1. Introduction
Vanguard Venture Capital (“we,” “us,” “our”) respects your privacy and is committed to protecting your personal data. This privacy policy explains how we collect, use, and safeguard your information in compliance with the EU General Data Protection Regulation (GDPR) and other applicable data protection laws.
2. Data Controller
Vanguard Venture Capital, registered in Greece, is the data controller responsible for your personal data. You can contact us at:
Athinas 18, Athina 105 51, Greece
Email: info@vanguardventurecapital.com
3. Data We Collect
When you submit a funding application, we collect:
- Company information (name, location, website, business description)
- Contact details (name, role, email, phone number)
- Financial information (funding amount, revenue, stage)
- Business documentation (executive summaries, pitch decks, cap tables)
- Identity verification documents (for KYC purposes at term sheet stage)
4. Lawful Basis for Processing
We process your data based on:
- Legitimate interests: Evaluating investment opportunities and conducting due diligence
- Consent: Where explicitly provided through application form
- Legal obligation: AML/KYC compliance under EU regulations
- Contractual necessity: Executing investment agreements
5. How We Use Your Data
We use your personal data to:
- Evaluate your funding application
- Conduct due diligence and investment analysis
- Communicate with you about your application
- Comply with legal and regulatory obligations (AML/KYC)
- Maintain records of investment decisions and portfolio management
6. Data Sharing
We may share your data with:
- Our fund investors (limited partners) for investment committee review
- Legal and financial advisors assisting with due diligence
- KYC/AML service providers for compliance verification
- Regulatory authorities when legally required
We do not sell or share your data with third parties for marketing purposes.
7. Data Retention
We retain application data for 2 years from submission unless you request earlier deletion. For funded portfolio companies, we retain data for the duration of the investment plus 10 years to comply with regulatory and legal requirements.
8. Your Rights Under GDPR
You have the right to:
- Access: Request a copy of your personal data
- Rectification: Correct inaccurate or incomplete data
- Erasure: Request deletion of your data (“right to be forgotten”)
- Restriction: Limit how we process your data
- Portability: Receive your data in a structured, machine-readable format
- Object: Object to processing based on legitimate interests
- Withdraw consent: Withdraw consent at any time (where processing is based on consent)
To exercise any of these rights, contact us at info@vanguardventurecapital.com. We will respond within 30 days.
9. Data Security
We implement appropriate technical and organizational measures to protect your data:
- TLS encryption for data in transit
- At-rest encryption for stored data
- Access controls and authentication
- Regular security audits and assessments
- SOC 2 compliant hosting providers
10. International Data Transfers
We primarily process data within the EU/EEA. If data is transferred outside the EU/EEA, we ensure appropriate safeguards are in place (Standard Contractual Clauses or adequacy decisions).
11. Cookies
We use essential cookies for website functionality and analytics cookies (with your consent) to understand how visitors use our site. You can manage cookie preferences through our cookie banner.
12. Complaints
If you have concerns about how we handle your data, you have the right to lodge a complaint with the Luxembourg National Commission for Data Protection (CNPD) or your local data protection authority.
13. Changes to This Policy
We may update this privacy policy from time to time. We will notify you of significant changes via email or prominent notice on our website.