Last updated: 21 May 2018

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The Ground_Up Project is a leading data aggregator for small-scale projects with an environmental and social impact. The Ground_Up Project Platform offers a set of tools for investors and for entrepreneurs on which they may do many things, including submitting, exchanging, and analyzing information.

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The Ground_Up Project respects your privacy and is committed to protecting it. This Privacy Policy describes The Ground_Up Projects’ policies and procedures on the collection, use and disclosure of your personal information when you use The Ground_Up Project Platform. We will not use or share your confidential information with anyone except as described in this Privacy Policy. This Privacy Policy does not apply to information we collect from other sources.

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From time to time, The Ground_Up Project may, in its sole discretion, update this Privacy Policy in order to reflect changes in its practices. The date at the top of this page indicates when this Privacy Policy was last updated. Whenever such changes are made, The Ground_Up Project will post an updated Privacy Policy on The Ground_Up Project Platform and may email registered users. The Ground_Up Project will provide at least 10-days' notice before any material changes take effect. If you do not agree with the modified Privacy Policy, please discontinue using The Ground_Up Project Platform.

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Scope of this Privacy Policy

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This Privacy Policy applies only to your relationship with The Ground_Up Project. It does not apply to the interactions that you have with any other individual, entity, investor or other group through The Ground_Up Project Platform. The Ground_Up Project has no control over this disclosure or sharing, and is not responsible for it.

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This Privacy Policy describes the types of information we may collect from you or that you may provide when you use The Ground_Up Project Platform, and our practices for collecting, using, maintaining, protecting and disclosing that information.

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This Privacy Policy applies to information we collect:

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1. On The Ground_Up Project Platform

2. In e-mail, text and other electronic messages between you and The Ground_Up Project, on the Ground_Up Project Platform or otherwise; and

3. When you interact with our links and applications on third-party websites and services.

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It does not apply to information collected by:

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1. Us offline or through any other means, including on any other website operated by The Ground_Up Project or any third party (including our affiliates and subsidiaries); or

2. Any third party (including our affiliates), including through any application or content (including advertising) that may link to or be accessible from or on The Ground_Up Project Platform.

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Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. Please read this Privacy Policy before providing us with your (personal) information. You are not obliged to provide us with any (personal) information when you navigate The Ground_Up Project Platform. If you do not agree with our policies and practices, please do not submit any (personal) information if your choice is not to use The Ground_Up Project Platform. By accessing or using The Ground_Up Project Platform, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of The Ground_Up Project Platform after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

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Definitions

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This Privacy Policy is a part of the Terms of Service for The Ground_Up Project Platform. The terms “The Ground_Up Project,” “The Ground_Up Project Platform,” as well as all other capitalized terms not otherwise defined in the Privacy Policy have the same meaning set forth in The Ground_Up Project Terms of Service.

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What is “personal data”?

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"Personal data" is any data that (1) is recorded in any form, (2) is about or pertains to a specific individual and (3) can be linked to that individual. For example, and without limitation, your first and last names, address, email address, telephone number and other contact information, and your project information are "personal data."What is “personal data”?

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Personal data does not include website data, aggregated data, or uploaded documents.

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What kind of personal data is collected?

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We collect personal data at different stages of your use of The Ground_Up Project Platform.

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When you visit groundupproject.net, groundupproject.co.uk - If you visit www.groundupproject.net, www.groundupproject.co.uk www.theinvestmentclinic.com or use an interface which interacts with any of The Ground_Up Project websites, whether or not you sign-in as a registered user, we collect your IP address, the location of your Internet Service Provider, the type and version of Internet browser that you are using, and the website from which you came. We also collect information regarding your site usage, such as the time spent on a page and the number of pages you viewed.

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When you set up an account - When you set up your account, you will be required to provide certain personal data including your name and email address. You may also be invited to provide optional personal data, such as photograph, postal address or phone number. If you choose to do so, our use of your personal data shall be governed by this Privacy Policy.

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When you interact with The Ground_Up Project Platform - We also collect personal data that you provide when you interact with The Ground_Up Project Platform such as, for example, by uploading documents, or when exchanging correspondence with us such as through support emails.

