This web site is maintained by Blue Green White Capital AEDAKES a SA established under the laws of Greece, with General Commercial Register Nr. 157033507000, having its registered office at 3, Mavromihali Street, Piraeus, Greece, as the Manager of BGW VCMF. We are responsible for ensuring that this website uses the Personal Data in compliance with data protection laws.
“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information, which is in the possession of, or is likely to come into our possession (or that of our representatives or service providers including but not limited to Blue Green White Capital AEDAKES). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of BGW or any other person in respect of an individual.
- THE PRODUCTS AND SERVICES WE PROVIDE
- Information we receive through our website (“BGW Website”), as described in our Terms and Conditions, and
- Information we receive through or in connection with our Portfolio Investment Activities and potential Investee Companies.
- THE TYPES OF PERSONAL DATA WE COLLECT
Many Investment Activities of BGW require us to obtain Personal Data about you in order to evaluate the eligibility of Investee Companies in compliance with the current legislation and provide funding to our Portfolio Companies. In relation to the abovementioned, we will collect and process the following Personal Data about you:
- Information that you provide to BGW: This includes information about you that you provide to us. The kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):
- Basic Personal Data (such as first name, family name, position in the company, company name, company email address, business phone number, business address, city, postcode, country),
- Project Data (such as financial forecasts, fundraising targets, business assumptions, pricing targets) describing a business that may or may not become incorporated in our eligible Investees,
- Any information that you choose to share with us (whether through our websites or otherwise) which may be considered Personal Data,
- Information that we collect or generate about you: This includes (by way of a non-exhaustive list):
- Information about the website contact tools you use, your interests in our informative content and our interactions with you,
- When you visit BGW Website, cookies are used to collect technical information about the services that you use, and how you use them.
- Information we obtain from other sources.
- We may be supplied with CV of prospective candidates for roles at both BGW and our portfolio companies.
- We may from time to time use 3rd party public and private data sources.
- Anonymized data: In addition to the categories of Personal Data described above, we will also process further anonymized information and data that is not processed by reference to a specific individual.
- HOW WE USE YOUR INFORMATION
4.1 Your Personal Data may be stored and processed by us in the following ways and for the following purposes:
- for ongoing review and improvement of the information provided on or operation and security of BGW Website,
- to evaluate investment opportunities
- to invest in Eligible Investee Companies,
- to understand feedback on our Investment Activities,
- to communicate with you in order to provide you with information aboutBGW upon subscription/account creation,
- to understand your needs and interests,
- for the management and administration of our business,
- to comply with and to assess compliance with applicable laws, rules and regulations, and internal policies and procedures,
- for the administration and maintenance of databases storing Personal Data, and / or
- to process business communications traffic data sent and received by us for the purposes of evaluating our existing or prospective business relationship.
4.2 However, the way we use Personal Data, we make sure that the processing complies with respective privacy laws and the laws only permits and requires us to process Personal Data on specific legal basis. These include where:
- we need to do so in order to perform our contractual obligations,
- we have obtained your consent,
- we have legal and regulatory obligations that we have to discharge,
- we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings,
- the processing of your Personal Data as described is necessary for our legitimate business interests, such as allowing us to (a) effectively and efficiently manage and administer the operation of our business, (b) conducting market research or business analysis, (c) maintaining compliance with internal policies and procedures.
- DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
5.1 We may share your Personal Data among BGW VCMF and Blue Green White Capital AEDAKES for the purposes described above.
5.2 We may also share your Personal Data outside of BGW for the following cases:
- with our business partners. For example, this could include intermediaries that introduced you to us. Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation,
- to the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend our legal rights,
- if we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes, and
- if we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third – party buyer.
- INTERNATIONAL TRANSFERS OF PERSONAL DATA
6.1 We may transfer your Personal Data to locations outside of your country.
6.2 Where we transfer your Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of Europe, for example, this may be done in one of the following ways:
- the country that we send the data to, might be approved by the European Commission as offering an adequate level of protection for Personal Data,
- the recipients might have entered into a contract incorporating “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data
- in other circumstances whereby the laws may permit us to otherwise transfer your Personal Data outside Europe.
6.3 For more information on the protection granted to your Personal Data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) you may contact us as indicated in paragraph 11 below.
- HOW WE SAFEGUARD YOUR INFORMATION
We have extensive controls in place to maintain the security of our information and information systems. The information that we handle is protected with safeguards appropriate to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed, or stored is exclusively limited to authorised employees.
As a condition of employment, BGW employees are required to follow all applicable laws and regulations, including personal data protection laws. Access to sensitive Personal Data is limited only to those employees for whom it is essential in order to discharge their duties. Unauthorized processing or disclosure of confidential client information by a BGW employee is prohibited.
- HOW LONG WE KEEP YOUR PERSONAL DATA
How long we will hold your Personal Data for will vary and be determined by the following criteria:
- the purpose for which we are processing it – BGW will need to keep the data for as long as is necessary for that purpose, and
- legal obligations – laws or regulations may set a minimum period for which we have to keep your Personal Data.
- YOUR RIGHTS
9.1 In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:
- the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you,
- the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation,
- in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to BGW,
- the right to request that we rectify your Personal Data if it is inaccurate or incomplete,
- the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it,
- the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request, and
- the right to lodge a complaint with the National Data Protection Authority if you think that any of your rights have been infringed by us.
9.2 You can exercise your rights by contacting us using the details listed in paragraph 11 below.
- DESIGNATED REPRESENTATIVE
BGW registered office may be contacted using the following contact information:
BLUE GREEN WHITE CAPITAL AEDAKES, 3 Mavromihali Str., Piraeus, 18545
- ENQUIRIES AND CONCERNS
If you have any questions or concerns about our processing of your Personal Data, or about this Policy, please contact us using the following contact information:
Via post: BLUE GREEN WHITE CAPITAL AEDAKES, 3 Mavromihali Str., Piraeus, 18545
We are usually able to resolve privacy enquiries or concerns promptly and effectively. If you are not satisfied with the response you receive, you may lodge a complaint with the National Data Protection Authority at www.dpa.gr