PRIVACY POLICY
BACKGROUND:
Aureus Ventures understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our website and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” |
means an account required to access and/or use certain areas and features of our Site; |
“Cookie” |
means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in Part 16, below; and |
“Cookie Law” |
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003; |
2. Information About Us
Our Site is owned and operated by Aureus Ventures, a Limited Company, registered in England under company number 12878424
Registered address: 3rd Floor, 86-90 Paul Street, London, England, United Kingdom, EC2A 4NE
Main trading address: 3rd Floor, 86-90 Paul Street, London, England, United Kingdom, EC2A 4NE
3. What Does This Policy Cover?
This Privacy Policy applies only to your use of our Site. our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
4. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
b) The right to access the personal data we hold about you. Part 12 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 19 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 19 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 19.
If you are a resident of California or Nevada in the United States, you may have additional rights regarding your personal data. More information may be found here.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 19.
6. What Data Do You Collect and How?
Depending upon your use of our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 16 for more information about our use of Cookies and similar technologies.
Data Collected |
How We Collect the Data |
Identity Information including name |
Using Contact Form / Apply Now form linked with Hubspot account of Aureus Ventures |
Contact information including email address, phone number, location. |
Using Contact Form / Apply Now form linked with Hubspot account of Aureus Ventures |
Business information including company name, position in company, company registration number, date Established, web address. |
Using Contact Form / Apply Now form linked with Hubspot account of Aureus Ventures |
Profile information including sector, description of idea, how did you come up with the idea, stage of development, total amount invested in the company, any investment raised, investment needed, problems the product or service solves, major competitors, competitor URL, uniqueness of the product, greatest inspiration, past businesses. |
Using Contact Form / Apply Now form linked with Hubspot account of Aureus Ventures |
7. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will OR may use your personal data, and our lawful bases for doing so:
What We Do |
What Data We Use |
Our Lawful Basis |
Business Operations ● Website Administration ● Invoicing |
Aureus Ventures may process your personal data in order to operate our website, for the processing of applications to Aureus Ventures Programmes and the fulfilment of information requests. Also for generating invoices, bills and other payment-related documentation |
The legal basis is Aureus Ventures legitimate interests; the administration of our website and operation of our business. To protect our legitimate interests, we will store such data for a limited period of time in order to be able to initiate a tracking of personal data in the event of actual or attempted unauthorized access to our servers. |
Company Administration ● Record keeping ● Creating and updating databases ● Backups |
Aureus Ventures may process your personal data, your contact data, your Aureus Ventures account information, your historical transaction data with Aureus Ventures and/or your communication data |
The legal basis is our legitimate interest in ensuring that Aureus Ventures has access to all the data needed to run our business |
Communications ● Relationship management ● Support services ● Complaint handling |
Aureus Ventures may process your contact data, your Aureus Ventures account information, your historical transaction data with Aureus Ventures and/or your communication data |
The legal basis for Aureus Ventures to process this data is our legitimate interests. These include communicating with our Aureus Ventures website visitors, service users, customers and customer staff, the management of our Aureus Ventures customer relationships, and the operations of our website and business |
Direct Marketing ● Emails ● SMS messages ● Phone calls ● Direct mail ● Fax ● Social media, direct messages |
Aureus Ventures may process your contact information, your account data and/or transaction history in order to create, target and send direct marketing communications by email, SMS, social media, post and/or fax and to make contact by telephone for marketing-related purposes. |
The legal basis for this processing is your consent and/or our legitimate interests, namely; the promotion of the Aureus Ventures business and the communication of marketing messages and offers to our website visitors and service users You may opt-out at any time by clicking on the opt-out link or emailing aureus ventures on info@aureusventures.com |
Research & Analysis ● Product & service improvement ● Website improvement ● Security |
Aureus Ventures might process your Aureus Ventures website usage data and/or transaction data in order to research and analyse the use of, and interaction with our Aureus Ventures business, our website and services. |
The legal basis for this processing is Aureus Ventures legitimate interests, namely the monitoring, improving, personalisation and securing our website, services and business. |
Security & Legal Compliance ● Fraud prevention ● Money Laundering ● Legal compliance |
Aureus Ventures may process your personal data for legal compliance, security and to prevent fraud and any other criminal activity. |
The legal basis of this processing is Aureus Ventures legitimate interests, namely the protection of our website, services and business, and the protection of others. Also to protect your vital interests or the vital interests of another natural person. |
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, or text message with information, news, and offers on our products. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
Third Parties whose content appears on our Site may use third-party Cookies, as detailed below in Part 16. Please refer to Part 16 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We use the following automated system[s] for carrying out certain kinds of decision-making AND/OR profiling If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 19.
