the user's first and last name and the date of registration.


    Use of Mailchimp; Transfer of Data outside the EU

    The mail provider “Mailchimp” by Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA receives and processes on our behalf the data necessary for the order, in particular email address, IP address, device name. These data are processed on servers in the USA. Mailchimp is certified according to “Privacy Shield”. The “Privacy Shield” is an agreement between the European Union (EU) and the USA to ensure compliance with European data protection standards in the USA.

    Mailchimp is a service with which the dispatch of newsletters can be organized and analyzed. With the help of Mailchimp we can analyze our newsletter campaigns. When you open an e-mail sent with Mailchimp, a file contained in the e-mail (so-called web beacon) connects to the Mailchimp servers in the USA. This allows you to determine whether a newsletter message has been opened and which links have been clicked on. In addition, technical information is recorded (e.g. time of registration, IP address, browser type and operating system). This information cannot be assigned to the respective newsletter recipient. They are used exclusively for statistical analysis of newsletter campaigns. The results of these analyses can be used to better adapt future newsletters to the interests of the recipients.

    If you do not want Mailchimp to analyze your data, you must unsubscribe from the newsletter. For this purpose, we provide a respective link in every newsletter.

    Details on Mailchimp and its privacy policy can be found here: https://Mailchimp.com/legal/privacy/

    The data are stored for the purpose of newsletter subscription will be stored by us until you unsubscribe from the newsletter and will be deleted from our servers as well as from the servers of Mailchimp after you unsubscribe from the newsletter. Data stored by us for other purposes (e.g. email address for the use of the Software) remain unaffected.


    OPT-OUT : The User can withdraw his or her consent to the storage of data, the email address and their respective use for sending the newsletter at any time. This can be done free of charge (except for the transmission costs) and via a link in the newsletter itself or notification to us or, if applicable, to Mailchimp.


    Profiling/Automated Decision-Making

    AngelsDen is profiling the Service users as the automated processing of personal data by our Website allows us to analyze and to make predictions about individuals within our internal scoring system.

    This, however, is only possible, if we will receive your explicit consent.

    Furthermore, such profiling may happen by third-party providers through the Website or Service. We will inform you about such fact if possible.

    Currently, the automated processing by us does not lead to automated decision-making.

    Profiling means any automated processing of personal data consisting in the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to the performance of work, economic situation, health, personal preferences, interests, reliability, behavior, location or relocation of that natural person. Examples of such profiling include the analysis of data (e.g. based on statistical methods) with the aim of displaying personalized advertising to the user or giving shopping tips. The data subject shall not be subject to a decision based exclusively on automated processing, including profiling, which has legal effect against him or significantly affects him or her in a similar manner. This shall not apply where the decision (i) is necessary for the conclusion or performance of a contract between the data subject and the data controller, (ii) is admissible under Union or Member State law to which the data controller is subject and where such law contains appropriate measures to safeguard the rights, freedoms and legitimate interests of the data subject or (iii) is taken with the data subject's express consent. In such exceptional cases, the person responsible shall take appropriate measures to safeguard the rights, freedoms and legitimate interests of the data subject, including at least the right to obtain the intervention of a person by the data subject, to state his own position and to challenge the decision.

    To use the Angels Den Services you are asked to provide us with certain data.

    We will use your submitted data for the Angels Den Services to implement this privacy policy and carrying out your investing or collecting investments activities based on Art. 6 (1) b. GDPR.

    We may contact you via email if you send us a request as well as for purposes related to the use of the Service based on Art. 6 (1) b. GDPR.

    We also use the information collected, including your personal data, in order to improve and analyze your use of our Service based on Art. 6 (1) b. and f. GDPR) and to ensure the technical functionality of our services fulfillment of contractual or pre-contractual obligations (based on Art. 6 (1) b. GDPR and as otherwise explained in this privacy policy. Regarding the data processing based on Art. 6 (1) f. GDPR we wish to achieve the legitimate interests of quality insurance, marketing and fraud prevention.

    To comply with our legal obligations for anti-money laundering we use the service by “Smartsearch”. If you register for our Service we and “Smartsearch” are joint controllers for complying with anti-money laundering obligations when you are using our Service (details: https://www.smartsearchsecure.com/dpa/dpajdc). Smartsearch is offered by SmartCredit Limited T/As SmartSearch, a company registered in England and Wales under registered number 05534508, registered office is at Mayfield House, Lower Railway Road, Ilkley, Leeds, LS29 8FL and may be contacted via email to clientservices@smartsearchuk.com. The data processing by Smartsearch and us is based on fulfilling our contractual obligations (Art. 6 (1) b. GDPR) and/or fulfilling a legal obligation (Art. 6 (1) c. GDPR). For Smartsearch’s privacy policy please refer to: http://www.smartsearchuk.com/privacy-policy .

