GDPR Compliant Privacy Policy

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Last updated: March 27, 2023
Introduction

Satgana is incorporated under the laws of the Grand Duchy of Luxembourg:

Satgana (GP) S.à r.l. Société à responsabilité limitée 18, rue Robert Stümper, L-2557 Luxembourg R.C.S. Luxembourg: B 254.599 (the “General Partner”)Acting in its capacity as General Partner of :Satgana Fund I SCSp Société en commandite spéciale 18, rue Robert Stümper, L-2557 Luxembourg R.C.S. Luxembourg: B254691 (the “Fund”)

The website www.satgana.com is operated and controlled by Satgana.

Thank you for choosing to be part of the Satgana community (“company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at jointhejourney@satgana.com

Agreement to Terms and Conditions of Use of this Website
When you visit our website (“Site”) and use our services, you trust us with your personal information and agree to the collection and use of information in accordance with this Privacy Policy. This may be amended from time to time by Satgana without notice. The terms and conditions hereunder are subject to the laws of the Grand Duchy of Luxembourg and the exclusive jurisdiction of the Tribunal d’Arrondissement of Luxembourg city.
No Reliance and Limitations of Liability
The information on this Website is provided by Satgana (hereinafter referred to us  “we” or “us”) for informational purposes only and on an “as is” and “as available” basis, without any express or implied warranties as to the accuracy or completeness of the information provided and which may be changed by Satgana without notice. The information contained on this Website should not be considered as an offer or solicitation, to deal in any of the investments or funds mentioned herein. Nothing contained in the information on this Website constitutes legal, tax, investment or other advice, nor to be relied upon in making any decision.

You are encouraged to confirm the information contained herein, and you should not construe any information herein as a warranty or guarantee of the quality or availability of services or financial products. Any reliance on information provided on this Website is at your own risk and in no event will Satgana or its service providers be liable for any loss or damage of any kind arising out of or in connection with your access, use, or browsing of thus Website.

Any links to other websites or to materials provided by other parties are provided by us for your convenience only and do not imply endorsement of such websites or materials by us. These sites and materials are not owned by or under the control of Satgana, and Satgana disclaims all liability with regard to your access to and use of such linked websites or materials from other parties.
Copyright
The contents of this Website is protected by copyright and may not be downloaded, extracted, reproduced, distributed, transmitted, or published, in whole or in part, for public or commercial purposes without Satgana's prior written consent, or in case of third-party materials, the owner of that content. You may not alter or remove any logo, trademark, copyright or other notice from copies of content on these Websites.

You may review, download, save, and/or print out a hard copy of individual pages and/or sections of these Websites for your personal, non-commercial, non-political use.

You agree not to license, distribute, create derivative works from, transfer, sell or re-sell any content obtained from this Website, nor to modify, deface content on this Website, or reproduce content on this Website separate and out of context from the original accompanying materials. You are not permitted to use the materials on this Website except as expressly set forth herein.
Cookies
Please be informed that this Website uses cookies and third-party cookies from Google Analytics, which are small data files that are downloaded onto your computer, to help us understand how this Website is used and how we can improve this Website. For instance, these cookies may track and provide us with statistics regarding which pages are visited, which articles are downloaded, the length of time spent per user on this Website etc.

If you do not wish to accept these cookies onto your computer, you can disable cookies via the setting on your browser.
Definitions
For the purposes of this Privacy Policy:
Account means a unique account created for You to access our Service or parts of our Service.
Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Satgana, 18, rue Robert Stümper, L-2557 Luxembourg.
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
Country refers to: Luxembourg
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual.
Service refers to the Website.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Website refers to Satgana, accessible from https://www.satgana.com/
You
means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Privacy Policy
This privacy policy applies to all information collected through our website (satgana.com), our social media channels and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the “Sites”).

Satgana understands the importance of keeping your personal data safe. The privacy policy of Satgana sets out what data we collect from clients and any further data collected in the course of the business relationship and why, how it is stored, processed and what your rights are in relation to this data. In case of any questions about this Policy or your data rights, please contact us by using the contact form, or alternatively:

Postal and visitor’s address:

Satgana
18, rue Robert Stümper

L-2557 Luxembourg

Grand Duchy of Luxembourg

E-mail: jointhejourney@satgana.com
Retention of Your Personal Data
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Changes to this Privacy Policy
We will update this policy as necessary to stay compliant with relevant laws. We will notify You of any changes by posting the new Privacy Policy on this page. Changes will be made and updated as per the "Last updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
1. Data categories and sources of data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
- Personal identification data, such as name, date of birth and contact details, bank account information, social security number, travel ID, CVs;
- IP addresses or other visitor origin profiles maybe traceable from visiting our website or social media profiles;
- Profile pictures, pictures from events and videos.

