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.
This Policy applies to any and all personal data received, and all employees of the Company are responsible for directing their activities towards strict compliance with the legal provisions in force and the rules and procedures set forth in this document.
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
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
Mail: mrg@bluecrowcapital.com
BlueCrow currently manages venture capital funds and specialised alternative investment funds, provides consultancy services for investments in financial instruments, and develops activities that are necessary to pursue its main purpose. under the legally prescribed terms.
For this purpose, BlueCrow needs to collect personal data for the following purposes:
"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 submitted through forms available on its website, which are completed by the holder of the personal data.
Recipients
Personal data is processed by BlueCrow's administrative services and may be transmitted to other Group Companies of which BlueCrow is part.
BlueCrow may also engage external entities, with the contractual relationship governed by an agreement that defines the security and organisational measures applicable to the processing activities and specifies that such entities shall act solely in accordance with BlueCrow’s instructions.
Data are also transmitted to public authorities to comply with legal obligations.
Data transfer outside the European Union
Data is not transferred outside the European Union.
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 which case it is anonymised.
BlueCrow will maintain data security by protecting the confidentiality, integrity, and availability of personal data.
To ensure data security, it adopted technical and organisational measures to prevent unauthorised use or access, modification, illicit or accidental destruction, accidental loss, and backup copies, as well as 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 to prevent unauthorised access to their account and respective personal data, limit third-party access to their computer, use secure sessions (https), and log off when they end their session, among others.
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 themselves in all communications with their 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).
This Policy and Privacy takes effect from 18-09-2020. BlueCrow may periodically update this policy to reflect changes in legislation or 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.
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 responsible for clarifying any questions it may raise.
For this purpose, BlueCrow is BlueCrow – SCR, S.A., BlueCrow – SCI, Empresa de Investimentos, and all related entities managed by them.