How we respect privacy when we deal with personal information
Effective Date: from May 25, 2018
If you have any comments or questions about this notice, feel free to contact us at firstname.lastname@example.org.
Astia is a not for profit community of people brought together by the shared values that inclusion is valued and that the playing field is leveled for women entrepreneurs: we take the privacy of our community members seriously and do not sell personal data to any one else. However, we are an organization which relies on our community members – so when you are taking part in our community please ensure that you play your own part in helping us keep everyone’s information secure.
1. How we collect your personal data
We collect your personal data in a number of ways, for example:
From the information you provide to us when you meet us;
From information about you provided to us by you, your company, an intermediary, an advisor or one of your investors;
When you communicate with us in writing, by telephone, newsletter signup, email or other forms of electronic communication. We may monitor, record and store any such communication;
When you complete an application to Astia (whether as an entrepreneur or an investor member or otherwise); and
From publicly available sources.
2. What personal data we collect about you
We collect personal data relevant to your participation in our community. This will vary depending on exactly how you choose to interact with us, but is likely to include:
Your name and contact information such as your home or business address, job title, email address and telephone number;
Information about your employment, expertise and experience;
Voice recordings (when we tell you this is happening); and
Regarding our Astia Angels members, information which may confirm your identity including your date of birth, tax identification number, country of domicile and/or your nationality.
3. How we use your data and the legal basis on which we process your personal data
We will use your personal data in a manner that is appropriate considering the basis on which that data was collected.
i. Performance of a contract with you
We process your personal data when it is necessary to perform a contract with you. This could be in a number of interactions as a community member, such as when you sign up as an Astia Angels member, as an Astia Advisor or screener, or submit an application as an entrepreneur.
ii. Legitimate interests
We process your personal data when it is necessary for the legitimate interests of managing the Astia community to which you have voluntarily become a part. The types of processing undertaken for this reason includes:
Sending messages to our community members about our achievements, interesting news and requests for donations to help support our work;
Dealing with enquiries about Astia, Astia Angels, our community or our work or introductions in connection with the same;
Processing an application as an entrepreneur to Astia;
Processing a donation you have made to us; and
Website functionality: it is necessary for us to store a small amount of information, usually through cookies, to deliver functionality that you would expect.
iii. Legal obligations
We process your personal data when it is necessary to comply with a legal obligation which we are under. In order to do this, we will use your personal data as set out below:
To meet our compliance and regulatory obligations; and
As required by tax authorities or any competent court or legal authority.
4. When we share your data
We may share your personal data with or transfer it to the following:
Your advisers or intermediaries who you tell us about;
Third parties whom we engage to assist in delivering the services under contract to you;
Our professional advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, auditors and outsourced finance functions;
Our data storage providers;
Our expert screeners who participate in our Expert Sift screening process for entrepreneurs;
With relevant regulators or law enforcement agencies where we are required to do so;
A named third party with your explicit consent; and
A third party purely for the purposes of processing data on our behalf when we have in place a data processing agreement with that third party that fulfils our legal obligations in relation to the use of third party data processors.
5. How long we keep your data
We take the principles of data minimization and removal seriously: we try to capture the minimum amount of data for the associated purpose and then have processes to delete that data once it is no longer required.
We send occasional marketing about the Astia community, which we believe might be of interest to you, in the form of alerts, newsletters and invitations to specially selected events. We use email and other digital channels to communicate with you.
If you would like to stop receiving marketing from us you can do so at any time. Please contact us at email@example.com or use the unsubscribe option at the end of any of our marketing emails:
7. Rights you have over your data
You have a range of rights over your data, which include the following:
Where data processing is based on consent, you may revoke this consent at any time and we will make it as easy as possible for you to do this (for example by putting ‘unsubscribe’ links at the bottom of all our marketing emails).
You have the right to ask for rectification and/or deletion of your information.
You have the right of access to your information.
You have the right to lodge a complaint with the UK Information Commissioner if you feel your rights have been infringed.
A full summary of your legal rights over your data can be found on the Information Commissioner’s website here: https://ico.org.uk/
If you would like to access the rights listed above, or any other legal rights you have over your data under current legislation, please get in touch with us. Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.
Please note that relying on some of these rights, such as the right to deleting your data, will make it impossible for us to continue to deliver services to you or including you within the Astia community. However, where possible we will always try to allow the maximum access to your rights while continuing to deliver as many services to you as possible. If you are not satisfied with how we are processing your personal data, you can make a complaint to www.ico.org.uk.
8. Your personal data outside of the European Union
Astia is an organisation headquartered in the United States of America. By providing your information to us you acknowledge that your personal data will definitely be shared within our organisation and as such will be transferred to that country. We do this using third party tools from well-respected multinational data organisations, such as Salesforce and Google, which we understand have appropriate protections and registrations in place.
If you have any questions about the transfer of your personal data outside of the European Union, please contact us on firstname.lastname@example.org.
9. Cookies & usage tracking
A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things, eg remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website.