We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent. You directly provide Our company with most of the data we collect.

We collect and process data when you:
- Apply for investment
- Voluntarily complete or provide feedback on any of our message boards or via email
- Sign up for Our company newsletter

Our company may also receive your data indirectly from the following sources:
- Partners, for example for start-up competitions or co-investment opportunities.
2. Lawful basis and purpose of the processing
Any personal data provided to us is processed based on the legal grounds enumerated in Art. 6, Par. 1 of the GDPR. Most of our data processing arises from regulatory or contractual requirements, without which we would not be able to provide the contracted services or be in compliance with applicable laws. Certain data, such as business cards and photographs we may have of you from events, is processed based on consent or legitimate interest. For the processing of data that are not central to our contractual or regulatory obligations, you have the right to withdraw your consent and request that we stop processing and to delete such data at any time.
3. Profiling and automated decision-making
Satgana does not use data profiling or automated decision-making as per Art. 22 and recital 71.
4. Third-party data processing
Satgana's data systems are maintained and backed-up by an external IT service provider which is also located in Luxembourg and is complying with GDPR requirements.In order to fulfil our obligations arising from contract or applicable laws, certain personal data may be transmitted to other service providers or regulatory authorities.Due diligence is performed on such third parties to ensure that they are complying with GDPR.Innpact shall be held liable for any kind of technical incidents that may occur during electronic transmission (including infection by virus, worm, etc.)
5. Transfer to third countries
To the extent practicable, Satgana avoids transferring your data to non-EU countries or to countries without EU equivalent data protection. To the extent required for the working relationships between service providers and between us and our clients, some data may be transferred outside of the EU, such as to affiliates of service providers or providers of IT cloud solutions. In such cases, prior due diligence is performed to ensure that service providers only transfer data to their affiliates which are compliant with GDPR and that the IT cloud solutions chosen have implemented GDPR compliant security measures.

The commitments relating to the protection of personal data herein shall apply mutadis mutandis to all data processors identified by Innpact.
6. Provision of data
Personal data relating to directors and officers must be provided in order to enable Satgana to perform its services. Certain data relating to representatives of investors and contractual counterparties are also required to be provided to enable effective notification to the respective parties.
7. Storage of personal data
Any and all personal data will not be retained for longer than necessary in order to fulfil our obligations arising from contract or applicable laws. For those data processes which are not strictly necessary for the fulfilment of our obligations arising from contract or applicable laws, you have the right to object to the processing and storage of your data and the right to request for your data to be securely deleted.
8. Your rights as a data subject
Please find below an outline of the most pertinent rights you have as data subjects vis-à-vis Satgana. The exhaustive list of your rights as data subject can be found in Art.15-22 and Art. 77 of the GDPR.

- Right to access (Art. 15 GDPR), rectification (Art. 16 GDPR), erasure (Art. 17+19 GDPR)
You have the right to see what personal data we have of you in our files.

If you spot an error in your personal data in our files, or that it is no longer up to date, you have the right to request that it is rectified.

Any of your personal data we have in our files will be deleted upon request, unless Satgana has an overriding obligation to maintain the data such as arising from contract or applicable laws.

- Right to restriction of processing (Art. 18+19 GDPR)

We will limit the ways and purposes your personal data is processed upon request, unless there are overriding obligations arising out of contract or applicable laws.

- Right to data portability (Art. 20 GDPR)

You have the right to request that your personal data is transferred from Satgana to another recipient of your choosing.

- Right to object (Art. 21+22 GDPR)

You have the right to object to the processing of your data by Satgana and to request Satgana to stop processing your data. In such case Satgana will stop processing your data unless there are overriding obligations such as those arising from contract or applicable laws.

- Right to complain (Art. 77 GDPR)
You have the right at all times to lodge a complaint with regarding the processing of your data, whether to Satgana or directly to a national data protection authority of a European Union Member State.
To access, modify or erase your data, kindly contact us at jointhejourney@satgana.com