BITKRAFT Ventures Management, LLC, domiciled in Delaware, U.S.A. (“BITKRAFT”, “we” or “our”), takes the protection of your personal data very seriously and therefore makes available to you the following information (the “Privacy Policy”).

BITKRAFT is the management company that manages an investment fund. In relation to the aforementioned activity, we also make available to the general public related and connected services (e.g. websites, information requests, and others) (collectively the “Service”).

Whenever you use our Service, we will be processing personal data, as described in the Processing Procedure section of this Privacy Policy. By processing the General Data Protection Regulation (“GDPR”) references a very broad spectrum of operations executed on personal data—basically, whenever we or others get in contact with your personal data, we process it, according to the GDPR definition. Personal data is information that we or others can use to identify a person, i.e. information that can be linked to a particular individual.

As a company based in the United States, we treat all personal data in compliance with GDPR, no matter where you are from or where you are currently located.

The following Privacy Policy will provide you with information about the type of personal data that is collected and how it is processed and used during your use of the Service. Unless otherwise provided in this Privacy Policy, this Privacy Policy exclusively regulates how BITKRAFT, including the companies that help us provide the Service (the “Vendors”), processes your personal data. In case you make use of services provided by third parties other than the Vendors, the privacy policies of these third parties apply exclusively.

Unless otherwise provided in this Privacy Policy and in case you want to exercise any right pursuant to this Privacy Policy or applicable data protection laws and regulations or if you have any questions concerning the Privacy Policy issues, please contact us. Through this form, you can inquire about privacy issues and issue a request to review, change, or delete your personal data stored by BITKRAFT, as described below.

In accordance with the requirements pursuant to the GDPR, you may exercise the following rights:

In each case mentioned in this Rights section please always ensure that provide us with all the all necessary information to process your request. Once we receive all necessary information, we will usually get back to you no later than a month after you completed your request. Please note, that we may require that you provide means of authentication, if we are not sure about your identity.

Whenever you access our website (the “Website”), without using any additional features or services as described below, we process data that your browser and the servers on which the website is hosted, automatically exchange.

In order for the content of the Website being displayed on your device, we process the following data, including as applicable personal data:

• Date and time of access,
• Amount of data sent,
• Browser used,
• Operating system used,
• IP address used (if applicable: in anonymous form).

• Vendors — Vendors provide applications and services, in this case host services and content delivery service for the Website. Our Vendor for the hosting and delivery of the website is Amazon Web Service, Inc.
  We have contractually agreed with this Vendor that it may only use your data as instructed by BITKRAFT and for our services. Any other use – including contact by this Vendor – is only permitted with your prior consent.
• Authorized public authorities — Law enforcement authorities or public authorities (e.g. tax authorities, social insurance), supervisory authorities in the event of requests for or obligations to provide information in the event of legal action, preliminary proceedings and to our own tax advisors, auditors and lawyers in order to exercise our rights and our legal obligations.
• Change in ownership — In the event of a takeover or merger with another company, we will pass on your data to that company. In such a case, we will ensure that the applicable data protection regulations are complied with and that the data will only be processed to the same extent as described in this policy.

Your data related to displaying the Website will be processed pursuant to Art. 6 para. 1 lit. b GDPR, which allows for the processing of personal data for the purpose of fulfilling a contract. Any processing of this data will cease as soon as you stop interacting with the website. Data is automatically deleted no later than 24 hours after your visit.

Each time you access the Website, we automatically collect a series of technical data and store them in our systems (the “Server Log Files”), some of which is considered personal data. We use Server Log Files to monitor and secure the services we offer to you and in order to improve and better our services, including error tracking, usage evaluation and technical analysis, anti intrusion and fraud protection.

The data processed in server log files includes:

• IP address,
• Operating system version,
• The configuration of your device and browser when accessing the Website,
• The time and date of your use of the Website.

This data is not combined with other personal data that you provide BITKRAFT during the use of the Website. We collect Server Log files for the purpose of administering and developing the Website and being able to recognize and prevent unauthorized access.

• Vendors — Vendors provide applications and services, e.g. host computers, backup services, database services, error tracking, usage evaluation and technical analysis, anti intrusion and fraud protection. These Vendors are: Amazon Web Service and Google, LLC. We have contractually agreed with these Vendors that they may only use your data as instructed by BITKRAFT and for our services. Any other use – including contact by one of these Vendors – is only permitted with your prior consent.
• Authorized public authorities — Law enforcement authorities or public authorities (e.g. tax authorities, social insurance), supervisory authorities in the event of requests for or obligations to provide information in the event of legal action preliminary proceedings and to our own tax advisors, auditors and lawyers in order to exercise our rights and our legal obligations.
• Change in ownership – In the event of a takeover or merger with another company, we will pass on your data to that company. In such a case, we will ensure that the applicable data protection regulations are complied with and that the data will only be processed to the same extent as described in this policy.

Server Log Files are processed pursuant to Art. 6 para. 1 lit. f GDPR, which allows the processing of personal data based on a “legitimate interest” of the controller, provided that your fundamental rights, freedoms or interests do not prevail. BITKRAFT’ legitimate interest in this instance is to make administration easier, to improve our services and to detect and to track unauthorized access attempts, errors and attacks on the services. You may object to this data processing at any time if you think there may be particular reasons regarding your particular situation which result in your interest prevailing against this data processing.

