I. TERMS OF USE

The purpose of this website (the “Website”) is to inform visitors as to the business and activities of SponsorCircle Investments GmbH (“SponsorCircle”). If you would like to contact SponsorCircle with any questions or comments, please send e-mail to contact@sponsor-circle.com.

Content of Website

By proceeding to read the contents of this Website you agree, so far as this is permitted under the provisions of the German regulatory system, to the exclusion by us of any liability, including without limitation that arising from any loss of profit or any other damage direct or consequential, in respect of any errors and/or omissions by us and/or any relevant third parties in respect of the content. Any opinions or estimates included herein constitute a judgment as of the date of publication and are subject to change without notice.
Although SponsorCircle has used reasonable efforts to obtain and provide information from reliable sources, no representation is made that the information and opinions contained in this Website are accurate, reliable or complete. You must in any event conduct your own due diligence and investigations rather than relying on any of the information in this Website.
SponsorCircle has not conducted detailed research into the legality or otherwise of the viewing or use of this Website in jurisdictions other than the United Kingdom. SponsorCircle makes no representation that any material contained on the Website is appropriate for any other jurisdiction. Non-German-resident persons choosing to view or make use of this Website do so on the basis that they have informed themselves of any regulatory or other consequences of their doing so.

No offer

The Website is for information purposes only. Nothing in the Website should be construed as an offer, invitation or general solicitation to buy or sell any investments or securities, or provide investment advisory services or to engage in any other transaction. The Website must not be relied upon in connection with any investment decision.

No advice

SponsorCircle does not provide investment advice or any other investment services to any person other than to its investment entity clients. SponsorCircle is not responsible to any other person for providing protections that would be afforded to clients or for advising any such person on any transaction or investment. The information on the Website, including all opinions or other content is not intended to and does not constitute financial, accounting, tax, legal, investment, consulting or other professional advice or services, or an invitation or inducement to engage in investment activity, but is for information purposes only. The Website is not a substitute for independent professional advice and users of this Website should obtain appropriate professional advice relevant to their particular circumstances prior to making any investment decisions.

Disclaimer

The Website may include forward-looking statements. These forward-looking statements are typically identified by terminology such as “may”, “should”, “will”, “expects”, “anticipates”, “plans”, “intends”, “believes”, “estimates”, “projects”, “predicts”, “seeks”, “potential”, “continue” or other similar terminology or by discussion of strategy, plans, objectives, goals, future events or intentions. Any such forward-looking statement is based on SponsorCircle’s expectations, assumptions, estimates and projections about future events at the date of publication. Actual outcomes are subject to numerous risks and uncertainties that could cause them to differ materially from those expressed in a forward-looking statement. Given these inherent risks and uncertainties, you should not rely on forward-looking statements.
SponsorCircle has no obligation to update or otherwise revise any forward-looking statements to reflect the occurrence of unanticipated events or for any other reason.
If and to the extent that the Website contains information regarding the past performance of any investments, you should be aware that this information has not been audited or verified by an independent party. Past performance is not indicative of future results. The value of any investment may fall as well as rise and there is no assurance that investors will get back any amount invested.

Further general provisions

Access to and use of this Website is subject to the following further terms and conditions (“Terms”) set out below. By using or accessing the Website or any part thereof you agree to be bound by the Terms.

Copyright

The copyright in the Website is licensed exclusively by SponsorCircle and protected by the copyright laws of Germany. Any party using or accessing the Website is entitled to copy any such information for their own personal use but may not re-publish, store or re-produce any such information in any manner, including without limitation electronic reproduction by “uploading” or “downloading”, without the prior written consent of SponsorCircle.
Any unauthorised downloading, re-transmission or other copying or modification of any of the contents of the Website may be in breach of statutory or common law rights which could be the subject of legal action. SponsorCircle disclaims all liability which may result from any unauthorised reproduction or use of the information on the Website. All rights not expressly granted are reserved by SponsorCircle.

Trade names

Certain names, words, titles, phrases, logos, icons, graphics and designs displayed on the Website constitute trade names or registered or unregistered trademarks licensed exclusively by SponsorCircle. The display of any trade names or registered or unregistered trade marks on the Website does not imply any licence has been granted to any third party in respect of the same.

Liability for damages

SponsorCircle shall not be liable for any direct or indirect, special, incidental or consequential damage including any loss of profits, business, revenue or goodwill arising from the use of, access to or inability to use or access, interruption or other non-availability of the Website, its operation or transmission, computer viruses (or equivalent), loss of data or otherwise in respect of its use or the downloading or use of any material from the Website.

