1. Introduction

Acme Innovation, together with its affiliates (“we”, “us” or “our”), respects your privacy and Personal Data. Acme Innovation collects and receives information that relates to identified or identifiable individuals. Personal Data (“Personal Data”) is any information that relates to identified or identifiable persons, in particular by reference to an identification number or to one or more factors specific to their physical, physiological, mental, economic, cultural or social identity. This statement describes what Personal Data we collect and how we use, process and disclose such Personal Data.

We may update this Privacy Statement as required. Each time you use our services you should review this Privacy Statement. If we make any material changes to this Privacy Statement we will post a notice on our website when these changes are implemented. Your use of our services following any such changes indicates your acceptance of our Privacy Statement.

2. Acme Innovation Services

Acme Innovation is a global, multi-stage venture capital firm that operates early stage startup development programs. Personal Data is only collected in accordance with the law. For example, we may require your Personal Data to provide services as requested by you or to enter into contractual relationships with you. If you do not consent to the provision of such Personal Data we may not be able to enter into such contractual relationships or provide such services. Our services are intended for adults only. We do not knowingly collect, solicit, use, process or disclose Personal Data relating to children.

3. What Personal Data Do We Collect And Why

a. General

We may collect Personal Data from direct and indirect interactions with you to provide our services as agreed by you or to fulfill our contractual obligations with you.
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‍In this regard we may gather Personal Data that may include your:
Full name, postal address, nationality, email address, telephone number, bank account details, job title, name of employer, tax identification or your national insurance number, forms of identification. We may also collect device/IP data, including IP address, device ID, domain server. In some cases, we may collect images and audio or visual recordings.
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‍We may use this information to:
Set up meetings with you, maintain a record of your contacts, respond to your enquiries and fulfill your requests, assist you with your transactions or provide you with investor related services.

The use and processing of Personal Data is necessary for our legitimate interests in providing our services, which includes primary operations as an accelerator venture capital organization, carrying out of administrative duties, the running of our business and in order to make or direct investment decisions.

b. Communications And Correspondence

In the course of communications or correspondence with you we may need to collect your Personal Data in order to develop our services and offerings and inform our marketing strategy.
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‍In this regard we may gather the following Personal Data:
Name, residential or business address, job title, name of employer, nationality, email address, home or office address.

The use and processing of your Personal Data is required for our legitimate interests to develop our services, grow our business and inform our marketing strategy.

c. Existing And Potential Limited Partners

Limited Partners (“LPs”) include any individual who invests in any fund managed by Acme Innovation or its Affiliates and/or individuals who invest or may potentially invest in our portfolio companies.
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‍We may collect your Personal Data for the following purposes:
Due diligence including identity verification and eligibility checks, to maintain communications by storing a record of contacts, organizing meetings with you, responding to your enquiries and requests, investment management (i.e. capital calls, payments and cash distributions, the completion of fund related documentation).
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‍In this regard we may gather the following Personal Data:
Full name, postal address, tax identification, social security number, forms of identification, email address, telephone number, bank account details.
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‍We use and process this information for the following purposes and legitimate interests:
providing our services, administrative purposes, making or directing investment decisions, performance of contractual relationships, to comply with relevant regulations and laws, tax and compliance obligations including anti money laundering regulations and criminal background checks.

d. Co-Investors Or Potential Co-Investors

Co-Investors or potential co-investors include individuals who solely or as part of a corporation invest in the same portfolio companies as Acme Innovation.
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‍In this regard we may gather the following Personal Data:
Full name, postal address, telephone number, social security number, forms of identification, email address, telephone number, job title, employer details.
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‍We use and process this information for the following purposes and legitimate interests:
providing our services, administrative purposes, making or directing investment decisions, performance of contractual relationships, to comply with relevant regulations, laws, tax and compliance obligations.

e. Corporate Partners And Mentors

Corporate partners or mentors include any individual who works with Acme Innovation to provide guidance and support to our portfolio companies on the basis of their expertise and skill in a given area.
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‍We may collect Personal Data from corporate partners and mentors including:
Full name, email address, telephone number, job title, bank account details, area of business and employment history.

