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Privacy Policy

We, at DEA Accelerator, respect and value the privacy of all individuals and are committed to process personal data in accordance with applicable laws. Please read this Policy carefully so that you understand our services and how we collect and use your personal data. 

 

This Privacy Policy ("Policy") describes how we process personal data with respect to:

  • Use of our website www.deaaccelerate.com;

  • Participation in our accelerator programs and events, including if you contact us via our Website, through other websites (like social media) or offline; 

  • Use of our services for promotion of your business and ideas. 

 

1. Data Controller and Contact Details

1.1. The data controller under this Policy is DEA Accelerate, a company registered in Republic of Bulgaria with company number and having its registered office at Sofia, Bulgaria, ("DEA Accelerator", "us", "we", "our").

1.2. If you have any questions regarding this Policy, you may contact us by mail on our registered office address or by email at [Insert email address for contacts].

 

2. Personal Data We Collect and Process

2.1. We may process the following types of personal data:

  • For the purposes of participation in our accelerator programmes we will process your name, address, contact details, such as phone number, email, social network profiles, education and professional experience, skills, photos and video, references and other relevant data and content you provide to us;

  • In your communication or interaction with us through any kind of contact (including telephone, email, forms on our Website, instant messengers, social media websites and profiles) we may receive and process the information you provide us, such as name, email, phone number, social network profile, preferences, photos, etc.;

  • When you access and use our Website we may collect and process information about your device (including, where available, your IP address, operating system, browser type, location) and how you use our Website. We may also receive cookies data and you may control your cookies preferences through your browser or our cookies tools.

2.2. We may collect your personal data:

  • From you, when you apply and want to take part in our accelerator programmes. We provide business accelerator services and assistance and our main goal is to promote you and your business ideas in public and across potential partners and investors. For that purpose, our accelerator programmes and participants’ data are public and available on the internet, including through our social media channels, such as Instagram, Facebook, on online media, newsletters, public events and other potential channels. If you do not want to make your data public, please do not take part in our programmes and services.

  • From third parties, when they provide reference about you or you made available your profiles on social networks. 

2.3. Sometimes, we may ask you to provide particular information for a specific purpose and provision of such information may be a prerequisite in meeting that purpose. That may be the case for instance to register for an event, to submit to us your information for accelerator programme, etc. In such cases, if you do not provide the necessary data, you will not be able to participate in such event/programme and to receive respective our services.

2.4. Your responsibility:

  • When you submit to us any data or materials, including personal information, you represent that you have the authority to do so and permit us to process such data as set out in this Policy and this will not violate any rights of third parties, including the right to privacy, the right to freedom, copyrights, related rights, intellectual property rights, etc.;

  • Although our policy is to process personal information only limited to the extent that is necessary in relation to the purposes set out herein, we encourage you not to submit to us unnecessary personal data (such as photos of your child, family member, health information, etc.); 

  • When you provide us personal data or get in touch with us you represent and warrant that you are at least 18 years old. Our services and processes are not intended to persons below that age, and we do not intentionally collect and process data of younger persons; 

  • Please note that when you contact us in social media, such as Facebook, Instagram or LinkedIn, our profiles are public and your information, interaction or posting will appear to public;

  • This Policy does not address, and we are not responsible for the privacy, information and other practices of third parties, including third parties operating external website, app or service (such as social network providers). We encourage you, if you choose to visit or use any of these third-party websites or services, to review their privacy policies.

