Updated: May 28, 2018
1.1 TotalStart and its Group Organizations are committed to safeguarding the privacy of our website visitors, email subscribers, investors or potential investors, investment applicants, and business associates and partners (collectively, “People”).
1.2 This policy applies where we are acting as a data controller with respect to the personal data of People; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 In this policy, “we”, “us” and “our” refer to TotalStart Entrepreneurship Ecosystem Developers and/or TSFE – The School For Entrepreneurs and/or other group organizations. For more information about us, see Section 12.
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
- How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system – Google Analytics. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process your account data (“account data“) if you apply to our fund manager or entrepreneurial investment programs through our website. The account data may include your name, email address, fund information, company information, and geographic location. The source of the account data is you or another founder/partner/principal/employee of your firm. The account data may be processed for the purposes of evaluating investment candidates and providing our investment services. The legal basis for this processing is the performance of a potential contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.4 We may process any personal data that is provided in the course of the use of our services (“service data“). The service data may include any founder, partner, principal, company-related, or fund-related information. The source of the service data is you or another partner/principal/employee of your firm. The service data may be processed for the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.5 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is your individual consent.
3.6 We may process information contained in any enquiry you submit to us regarding investment services (“enquiry data“). The enquiry data may be processed [for the purposes of offering, marketing and selling relevant services to you.
3.7 We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or another partner/principal/employee of your firm. The customer relationship data may be processed for the purposes of managing our relationships with investment applicants, communicating with applicants, keeping records of those communications and promoting our services. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
3.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.10 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
- Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our group of companies and programs can be found at http://totalstart.org and http://tsfe.in and other group companies.
4.2 We may disclose your personal data to our professional advisers and or business partners insofar as reasonably necessary for the purposes of analyzing opportunities, performing market research, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) Personal data, company data, investor data, and fund data will be retained indefinitely as our customer relationships typically span a 10-20 year period, unless an individual requests to have their data removed from our systems, in which case we will respond to the request in full within 24 hours.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of significant changes to this policy by email.
- Your rights (Applies to EU citizens only).
7.1 In this Section 7, we have summarized the rights that you have under data protection law as a citizen of the EU. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. (Applies to EU citizens only).
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. (Applies to EU citizens only).
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims. (Applies to EU citizens only).
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest. (Applies to EU citizens only).
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims. (Applies to EU citizens only).
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose. (Applies to EU citizens only).
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest. (Applies to EU citizens only).
7.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others. (Applies to EU citizens only).
7.11 If you consider that our processing of your personal information infringes data protection laws and you are a citizen of the EU, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. (Applies to EU citizens only).
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. (Applies to EU citizens only).
7.13 EU citizens may exercise any of their rights in relation to personal data by emailing us at firstname.lastname@example.org, in addition to the other methods specified in this Section 7.
- About cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
- Cookies that we use
- Cookies used by our service providers
- Managing cookies
11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
11.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.3 If you block cookies, you will not be able to use all the features on our website.
- Our details
12.1 This website is owned and operated by TotalStart Entrepreneurship Ecosystem Developers.
12.2 We are registered in the state of West Bengal, India and our registered office is at 8/3C Clubtown, VIP Road, Teghoria, Kolkata, West Bengal 700052, India.
12.3 Our principal place of business is at IICML (A TotalStart Initiative), STPI Kolkata, WEBEL STP 2, DN-53, Sector 5, Salt Lake, Kolkata, West Bengal 700091, India.
12.4 You can contact us:
(a) by mail, at the postal address given above;
(b) using our website contact form;
(c) by email, at email@example.com
- Data protection officer
13.1 Our data protection officer’s contact details are: beatrice (dot) ghosh (at) totalstart (dot) org