1. Who we are
Seedblink S.A, a joint-stock company registered with the Trade Registry under number J40/722/2020, with the unique registration code 42141358,with its legal office at 4B and 2-4 George Constantinescu street, Building A, rooms601, 602 and 603, floor 6, 2nd District, Bucharest, Romania(“Seedblink”, “us”, “we”, “our”, or “ours”), acting as personal data controller, is committed to protecting and respecting your confidentiality. This document (“Privacy Notice”) is designed to present to you our practices regarding the collection, use, and disclosure of the information which you can provide through the use of the services available on the platform www.nimity.com (the “Platform”).
We collect personal data from and about you via the Platform, or, where appropriate, through other types of interactions which we have with you.
This Privacy Notice (along with our Terms and Conditions and any other documents referenced within them) represents the basis on which any personal data collected from you, or which you provide to us, will be processed by us. We ask you to read the following information carefully to understand our points of view and practices regarding your personal data and the way it is treated.
2. What kind of information do we collect from you, and for what period?
We can collect and process the following personal data about you:
2.1 Information which you provide to us
You can give us information, including information which can identify you (“Personal data”) when you use our Platform and services, when you participate in any of our contests, promotions or surveys, when you speak to us by phone, e-mail, or otherwise, as well as when you report a problem with our Platform.
Information which you may provide includes:
2.1.1 Information necessary to create a user account on our Platform: First name, last name, email address, date of birth, address of residence;
2.1.2 Information necessary for equity and SOP management – in addition to the information from clause 2.1.1: number of securities held, value of securities held, initial invested amount, additional information including information which may be found in documents uploaded on the platform (e.g., securities-related rights, vesting period, strike price, event triggers, etc.);
Nimity may not be able to provide the services offered by our Platform if the necessary information is not provided;
2.2 Information collected by third parties and provided to us (such us companies providing stakeholder data)
2.2.1 Same information as in clauses 2.1.1 and 2.1.2 above.
2.3 Information which we collect automatically
2.3.1 With regards to each of your visits on our Platform, we can collect, according to the applicable laws and, when it is necessary, with your permission, information about the devices which you use and the networks to which you are connected when you use our services. This can include the following information: the user’s address, login information, operating system and platform, location data, details of your visit on the Platform, usage and website interaction and advertising identifier. Furthermore, we process the history of your equity/SOP-related transactions.
2.4 Data retention
2.4.1 We keep your data only while it is necessary for the purposes presented in this Privacy Notice.
3. How do we use the information which we collect from you?
We will use the information we collect: PURPOSE and LEGAL BASIS
3.1 to conclude our terms of service with you and to fulfill our obligations arising from any contract concluded between you and us, as well as to provide the information and services which you seek (equity and SOP management); This processing is necessary to fulfill our mutual contractual obligations (art. 6 par. 1 let. b GDPR).
3.2 to send you information by email and/or any other communication method (related to the provided services), as well as to notify you of changes regarding our services; This processing is necessary to fulfill our mutual contractual obligations (art. 6 par. 1 let. b GDPR).
3.3 to send you information by email and/or any other communication method in respect to other services provided by us (such as opportunities to invest in startups or to seek investments in your startup), or other similar marketing materials; This processing is based exclusively on your explicit consent via the Platform (art. 6 par. 1 let. a GDPR)
3.4 to protect our rights resulting from terms of service concluded between you and us; This processing is based on our legitimate interest and is necessary for the determination, exercise, or protection of rights (art.6 par. 1 let. f GDPR)
3.5 to manage our Platform, to provide our services (even if you don’t have an user account) and for internal operations, including troubleshooting, data analysis, testing, research, and analytical and survey purposes; manage our Platform, to provide our services (even if you don’t have an user account) and for internal operations, including troubleshooting, data analysis, testing, research, and analytical and survey purposes; This processing is based on our legitimate interest (for example equity/SOP management services provided to the companies where you are a stakeholder, the improvement of the Platform’s functions, etc.)(art. 6 par. 1 let. f GDPR).
3.6 to improve our Platform so that we can make sure that the content is presented in the most efficient way for you and your device; This processing is based on our legitimate interest (for example the provision of significant content for you) (art. 6 par.1 let. f GDPR)
3.7 as part of our efforts to maintain the safety and security of the Platform; This processing is based on our legitimate interest (the assurance of the Platform’s security) (art. 6 par. 1 let. f GDPR)
Nimity, will never process your personal data for the purpose of big data analysis or in any other manner than what is extensively described in the present Privacy Notice.
Not least, Nimity will never send marketing communications to you unless you expressly choose to receive such communications by means of the opt-in mechanism found in the “User settings” section on the Platform.
