At Ufounders we are especially committed to protecting the privacy and confidentiality of the personal data of entrepreneurs, advisors, investors, or other people who maintain or intend to establish a link with us, in accordance with EU Regulation 2016/679 of the European Parliament. and of the Council of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data (RGPD); and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPDGDD).

This statement establishes our privacy and data protection policy with respect to the information we process, in order to guarantee, among other things, that (i) at any time, you may request the cancellation of your personal data, as well as exercise any of the the rights that correspond to you in accordance with the applicable regulations; (ii) we will comply with the obligation of secrecy and confidentiality of the personal data collected, and that we will not communicate them to third parties without your consent; (iii) we have adopted the necessary technical and organizational measures, taking into account the state of the art, the costs of application, and the nature, scope, context and purposes of the treatment, as well as risks of variable probability and severity for the rights and freedoms of natural persons, to guarantee a level of security appropriate to the risk detected, and ensure the pseudonymization and encryption of personal data as well as the ability to guarantee the confidentiality, integrity, availability and permanent resilience of systems and services of treatment.

The personal data processed will be hosted on secure servers. Ufounders will not have access to said information beyond what is necessary to ensure the execution of the services and the rest of the purposes detailed here, as well as to ensure the integrity, confidentiality and availability of the data hosted.

Only natural persons over 18 years of age with full legal capacity to act, acting on their own behalf or on behalf and on behalf of legal persons, may register with Ufounders. Ufounders reserves the right to check the age of the entrepreneurs, advisors or investors at any time, and may proceed to remove them if it is confirmed that they are minors. Likewise, in the event that a user selects a username or identifier similar to another for their account, Ufounders reserves the right to eliminate or claim it if it deems appropriate.

We recommend that you read this Privacy Policy carefully, as well as that you visit it regularly, to be aware of the latest version published.

BASIC INFORMATION ON DATA PROTECTION

Responsible for Treatment

UFOUNDERS MANAGEMENT, S.L.

N.I.F.: B-88502463, sociedad inscrita en el Registro Mercantil de Madrid, Tomo 33.937, Folio 148, Sección 8ª, Hoja M-610752.

Address: C/ de Prim, 19, 28004, Madrid, España

Treatment Purposes

- Manage the contracting of the UFO Entrepreneurs Program, as well as the development, maintenance and control of the contractual relationship and, where appropriate, the management of startup investment rounds.

- Manage the contracting of the UFO Advisors Program, as well as the development, maintenance and control of the contractual relationship derived from access to the private Advisors network.

- Manage the contracting of the UFO Investors Program, as well as the development, maintenance and control of the contractual relationship derived from access to the investment platform.

- Conducting interviews, validating skills and subsequent registration in the Ufounders Training Programs for Entrepreneurs, Advisors and Investors.

- Manage the participation of investors in investment rounds of Ufounders startups.

- Respond to queries made through our contact channels.

- Send commercial, advertising and marketing information about our services.

- Properly manage our business.

- Manage our official profiles on social networks.

- Management of personnel selection processes.

- Exploitation of the image rights of entrepreneurial advisors and investors.

- Compliance with applicable legal obligations.

Legitimation

The legal basis for the processing of your personal data will depend on the aforementioned purposes, which may be (i) your consent; (ii) the execution and maintenance of the commercial relationship derived from the contracting of our services; (iii) compliance with our legal obligations; (iv) or, in some cases, our legitimate interest.

Recipients

Personal data may be shared between entrepreneurs, advisors and investors to guarantee the execution of the contracted services, or to give effect to the purpose for which they were collected. Likewise, our service providers may have access to your personal data, but they will treat it on our behalf and name, and always following our instructions. Likewise, we inform you that your personal data may be transferred to the Public Administrations, the State Security Forces and Bodies, Judges and Courts, in compliance with our legal obligations.

