Privacy Policy

General disclaimer

The information contained on this website has been prepared using sources believed by Junction to be reliable. Whilst reasonable care has been taken to ensure that the facts stated herein are accurate and that the opinions and expectations contained herein are fair and reasonable, no representation or warranty, express or implied, is made by Junction or its affiliates, with respect to the fairness, completeness, correctness, reasonableness or accuracy of any information and opinions contained herein. Any opinion, estimate or projection contained herein constitutes an opinion, estimate or projection as of the date of this document, and there can be no assurance that future results will be consistent with any such opinion, estimate or projection. The information in this presentation is subject to change without notice, it may be incomplete or condensed, and it may not contain all material information concerning Junction and/or its affiliates. Without limiting the generality of the foregoing, liability for negligent misstatement in respect of the contents of, or any omission from, this document are hereby expressly excluded.

Use of the information contained in this document is at the sole risk of the user. The information (i) does not constitute an offer to sell or a solicitation of an offer to buy an interest in any fund managed by Junction; (ii) is not, and under no circumstances is it to be construed as a prospectus; and (iii) is not intended for distribution to or use by any person or entity in any jurisdiction or country where such distribution would be contrary to local law or regulation.

The information in this website is not intended and should not be construed as investment, tax, legal, financial or other advice.

The information contained on this website is proprietary information belonging to Junction. Nothing this website may not be reproduced, in whole or in part, without the written express consent of Junction. The information contained on this website is protected under the applicable copyright laws in Belgium. Unauthorized retransmission, redistribution or other reproduction or modification of information contained in this site is prohibited and may be a violation of laws, including trademark or copyright laws and could subject the user to legal action.

By entering our site, you acknowledge that you have read and agree to these terms and conditions.

Privacy statement

Please read this Privacy Statement carefully prior to using our website (the “Website”), as this will apply to your use of our Website and our Services (as defined below).

Junction Growth Partners BV, with registered office at Tervuursesteenweg 205, 3060 Bertem, Belgium and registered with the Crossroads Bank for Enterprises under number 0782.660.732 (“Junction”, “we”, “our”, “us”) takes the security of and our legal responsibilities around your personal data very seriously.  This privacy statement sets out which personal data we collect from you when you contact us, when you use our Website (as defined below).

All your Personal Data (as defined below) collected by Junction shall be processed in accordance with the applicable privacy legislation, more specifically, the European Regulation 2016/679 on the protection of personal data, together with the codes of practice, codes of conduct, regulatory guidance and standard clauses and other related legislation resulting from such Regulation, as amended or supplemented from time to time (the “Privacy Legislation”). Junction shall solely use your Personal Data for purposes mentioned in this Privacy Policy and we shall not disclose your Personal Data to any Third Parties (as defined below), unless stated otherwise in this Privacy Policy.

In this Privacy Policy you can find information on:

  • what Personal Data we collect from you and for which purpose;
  • the measures to safeguard the access to and the security of your Personal Data;
  • which Third Parties (as defined below) may have access to your Personal Data; and
  • your rights to access, rectify, and erase your Personal Data and object to the processing of your Personal Data.

 

This Privacy Policy applies to the relationship between you and Junction. Junction undertakes to process, store and utilize your Personal Data in accordance with this Privacy Policy and the provisions of the applicable Privacy Legislation.

By using the Services (as defined below), you consent to the privacy practices described in this Privacy Policy. This Privacy Policy is incorporated into and is subject to the general terms and conditions for the Services you use.

 

1. General

All capitalized terms shall have the meaning as set forth in section 2 of this Privacy Policy.

 

2. Definitions

Personal Data” means any information relating to an identified or identifiable natural person, and more specifically the information as mentioned under section 3;

Purpose” shall have the meaning as set out in section 4;

Services” means the websites and services provided by us, including but not limited to the services provided within the framework of fundraising or other investment related cooperation;

Third Parties” means any natural or legal person or entity other than Junction;

Website” means this website available at www.junctiongrowthinvestors.com

 

3. Personal data we collect

3.1. We may collect several types of Personal Data, and store it on our servers such as:

3.1.1. contact information (e.g. your name, job title, qualifications, postal address, e-mail address, phone number);

3.1.2. the profile data provided by you (e.g. profile picture, professional skills, date of birth, gender, social network profile, password, educational and work history, hobbies and any other information you may provide as part of the Junction application process);

3.1.3. any Personal Data that forms a part of business cards provided to Junction;

3.1.4. any Personal Data that forms a part of the information provided to Junction within the framework of a fundraising or other investment related documentation;

3.1.5. any additional information, relating to an individual, provided to Junction directly or indirectly through Junction’s website or online presence (e.g. by e-mail) or through Junction’s representatives;

3.1.6. any Personal Data of staff employed by Third Parties;

3.1.7. information in the framework of regulatory compliance (including KYC / AML); and

3.1.8. web behaviour information such as information related to how you use the Website (e.g. browser type, domains, page views) collected through cookies and other automated technology (section 7 ‘Cookies’).