    We do not process any payment data but work with external payment providers Gocardless (for more information see: https://gocardless.com/ ) and Paypoint (for more information see: https://www.paypoint.com/en-gb ).

    Cookies

    In order to offer you a convenient online service featuring numerous functions, our Website uses text files (“Cookies”) containing information to identify returning visitors for the time of their visit to our Website. Cookies are usually saved on your device and do not cause any harm. Cookies facilitate the transfer of specific content, such as entering data, which has already been supplied, and help us identify popular sections of our Website.

    The processing of data when using Cookies is based on our legitimate interests of a statistical analysis of the User relationship for marketing and quality assurance purposes according to Art. 6 (1) f. GDPR.


    OPT-OUT: You can deactivate the use of Cookies in the settings of your browser at any time. To find out how to change the settings, please consult the help function of your browser. Users may also deactivate and manage a lot of online Cookies by different businesses on the US-website or the EU-website . However, we want to point out that without Cookies the use and comfort of use of our services may be restricted.


    Google Analytics

    We use Google Analytics a web analytics tool offered by Google LLC, Mountain View, CA, USA (“Google“). This analysis service uses so-called “cookies”. For analysis, text files will be stored on your device. The information stored in the corresponding files about the use of this website are generally transmitted and stored in Google server in the USA. As the IP anonymization is active on this Website, your IP address will be shortened by Google within the member states of the European Union (EU). This information will be used to evaluate your use of the services offered here and enable the operator of this website to analyze your website activity and provide other services associated with the website service. The IP address transmitted from your browser, as part of Google Analytics will not be merged with other data from Google.


    OPT-OUT: 

    Adjusting the settings of your browser software can prevent the use of cookies. In this case, it may be possible that the functions of the service offered here cannot be used in its entirety. Furthermore, it is possible to prevent the acquisition and processing of data generated by the “cookies” in relation to the use of this website, by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de

    We point out that an automated decision-making ("profiling") (see also the“profiling” link above) can take place when integrating Google and an existing Google account. OPT-OUT: https://adssettings.google.com/authenticated


    Google Tag Manager

    This Website uses the Google Tag Manager by  Google LLC, Mountain View, CA, USA. Google Tag Manager is a solution that allows marketers to manage website tags through a single interface. The tool Google Tag Manager itself (which implements the tags) is a cookieless domain and does not collect any personal data. The tool triggers other tags, which in turn may collect data. Google Tag Manager does not access this data. If deactivation has been made at the domain or cookie level, it will remain in effect for all tracking tags implemented with Google Tag Manager. You can also find more information in Google's privacy policy: services.google.com/sitestats/en.html


    Social Plugins

    The Website is connected to the social networks Facebook and LinkedIn, via “Social Plugins“.

    Without any action by you as User the Social Plugins are deactivated and therefore no data are transferred. If you wish to share for example a content you have to click the respective button first. Only with the click of the respective button a connection to the respective social network will be set up and data transferred thereto. In the event you are already logged in your User profile within the social network, your visit of the Website is tracked instantly. In any case you can deactivate this function anytime.

    The data processing described is based on Art. 6 (1) f. GDPR based on the legitimate interests of the respective provider of the network the Social Plugin is referring to display personalized advertisement, inform other users of the social network about their activities and for a customized design of the service.

    If you do not want any collection of data through the Website by the social networks you need to log out from the social network every time you visit the Website. However, with every visit of the Website (a) Cookie(s) with an identification is/are set if the Social Plugin buttons are/were activated via clicking. Therefore through this function data might be collected and a profile might be created, which could be tracked back to the individual person. If you do not want this you can either deactivate the Social Plugin on the Website via clicking the button or you can change your browser settings accordingly and exclude the acceptance of any Cookies; we hereby inform you that in this event the functionality of this Website could be restricted.


    Social Network

    Profiling / OPT-OUT

    Further information

    Facebook

    The Website uses the Social Plugin for the social network Facebook (facebook.com) by Facebook Inc., Facebook Inc., 1601 Willow Road, Menlo Park, CA 94025, USA or Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland

    Please note that when Facebook is integrated, an automated decision making (“profiling”) takes place. If you do not want this, you can deactivate the corresponding link on the Website. You can also set your browser so that the acceptance of cookies is generally excluded; however, we would like to point out that in this case the functionality of the Website may be restricted. You can also make various settings for possible advertising or profiling within your Facebook account.

    The data and privacy policy of Facebook can be found here .

