# Privacy Policy

At **OceUp**, we respect your privacy and are committed to protecting it through our compliance with this policy.

This Privacy Policy outlines how we collect, use, and safeguard your personal data when you use our platform. By using **OceUp** (the “Platform” or website https//[www.oceup.net](http://www.oceup.net)), you agree to the terms outlined in this Privacy Policy.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may and likely will change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

**Children under Age of 18**

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will immediately delete that information. If you believe we might have any information from or about a child under 18, please contact us at <contact@oceup.net>.

**Information that we collect about you**

We collect several types of information from and about users of our Website, including information:

* ● By which you may be personally identified, such as your name or e-mail or any other identifier by which you may be contacted online or offline ("personal information");
* ● For registered StartUps on the platform, information regarding your StartUp that you provide to us;
* ● For registered investors on the platform, information regarding your investor profile;
* ● To fulfill any other purpose for which you provide it.

We collect this information:

* ● Directly from you when you provide it to us.
* ● Automatically as you navigate through the site. Information collected automatically may include usage details and information collected through cookies.
* ● From third parties, for example, our business partners.

**Information your provide to Us**

The information we collect on or through our Website may include:

* ● Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
* ● Records and copies of your correspondence (including email addresses), if you contact us.
* ● Your responses to surveys that we might ask you to complete for research purposes.
* ● Your search queries on the Website.

You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties through chats with prospective, investors, StartUps, buyers, sellers, or advisors (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

**Information We Collect Through Automatic Data Collection Technologies**

As you navigate through and interact with our Website, we use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

* ● Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
* ● Information about your computer and internet connection, operating system, and browser type

The information we collect automatically may include personal information. We collect this information because it helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

* ● Estimate our audience size and usage patterns
* ● Store information about your preferences, allowing us to customize our Website according to your individual interests.
* ● Speed up your searches.
* ● Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

* ● **Cookies (or browser cookies)**. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
* ● **Analytics Software**. We subscribe to and use Google Analytics and Hubspot in order to collect information that will improve our capabilities to provide our services to you.

**Information Provided Voluntarily For Use Of Services**

We collect information that you voluntarily provide to us in order to fulfill a request, such as when you sign up to use our services and website, request support from our support team, write to us by email, complete a contact form, want to use our services, or communicate with us in any way. This information includes your name and surname, company name, physical address, email address, and certain types of business information of your business such as client payment information, revenue, analytics information regarding your website, customer churn, customer lifetime and other metrics and data, as well any other information you provide to us regarding your business.

**Third-Party Use of Cookies**

Some content or applications on the Website are served by third-parties such as content providers application providers, such as Google Analytics and Hubspot like we mentioned above. These third parties use cookies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services.

**How We Use Your Information**

We use information that we collect about you or that you provide to us, including any personal information:

* ● To present our Website and its contents to you.
* ● To facilitate the listing of your investor, StartUp, buyer, seller, or advisor profile on the Website.
* ● To provide you with information, products, or services that you request from us, including without limitation, (for startup users) displaying authorized business information of startups to certain potential buyers.
* ● To fulfill any other purpose for which you provide it.
* ● To provide you with notices about your account, including expiration and renewal notices.
* ● To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
* ● To notify you about changes to our Website or any products or services we offer or provide through it.
* ● To allow you to participate in interactive features on our Website.
* ● In any other way we describe when you provide the information.
* ●For any other purpose with your consent.

With your consent, we will use your information to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see “Your Information Rights and Controls” below.

**Sale of Personal Information**

Please note that we do not sell your personal information to anyone.

**Disclosure of Your Information**

We may disclose aggregated information about our users, and information that does not identify any individual or otherwise fall under the definition of “Personal Information,” “Personal Data,” or any other similar definition under any regulation, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

* ● To our subsidiaries and affiliates so that we can provide our services to you.
* ● To contractors, service providers, and other third parties we use to support our business so that we can provide our services to you.
* ● To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
* ● To fulfill the purpose for which you provide it.
* ● For any other purpose disclosed by us when you provide the information.
* ● With your consent.

We may also disclose your personal information:

* ● To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
* ● To enforce or apply our Terms of Use and Investor/Buyer and StartUp/Seller Terms of Use and other agreements, including for billing and collection purposes.
* ● If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

**Your Information Rights and Controls**

The General Data Protection Regulation (“GDPR”), gives rights to individuals over their personal information. While the following rights are specific to members of the European Economic Area (EEA), when feasible we provide all of our users the same rights as the GDPR offers to members of the EEA.

Please see your rights and their descriptions in the following table.

**It is your right to:**

* **Access**Be informed of the personal information we process about you and to request access to it
* **Rectification** Request that we amend or update your personal information where it’s inaccurate or incomplete
* **Erasure**Request that we delete certain portions of your personal data under certain circumstances
* **Restriction** Request that we temporarily or permanently stop processing all or some of your personal information
* **Object** Object to us processing your personal information at any time, on grounds relating to your particular situation
* Object to your personal information being processed for direct marketing purposes
* **Data portability**Request a copy of your personal information in electronic format and the right to transmit that personal information for use in another party’s service
* **Not subject to automated decision-making** Not be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect

**How to Exercise Your Rights With Us**

* **Access**: To make a verifiable request for information about the personal information we have collected about you, please email <contact@oceup.net>. Please note that almost all, if not all, of the information that we collect from you will be contained in your account profile on the platform.
* **Rectification**: You can edit your personal information in your account profile on our platform.
* **Erasure**: You may exercise this right by emailing <contact@oceup.net>. Please note that if you request the erasure of your personal information:
* ● We may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention and enhancing safety. For example, if we suspend an Oceup account for fraud or safety reasons, we may retain information from that OceUp account to prevent that person from opening a new OceUp account in the future.
* ● We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, OceUp may keep your information for tax, legal reporting and auditing obligations, or as record of any dispute with you.
* ● Some copies of your information (e.g., email) will remain in our database, but are disassociated from personal identifiers and are kept for record-keeping purposes only.
* **Restriction**: You may exercise this right by emailing <contact@oceup.net> or by discontinuing your use of the platform.
* **Object**: You may exercise this right by emailing <contact@oceup.net>.
* **Data portability**: You may exercise this right by emailing <contact@oceup.net>.
* **Automated decision-making**: You may exercise this right by emailing <contact@oceup.net>. However, please know that we do not exercise any sort of automated decision-making. All of our decisions regarding your profile are made internally by our support staff.

You also have the right to contact your local data protection authority about any questions or concerns.

**Data Retention and Deletion**

We will keep your personal information only as long as necessary to provide you with the services available on the OceUp platform and for our legitimate and essential business purposes.

**Deletion**

If you close or request that we close your account, we'll delete, or de identify or anonymize your personal data so it no longer identifies you, unless we're required to keep something or we still need to use it for a legally justifiable reason.

Here are some examples of situations where we're legally allowed or required to keep some of your personal data:

If there's an unresolved issue relating to your account, such as an outstanding credit or unresolved claim or dispute for our legal, tax, audit and accounting obligations for our legitimate business interests such as fraud prevention or to maintain security.

**Data Security**

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

**Changes to Our Privacy Policy**

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

**Contact Information**

To ask questions or comment about this privacy policy and our privacy practices, contact us and our Data Protection Officer at <contact@oceup.net>.

To register a complaint or concern, please email <contact@oceup.net>.

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