Rights

You can freely exercise your rights of access, rectification or deletion, limitation of treatment, opposition, portability, or withdraw your consent, by sending your request in writing to our postal address, or by sending an email to [email protected]

ADDITIONAL INFORMATION ON DATA PROTECTION

Table of Contents:

• Responsible for Treatment

• Origin of the data we obtain

• Type of data we process

• Purpose of the treatments and basis of legitimacy

• Recipients

• Data retention

• Exercise of rights by the owner

• Claims before the Data Protection Authority

1. Responsible for Treatment

The entity responsible for processing your personal data is UFOUNDERS MANAGEMENT, S.L., NIF B-88502463 (hereinafter, “Ufounders”), entity domiciled at C/ de Prim, 19, 28004, Madrid, Spain. Registered in the Mercantile Registry of Madrid, Volume 33,937, Folio 148, Section 8, Sheet M-610752.

2. Origin of the data we obtain

We can collect your personal data because you have provided it to us directly (through one of the communication channels that we make available to you), in order to request information, make a query, request the hiring of any of our services, participate in our events, contests or surveys, interact in any of our official social networks, or any other operation or transaction that we carry out with you during the execution of the services. We may also automatically collect technical or behavioral data through your browsing on this website or that of third parties, by installing cookies or other tracking technologies or devices, as detailed in the Cookies Policy.

The personal data provided must be correct, complete, exact and duly updated. If the entrepreneur, advisor or investor does not provide the data requested by Ufounders during the registration process, we may not be able to process the request and execute the service.

3. Type of data we process

We may process your (i) identification data, such as your name and surnames or the number of your identification document; (ii) contact, such as email, or telephone; (iii) economic and financial; (iv) academic and professional experience; (v) employment; (vi) images and photographs.

Keep in mind that, in the event that you act on behalf of a company or startup, we can legitimately process your contact data and your function or position held in the entity you represent, when the processing refers only to the necessary data. for their professional location and in order to maintain relations with it. The same circumstances apply to the processing of data relating to individual entrepreneurs.

4. Purposes of treatment and basis of legitimacy

Your personal data will only be obtained by Ufounders for its treatment, when they are adequate, pertinent and not excessive in relation to the scope and the specific explicit and legitimate purposes for which they have been collected.

For this purpose, we will treat your personal data for the fulfillment of the following purposes:

(i) Manage the contracting of the UFO Entrepreneurs Program, as well as the development, maintenance and control of the contractual relationship and, where appropriate, the management of startup investment rounds.

To process the hiring by the entrepreneur of our UFO Entrepreneurs Program, manage the student’s profile and their file, guarantee access to the personal area of ​​the course, and carry out all the phases of the training program and provide all the services that form part of it, we must have access to your personal data. If you do not provide us with the requested data, we may not be able to process your participation in the Program.

The basis of legitimation of this purpose will be the administration, management and execution of the contractual relationship derived from the contracting of the UFO Entrepreneurs Program.

(ii) Manage the contracting of the UFO Advisors Program, as well as the development, maintenance and control of the contractual relationship derived from access to the private advisors network

We must process personal data of professionals interested in participating in the UFO Advisors Program, to manage their hiring, manage their student profile and file, guarantee access to the personal area of ​​the course and the Ufounders startup portfolio and their inclusion in the Private network of Advisors to which entrepreneurs have access. For this purpose, the basis of legitimacy will be the administration, management and execution of the contractual relationship derived from the registration in the UFO Advisors Program, and the management of the private community of advisors.

(iii) Manage the contracting of the UFO Investors Program, as well as the development, maintenance and control of the contractual relationship derived from access to the investment platform

We must process personal data of professionals interested in participating in the UFO Investors Program, to manage their recruitment, manage their student profile and file, and guarantee access to the personal area of ​​the course and provide all the services that are part of the program. For this purpose, the basis of legitimation will be the administration, management and execution of the contractual relationship derived from the registration in the UFO Investors Program, and the management of access to the investment platform.

Likewise, the data of investors may be processed to facilitate registration and access to the Ufounders investment platform where investment opportunities of the entrepreneurial ecosystem are offered. All investors who take part in the UFO Investors Program have a preferential time period to access Ufounders startup investment opportunities.

(iv) Conducting interviews, validation of skills and subsequent enrollment in the Training Programs for Entrepreneurs, Advisors and Investors.

To process the registration of entrepreneurs, advisors and investors, we will need to conduct interviews and obtain a series of information and data of interest that will allow us to validate the suitability of each of them. For this purpose, the basis of legitimacy will be the administration, management and execution of the contractual relationship derived from the registration as entrepreneurs, advisors and investors in the Ufounders Programs.