● The following automated decision-making method(s) may be used:
o Auto Reply in the format of email to the user when form is successfully submitted, from Hubspot Account.
o Future marketing emails, send automatically from Hubspot
● The following automated profiling may take place:
o Auto user creation on Aureus Ventures Hubspot account, upon successful submission of form.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If We do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 19.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
Type of Data |
How Long We Keep It |
Identity Information including name. |
No fixed retention period, till either Aureus Ventures or User opts out of the services. |
Contact information including email address, phone number, location. |
No fixed retention period, till either Aureus Ventures or User opts out of the services. |
Business information including company name, position in company, company registration number, date Established, web address. |
No fixed retention period, till either Aureus Ventures or User opts out of the services. |
Profile information including sector, description of idea, how did you come up with the idea, stage of development, total amount invested in the company, any investment raised, investment needed, problems the product or service solves, major competitors, competitor URL, uniqueness of the product, greatest inspiration, past businesses. |
No fixed retention period, till either Aureus Ventures or User opts out of the services. |
9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exception[s].
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10. How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us, which you may do by unsubscribing using the links provided in our emails and at the point of providing your details.
If you wish to exercise your rights, please address your request to the contact form or to our
11. Can I Withhold Information?
You may access our Site without providing any personal data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.
You may restrict our use of Cookies. For more information, see Part 14.
12. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 19.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 30 days of receiving it. Normally, to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
13. What cookies do we use?
We differentiate between two categories of cookies: (1) functional cookies, without which the functionality of our Website would be reduced, and (2) optional cookies used for e.g. website analysis and marketing purposes.
14. How do you use Cookies?
Aureus Ventures may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by Aureus Ventures and are used only by us. We use Cookies to facilitate and improve your experience of our Site and to provide and improve our products AND/OR services. By using our Site you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on our Site for Analytics and Form Data Collection by Hubspot.
15. Cookies subject to your consent
We only use optional cookies if we have obtained your prior consent. Upon your first access to our Website, a banner will appear, asking you to give us your consent to the setting of optional cookies. If your consent is given, we will place a cookie on your computer and the banner will not appear again as long as the cookie is active. After expiration of the cookie’s lifespan, or if you actively delete the cookie, the banner will reappear upon your next visit to our Website and again ask for your consent.
16. How to prevent the setting of cookies
Of course, you may use our Website without any cookies being set. In your browser, you can at any time configure or completely deactivate the use of cookies. This may, however, lead to a restriction of the functions or have adverse effects on the user-friendliness of our Website.
16.1 Website Analysis and Online Behavioral Advertising
On our Website we use Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).
Google will analyze your use of our Website on our behalf. To this purpose we use, among others, the cookies described in more detail in the above table. The information collected by Google in connection with your use of our Website (e.g. the referring URL, our webpages visited by you, your browser type, your language settings, your operating system, your screen resolution) will be transmitted to a server of Google in the US, where it will be stored and analyzed. The respective results will then be made available to us in anonymized form. Your usage data will not be connected to your full IP address during this process. We have activated on our Website the IP anonymizing function offered by Google, which will delete the last 8 digits (type IPv4) or the last 80 bits (type IPv6) of your IP address. Moreover, Google is certified under the EU-US Privacy Shield, which ensures that an adequate level of data protection is maintained with respect to the processing of data by Google in the US.
You may revoke your consent to the use of web analysis at any time, either by downloading and installing the provided Google Browser Plugin or by administrating your consents in the
Further information on Google Analytics is available in the Google Analytics Terms of Use, the Privacy and Data Protection Guidelines of Google Analytics and in the Google Privacy Policy.
This Website uses an online behavioral advertising service of Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (using Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA as subprocessor) (“Facebook”).
Facebook will analyze your use of this Website. To this purpose, we use the cookies described in more detail in the above table. The information collected by Facebook in connection with your use of our Website will be transmitted to a server of Facebook in the US, where it will be stored and analyzed. These information include the referring URL, your browser type, your language settings, your operating system, your screen resolution and further information depending on the implemented pixel events (e.g. “purchase”: processes the type, ID and number of the selected item as well as payment information and currency; “search”: processes the search string, when you search for a product on our website; “view content”: processes the content ID, name, type, currency and value). We and our partner Facebook will use this information to better tailor our advertisements to you and your interests, to limit the number of times you are shown the same advertisement, to evaluate the efficiency of promotional campaigns, and to better comprehend the behavior of visitors after they have looked at a certain ad. When you visit your Facebook timeline or another websites of Facebook’s advertisement network (so called “Audience Network”), customized feeds tailored to your interests can be presented to you on the basis of the information collected on our Website.
Facebook Inc. is certified under the EU-US Privacy Shield, which ensures that an adequate level of data protection is maintained with respect to the processing of personal data by Facebook in the US.
You may withdraw your consent to this transfer of information to Facebook for online behavioral advertising purposes at any time by administrating your consent in the
Facebook is responsible for processing your personal data which Facebook collects directly from our Website for online behavioral advertisement services. Since we have no control over personal data collected and processed by third parties, we are not in a position to provide binding information regarding the scope and purpose of such processing of your personal data. Thus, please visit Facebook’s information on data privacy to receive further information on how Facebook processes your personal data and for how long. At the time of preparation of this privacy statement, Facebook’s information was available on their Privacy Policy.