Unless otherwise provided herein, personal data contained in Server Log Files is automatically deleted and generally not processed longer than 90 days. We reserve the right to store the server log files for longer if there is evidence suggesting that an incident (such as an attempt at hacking, a database error or a so-called DDOS attack) has taken place. In this case the Server Log Files in question will be deleted, once the investigation regarding the incident has been closed.

Cookies are small files that are stored on a user’s device. They are designed to contain a limited amount of data specific to a particular user and website and can be called up either from the web server or the client device. This allows the server to deliver a page which is tailored to a specific user, or the website itself may contain a script that understands the information in the cookie and is thus able to transfer information from one visit to the website (or a related website) to the next.

A full list of all the cookies currently used on the Website, and the choices available to you with regard to the use of the different type of cookies is made available when you first visit the Website.

We offer you the possibility to get in contact via email or telephone. You may get in contact with us in order for us to fulfill applicable legal obligations such as assisting you with data protection related requests under GDPR or for other types of inquiries or requests.

When you get in contact with us, certain personal data is processed. You are able to decide which personal data you provide us with during your request, but in general we need your contact information, to respond to your request. We therefore, process the following information:

• Phone number,
• Email address,
• Other contact information, as provided by you.

This data is stored and processed exclusively for the purpose of responding to your request, for establishing contact and the associated technical administration.

• Vendors — Vendors provide applications and services, in this case host services and email provider services. Our Vendor for the hosting and processing of all our emails is the Google LLC through their Google Apps for Business service. We have contractually agreed with this Vendor that it may only use your data as instructed by BITKRAFT and for our services. Any other use—including contact by this Vendor—is only permitted with your prior consent.
• Authorized public authorities — Law enforcement authorities or public authorities (e.g. tax authorities, social insurance), supervisory authorities in the event of requests for or obligations to provide information in the event of legal action preliminary proceedings and to our own tax advisors, auditors and lawyers in order to exercise our rights and our legal obligations.
• Change in ownership — In the event of a takeover or merger with another company, we will pass on your data to that company. In such a case, we will ensure that the applicable data protection regulations are complied with and that the data will only be processed to the same extent as described in this policy.

Your contact data will be processed pursuant to Art. 6 para. 1 lit. b GDPR, which allows for the processing of personal data for the purpose of fulfilling a contract of fulfilling a contract or Art. 6 para. 1 lit. c GDPR, which allows for the processing of personal data for the purpose of compliance with a legal obligation to which the controller is subject, depending from the scope and reason of your request..

This data will be deleted after your request has been processed: This is the case if it is clear from the circumstances that the matter has been finally clarified and no legal storage obligations to the contrary exist.

We use reports provided by analytics providers to help us understand Website traffic and Website usage.

When you access our Website, we will analyse how our Website is used.
To this end an analytics cookie is set on your device. This cookie enables us to track your use of the Website and your interaction with other websites.

• Vendors — Vendors provide applications and services, in this case host and analytics services.
  This Vendor is the Google, LLC through their Google Analytics service.
  We have contractually agreed with this Vendor that it may only use your data as instructed by BITKRAFT and for our services. Any other use – including contact by  this Vendor – is only permitted with your prior consent.
• Authorized public authorities — Law enforcement authorities or public authorities (e.g. tax authorities, social insurance), supervisory authorities in the event of requests for or obligations to provide information in the event of legal action preliminary proceedings and to our own tax advisors, auditors and lawyers in order to exercise our rights and our legal obligations.
• Change in ownership — In the event of a takeover or merger with another company, we will pass on your data to that company. In such a case, we will ensure that the applicable data protection regulations are complied with and that the data will only be processed to the same extent as described in this policy.

The data processing for the purpose of analytics is based on your consent, which you gave with the first visited the Website. Pursuant to Art. 6 para. 1 lit. a GDPR, data processing is permitted if you have given your consent for data processing for one or more specific purposes. Within the scope of the opt in you have given a declaration of consent with which you have agreed to evaluation of your use of the website for analytic services. A revocation is possible at any time free of charge through the Website’s privacy settings.

You can opt out from analytic services at any point. To opt out of analytics services on the Website on your device, either change your setting for all websites by following this link or simply change the respective setting in the Website’s privacy settings. The data retention for analytic services is 14 months.

We provide you with information and updates about our company and we offer you the possibility to receive updates and news, including articles about us with third parties, via our newsletter (“Newsletter”).

When signing up for our Newsletter, we will need to process certain personal data in order to provide you with the information you requested. This data includes:

• Your email address,
• Your IP address.

• Authorized public authorities — Law enforcement authorities or public authorities (e.g. tax authorities, social insurance), supervisory authorities in the event of requests for or obligations to provide information in the event of legal action preliminary proceedings and to our own tax advisors, auditors and lawyers in order to exercise our rights and our legal obligations.
• Change in ownership — In the event of a takeover or merger with another company, we will pass on your data to that company. In such a case, we will ensure that the applicable data protection regulations are complied with and that the data will only be processed to the same extent as described in this policy.

The data processing for the purpose of providing newsletter functionalities is based on your consent, which you gave when you signed up for the newsletter on the Website. Pursuant to Art. 6 para. 1 lit. a GDPR, data processing is permitted if you have given your consent for data processing for one or more specific purposes. Within the scope of the sign up you have given a declaration of consent with which you have agreed to evaluation of your use of the newsletter functionalities. A revocation is possible at any time free of charge through the Website’s privacy settings.

Any processing will cease when you unsubscribe from receiving the Newsletter.