(v) Manage the participation of investors in investment rounds of Ufounders startups.

We must manage the participation of those interested in being part of the private investor network of Ufounders. For this purpose, the basis of legitimation will be the administration, management and execution of the contractual relationship derived from the registration in said network of investors.

(vi) Respond to queries made through our contact channels.

We will be able to attend to all your queries, suggestions and doubts, which you can send us through any of our contact channels. The basis of legitimacy, in this case, will be our legitimate interest to meet your query request.

(vii) Send commercial, advertising and marketing information about our services

With your express consent, we may send you communications for commercial, advertising and marketing purposes, so that you may receive information about our services for entrepreneurs, advisors and investors through electronic means (email, instant messaging or telephone call), or about events or news related to entrepreneurs, startups and investment, which may be of interest to you.

Likewise, we inform you that, based on our legitimate interest, we may carry out these advertising activities through automated processing of personal data based on your needs, your contracted services, your behavior, preferences and interests, which we may elaborate through from our own internal sources, as well as from third parties, as well as from browsing and/or Internet data. However, no automated decisions will be made based on this profiling that produce legal effects or significantly affect you.

Likewise, based on our legitimate interest, we may also send you communications for commercial purposes, about services similar to those you have already contracted with us.

At any time, you have the right to oppose these treatments, including profiling, as well as to revoke your consent.

(viii) Properly manage our business.

We may process your data to properly manage our services, as well as maintain the security of the website, prevent fraud, perform internal statistics, risk analysis, market research or business development projects, as well as prepare business reports, improve quality of our services and user experience, as well as evaluating the effectiveness of advertising campaigns. The basis of legitimacy of these treatments is our legitimate interest.

(ix) Manage our official profiles on social networks.

We are present on the following social networks: Facebook, Youtube, Instagram, and LinkedIn. The treatment of your data and the conditions of use, in case of subscribing as a follower in any of our official channels on social networks, will be governed, apart from this Privacy Policy, by those general terms and other regulations of access, use , privacy and the like that belong to the corresponding social network. For your part, you may publish comments, links, images or photographs, or any other type of content supported on social networks, provided that it belongs to you or for which you have authorization from third parties. Please note that your posts may be known to other social media users.

Once you register as a follower, we will process your data for the purpose of correctly managing your presence in each of them, accessing the public information of your profile, answering your questions, informing you of our services, providing you with information about the startups that are part of of Ufounders, carry out promotions or contests, show you relevant news from the entrepreneurship and investment sector, as well as for any other similar purpose in accordance with the terms indicated.

(x) Management of personnel selection processes

We may process your data in case you want to participate in an active personnel selection process at Ufounders, as well as to evaluate your participation in future selection processes that fit your professional profile. The candidate agrees to provide up-to-date, accurate and truthful information, as well as to report any inaccurate or incomplete information about their professional profile.

We can obtain your data directly from you or from third parties that collaborate with us in the search for candidates (external portals or employment consultancies) and who give us the data so that we can assess your candidacy and, eventually, consider hiring you.

The legal basis for the processing of your data is based on the consent granted when you voluntarily register for our job offers.

(xi) Exploitation of the image rights of entrepreneurs, advisors and investors

In order to promote the services of Ufounders, we may process the image of advisors and entrepreneurs for its reproduction, distribution, disclosure and public dissemination on our social networks and/or websites owned by us.

The legal basis for the treatment of the image will be the consent granted by the transferor.

(xii) Compliance with applicable legal obligations.

In order to comply with our legal obligations, Ufounders must carry out certain processing of your personal data by legal imperative.

5. Recipients

When we communicate your data to other recipients, we undertake to ensure that they have the appropriate technical and organizational measures in place to guarantee the confidentiality and security of the transferred data.