3.2. Less commonly, but where necessary for the provision of a Service or compliance with the lawful authority, Junction may also collect special category / sensitive information including, but not limited to:

3.2.1. immigration status;

3.2.2. membership of a trade association and/or trade union; and

3.2.3. details published in the EU lists for Anti-Money Laundering Countering – Terrorism Financing and Autonomous Sanctions purposes.

3.3. Personal Data may be transferred to, stored and processed outside the European Economic Area. In the event the Personal Data is transferred outside the European Economic Area, appropriate measures will be taken.

 

4. How your Personal Data is processed – Purpose of the processing

4.1. Junction collects, uses, maintains and may share the Personal Data provided by you or collected by Junction with its affiliates, parent companies or other related companies. Junction may share your Personal Data for all purposes necessary to provide the Services. We may use the Personal Data we collect from you or about you in the following ways:

4.1.1. operate, maintain, enhance and provide features of the Services, to provide services and information that you request, to respond to comments and questions and otherwise to provide support;

4.1.2. to improve the Services, to evaluate and improve the quality of our services, and to develop new products, services, features, and functionality (including de-identified of Personal Data);

4.1.3. contact you for administrative, informational, and marketing purposes. This may include providing customer service or sending communications, including updates on promotions and events, relating to products and services offered by us and by third parties we work with. Where required under applicable law, we obtain appropriate consent to send you marketing communications;

4.1.4. comply with applicable legal requirements and industry standards and our policies;

4.1.5. enforce our general terms and conditions;

4.1.6. manage our partner and service provider relationships.

4.2. In addition, we may use information we automatically collect when you use certain Services to: (i) analyze your preferences in order to personalize or customize the Services; (ii) analyze the effectiveness of the Services; and (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed.

4.3. Furthermore, you agree that Junction is free to access, retain, and disclose Personal Data in the following events:

4.3.1. in order to be in compliance with any applicable legislation or regulations;

4.3.2. in order to perform you with Services or to fulfil our contract with you (in accordance with our legitimate interest to run our business efficiently);

4.3.3. if a law enforcement authority or other government official requests so;

4.3.4. to enforce the Junction terms of use or Privacy Policy;

4.3.5. the investigation of any suspected or actual fraudulent or illegal activity; and

4.3.6. to protect your or Junction’s safety and/or rights.

 

5. Security

5.1. Junction shall take appropriate administrative, technical and organizational measures against unauthorized or unlawful processing of any Personal Data or its accidental loss, destruction or damage, access, disclosure or use. We restrict access to Personal Data about you to those employees who need to know that information to provide Services to you. In the event of and following discovery or notification of a breach of the security of the Personal Data, or access by an unauthorized person, Junction is required by law to notify you if the breach is likely to affect your privacy.

5.2. Please be aware that no security measures are perfect or impenetrable and thus we cannot and do not guarantee that your information will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or organizational safeguards, subject to requirements under applicable law to ensure or warrant information security.

 

6. Cookies

6.1. When using the Website or the Services, Junction may collect certain information by automated means, such as cookies (small text files stored in your browser) and similar technologies, including mobile application identifiers, to improve your experience of the Website, increase security, measure use and effectiveness of the Website, identify and resolve issues and publicity purposes. We may also use cookies and other automated means for purposes such as management of the Website and other aspects of our business.

6.2. The information we collect in this manner includes IP address, browser characteristics, device characteristics, operating system version, information on actions taken on our Website (such as usage, activity logs and click-throughs), and dates and times of visits. Log data is deleted on a regular basis.

6.3. You can control cookies through your browser settings and other tools. You may be able to set your browser to disable, clear, reset or block the use of cookies or similar technologies. Please note, however, that without cookies the Website may not work properly or you may not be able to use all of its features.

6.4. Third Parties may also use cookies to collect information about your activities on our Website to understand and continue improving the performance of our Website. Please check the relevant Third Party’s website for more information about their use of cookies as they will use cookies in accordance with their own cookies policy, which may differ from our policy.

6.5. By continuing to use our Website and Services, you consent to the placement of cookies and other automated means in your browser in accordance with this Privacy Policy.

6.6. Manage cookie preferences

Cookie Settings

You can change your cookie preferences any time by clicking the above button. This will let you revisit the cookie consent banner and change your preferences or withdraw your consent right away.