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When you use your account - We collect information that you provide or create when you use your account, such as:

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• If you provide project information, for example, information about your customers, product/service, financials, and impact. You may also include a video recording or picture. All information you put onto The Ground_Up Project Platform is confidential unless you decide to share any of it.
  If you provide any information about or personal data of a third party (such as a person's name or photograph), you are representing to The Ground_Up Project that you have all necessary authority and/or have obtained all necessary consents from such individual to enable The Ground_Up Project to collect, use and disclose his or her personal data as set forth in this Privacy Policy. If we receive a written complaint or direction from the person, we will take down his or her information and notify you that we have done so.

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How is personal data collected?

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We collect personal data directly from you when you provide it through your use of The Ground_Up Project, such as in emails or when you fill out forms that are displayed on The Ground_Up Project Platform.

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We also use cookies that are sent to your computer, or action tags that are placed on The Ground_Up Project Platform. For additional explanation on cookies and action tags, please refer to The Ground_Up Project’s Cookie Policy.

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For what purpose will my personal data be used?

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The Ground_Up Project uses your personal data to maintain your account and to provide you with services such as data analytics and portfolio aggregation on The Ground_Up Project Platform. We also use your personal data to respond to requests that you make of us, and to contact you and to provide you with information that we believe may be of interest to you.

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We may also use your name and contact information to make queries to social networking and other sites, such as LinkedIn, for a variety of purposes, including, but not limited to, verifying your identity, and showing you how you are linked or connected to other individuals who are also users of The Ground_Up Project.

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Your personal data may also be shared with other users of The Ground_Up Project Platform.

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With whom may The Ground_Up Project share personal data?

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Under certain business or legal conditions, The Ground_Up Project may have to disclose your personal data to others as follows:

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• Within The Ground_Up Project family – The Ground_Up Project may now or in the future have a parent, subsidiary or related company or companies within The Ground_Up Project family of companies. The Ground_Up Project has the right to share all personal data with all such affiliated companies.

• Service Providers - The Ground_Up Project may engage other companies and individuals to perform necessary business functions on behalf of The Ground_Up Project (e.g. outside contractors or service providers). If it is necessary to perform these functions, these companies or individuals may have access to personal data of our users. These service providers have agreed not to use the personal data for any other purpose other than providing the required services.

• Legally Required Disclosure -Under certain circumstances, disclosure of your personal data may be required by law. The Ground_Up Project may disclose your personal data (1) if, in its own best judgment, it is required to do so in order to comply with a facially valid judicial or governmental subpoena, warrant, or other order, or (2) to a government institution that has asserted its lawful authority to obtain the information, or (3) in connection with the exercise or defense of its rights.

• Change of Ownership - If ownership of The Ground_Up Project changes as a result of a merger, acquisition, or transfer to another company, your personal data may be transferred to the successor entity. If such transfer takes place, you will be notified of any material changes to the Privacy Policy and provided with the ability to opt-out of the transfer of your personal data to the successor entity.

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Can I access or change my personal data?

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All registered users of The Ground_Up Project Platform can access the personal data that The Ground_Up Project holds about them and can see it listed in their profiles. They can correct, amend, or delete this data at their convenience.

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For auditing and security purposes, The Ground_Up Project keeps a log of all users' activities, which is retained in its archives as necessary for The Ground_Up Project to fulfill its obligations. Users may, but are not guaranteed to, have access to the personal data that pertain to them. However, because the administrative and technical burden associated with the retrieval of these archived data is substantial, The Ground_Up Project charges a fee for this effort in a manner that is consistent with its actual cost. In addition, each user's right of access may be limited to the extent that providing access might infringe on a third party's privacy rights. Requests for access to this archived information are handled on a case-by-case basis, after The Ground_Up Project has verified the identity of the requestor. Inquiries should be made as provided in the section.

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Can I have my personal data deleted?

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You can have any personal data The Ground_Up Project holds concerning you deleted upon request. You may do so by emailing support@groundupproject.net

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What is Aggregated Data, and how is it used?

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Data aggregation is a process in which information is gathered and expressed in a summary form for purposes such as statistical analysis, in order to obtain information about a particular group based on specific variables. Data used for aggregation purposes are collected in a form that removes all identifiers, and may be combined with other data for which all identifiers have also been removed. The Ground_Up Project uses aggregated data to generate accurate metrics about the early stage private equity industry.