 

3. Purposes of Processing (How We Use Your Data)

We may use and process your data for the following particular purposes:

  • For promotional purposes of you and your business ideas. This includes, but is not limited to all kind of marketing campaigns, publications, advertisement and introductions, social media sharing, mentors’ recommendation, etc.; 

  • For promotional purposes of our programmes; 

  • To communicate and contact you with respect to our programmes and services, including to send you updates, reports and information regarding our rules and changes to our terms and policies; 

  • For purposes of social or public events organised or hosted by us or with our support, including to invite you, to provide you relevant information and materials, to make public photos and video during the event, to introduce you on the event to other participants, to advertise and publicise the event in different medias;

  • For the purpose to assess your profile and ideas in their participation in our programmes and campaigns; 

  • To send you marketing materials for our services, when you consented;   

  • For safety and security purposes, such as to verify accounts and activity, to detect and prevent harmful conduct, fraud or violations of our, or our partners', or public rights and interests;

  • For statistics and analysis to improve our services, procedures, policies and Website, including to prepare offers, market or trends information to potential or actual investors and media;

  • to comply with or fulfil obligations arising from law, act of the authorities or of the court, including to address disputes and legal claims that may arise.

 

4. Legal Basis for Processing Your Data 

4.1. When we process your personal data, we will usually do that on the basis that it's necessary for the conclusion or performance of a contract to which you are party and to provide you our services. That will be the case when we process your data for your participation in our accelerator programmes and to promote you and your ideas. 

4.2. In certain events we may need your consent to use and process your data. That will be the case when we may send you promotional materials for our services and events, other than those you use and utilize. In such case you will always have the right to withdraw your consent as detailed below in this Policy.

4.3. We may also process your personal data on the basis of our legitimate interest or the legitimate interests of a third party, where such interest is not outweighed by your interests or fundamental rights and freedoms. Such will be the case when we process your data for the purposes of contacting your public profile in professional social networks based on your stated experience, for safety and security purposes and to prevent violation of rights or other interests, for statistics and analysis to improve performance and services.

4.4. We may also process your information where that is necessary for compliance with our legal obligations, such as for accounting purposes or to maintain records.

 

5. Recipients of Personal Data 

Your personal data may be disclosed in the following ways:

  • To other participants in our accelerator programmes, including to mentors, professional consultants, jury members, entrepreneurs, potential investors, applicants and others;

  • To public, when you take part in our accelerator programme and provide information with that regard. Our accelerator programmes and participants’ data and business ideas are public and available on the internet, including on our Website, through our social media channels, such as Instagram, Facebook, on blog platforms, online media and others. certain interactions to our social network profiles, or attended to sponsored, hosted or organised public event;

To our vendors and service providers who support our projects and in particular such who provide us technical infrastructure services, hosting or cloud services, Website maintenance, software and product licenses, email services, payment services, professional advisers, insurance companies and others;

  • To public or regulatory authorities, if we are required to do so pursuant to applicable laws or legal, or court process, or in connection with an investigation of illegal activity or under lawful request from public or government or regulatory authorities; we may also share your data when we have a good-faith belief that this is necessary to prevent death or harm or financial loss, or in connection with an investigation of actual or suspected fraud or illegal activity, including violation of our or third party rights, such as copyrights, intellectual property rights or privacy rights.

 

6. Transfer of Data to Third Countries 

6.1. In certain events for the purposes as detailed in this Policy we may transfer personal data to third countries outside the European Economic Area, that may have different data protection laws than those of Bulgaria and of the EU. In particular, this may be the case in which we use a US based e-mail or cloud storage service provider. In such event we will take reasonable and appropriate safeguards and will transfer personal data to third country only on a legal basis such as: (a) a European Commission decision on an adequate level of protection for that third country (art. 45 of the GDPR); or (b) appropriate safeguards as provided under art. 46 of the GDPR, including by utilising Standard Contractual Clauses as adopted over time by the European Commission, or other appropriate safeguards, including subject to specific permission of a competent supervisory authority.

6.2. In other events we may rely on and request your consent for particular transfer to third country.

 

7. Right to Withdraw Your Consent 

When we process personal data based on your consent, you have the right to withdraw your consent at any time. This will not affect the lawfulness of processing based on your consent before its withdrawal. You may exercise that right without additional costs to you by one of the following:

  • At any time by sending us email to [Insert email address] with clear statement that you withdraw you consent; or

  • By using our Website’s forms; or

  • By post a mail to our registered office;

In the event that you withdraw your consent for the processing of personal data we will, without undue delay and to the extent provided under applicable laws, erase the relevant data from our systems.