Ufounders will not transfer your data to third parties without your consent, except in the following cases:

1. a) In order to give effect to the UFO Entrepreneurs Program, the UFO Advisors Program, the UFO Investors Program, or the inclusion of investors in the private investment network, Ufounders, depending on the nature of the service and the purpose for which they were collected, you must share personal data with entrepreneurs, mentors and investors. For example, the personal data of the entrepreneurs may be shared with the advisors in the training programs, as well as that of the entrepreneurs with the investors in the case of wanting to raise a round of financing.
2. b) Where appropriate, entrepreneurs who wish to have access to exclusive advantages and Perks must, in some cases, consent to the transfer of their data for the provision of services by third parties.
3. c) In order to comply with our legal obligations, we may communicate your data to the Public Administrations, to the State Security Forces and Bodies, or to Judges and Courts.
4. d) In the event that the User chooses to contract the Training Programs in the deferred payment method, Ufounders must share certain personal data with the company Payin7 or Instant Credit, which will be the new entity responsible for the treatment. You can consult the general conditions of contracting the loan, as well as its personal data processing policy through the following link.
5. e) Certain third parties that provide services to us may have access to your personal data, such as online payment service providers. (Paycomet and Stripe)Said treatment will be regulated by a written contract that will bind the provider to us, expressly establishing that it will only treat the data in accordance with the instructions that we have given it, committing to keep confidentiality and adopt the appropriate security measures when treating your personal data.

1. f) In case of having the authorization for the exploitation of image rights of advisors, investors or entrepreneurs, their images or videos may be shared on our social networks.

In some situations, in order to make the requested services effective, your personal data may be shared with entrepreneurs, advisors and investors outside your country or the European Economic Area (EEA), both by recipients declared of an adequate level by the European Commission, as by those others where a level of protection comparable to that of the EEA is not provided, such as in the United States. In this case, all the transfers that we can carry out will be legitimate and will be governed by standard contractual clauses of the European Commission for providers established outside the European Union, in addition to the fact that we will choose appropriate providers in accordance with the recommendations issued by the European Committee for Data Protection, in order to ensure that your data is adequately protected.

6. Data retention

By virtue of the principle of limitation of the retention period, we will keep your personal data for the time strictly necessary to provide the contracted services or facilitate your registration as a mentor or investor, and as long as you do not request its deletion or revoke, where appropriate, your consent given. , as well as the time necessary to comply with the legal obligations and possible responsibilities that may arise, and that, in each case, correspond according to each category of data.

We may keep your personal data even after you have ceased to be a member of Ufounders or have requested their deletion, for the attention of the possible responsibilities arising from the treatment during the limitation period of these, but we will keep them duly blocked, with access restricted, and will only be available to the Public Administrations, Judges and Courts, and for the demand of possible responsibilities derived from the treatment and only for the limitation period of the same.

In the case of the processing of professional and academic data for participation in selection processes, these will be kept for a period of two years, to be computed from the day of their last update, unless you notify us otherwise.

In cases where we automatically obtain data through cookies, you can limit their use over time by removing them from browsers or devices. You can consult more information in the Cookies Policy.

7. Exercise of rights by the owner

We inform you that you have the right, free of charge and to the extent that the legal requirements are met, to exercise the following rights:

Right of access: You have the right to obtain information about the personal data that concerns you that we are treating or not, and in such case, access them. If you request it, we will provide you with a copy of the personal data that we are processing.

Right of rectification: You have the right to rectify your personal data that is or inaccurate, or to have incomplete data completed.

Right of deletion: You may request the deletion of your data when, among other circumstances, they are no longer necessary for the purposes for which they were collected or otherwise processed.

Right to limitation of treatment: You have the right to limit the treatment of your data, in certain circumstances established by the data protection regulations.

Right to data portability: You have the right to receive your personal data in a structured, commonly used and machine-readable format, and to transmit it to another entity.

Right of opposition: In certain situations, you may oppose a certain treatment for reasons related to your particular situation, including profiling. You may object to the processing of your personal data for direct marketing purposes at any time.

Right to revoke your consent: At any time, you may withdraw the consent you have given us for any treatment, although said withdrawal will not affect the legality of the treatment based on the consent that was previously provided.

To exercise these rights, you may write to the address C/ de Prim, 19, 28004, Madrid, Spain; or via email to [email protected].

8. Claims before the Data Protection Authority

You are informed that you can direct your claims arising from the processing of your personal data to the Spanish Agency for Data Protection (www.aepd.es).

This data protection policy was last modified on 09/09/2021