Privacy Policy of fulgur.ventures/This Application collects some Personal Data from its Users.
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Owner and Data Controller
Fulgur Ventures, 919 North Market Street, Suite 950, Wilmington, DE 19801
Owner contact email: office@fulgur.ventures

Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there
are: full name; email address.
Complete details on each type of Personal Data collected are provided in the dedicated sections ofthis privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automaticallywhen using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide
this Data may make it impossible for this Application to provide its services. In cases where thisApplication specifically states that some Data is not mandatory, Users are free not to communicate
this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party
services used by this Application serves the purpose of providing the Service required by the User, inaddition to any other purposes described in the present document and in the Cookie Policy, ifavailable.
Users are responsible for any third-party Personal Data obtained, published or shared through thisApplication and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure,modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational
procedures and modes strictly related to the purposes indicated. In addition to the Owner, in somecases, the Data may be accessible to certain types of persons in charge, involved with the operationof this Application (administration, sales, marketing, legal, system administration) or external parties(such as third-party technical service providers, mail carriers, hosting providers, IT companies,

communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated
list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:●Users have given their consent for one or more specific purposes. Note: Under somelegislations the Owner may be allowed to process Personal Data until the User objectsto such processing (“opt-out”), without having to rely on consent or any other of thefollowing legal bases. This, however, does not apply, whenever the processing of
Personal Data is subject to European data protection law;●provision of Data is necessary for the performance of an agreement with the User and/or
for any pre-contractual obligations thereof;●

processing is necessary for compliance with a legal obligation to which the Owner issubject;●

processing is related to a task that is carried out in the public interest or in the exerciseof official authority vested in the Owner;●processing is necessary for the purposes of the legitimate interests pursued by theOwner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing,and in particular whether the provision of Personal Data is a statutory or contractual requirement, or arequirement necessary to enter into a contract.
PlaceThe Data is processed at the Owner's operating offices and in any other places where the parties
involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country
other than their own. To find out more about the place of processing of such transferred Data, Users
can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside theEuropean Union or to any international organization governed by public international law or set up by
two or more countries, such as the UN, and about the security measures taken by the Owner tosafeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of thisdocument or inquire with the Owner using the information provided in the contact section.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have beencollected for.

Therefore:●

Personal Data collected for purposes related to the performance of a contract between
the Owner and the User shall be retained until such contract has been fully performed.

●

Personal Data collected for the purposes of the Owner’s legitimate interests shall be
retained as long as needed to fulfill such purposes. Users may find specific information
regarding the legitimate interests pursued by the Owner within the relevant sections of
this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given
consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may
be obliged to retain Personal Data for a longer period whenever required to do so for the performanceof a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, theright to erasure, the right to rectification and the right to data portability cannot be enforced after
expiration of the retention period.

The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its
legal obligations, respond to enforcement requests, protect its rights and interests (or those of its
Users or third parties), detect any malicious or fraudulent activity, as well as the following: Connecting
Data.
For specific information about the Personal Data used for each purpose, the User may refer to thesection “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:●Connecting Data

The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:●Withdraw their consent at any time. Users have the right to withdraw consent where
they have previously given their consent to the processing of their Personal Data.

●Object to processing of their Data. Users have the right to object to the processing oftheir Data if the processing is carried out on a legal basis other than consent. Furtherdetails are provided in the dedicated section below.

●Access their Data. Users have the right to learn if Data is being processed by theOwner, obtain disclosure regarding certain aspects of the processing and obtain a copyof the Data undergoing processing.

●Verify and seek rectification. Users have the right to verify the accuracy of their Dataand ask for it to be updated or corrected.

●Restrict the processing of their Data. Users have the right, under certain
circumstances, to restrict the processing of their Data. In this case, the Owner will notprocess their Data for any purpose other than storing it.

●Have their Personal Data deleted or otherwise removed. Users have the right, undercertain circumstances, to obtain the erasure of their Data from the Owner.

●Receive their Data and have it transferred to another controller. Users have theright to receive their Data in a structured, commonly used and machine readable format
and, if technically feasible, to have it transmitted to another controller without any
hindrance. This provision is applicable provided that the Data is processed byautomated means and that the processing is based on the User's consent, on a contract
which the User is part of or on pre-contractual obligations thereof.

●Lodge a complaint. Users have the right to bring a claim before their competent dataprotection authority.

Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested
in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object
to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing
purposes, they can object to that processing at any time without providing any justification. To learn,
whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to therelevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details
provided in this document. These requests can be exercised free of charge and will be addressed by
the Owner as early as possible and always within one month.

Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages
leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon requestof public authorities.

Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User
with additional and contextual information concerning particular Services or the collection andprocessing of Personal Data upon request.
System logs and maintenanceFor operation and maintenance purposes, this Application and any third-party services may collectfiles that record interaction with this Application (System logs) use other Personal Data (such as theIP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from theOwner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handledThis Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please
read their privacy policies.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Userson this page and possibly within this Application and/or - as far as technically and legally feasible sending a notice to Users via any contact information available to the Owner. It is strongly
recommended to check this page often, referring to the date of the last modification listed at thebottom.
Should the changes affect processing activities performed on the basis of the User’s consent, theOwner shall collect new consent from the User, where required.