This Website uses an online behavioral advertising service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google“).
Google will analyze your use of this Website. To this purpose, Google uses the cookies described in more detail in the
Google is certified under the EU-US Privacy Shield, which ensures that an adequate level of data protection is maintained with respect to the processing of personal data by Google in the US. You may withdraw your consent to this transfer of information to Google for online behavioral advertising purposes at any time either by administrating your consents in the
Google is responsible for processing your personal data which Google collects directly from our Website for online behavioral advertisement services. Since we have no control over personal data collected and processed by third parties, we are not in a position to provide binding information regarding the scope and purpose of such processing of your personal data. Thus, please visit Google’s information on data privacy to receive further information on how Google processes your personal data and for how long. At the time of preparation of this privacy statement, Google’s information was available on the Google Data Protection Guidelines for Advertising.
The LinkedIn Insight Tag enables the collection of data regarding members’ visits to your website, including the URL, referrer, IP address, device and browser characteristics (User Agent), and timestamp. The IP addresses are truncated or (when used for reaching members across devices) hashed, and members’ direct identifiers are removed within seven days in order to make the data pseudonymous. This remaining pseudonymized data is then deleted within 180 days.
LinkedIn does not share the personal data with the website owner, it only provides reports (which do not identify you) about the website audience and ad performance. LinkedIn also provides retargeting for website visitors (up to 90 days after the visit), enabling the website owner to show personalized ads off its website by using this data, but without identifying the member. We also use data that does not identify you to improve ad relevance and reach members across devices. LinkedIn members can control the use of their personal data for advertising purposes through their account settings.
You can contact us directly via the contact forms available on our Website. In particular, you may provide us with the following information:
● First Name & Last Name
● Company Name and Web Address
● Contact data (e.g. e-mail address, phone number)
● Message
We collect, process and use the information provided by you via the contact forms exclusively for the processing of your specific request.
Aureus Ventures uses HubSpot to collect data from forms on our website that you must fill out to access some marketing content. You can read the privacy policy for HubSpot online.
Subscription to our newsletter
On our Website, you may subscribe to receive our newsletter. Based on your prior consent, we will collect and use the email address you indicate for providing you with the newsletter (Art. 6(1)(a) General Data Protection Regulation).If you wish to receive a customized newsletter, you may, on a voluntary basis, provide us with the following additional information:
● First Name and Last Name
● E-mail Address
For subscription to our newsletter we use the so-called double opt-in procedure. After you have subscribed to the newsletter on our Website, we will send you a message to the indicated email address asking for your confirmation. If you do not confirm your subscription, your subscription will automatically be deleted. In order to prevent any misuse of your personal data, we will log your subscription and confirmation, filing the IP address you use when subscribing, the time of your subscription and confirmation, the messages sent by us regarding your subscription, and the wording of your subscription and confirmation.
You may at any time with future effect revoke your consent to receive our newsletter. To declare that you wish to unsubscribe, you may use the respective link included in all newsletters, or refer to the
External services or content on our Website
We include or may include third-party services and/or content on our Website. When you use such third-party services or when third-party content is displayed, communication data are exchanged between you and the respective provider for technical reasons.
The respective provider of the services or content may also process your data for own additional purposes. To the best of our knowledge, we have configured the services and content of providers known to process data for own purposes in such a way that either any communication for other purposes than to present their services or content on our Website is blocked, or communication only takes place once you have actively opted to use the respective service. However, since we have no control over data collected and processed by third parties, we are not in a position to provide binding information regarding the scope and purpose of such processing of your data.
For further information regarding the scope and purpose of such collection and processing of your data, please consult the privacy statements of the providers whose services and/or content we include and who are responsible for the protection of your data in this context:
17. Transfer of data for commissioned processing
We may process your data and for the processing of your data we will to some extent use specialized service contractors. Such service contractors are carefully selected and regularly monitored by us. Based on respective data processor agreements, they will only process personal data upon our instruction and strictly in accordance with our directives.
18. Processing of data outside the EU / the EEA
Your data will in part also be processed in countries outside the European Union (“EU”) or the European Economic Area (“EEA”), which may have a lower data protection level than European countries. In such cases, we will ensure that a sufficient level of protection is provided for your data, e.g. by concluding specific agreements with our contractual partners (copy available on request), or we will ask for your explicit consent to such processing.
19. How Do I Contact You?
To contact [us] OR [me] about anything to do with your personal data and data protection, including to make a subject access request, please use the following details, for the attention of Alexis Monoogian
Email address: alexis@aureusventures.com
Postal Address: 3rd Floor, 86-90 Paul Street, London, England, United Kingdom, EC2A 4NE
20. Changes to this Privacy Policy
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 11th December 2020.