Warranties

The content displayed on the Website including text, graphics, links or other items are provided on an “as is” basis excluding any warranty whatsoever, express or implied (including, but not limited to, warranties of satisfactory quality, fitness for any particular purpose or freedom from computer viruses). SponsorCircle excludes any liability for (i) any errors in or omissions from content displayed on the Website and (ii) any other websites linked to or from the Website.

Accuracy of content on the Website

Content provided on the Website is believed to be reliable when displayed. SponsorCircle cannot guarantee that content will be accurate, complete and current at all times. All content on the Website is subject to modification from time to time without notice.

Governing law

The Terms shall be governed by and construed in accordance with German law.

II. PRIVACY POLICY

Article 5 of the General Data Protection Regulation (GDPR (EU) 2016/679) states that Personal Data must be processed lawfully, fairly and in a transparent manner. We take your privacy seriously and we are committed to protecting personal data that we receive from you. This privacy policy explains our policies and practices regarding its processing of your personal data, and explains your privacy rights under applicable privacy and security laws.
This privacy policy is effective as of 25th May, 2018. We review our privacy practices on an ongoing basis, and as such we may change this privacy policy from time to time. If such change includes any significant, material changes, we will provide clear notice of the update on the homepage of our website. Please check this policy frequently to ensure that you are familiar with its current content.
If you are an EU national and reside in the EU, or are non-EU national residing in the EU, the data controller (as defined under EU data protection law) will be SponsorCircle Limited.

What type of data may we process?

We  may  control,  process  and  use  your  Personal  Data,  which  may  include  names,  postal  addresses,  email  addresses,  telephone  numbers  or  any  other  Personal  Data  that  you provide  to  us.  We  may  also,  in  appropriate  cases  and  to  the  extent  permitted  by  law, control,  process  and  use  certain  special  categories  of  Personal  Data  which  are  more confidential in nature (e.g. when undertaking “Know Your Customer” (KYC) or anti-­‐money laundering (AML) checks, we may collect information about any criminal conviction offence that  you  or  the  directors  of  any  company  might  have  committed).  We  do  not  intend  to  intentionally  collect  or  process  any  Sensitive  Data.  By  Sensitive  Data  we  mean:  (a)  data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life; and (b) any other information that falls within the definition of “special categories of data” under Data Protection Laws or any other applicable law relating to privacy and data protection.

Identity of the firm

SponsorCircle Investments GmbH is a limited  liability company registered in Germany with registered number HRB 95421 with registered office at Richard-Strauss-Allee 5, 60598 Frankfurt am Main, Germany.

Lawful basis for processing

Where we act as Data Controller, we rely on the following legal basis for processing your Personal Data:
– Consent: if you are a recipient of our online direct marketing;
– Legitimate interests: if  you  are  our  client  or  prospect  client,  business  affiliate, employee or potential employee, or our website visitor;
– Soft  opt‐in  exception: when  consent  is  not  required  and  the  Firm  gives  the opportunity to opt-out;
– Performance of contract: if you are our client, supplier, employee, akin to employee or business affiliate or our website visitor;
– Legal obligation: if we process Personal Data according to requirements of domestic legislation.
Where we act as Data Processor, we process Personal Data on behalf of Data Controllers and we act on their instructions.

Data protection officer

The Firm has no regulatory obligations under the GDPR to appoint a data protection officer (DPO); the Firm has no DPO currently appointed. It has, however, named a Responsible Officer who may be reached at info@sponsor-circle.com.