 

8. Your Other Rights 

8.1. You have the following rights with respect to your personal data and as provided under applicable laws:

  • Right to access - at any time you may request information about the personal data we have for you and the purposes of processing;

  • Right to rectification - you have the right to ask to rectify your data if they are inaccurate;

  • Right to erasure ("the right to be forgotten"). You should keep in mind that this is not an absolute right and applies in accordance with applicable laws. For example, you have the right to request the deletion of your personal data if it is no longer necessary for the purposes for which it was collected or otherwise processed, but only if there is no legal obligation upon us that requires further processing (e.g. some of your data to be further processed for accounting, control, or compliance purposes). In any case, we will respect any lawful and legitimate request for erasure of your data;

  • Right to restriction of processing - this is your right to request that we limit the processing operations with your personal data as provided under applicable laws, such as if you dispute the accuracy of your data and for the verification period;

  • Right to data portability - you may request that data provided directly by you and processed by automated means by us is transferred to you or to another controller. This right is only applicable where our processing of your data is based on your consent or on a contract with you;

  • Right to object. In particular the right to object includes that you may object at any time to processing of your personal data which is based on: a) the performance of a task carried out in the public interest or in the exercise of official authority vested to us; or b) pursuing our or third party's legitimate interests; or) the purposes of direct marketing.

8.2. In order to exercise your rights, you may contact us at any time by sending us an email to [Insert email address]. We may need to verify your identity or to contact you with respect to your requests.

8.3. In the event that you are established in the European Economic Area, you also have the right to lodge a complaint with a supervisory authority, in particular in the EEA country of your habitual residence, place of work or place of the alleged infringement. For Bulgaria, the supervisory authority is the Commission for Protection of Personal Data, having its website at www.cpdp.bg.

 

9. Automated Decisions 

9.1. We may use software for automated processing to provide our services or to process certain personal data. This may be the case, for example, when we divide inactive from the active accounts on the Website or to determine certain criteria relating to your business idea or use of the Website, or to identify certain individuals. We will not take any of our decisions solely based on such software for automated data processing and we will always use also a human factor. 

9.2 You may request an explanation if you think a particular result of an automated processing is incorrect. You may also oppose any decision that is of major concern to you and which is taken solely by a computer, software, or other automated process, if any.

 

10. Storage Period 

10.1. We will retain your personal information for as long as necessary for the respective purposes of the processing and to comply with our obligations under applicable laws.

10.2. In particular, unless otherwise allowed by applicable law, we may retain personal data for the following periods:

  • Data for the purposes of promotion of your business or idea – for the duration of the respective campaign and for 2 more years after its completion;

  • Data for the purposes of provision of services or for executing or performance of a contract - generally for 5 years from the termination date of the agreement; 

  • Data to send you marketing materials or based on your consent - until you withdraw your consent (where applicable) or until you object to processing or for 2 year as from our latest contact with you that provides you the option to opt-out; 

  • Data for accounting and control purposes - in accordance with the applicable law, as for instance for 5 years from the end of the respective tax year; 

  • Data we process for safety and security purposes may be retained for 1 year unless a law provides for shorter period;

  • We will delete inactive profiles on the Website 2 years after the last active action;

  • You may stop communicating with us in social networks at any time and according to the tools of the relevant social network, for example, if you have liked our Facebook page, you may withdraw such like (unlike), and so on.

 

11. Changes in this Privacy Policy 

We may change this Policy from time to time and you may see the last revision date of this Policy at the end of the document. Where the changes in the Policy affect processing of your data on the basis of your consent, we will notify you of the new Policy and request your consent on it.

 

Adopted on May 29, 2024

 

Last update made on 29.05.2024

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