seedsofbravery.eu

We are committed to protecting your personal data and ensuring transparency in how we process it. Please read our seedsofbravery.eu Website Privacy policy to find out how we collect and treat your personal data. 

The Joint Controllers are:

• Fundingbox Accelerator sp. z o.o. (FBOX) (Postępu 15, 02-676; Warsaw, Poland),
• FOND ROZVYTKU INNOVACIJ UNK (USF) (26 Otto Schmidt street, po box: 000, 04107, Kyiv, Ukraine),

as the Joint Controllers. Joint Controllers have agreed on common data processing purposes.

In all matters regarding personal data, you can contact us using the following email address: privacy@fundingbox.com.

The essence of arrangements between Joint Controllers are described in point 8.

All terms should be understood in accordance with the Website Terms of Use available at:
https://seedsofbravery.eu/terms-of-use/. 

1. Purposes, legal basis and retention of data processing

Purpose of processing and legitimate interests	Legal basis for processing	Retention period
Realised as Joint Controllers: Enabling the use of the website and ensuring its proper functioning.	The legitimate interest of the data controller (art. 6.1(f) of GDPR).	Until the limitation period for claims expires or effective objection is raised.
Realised independently: Determining and pursuing or defending against claims.
Realised independently: Acceptance and consideration of the request based on the GDPR.	Obligation under the GDPR to provide the data subject with information (art. 6.1(c) of GDPR).	5 years from the date of completion of responding to the request.

2. Who has access to personal data?

Joint Controllers will transfer personal data only to trusted recipients such as marketing and event agencies, IT service providers, hosting providers, accountants, law firms, postal and courier companies (who process personal data on the controllers’ behalf).

Due to the fact that we use the services of Google LLC, your data may be transferred to the USA. We have concluded an agreement with Google – the so-called Standard Contractual Clauses. This means that in accordance with the decision of the European Commission No. 2021/914 EU of June 4, 2021, your personal data may be processed by this company in the USA. More information about the decision at:
https://fundingbox.com/trust/transfer-outside-eea/. 

To realize the Project data can be transferred also to Project Partners (complete list of the project partners is available at the email address: privacy@fundingbox.com) and European Commision.

Due to the fact that some of the Project Partners and vendors have their headquarters outside European Union your data may transferred to a third country, in particular Ukraine. Within Consortium all the Project Partners have concluded a Standard Contractual Clauses pursuant to the decision of the European Commission No. 2021/914 EU of June 4, 2021. To learn more about it or about suitable safeguards we have implemented email us at: privacy@fundingbox.com. 

3. External links

The Website may contain links to other websites. Such websites may operate independently of the Controller and may not supervised by the Controller in any way. These websites may have their own privacy policies and regulations, which we recommend that you read.

4. What rights do you have regarding the processing of your personal data?

Due to the fact that we process your personal data, you have the right to:

1. request access to your personal data,
2. demand the rectification of their personal data,
3. request to remove or limit the processing of your personal data,
4. complain with the supervisory authority
   (https://edpb.europa.eu/about-edpb/about-edpb/members_en).

You also have a right to object to processing of your personal data for all purposes indicated above (according to the Article 21 of GDPR).

5. How can you notify us of your desire to exercise your rights?

You can exercise your rights in person at the Controller’s office, by post or e-mail (the Controller’s contact details are provided at the beginning).

In response to your request, you may be asked to provide data necessary to identify your personal data (including finding them) or verify your identity (confirming that you are the person you claim to be).

6. Where does the Controller obtain data?

As a rule, the Controller obtains data directly from you. If we obtain data from another source, you will be informed separately and clearly.

7. Is providing data voluntary?

Providing data is generally voluntary. Whenever data is provided:

• voluntary, but necessary to achieve specific purposes (e.g. e-mail contact via an online form) or
• obligatory (e.g. it will result from legal provisions)

you will be informed about this separately and clearly (e.g. on the form through which personal data will be collected).

8. Joint Controllership arrangements

Purposes of processing

1. The Parties to the Joint Controller Agreement jointly establish the overriding purpose of personal data processing: operating and maintaining the Website, hereinafter referred to as the “Main purpose“.
2. Any data processing that is not related to the implementation of the Main purpose, and is carried out individually by either of the Parties, does not fall within the scope of the Joint Controller Agreement.
3. The Joint Controllers set the following common specific purpose for the processing of personal data: Operating and maintaining the Website.

Roles of the Parties

1. Each Party undertakes to immediately update all related information with the performance of this Joint Controller Agreement in terms of ensuring compliance with the principles of the GDPR.
2. In the event of an inspection or other proceeding by any personal data protection authority against any of the Parties, the Party shall immediately provide such information to the other Party.
3. The coordination between the Parties to make them available to data subjects are determined solely by FBOX.
4. If the data subject submits any request to exercise his/her rights under Art. 12-22 of the GDPR, the Party that received such a request/request shall immediately forward it to FBOX (max. 1 business day), along with all documents, data, copies that it has about the data subject and the request to the address privacy@fundingbox.com. If the data subject’s request is received in Ukrainian, USF will translate it into English before forwarding the request to FBOX.  FBOX will determine which Party the request concerns and which Party should fulfil the request. If the data subject, while considering his/her request, continues to communicate in Ukrainian, USF will be responsible for maintaining correspondence with this data subject and handling such a request.
5. Each Party:
   • provides FBOX with all kinds of correspondence related to the implementation of the rights of persons under Art. 12-22 GDPR,
   • prepares the necessary information and takes an active part in the risk assessment process and selection of technical and organisational measures referred to in Art. 24, 25 and 35 GDPR, 
   • issues authorisations and instructions to persons who are to have or have access to personal data,
   • enforces from the staff appropriate statements on the confidentiality of data and the method of securing this data.
6. FBOX is committed to:
   • providing substantive support to all Parties,
   • developing and sharing templates of information clauses related to the joint controlling of personal data,
   • keeping a repository of all information clauses published by the Parties,
   • keeping a repository of all communication with data subjects in the implementation of the rights of these persons by the Parties that are the Joint Controllers of the personal data of that person,
   • keeping documentation of risk assessment and identifying technical measures and organisational ones ensuring the processing of personal data in accordance with the GDPR.