We use and process such Personal Data for our legitimate interests such as providing services, running our business and administrative purposes.

f. Portfolio Companies

We gather Personal Data from individuals involved in our portfolio companies for the following purposes:
Founder, director, shareholder and relevant third party identity verification, founder background checks, due diligence checks, ongoing investment management, analysis of company proposals, pitches and presentations, organizing meetings with you and maintaining a record of contacts.
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‍Personal Data collected for the above purposes include:
Founder, director and shareholder full names, postal addresses, email addresses, phone numbers, bank account details; founder nationalities and gender; forms of founder identification.
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‍We use and process such Personal Data for the following purposes and legitimate interests: Providing program and general services, administrative purposes, making or advising on investment decisions, performance of contractual rights and obligations with you.

We may share this information with third party background check providers in which case your specific consent will be required for any sharing of your Personal Data.

g. Employees And Applicant Employees Or Interns

Our employee’s Personal Data is held on various internal systems. An employee’s Personal Data policy has been made available to all our employee’s setting out their rights as a data subject. Our legal basis for such processing concerns the employer/ employee contractual relationship.
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We may collect Personal Data of applicant employees/interns via the Acme Innovation website (www.acmeinnovation.com) in order to consider and manage employment applications. Personal Data collected may include the following: Full name, postal address, date of birth, social security number or tax identification, form of identification, nationality, email address, telephone number, job title, education and employment history, resumé.
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We may share this data with colleagues and associates in respect of relevant positions within Acme Innovation.
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We may also share this data with Acme Innovation portfolio companies, (in which case your specific consent will be required for any sharing of your data with an Acme Innovation portfolio company), in respect of relevant positions within an Acme Innovation portfolio company.
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We may also share your data and with Acme Innovation third party service providers.

We require the above information in accordance with your consent and for our legitimate interests in providing our services, running our business, administrative purposes, to enable performance of contractual relations and to allow us to progress your potential employment or internship.

We will retain this data from applicant employees/interns for as long as such applicant employee/intern is interested in positions within the Acme Innovation organization or wider community (i.e. Acme Innovation portfolio companies) and you have confirmed that you are interested in being retained within the Acme Innovation talent pool.

4. How Personal Data Is Collected

Personal Data may be collected directly by interacting with us via:

• Our websites, owned and operated by Acme Innovation (www.acmeinnovation.com) which also include:
  — Collideronthelot.com
• Our social media and networking pages including:
  — Linkedin (https://www.linkedin.com/company/acme-innovation);
  — Twitter (https://twitter.com/AcmeInnovation);
  — Our Affiliates social media and networking pages.
• At our events. Acme Innovation may host, co-host, co-ordinate and/or operate Acme Innovation events, at which we may create visual or audio recordings, take photographs, conduct surveys or similar activities, and/or make available products and services of participating companies at such events and may as a result collect and process certain Personal Data.
• Email, telephone, in person, by post or by providing us with Personal Data for the purposes of applying for investment, becoming or applying to become an investor or applying for employment or in the course of employment.

Personal Data may also be gathered by automated means or indirectly via public sources such as results from search engines, third party databases, company registration offices or cookies on our websites. 

5. Use/Disclosures Of Personal Data

Acme Innovation may, where necessary and/or appropriate, process Personal Data that you provide or that we receive if you participate on any Acme Innovation program, use any Acme Innovation service or websites or social media and networking pages (“Acme Innovation Services”), in order to:

• provide the Acme Innovation Services you request;
• be compliant with the terms and conditions of the Acme Innovation Service;
• be compliant with legal obligations that apply to Acme Innovation (e.g. deduction of taxes, etc.);
• protect the vital interests of individuals engaging with Acme Innovation (including employees, prospective employees, LPs, etc.);
• comply with business and operational measures, such as data security monitoring, service analytics, internal research, quality control;
• protect Acme Innovation’s legitimate interest, and rights, privacy, safety and/or property, and/or that of others. 
• protect, investigate and deter against any fraudulent, harmful, unauthorized, unethical or illegal activity.