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Aggregated data are packaged and licensed to third parties such as governments, economic development agencies and financial institutions. Examples of aggregated data may include:

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• Data about the early equity space, such as number of deals in a month-to-month or quarter-to-quarter basis at various generic stages of the funding process (e.g. new deals, in-progress deals, inactive deals, and invested deals).

• Data about industries and geographies related to companies seeking investors and those successfully obtaining investments.

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What is Website Data, and how is it used?

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Website data is aggregated data about the overall traffic to, and usage of The Ground_Up Project Platform. Examples include the number of visitors to the groundupproject.net and www.theinvestmentclinic.com website and the number of registered users of The Ground_Up Project Platform. The Ground_Up Project may extract and use website data for internal purposes, in order to analyze the performance of The Ground_Up Project Platform and applications. For example, we may use these data for traffic analysis and business decision making, in order to determine how we can improve our site or its functionalities.

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The statistics generated in this manner contain no personal data and cannot be used to gather any information about individual visitors to the site.

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What security measures are in place to protect my personal data?

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Because the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of personal data on an international basis. Therefore, by browsing The Ground_Up Project Platform and submitting personal data to us, you acknowledge our processing of your personal data accordingly.

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However, we will maintain physical, technical, and administrative procedures in order to safeguard and protect personal data provided to us through The Ground_Up Project Platform against loss, misuse, unauthorized access, disclosure, alteration, and destruction unauthorized disclosure, use, alteration, or destruction.

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The Ground_Up Project uses industry-standard technological means to protect your personal data while in transit through the Internet. We use encryption and a comprehensive authentication protocol to provide reasonable security. Please note, however, that perfect security does not exist on the Internet. Therefore, while we endeavour to protect your Personal Information, when data is transferred over the Internet it may potentially be accessed and used by unauthorised parties.

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What about Uploaded Documents? What security measures are in place to protect my personal data?

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Documents that are uploaded to The Ground_Up Project Platform for sharing are stored at a third party data-storage service. Some of the service providers The Ground_Up Project engages may be based in countries outside the European Economic Area (“EEA”). If this is the case, The Ground_Up Project shall comply with all applicable laws and take steps to ensure that your personal data receives the same level of protection as within the EEA and that it is kept and used only in accordance with our instructions and for the purposes that we have indicated to you at the time of the collection of your personal data. All uploads and downloads are transmitted through the web between users and the data storage service using the same encryption techniques as those that are used with personal data. However, uploaded documents are neither stored redundantly, nor backed up. Therefore, we recommend that The Ground_Up Project users keep back-up copies of their documents if they upload them to the groundupproject.net or groundupproject.co.uk website.

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When will The Ground_Up Project contact me?

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The Ground_Up Project will communicate with you in response to your requests for service or customer support. We will contact you by phone or by email, according to your preference.

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The Ground_Up Project will send you service-related emails if it becomes necessary to do so. The Ground_Up Project may also send you an email in order to notify you of new products, services or features, or updates to our Privacy Policy, Terms of Service, or other agreement that you have with The Ground_Up Project.

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Limitation of Liability

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The Ground_Up Project will not be liable for unauthorized disclosure of personal data that occurs through no fault of The Ground_Up Project including, but not limited to, errors in transmission, access to your account by anyone uses your user ID and password, your failure to comply with your security obligations, and the unauthorized acts of The Ground_Up Project's employees.

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Choice

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If at any time The Ground_Up Project wishes to disclose, or use your personal data in a way, or for a purpose other than as described in this Privacy Policy, The Ground_Up Project will give you the opportunity to choose whether your personal data (1) may be disclosed to a third party and (2) may be used for a purpose other than the purposes that are set forth in this Privacy Policy.

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Dispute Resolution

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If you have any concerns or claims with respect to our Privacy Policy, please contact us at: support@groundupproject.net. We will investigate and attempt to resolve any complaints and disputes regarding our use and disclosure of personal data.

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Contacting The Ground_Up Project

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The Ground_Up Project owns and operates the groundupproject.net, groundupproject.co.uk, groundup.noip.me, groundup.webhop.me, ground-up-project-com and theinvestmentclinic.com domain names and web sites and The Ground_Up Project Platform.

 

Our mailing address is The Ground_Up Project SA, c/o Comservice, Rue De-Candolle 34, 1205 Geneva, Switzerland.

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If you have any questions about this Privacy Policy, or believe that its terms have not been complied with, please email The Ground_Up Project at: support@groundupproject.net.