    LinkedIn

    The Website uses the Social Plugin for the social media platform by LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, CA 94085, USA or LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

    Please note that when LinkedIn is integrated, an automated decision making (“profiling”) takes place. If you do not want this, you can deactivate the corresponding link on the Website. You can also set your browser so that the acceptance of cookies is generally excluded; however, we would like to point out that in this case the functionality of the Website may be restricted. You can also make various settings for possible advertising or profiling within your LinkedIn account.

    The data and privacy policy of LinkedIn can be found here .


    External Links; Vimeo

    We included links on third-party providers on the Website, such as videos of Vimeo. The integrated button or content only contains an HTTP link to the external content or webpage offered by third-party providers. When you visit our Website, no direct connection is established with such third party services.

    We will transfer your personal data to a third party only within the scope of legal provisions, i.e. if we are obliged to transfer the data due to a government or court order, or, if applicable, legal provisions authorize the transfer or if you give your explicit consent.

    When using our Website and Service your data may be transferred to countries outside the EU because of the use of third-party providers.


    Use of Services on the Website that process data outside the EU

    When visiting the Website data may be transferred to countries outside the EU whereas the services by Google, as well as the “Social Plugins” (Facebook and LinkedIn) are affected. The US companies providing the services of Google, Facebook and  LinkedIn are certified under EU-US-Privacy-Shield and comply with data protection standards applicable in the EU.


    Further Third Party Providers that process data outside the EU

    Data is transferred outside the EU due to the integration of cloud and hosting services, CRM services or external service partners, for example for processing customer inquiries or internal communication, who work on our behalf and assist us in carrying out our business activities or presenting the website (legal basis Art. 6 (1) b. or f.). GDPR).


    Mailchimp

    We use Mailchimp for the purpose of sending emails for our Service offered by Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA. Mailchimp receives and processes on our behalf the data necessary for the order, in particular email address, IP address, device name. These data are processed on servers in the USA. Mailchimp is a service with which the dispatch of emails can be organized and analyzed. When you open an e-mail sent with Mailchimp , a file contained in the e-mail (so-called web beacon) connects to the Mailchimp servers in the USA. This allows you to determine whether a message has been opened and which links have been clicked on. In addition, technical information is recorded (e.g. time of registration, IP address, browser type and operating system). This information cannot be assigned to the respective recipient. They are used exclusively for statistical analysis.

    Mailchimp participates in and has certified its compliance with the EU-U.S-Privacy Shield Framework and complies with data protection standards applicable in the EU.

    https://mailchimp.com/legal/privacy/

    For more information please refer to the Compliance Department at Angels Den via email .

    Right to access, rectification and erasure; right to restriction of processing, right to withdraw, right to data portability

    According to the legal regulations you as the person concerned have the right to receive information about your data stored by us or other controllers named here free of charge at any time.

    Furthermore, you can assert your rights to rectification, erasure or restriction of the processing or the right of withdrawal against us or other controllers named here at any time. This also applies to a right to data portability.

    If you have provided us with your personal data on the basis of a consent, you could withdraw the consent at any time with effect for the future.

    For these purposes please contact us via email at any time. Contact person Chitraj Singh – Compliance Director at Angels Den – cl@angelsden.com


    Right to lodge a complaint

    Each user has a right to lodge a complaint vis-á-vis a supervisory authority of his/her choice.

    An overview of the European National Data Protection Authorities may be found here .


    Duration of the storage of personal data; deletion periods

    As a rule, we only store your personal data for as long as it is necessary for the execution of the contract or the respective purpose and limit the storage period to an absolutely necessary minimum.

    In the case of long-term contractual relationships, such as the use of our Offer, these storage periods may vary, but are generally limited to the duration of the contractual relationship or, with regard to the inventory data, to the maximum legal retention periods.

    Criteria for the storage period include whether the data are still up-to-date, whether the contractual relationship with us still exists, whether an inquiry has already been processed, whether a process has been completed or not, and whether legal retention periods for the personal data concerned are relevant or not.

    Data Security

    We have installed technical and organizational measures in order to safeguard our Website and/or Service against loss, destruction, access, changes or the distribution of your data by unauthorized persons. However, we cannot guarantee a complete protection for data transmitted to us against all dangers at all times, because information via the internet is not completely secure.

    The Website is operated through a safe SSL-connection. If an SSL-connection is activated third parties are prevented from reading any data that are transferred by you to us.

    We will store your data on servers, which are located within the European Union and, as applicable and set forth in this privacy policy, in the USA.


    Access and Changes to this Privacy Policy

    This privacy policy is accessible via our Website as well as the Service more/privacy and may be downloaded and printed anytime.

    We reserve the right to change the regulations of this privacy policy at any time, taking into account currently applicable data protection provisions. In case of any changes, you will be notified and you will have to agree to the modified provisions.


    Contact Details

    For any inquiries and additional questions about processing personal data please contact our Compliance Department at Angels Den via email.