Acme Innovation may disclose Personal Data to Acme Innovation Affiliates, third party service providers such as human resources, legal, accounting and cloud storage services, communications and networking services, IT system administrators and professional advisors, background check providers, regulators, government or law enforcement officials (where required) and other relevant authorities (where required). Such disclosures will only be made in accordance with this Privacy Statement and any iterations of this Privacy Statement made over time. All third-party service providers are only permitted to process Personal Data in accordance with stated purposes and in accordance with our instructions. All processing of Personal Data by third parties is carried out in accordance with the law and industry standard security measures.

Acme Innovation may also disclose Personal Data to any Potential Co-Investors, Corporate Partners and Mentors. These parties may use such Personal Information for their own business purposes in accordance with applicable law, including to communicate with you, evaluate your company, products, and services, carry out business and administrative operations, and to make or direct investment decisions.

Acme Innovation will not sell, rent, release, disclose, disseminate, make available transfer or otherwise communicate in any manner your Personal Data to any third party in exchange for monetary or other valuable consideration.Acme Innovation may sell, transfer, or otherwise share some or all of our business or assets, which may include Personal Data, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization, asset sale or bankruptcy. In any such circumstances, best efforts will be made to require the recipient to adhere to this Privacy Statement.

6. Security Of Your Data

Acme Innovation uses industry standard security measures to prevent the loss, misuse or alteration of Personal Data within our control, including organizational, technical and physical measures. In addition, we limit access to Personal Data to those Acme Innovation authorized personnel who have a legitimate business purpose to access such Personal Data. All such personnel are subject to strict confidentiality obligations.

We have implemented measures in the event of any suspected Personal Data breach. In such instances we will notify you and the applicable data protection regulator as required by law. Unfortunately, no security system is entirely secure, and we cannot guarantee the security of your information.

7. Data Retention

We only retain Personal Data for the period required to achieve the purposes for which it was collected. Note that such purposes include legal, accounting or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the purposes for which we process Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In certain circumstances, we may anonymize Personal Data. In such circumstances we may use such anonymized data indefinitely without further notice to you.

8. International Transfers

The Acme Innovation website is hosted and operated in the United States (“U.S.”) by us and through our service providers.  If you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. If you are a resident of the EEA or UK, you may have additional rights under the General Data Protection Regulation (Regulation (EU) 2016/679), the United Kingdom Data Protection Act 2018, and the United Kingdom General Data Protection Regulation (collectively, the “GDPR”), as applicable, with respect to your Personal Data, as outlined in this Policy. By using the Acme Innovation website, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to us and will be hosted on U.S. servers, and you authorize us 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.

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.

9. Your Rights

Your rights with regard to your Personal Data:

• Stay informed: The right to know how we use your Personal Data;
• Access: The right to request a copy of and access to your Personal Data;
• Amend or update: The right to update or correct your Personal Data;
• Erase: The right to erase your Personal Data;
• Restrict: The right to restrict the processing of your Personal Data;
• Data Portability: The right to obtain your Personal Data from us and re-use such data for your own purposes. We may also transfer your Personal Data to third parties as appointed by you;
• Object: The right to object to the processing of your Personal Data e.g. when you believe our legitimate interest for processing your data negatively impacts your rights;
• Automated decision making or profiling: The right to object to decisions that are based on automated processing of your Personal Data.

You may opt out of any Acme Innovation newsletter or related emails by following the unsubscribe instructions on such emails, or by contacting us directly at contact@acmeinnovation.com

10. Privacy Rights of California Residents

To the extent provided for under the California Consumer Privacy Act (“CCPA”) and subject to applicable exceptions, California residents have the following privacy rights in relation to Personal Data we collect:

• Information: The right to know what Personal Data we have collected and how we have used and disclosed that Personal Data;
• Access: You can request a copy of the personal information that we have collected about you during the past 12 months;
• Deletion: The right to request deletion of your Personal Data; and
• Non discrimination: The right to be free from discrimination relating to the exercise of any of your privacy rights.

11. Changes to this Privacy Statement

Acme Innovation reserves the right to make changes to this Privacy Statement at any time without prior consultation. Any changes to this Privacy Statement will be posted on the Acme Innovation website (www.acmeinnovation.com).

12. Contact Us

To exercise your rights please contact Acme Innovation via email: contact@acmeinnovation.com along with a copy of your identification. Depending on your request and the applicable law, we may be entitled to decline your request.