BlueCrow, for the services and activities to which it is dedicated, is subject to the duty to protect the personal data it collects and has access to in the exercise of its functions under the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data and which repeals Directive 95/46/EC (General Regulation on Data Protection) and Law n. 58/2019.
This Policy contains the rules applicable to the collection and processing of personal data by all companies belonging to BlueCrow, in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data (GDPR).
These rules do not replace any clauses that are subject to a specific agreement with any customer, partner or supplier. In that case, this Policy may supplement such documents, but does not replace them. The terms “holder” and “user” are used interchangeably in this Policy to designate the owner of personal data.
Scope of application
This Policy applies to any and all personal data received, and all employees of the Company are responsible for directing their activity towards strict compliance with the legal provisions in force, as well as the rules and procedures set forth in this document.
Guiding principles
BlueCrow in the processing of personal data guides its activity towards strict compliance with the following principles:
a) Principle of loyalty and transparency in relation to the data subject;
b) Principle of limiting the purposes of the use of personal data;
c) Principle of adequacy;
d) Principle of accuracy and updating;
e) Principle of the limit of conservation;
f) Principle of security
Who is responsible for processing your data?
- Contact details of the Responsible for Treatment:
| Entity: | BlueCrow |
| Address: | Avenida Duque D´Avila 141 4ºEsq 1050-081 Lisbon |
BlueCrow has appointed a Data Protection Manager. For any question related to data protection contact:
| G.P.D.: | Maria Manuela Rocha Garcia |
| mrg@bluecrowcapital.com |
For what purpose do we treat your personal data?
BlueCrow currently manages venture capital funds and specialized alternative investment funds, as well as providing consultancy services for investments in financial instruments, also developing activities that prove necessary to pursue its main purpose. under the legally prescribed terms.
For this purpose, BlueCrow needs to collect personal data for the following purposes:
- Compliance with legal obligations;
- Management of contractual relationships with customers and suppliers;
- Business prospecting;
- Processing of requests for information;
- Complaints processing;
- Commercial communications, provided that the user has given his consent and has not refused the use of his contacts for this purpose.
What personal data do we collect?
"Personal data" consists of information relating to an identified or identifiable natural person ("data subject"); Identifiable is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, electronic identifiers or one or more specific elements of physical, economic identity , cultural or social status of that natural person.
BlueCrow collects the following categories of personal data: name, nationality, date of birth, identification document number, type of identification document, address, tax number, telephone, profession, employer, e-mail, PPE (Politically Exposed Person), experience and knowledge in markets and financial instruments, investment objectives, characterization of the financial situation.
BlueCrow has access to personal data by completing the forms available on its website, which are completed by the holder of the personal data.
To whom do we transmit your data?
- Recipients
Personal data is processed by BlueCrow's administrative services and may be transmitted to other Group Companies of which BlueCrow is part.
A BlueCrow pode recorrer ainda a entidades externas, sendo a relação contratual regulada por contrato no qual são definidas as medidas de segurança e de organização do tratamento e no qual se especifica que o mesmo só atua mediante instruções da BlueCrow.
Data are also transmitted to public authorities for the purposes of complying with legal obligations.
- Data transfer outside the European Union
Data is not transferred outside the European Union.
How long do we keep your data?
Personal data relating to the execution of the contract are kept for 5 (five) years after the contractual termination and the personal data contained in the reserved area of the website made available to the beneficiaries are kept for 3 (three) years after the closure or cancellation of the account, except for other legal obligations that impose a longer period of conservation, nevertheless, it may be necessary to retain certain data for a longer period for the purposes of complying with legal obligations.
Beyond these periods, some data may be kept for archival or statistical purposes, in these cases being anonymized.
How do we protect your information?
BlueCrow will maintain data security by protecting the confidentiality, integrity, and availability of personal data.
To ensure data security, it adopted technical and organizational measures to prevent unauthorized use or access, modification, illicit or accidental destruction, accidental loss, backup copies, and disaster recovery procedures.
Some of the site's features can only be accessed via login. To do so, the holder must choose a username and an access key.
It will be up to the user to protect the confidentiality of such elements in order to prevent unauthorized access to their account and respective personal data, limiting third-party access to their computer, using secure sessions (https), and logging off when it ends its use, among others.
What are the rights of data subjects?
The data subject has, at any time, the right to access, rectify, update or delete their personal data, as well as the rights of portability, limitation and opposition to the processing thereof.
The data subject may exercise any of these rights in writing through the contacts made available in this Policy and must identify himself in all communications with his full name and respective Tax Identification Number (VAT).
In the event of a dispute regarding the use of their data, the data subject has the right to file a complaint with the National Data Protection Commission (NDPC).
Policy Changes
This Policy and Privacy takes effect from 18-09-2020. BlueCrow may periodically change this policy in order to reflect changes in legislation or changes in the site itself and its contents.
Any significant changes will be communicated with the same degree of publicity that presided over the dissemination of its initial version.
Disclosure
The Privacy Policy is accessible for consultation by any interested entity, at www.bluecrowcapital.com.
This Policy, as well as its subsequent amendments, will also be distributed and disclosed to all BlueCrow employees, with the Company's Management being responsible for clarifying any doubts that it may raise.
BlueCrow for this purpose is BlueCrow – SCR, S.A. and BlueCrow- SCI, Empresa de Investimentos and all related entities managed by them.