In addition to this, different browsers provide different methods to block and delete cookies used by websites. You can change the settings of your browser to block/delete the cookies. Listed below are the links to the support documents on how to manage and delete cookies from the major web browsers.

Chrome;

Safari;

Firefox; 

Internet Explorer.

If you are using any other web browser, please visit your browser’s official support documents.

 

7. Disclosure to Third Parties

7.1. Other than as set out in this Privacy Policy, Junction shall not sell or otherwise disclose your Personal Data to Third Parties without obtaining your prior explicit consent, unless this is necessary for the Purpose set out in this Privacy Policy or unless we are required to do so by law.

7.2. In the event of the transfer of control over Junction, Junction may transfer your Personal Data to the Third Parties acquiring such control over Junction. In such event, Junction shall impose this Third Party to use any Personal Data strictly consistent with this Privacy Policy.

7.3. We may also share Personal Data with Third Party cloud providers and service providers who help us to provide, understand, commercialize and improve the Website and our Services and professional advisors such as accountants, solicitors, business advisors and consultants (in accordance with our legitimate interest to run our business appropriately) within the framework of the Services. We do not authorize these Third Party service providers or other professional advisors to use or disclose your Personal Data except as strictly necessary to perform any services under our supervision or to comply with applicable legislation. We seek to provide any such Third Party service provider with only the Personal Data they need to perform their specific function.

7.4. In any event, such Third Party service providers or advisor shall be obliged to treat your Personal Data in accordance with this Privacy Policy. However, we cannot be held liable for any damages, whether direct or indirect, that may result from the misuse of your Personal Data by such Third Party service providers.

 

8. Your rights as Data Subject

We want to guarantee a safe and lawful processing of Personal Data, and we assure you that your Personal Data will be processed in a straightforward and lawful way. This implies that the Personal Data will only be processed for the aforementioned, explicitly states and legal Purpose. Junction furthermore assures that the Personal Data will always be processed in an adequate, relevant and non-extensive manner.

8.1. Right for information and access

If you are concerned or have any questions about your Personal Data, and provided you are able to prove your identity, you have the right to request information and/or access to your Personal Data, which Junction holds or processes about you. We will then provide you with information and/or access to the Personal Data that is being processed and on the source of such Personal Data.

8.2. Right of rectification and right of erasure

You have the right to request us, free of charge, to correct, erase or block any inaccuracies in your Personal Data if such Personal Data would be incomplete, inaccurate or processed unlawfully. You have the right to request us, free of charge, to erase all your Personal Data collected, stored and processed by us, without unreasonable delay.

8.3. Right to object to data processing

8.4. You may withdraw your consent to the processing of your Personal Data by Junction at any time. We may solely use your Personal Data to contact you through mail to suggest certain user tests that might be interesting to you and/or for direct marketing purposes in the event that you have explicitly consented hereto. If you have consented hereto in the past, and you no longer want to receive suggestions and/or direct marketing through mail, you may at any time unsubscribe.

8.5. To exercise your abovementioned rights or any other questions concerning this Privacy Policy, please contact us by e-mail at info@junctiongrowthinvestors.com or by writing to Junction Growth Partners BV, with registered office at Tervuursesteenweg 205, 3060 Bertem, Belgium.

 

9. Data retention and deletion

We may retain information regarding you, your use of the Website and your investment related cooperation, including Personal Data, for as long as reasonably needed taking into consideration (i) our need to answer queries and resolve problems, (ii) to provide you with improved and new Services and (iii) to comply with legal requirements under applicable law(s).

 

10. Third Party websites or applications

You acknowledge and agree that certain content or services provided by Third Parties may be made available to you through the Website. You agree that such linked content or services may have their own privacy policies for which Junction cannot be held responsible. Junction does not in any way review or endorse the privacy practices of such Third Parties.

 

11. Children and our website

Junction understands the importance of protecting children’s privacy, especially in an online environment. Our Website and Services are not intentionally designed for or directed at children. It is our policy never to knowingly collect or maintain information about anyone under the age of 18 through our Website or Services. If you are under 18 years of age you must obtain the consent of a parent or guardian to submit information via our Website. Please ask them to review this information before you communicate with us.

 

12. Updates or changes to our Privacy Policy

Occasionally, we may change or update this Privacy Policy to allow us to use or share your previously collected Personal Data for other purposes. If Junction would use your Personal Data in a manner materially different from that stated at the time of the collection, we will provide you with a notice on our Website indicating that the Privacy Policy has been changed or updated and request you to agree with the updated or changed Privacy Policy.