4. Who are the beneficiaries of the information we collect from you, and to what end?
4.1 Your personal data is disclosed via the Platform to all other existing stakeholders in the concerned company/group of companies (who have a user account on the Platform and who have been given access to such information by the relevant company representative), by minimizing the disclosed personal data to what is strictly necessary for the purpose of the services (i.e., equity and SOP management).
4.2 In addition, we work closely with third parties who may have access to your personal data (after applying the minimization principle), such as:, such as:
· Our partners who offer the service of sending marketing materials, in case you opt to receive such materials
· Our partners who offer electronic document signing services (for example, DocuSign);
4.4 We do not disclose any of the information which you provide, including your personal data, to any third party, with the following exceptions:
· Nimity may disclose your information if it is required by law or if, in good faith, it considers that such access or disclosure is reasonably necessary to (i) respond to a complaint against Nimity, (ii) to comply with legal procedures, (iii) to implement any agreement with our users, such as our Terms and Conditions, as well as the Privacy Notice, (iv) in an investigation or (v) to protect the rights of Nimity, our partners, or other parties;
· If we sell a business or assets, we may disclose your personal data to the possible buyer or seller of such a business or asset; and
· If Nimity is acquired, in part or in full, by a third party, the personal data held by Nimity of its users will represent one of the assets transferred.
5. Targeted announcements on social media platforms and our electronic communications
In accordance with the legislation in force and with your permission, we may use the information which you give us on our Platform for direct electronic marketing (for example (i) sending our informative bulletins, invitations to events organized by us, or other communications that we consider of interest for you or (ii) showing you targeted advertisements on social media platforms.
For electronic marketing communications (newsletters): You can withdraw your consent at any time by(i) unchecking the appropriate box in your member account, (ii) clicking on the unsubscribe button available in every Nimity communication or (iii)contacting us on the basis of the contact details provided in section 10 further down.
6. Is your information transferred? How and where?
In principle, we keep your personal data in the European Union (“EU”). In case your personal data must be transferred to countries outside of the EU for the purposes set out in this Privacy Notice, we always make sure that the transfer is made in accordance with the applicable laws and that there are adequate guarantees (especially standard contractual clauses, as they have been issued by the European Commission) to guarantee a sufficient level of protection for the private lives and fundamental rights of individuals.
By sending a request towards the person responsible for data protection (dpo@nimity.com), we can provide you with details concerning these adequate guarantees (for example, the standard contractual clauses issued by the European Commission).
7. What are your rights regarding your personal data?
7.1 You have the right to receive a copy of the personal data in our possession (your right of access to data).
7.2 You can request the erasing of your personal data or the correction of inaccurate personal data (your right of erasing and rectification). We remind you that we may keep certain information that concerns you, as the law provides or when we have a legal basis for proceeding as such.
7.3 You have the right to oppose, at anytime, (i) the processing of your personal data with the purpose of direct marketing, or (ii) the processing of your personal data with reasons tied to your specific situation or with other purposes (your right to oppose processing). We remind you that in this latter case, the right is applicable only if the processing of your personal data is based on our legitimate interest.
7.4 You have the right to limit the processing of your personal data (your right to limit processing). We remind you that this only applies if (i) you have contested the accuracy of your personal data, and we are verifying the accuracy of your personal data, (ii) you have exercised your right of opposition, but we are still analyzing, as provided by the applicable laws, if our legitimate reasons for processing your personal data in this case overrides your interests, rights, and freedoms; or (iii) your personal data have been processed illegally, but you oppose the erasing of your personal data, or you wish for us to keep your personal data to formulate, exercise, or protect you against a legal action.
7.5 You have the right to receive, and/or for us to transfer to another data controller, a part of the personal information which concerns you and which you provided to us, which we process with the purpose of executing our contract, or because you consented before hand to this, in a commonly used and electronically readable structured format (your right to portability of data).
7.6 You have the right to withdraw your consent at any time, without the legality of the processing performed based on your consent before this withdrawal being affected (your right to withdraw consent).
7.7 To exercise your rights, we ask you to contact the person responsible for data protection (dpo@nimity.com).
7.8 You also have the right to make a complaint to the relevant data protection authority or to find a solution through the courts if you feel that your rights have been violated.
8. The confidentiality of your password
The moment you must choose a password to gain access to our Platform, you are responsible to keep this password secret. We ask you to not share this password with anyone. Nimity will never ask you for your password.
9. Amendment of the Privacy Notice
Any amendment which we may make in the future in the Privacy Notice will be posted on this page and we will notify you in this respect.
10. Contact
If you wish, at any time, to contact us, with your points of view about our confidentiality practices or any request concerning your personal data, we ask you to contact us by e-mail at the address: dpo@nimity.com, or by mail at the address mentioned at point 1.
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