Source, purpose, handling, retention and protection of data collected

The Firm controls and processes Personal Data when using a client relationship management software which includes the handling of investment-related information (for the entire life-span of an investment).
– Source: The Firm collects information about clients, prospects and other business contacts like stakeholders and industry participants from existing contacts, industry events, etc.
– Personal Data: Names, professional mailing addresses, professional telephone numbers, notes, emails (“Contacts”). The Firm does not intend to intentionally collect or process any Sensitive Data into its Client Relationship Management (CRM) tool.
– Purpose: a) processing and managing your use of our services; b) responding to your questions, comments, complaints, or requests; c) Following up with you on a job application; d) creating and delivering personalized communications that are relevant to your preferences; e) carrying out, in appropriate cases, KYC checks and  other procedures that we undertake prior to you becoming a client of ours; and f) other business purposes, such as performing data analysis, audits, fraud monitoring, and prevention.
– Handling: Your data is stored using cloud based applications such as dropbox and Triple8 (both hosts domiciled in the United States). The client relationship management software was programmed on the basis of FileMaker, an Apple subsidiary.
– Retention: We retain your personal data only for as long as is necessary for our relationship with you, in accordance with our retention policies, and in accordance with applicable laws. We do not collect more personal data than we need to fulfil our purposes stated in this privacy policy, and we will not retain it for longer than is necessary.
– Protection: We have implemented security policies and technical measures to protect the personal data that we collect, consistent with applicable privacy and security laws. These security measures are designed to prevent unauthorized access, improper use or disclosure, unauthorized modification, and unlawful destruction or accidental loss of your personal data.

Special Categories of data (if applicable)

Owing to the products and services that we offer, such as the performance of KYC and other background  checks, we sometimes need to process special categories of  data which are deemed to be more confidential in nature. Where we collect such information, we will only request and process the  minimum necessary  for  the  specified purpose and identify a compliant legal basis for doing so.

Legitimate Interests (if applicable)

We occasionally process your personal information under the Legitimate Interests’  legal basis (e.g. personal phone number, personal electronic address). Where this is the case, we have carried out a Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own and that such interests are proportionate and appropriate such as for the purposes of doing business together.

Who we share our information with

We will not share personal information about you with third parties without your consent. We are required, by law, to sometimes pass on some of this Personal Data to:
– Law enforcement agencies; financial regulators and other relevant regulatory authorities; government bodies; tax authorities; courts tribunals and complaints/dispute resolution bodies;
– Other bodies as required by law or regulation; or
– Related  financial  institutions  such  as  trustees,  custodians  and  sub-­custodians; insurers; fraud protection agencies; and/or similar suppliers or service providers.
To fulfil our contract with you, the Firm may sometimes pass information to:
– IT services including client relationship management platforms; and
– Intra-group to related affiliates also working on providing you with related services.

International transfers outside the EEA

The Firm does not transfer your personal information outside of the European Economic Area (EEA) unless the transfer is necessary for one of the reasons set out in the GDPR including the performance of a contract between the Firm and the Data Subject, reasons of public interest, to establish, exercise or defend legal claims or to protect the vital interests of the Data Subject where the Data Subject is physically or legally incapable of giving consent and, in some limited cases, for our legitimate interest. In these cases, we will follow the GDPR Guidelines in  protecting the transfer of data to countries outside the EEA to ensure that the level of data protection afforded to individuals by the GDPR is not undermined.

Your rights and your Personal Data

If you are an EU citizen and reside in the EU, or are non-EU national residing in the EU, you may have the following rights with respect to the Personal Data you provide to us, to the extent permitted by applicable data protection laws:
– To withdraw any consent that you have provided to us to process your personal data;
– To access or rectify your personal data;
– To have your Personal Data erased if it is no longer necessary for the purposes for which it was processed, you have withdrawn your consent to, or object to, its processing and there is no other legitimate grounds for processing it or you consider it has been unlawfully processed;
– To have the processing of your Personal Data restricted if you contest its accuracy, its processing is unlawful, we no longer need it but you need it for a legal claim, or you have objected to its processing and await verification of our legitimate grounds for processing it;
– To have your Personal Data transferred to another company under certain circumstances; and
– To complain to your national data protection regulator if you feel that your personal data has been unlawfully processed.

Cookies, analytics, traffic data

“Cookies” are small pieces of information that are stored by your browser on your computer’s hard-drive for record-keeping purposes. We may use cookies on our website for the following reasons:
– Enhanced website functionality: for instance to provide account log-in prompts and to record preferences that you input on areas of the website so that you do not have to keep re-entering information; and
– Analysis: to receive web analytics from third-party vendors. These third parties use cookies to help analyse how users use the website. The information generated by the cookie about your use of the website (including your IP address) will be transferred to and stored by third-party vendors on servers located worldwide. These vendors will use this information for the purposes of analysing your use of the website, creating reports on the website activity, and providing other services relating to the website activity. These vendors may also transfer this information to other third parties where required to do so by law, or where such third parties process the information on the vendor’s behalf. However, we do currently not receive such information and WordPress (website software) does not collect any analytics data by default.
You can refuse the use of cookies by selecting the appropriate settings on your browser.