Privacy Policy

Introduction

Data privacy is important to us. At Werfen, we recognize the importance of protecting your personal data and are committed to processing it responsibly and in compliance with the applicable laws.

This Privacy Policy is intended to describe how we, Werfen, S.A. (hereinafter “Werfen”, “we” or “us”), a Spanish company holding tax Identification number A08754111, with corporate address at Plaza Europa, 21-23, 08908 L’Hospitalet de Llobregat, Barcelona and registered with the Commercial Registry of Barcelona under volume 4.853, book 4.172, section 157 and sheet 54.551, process your personal identifiable information (“PII”) in our capacity as data controller, determining the means and/or purposes of their processing.

We may update this Privacy Policy from time to time. When doing so, changes will be effective immediately upon posting the revised Privacy Policy on the Site. As a result, we recommend that you check this Privacy Policy on a regular basis. This Privacy Policy was last updated on September 5, 2023.

Scope of our Privacy Policy

This Privacy Policy applies to all PII we collect, use, share, or otherwise process when using the We Venture Capital site www.weventurecapital.com (the “Site”), our way of getting startups to pitch their ideas to us. Our Site makes use of cookies. For more information, please consult our Cookies Policy. Further, please read our Terms of Service.

Note that our Site may contain hyperlinks to third-party websites which are not controlled by Werfen, and which are not covered by this Privacy Policy. We have no responsibility or liability for the content and activities of these third-party websites. As these third parties may collect your PII, we suggest that you consult the privacy policies of these third-party websites to learn more about their use of your PII.

Information that you give us

As an individual, we gather your PII as explained below:

Information we automatically collect: Some PII may be collected automatically when you visit our Site, such as information collected by cookies. PII collected this way may include information about your IP address, type of browser, log information, and performance and metric statistics to help improve and further develop our Site.
Information you provide to us: PII collected this way is essentially the contact information you voluntarily include in your email (i.e., your name, surname, job title, company, and e-mail) when you submit your startup pitch to us.

How we use your information and legal reason for the processing

We process your PII for the purposes indicated below on the following legal grounds:

To take steps to enter into a contract with you:
- To contact you, either electronically or non-electronically, for more information, to clarify questions, or to begin exploring the possibility of a potential investment if, after reviewing the deck you submitted to pitch your startup, we think that there is a good fit.
Because it furthers the legitimate interests of Werfen, and because that handling does not unduly impact your interests, rights, and freedoms:
- To respond to your requests for information.
- To manage, operate, and protect our Site to make your experience safer and better when visiting us as well as to carry out the relevant administrative and maintenance tasks of the Site.
- For a business sale, merger, consolidation, change of control, transfer of substantial assets, reorganization, or due diligence in anticipation of such an event (e.g., if a company were to acquire Werfen, it may also acquire the PII we hold).
To meet legal compliance obligations, regulatory requirements, and claims:
- We manage your PII as required by the applicable regulations (including administrative, tax, accounting, and labor obligations).
- To establish, exercise, or defend legal claims.
- Under certain circumstances where we believe that using or disclosing the PII is appropriate to protect the rights, safety, and property of Werfen or others (e.g. when required to make disclosures in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements).

We will not use your PII for any other purpose incompatible with the purposes listed above unless it is authorized by you, or it is necessary for us to comply with a legal obligation, to resolve disputes and/or to prevent security issues or abuse.

How long does Werfen store your PII?

We will not retain your PII longer than is legally permitted and necessary for the related processing purposes. If, after reviewing the information about your startup, we decide not to invest in it, your PII will be stored for 2 years from the date of rejection. Conversely, if we find a good fit and decide to invest in it, we will store your PII for the duration of our business relationship. Once this time has expired, certain regulations oblige us to keep such data for a longer period, especially to deal with possible complaints or comply with legal obligations. During this time, we will keep your PII blocked only to comply with these purposes.

To whom we may share your PII

We share your PII with other organizations in the following limited circumstances:

Third-party service providers:
- When we use trusted third-party service providers who work on our behalf, such as marketing agencies, software, data hosting and other IT service providers, payment processors, etc. These third-party service providers are required not to use your PII other than to provide the services requested by us or otherwise in accordance with our instructions.
Acquisitions:
- In connection with a corporate transaction, such as the sale of all or a portion of our business, a divestiture, merger, consolidation, or an asset sale, the recipient company may acquire all or part of the PII collected by us and will assume the rights and obligations regarding your PII as described in this Privacy Policy. In the unlikely event of an insolvency, bankruptcy, or receivership, your PII may also be transferred as a business asset, subject to applicable law.
Disclosures:
- We may disclose your PII if we believe in good faith that such disclosure is necessary for our legitimate interest or prudent considering our obligations under applicable law:
  - In response to a subpoena or similar investigative demand, a court order, or other request from a law enforcement or public administration.
  - To establish or exercise our legal right, to defend against legal claims or as otherwise required by law.
  - In connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud, or other wrongdoing.
  - To protect and defend the rights, property, or safety of Werfen, our employees, or others.
  - To investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or any applicable Terms of Use.

We and our third-party service providers may operate in various locations around the world. As a result, we and our third-party service providers may transfer PII to, or access PII from, countries outside of your country of residence.

We take steps to ensure that your PII receives an adequate level of protection in the countries where we process it. If your PII is transferred from the EU to a third-party service provider in a country outside the EU that is not recognized as providing an adequate level of protection for PII, we will provide appropriate safeguards through the EU Commission’s standard contractual clauses or other appropriate safeguards as required by applicable data protection regulations.

You may contact us in the “How to Contact Us” section for more information regarding the international transfer of PII.

Your rights

We offer the options below for exercising your rights and choices about how we use your PII. Many of these are subject to important limits or exceptions under applicable laws:

Request a copy of the PII we hold about you. Depending on the Site or the Services, you may review and update certain information by accessing yourself to the relevant Site or Services.
Ask that we restrict the way in which we use your PII.
Ask that we update the PII we hold about you or correct any PII that you think is incorrect or incomplete.
Ask that we delete the PII that we hold about you (the “right to be forgotten”).
Withdraw your consent, at any time in the future, to our processing of your PII (to the extent such processing is based on the legal grounds of your consent).
Object to us processing of your PII.
Request your PII be transferred to you or another data controller (the “data portability” right).

You may contact us with any concerns or complaints regarding our privacy practices or to exercise any of the aforementioned rights. If you would like to exercise these rights or understand if they apply to you, you can get in touch using the details set out at “how to contact us” below. For your protection, we will only implement requests with respect to PII after we have verified your identity to our satisfaction, taking into consideration the nature of your request.

Whenever, in your opinion, the processing of your PII involves an infringement of the legal requirements, or if you are unhappy with the way we have handled your PII or any privacy query or request that you have raised with us, you have the right to complain to your local data protection regulator. For further details, you can see the list of the different European Data Protection Authorities by clicking here.

How we protect your information

We use commercially reasonable technical and organizational measures to protect your PII against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access, and against all other unlawful forms of processing. If, despite our security measures, there is a breach of security that could put your PII at risk, we will notify the affected parties and, where required by applicable data protection laws, the relevant authorities as soon as reasonably possible.

How to contact us

As a global company, Werfen has appointed a person as the Data Protection Officer (DPO) to ensure that Werfen complies with all the legal requirements of the regulation regarding the protection of PII. The DPO of Werfen can be contacted by e-mail at DPO@werfen.com or by post at Werfen, S.A., Plaza Europa, 21-23, 08908, L’Hospitalet de Llobregat, Barcelona, Spain.