Privacy Policy

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Irkalla Capital knows your privacy is important to you, and it is important to us too. This Privacy Policy explains the types of information we collect through www.irkallacapital.com (the “Site”), how we will use it, and how we plan to protect such information once it is collected. Please review this Policy to make sure you understand how any personal information you provide us will be handled. We may change this Privacy Policy from time to time. When we do, we will let you know by posting the changed Privacy Policy on this page. In some cases, for example, if we make any significant changes, we may contact you directly about them, such as by sending you an email if we have your email address. Any changes will be effective immediately upon posting to the Site.

Any reference to “Irkalla Capital” refers to various affiliated entities using the Irkalla name and not a single entity.

We are located in the United States and the United Kingdom. If you are a non U.S. / U,K, user of the Site, your Personal Information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Information may be less stringent than the laws in your country. By providing your data, you consent to such transfer. If you are a resident of the European Union (“EU”), Liechtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”), and we direct you to the “EU Residents” section below.

We collect two general types of information from Site users: (1) information collected automatically concerning your use of the Site (such information is considered nonpersonal information in many jurisdictions) and (2) personal information that identifies or can be used to identify or contact an individual.

Information Collected Automatically: As is the case with many websites, our servers automatically collect your browser type and IP address when you visit the Site. In addition, we may use standard tracking technologies (e.g., cookies, local shared objects, and pixel tags) and website analytics tools to monitor and better understand user behavior on the Site. Data captured may include, for example, the referring page that linked you to the Site, the country from which you are conducting your browsing session, the next website you visit when you leave the Site, and any search terms you have entered on the Site or a referral site. Such data does not identify you personally.

• Cookies: We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. Please see our Cookie Policy for more information.
• Pixel tags: We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Site to track the actions of users on our Site. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing efforts and compile statistics about usage of the Site, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal information.

Personal Information: Personal information means information that allows someone to identify or contact you, including, for example, your name, email, address, city and any other non-public information about you that is associated with or linked to your personal information. We may collect your email address and, if you choose to provide, certain other information, such as name, company, and city of residence. We may also collect names, addresses, or other types of personal information from our investors and business partners to help verify that they are authorized to access the pages of the Site dedicated to them, if any such pages exist.

If you apply to a event (including but not limited to, a pitch competition, summit, conference or other gathering related to Irkalla Capital, you may submit personal information in connection with submitting information about your business, including but not limited to your name, email, city of residence or headquarters, and professional or social media profile. If you apply for an event, we share your information with our third party service provider who administers the application and registration process for us.

Personal Data of Children: We do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register on the Site or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please email us at media@Irkallacapital.com.

We use the information collected automatically about Site visits, including the pages you view, information you search for, and the average time spent on the Site, in the aggregate to better understand our audience and increase the functionality and user-friendliness of the Site. Aggregate information is anonymous.

We consider the personal information that we receive to be confidential. If you submit your email address or other personal information to us via the Site, we will use this information only to the extent necessary to respond to your request or to provide you with the information or newsletters requested by you.

We generally do not share personal information collected through the Site. We may, however, share your personal information (i) with trusted third parties who provide services to us, (ii) as required by law and when we believe in good faith that disclosure is necessary to protect our rights or those of third parties, to protect your safety or the safety of others, to investigate fraud or other illegality, or to comply with a court order or other legal process, or (iii) in connection with a corporate change affecting us or our affiliates, including without limitation a merger, acquisition, sale of assets, or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.

In addition, the third parties that support our website analytics tools may be able to view aggregate Site usage information that we obtain.

While we endeavor to protect the security and integrity of Personal Information in our care, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.

Our Site may contain links, banners, widgets, or advertisements that lead to other websites, including personal blogs written or edited by members of our staff. We are not responsible for these other websites or the accuracy thereof, and so their privacy policies (not this Policy) will govern the collection and use of your information on them. We encourage you to read the privacy policies of those websites to understand how your information is treated there.

Through cookies we place on your browser or device, we may collect information about your online activity after you leave our Site. Just like any other usage information we collect, this information allows us to improve the Site and customize your online experience, and otherwise as described in this Privacy Policy. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different websites. Our Site does not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Site and after you leave our Site.

You may change any of your Personal Information in your account by editing your profile within your account or by sending an e-mail to us at accounts@irkallacapital.com

You may unsubscribe from newsletters and marketing emails at any time by using the unsubscribe instructions on a link at the bottom of such email, or by sending an e-mail to us at media@irkallacapital.com.

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: media@irkallacapital.com

You may request us to delete your Personal Information by sending an e-mail to us at media@irkallacapital.com and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives.

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Irkalla Capital will be the controller of your Personal Data processed in connection with the Site.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at media@Irkallacapital.com

What Personal Data Do We Collect From You? We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Site.

Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data directly on the Site or otherwise when you interact with us. You can provide your email address on our Site to receive news and updates from Irkalla Capital, and once you have received the welcome email through our third party campaign email provider (currently Mailchimp, a processor for us), you have the option to complete your profile with more information such as your name, company and location, but note that providing such information is optional. You can unsubscribe from our emails at any time by clicking on the “unsubscribe” link in the email or by contact us at media@irkallacapital.com

Our lawful basis for processing the foregoing categories of data is our legitimate interest in interacting with you through our Site, providing you with updates about our business, news and events that may be of interest to you, and for us to understand who our email recipients are so that we can better personalize the content for our recipients’ interests.

We also collect names, addresses, or other types of personal information from our investors and business partners to help verify that they are authorized to access the pages of the Site dedicated to them, if any such pages exist.

Our lawful basis for processing the above categories of data is our legitimate interest in preventing fraud and keeping information secure for our investors and business partners.

Information we automatically collect when you use our Site: Some Personal Data is automatically collected when you use our Site. Please see the above section “Information Collected Automatically” for more details on the type of information we collect automatically when you visit our Site.

We use this Personal Data to operate, improve, understand and personalize our Site. Our legal basis for processing information we automatically collect from you is our legitimate interest in operating, improving, understanding and personalizing our Site, so that you have a useful experience visiting the Site.

Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

How and With Whom Do We Share Your Data? We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:

• Fraud prevention service providers
• Ad networks (e.g., Google Adwords)
• Analytics service providers (e.g., Google Analytics)
• Email campaign management providers (e.g., Mailchimp)
• Hosting service providers
• Co-location service providers
• Fund administrators (We share information with these parties for purposes of administering funds, so this applies with respect to our investors’ information only)
• Social media networks (We share limited information for purposes of targeting advertisements on these networks and for analytics purposes.)
• Telecommunications service providers

We will also share Personal Data when we believe it is necessary to:

• Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
• Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
• Maintain the security of our Site

We also share information with third parties when you give us consent to do so.

Last, we share Personal Data with our affiliates or other members of our corporate family. Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

How Long Do We Retain Your Personal Data? We retain Personal Data about you for as long as you remain a subscriber to our email marketing list. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

What Security Measures Do We Use? We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity.

What Rights Do You Have Regarding Your Personal Data? You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email media@irkallacapital.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our services.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about Irkalla Capital’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Transfers of Personal Data: The Site is hosted and operated in the United States (“U.S.”) through Irkalla Capital and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Site, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Irkalla Capital in the U.S. and will be hosted on U.S. servers, and you authorize Irkalla Capital to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S.

We welcome your questions and comments about privacy. Please feel free to contact us by sending an email to media@irkallacapital.com