START-UP NATION CENTRAL PRIVACY POLICY (GDPR)
Last Updated: November 2019
This privacy policy (“Privacy Policy”) governs how we, Start-Up Nation Central Ltd. (CC) (“Start-Up Nation Central”, "SNC", or “we”, “our” or “us”) use, collect andstore information pertaining to you (“User”, “you”) such as in the following use cases:(i)(ii)(iii)(iv)

When you visit and make use of our website https://www.startupnationcentral.org/ and https://finder.startupnationcentral.org/
subdomains(“Website(s)”);When you register or sign up on our Website;
When you contact us or fill in any other form on our Website (including when you request a visit with SNC); or
When you request introductions through Finder.

and all its

Please note that some of these use cases only apply to certain subdomains of our Website.
We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy
Policy carefully, so you can fully understand our practices in relation to Personal Data. “Personal Data” means any information that can be used, alone or together with otherdata, to uniquely identify any living human being.
Table of contents:
••••
•
••

What information we collect, why we collect it, and how it is used
How we protect and store your personal data
How we share your personal data
Additional information regarding transfers of personal dataYour rights
Use by children
How to contact us

This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below. Ifthere will be any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a noticeon our Website or by other means.
1.

WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Data we collect

Why is the data collected
and for what purposes?

When you visit and make use of our Website
To:• IP address• create reports on the• Referral URLs
innovation industry• improve our products,
including the usabilityof our Website

Legal basis (GDPR only)

Third parties withwhom we share yourpersonal data

PeriodstorageofConsequences of
not providing thedata

Legitimate interest (i.e. toprovide relevant information tovisitors and improve ourWebsite)•

Thirdparty
applications (suchasGoogle
Analytics,
Intercom,Fullstory,
Marketo).

For as long as
wehave
alegitimate
business needfor using theinformation.

No consequences.
However,
pleasenote that you may
not receive content
suggestions.

•

Hosting companies(such as Google)•

SNC's consultants(such as for R&D
purposes, digitalmarketingpurposes and SEO
purposes).

•Thirdparty
applications (suchasGoogle
Analytics,Intercom,Fullstory,Marketo).

Untilyouwithdraw
consent(orunsubscribe) or
we proactively
delete the data.

We cannot sendyou, and you cannot
receive,
Informational
Emails. We cannot
identify potential
partners.

•Hosting companies(such as Google)•SNC's consultants(such as for R&D
purposes, digitalmarketingpurposes and SEO
purposes).

Cookies
When you register or sign up on our Website
To:• First name• Sendinformational• Last nameemails (i.e. future• Gender
informational, event• Email address
related or other Site• Additional Email address
related emails from• Positionus, which may include• Company Nameevents or information• Phone Number
from third parties• LinkedIn details(“Informational• Headline (taken from LinkedIn)Emails”)).
• Google Details• Identify
potential• Picture (taken from LinkedIn andpartners
Google• Total time on the Website• Average session length• Average events per session• Location (City, State/Region,Country, IP address)• Device type
• Browser• Operating System• Referral URLs
• User journey• Any other data you decide toprovide•••

Consent (even if you agree
to receive InformationalEmails, you always havethe option to opt-out fromreceiving
such
Informational Emails byselecting an unsubscribe
link at the bottom of eachemail that is sent
Processing is necessary inorder to take steps at therequest of the data subject
prior to entering into acontract.
Legitimate interest (such asidentifying
potential
partners or contacting you
after you have shown
interest in a company or afield)

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When you contact us or fill in any other form on our Website (including requests for visits with SNC)
••
•
•
•
•
•

First nameLast name
Email address and contact details
Organization nameJob title
Country
Information related to yourcompany or institution
Any other data you decide toprovide in the context of yourquery•To:• respond
toyourquestion or query• Organize a visit to theextent appropriate• B2B
marketingpurposes•Legitimate interest (e.g. torespondtoyourquery/request)•Regarding B2B marketing,
we rely on Recital 47 of theGDPRandlegitimate
interest. In this situation, weoffer
anunsubscribe
capability.

•Thirdparty
applications (suchasGoogle
Analytics,Intercom,Fullstory,Marketo).

•

Hosting companies(such as Google)•SNC's consultants(such as for R&D
purposes, digitalmarketingpurposes and SEO
purposes).

•

Hosting companies(such as Google)•Companies
that
you have approved

Depending on
the context, we
keep it until you
requestyourdata
tobedeleted or we
proactivelydelete the data.

We cannot respondto your query orrequest.
We cannot consider
you for a visit withSNC.
We cannot send you
marketingcommunications.

When you request an introduction through Finder•
•••••

Name
Email address
Contact details
Message
Attachments
Information you provide inconnection with the introduction
requestIf you are sending information
about third parties you represent
and warrant that you have all
required consents and the right tosend the information•2.

To make introductions tocompanies that you haveapproved•

Legitimate interest (e.g. toprocess your request)

Depending on
the context, we
keep it until you
requestyourdata
tobedeleted or we
proactively
delete the data.

Cannotprocess
your introduction
requestHOW WE PROTECT AND STORE YOUR INFORMATIONI. Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or theunauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that theinformation will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection andsecurity of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security ofthe computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate
measures to protect this information.

II. Retention of your Personal Data. In addition to the retention periods mentioned in Section 1 above, in some circumstances we may store your Personal Data for longer
periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate
record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Dataor dealings.
3.

HOW WE SHARE YOUR PERSONAL INFORMATION
In addition to the recipients described in Section 1, we may share your information as follows:

4.

5.

•To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental
agencies or if required to do so by court order;•If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or
actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or acomparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events;•

Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services orfunctionality);•With related parties to advance the mission of SNC.

ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION•With respect to the access from Israel, please note that Israel was declared as a country offering adequate level of data protection by the European Commission. Please
read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en;•Where we transfer your Personal Data outside of the EU/EEA, for example to third parties who help provide our products and services, we will obtain contractual
commitments from them to protect your Personal Data. Some of these assurances are well recognized certification schemes like the EU - US Privacy Shield for theprotection of Personal Data transferred from within the EU to the United States;•Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

YOUR RIGHTS
The following rights (which may be subject to certain exemptions or derogations), shall apply to individuals who are protected by the GDPR (as applicable):

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You have a right to access information held about you. Your right of access is normally be exercised free of charge, however we reserve the right to charge anappropriate administrative fee where permitted by applicable law;
You have the right to request that we amend any Personal Data we hold that it is inaccurate or misleading;You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain yourdata, for example for the establishment, exercise or defense of legal claims;
The right to object to or to request restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
The right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, andthat you have the right to transmit that data to another controller;
You have the right to object to profiling;
You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of allegedinfringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority;
The right to withdraw your consent. Please note that t there may be circumstances in which we are entitled to continue processing your data, in particular if theprocessing is required to meet our legal and regulatory obligations;
You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that datatransfer agreements may need to be partially redacted for reasons of commercial confidentiality.
You can exercise your rights by contacting us at finder@sncentral.org. Subject to legal and other permissible considerations, we will make every reasonable effort tohonor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional
information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted
by law, for instance if your request is manifestly unfounded or excessive.
In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if weare legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance withapplicable law.

6.

USE BY CHILDREN
We do not offer our products or services for use by children. We do not knowingly collect information from, and/or about children.

7.

CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage
you to first contact us at finder@sncentral.org.