Privacy Policy

1. Introduction and Data Controller Identity

Elinuse AI Capital ("we," "us," "our," or "the Company") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website at elinuseai.org, contact us, or otherwise interact with us.

Elinuse AI Capital is the data controller responsible for your personal information. Our registered address is Boston, Massachusetts, United States. We were founded in 2022 and manage $95 million in assets under management as a seed-stage venture capital fund focused on European fintech and insurtech.

We are committed to compliance with applicable privacy laws, including the General Data Protection Regulation (GDPR) where it applies to individuals in the European Economic Area and United Kingdom, and other applicable data protection legislation. Please read this policy carefully to understand our practices regarding your personal data and how we will treat it.

If you have questions about this Privacy Policy or our privacy practices, you may contact us at: privacy@elinuseai.org.

2. Information We Collect

2.1 Information You Provide Directly

We collect information you provide when you interact with us, including:

• Contact form submissions: When you submit our contact form, we collect your name, email address, company name, role, the nature of your inquiry, and any other information you choose to include in your message.
• Email correspondence: When you send us emails, we receive and store the contents of those messages along with your email address and any personal information included in the communication.
• Pitch deck and investment materials: If you are a founder submitting materials for investment consideration, we collect information about you, your team, your business, and your financial projections as included in those materials.
• Event registrations: If you register for events we organize or co-host, we collect registration information including your name, email address, company, and role.
• Newsletter subscriptions: If you subscribe to our insights newsletter or other communications, we collect your email address and communication preferences.

2.2 Information Collected Automatically

When you visit our website, we and our service providers automatically collect certain technical information, including:

• Log data: Your IP address, browser type and version, operating system, referring URLs, pages visited, time and date of visits, and time spent on pages.
• Device information: Device type, screen resolution, and other technical characteristics of your device.
• Cookie data: Information collected through cookies and similar tracking technologies, as described in our Cookie Policy.
• Analytics data: Aggregated information about how visitors use our website, including which pages are most frequently visited and how users navigate between pages.

2.3 Information from Third Parties

We may receive information about you from third parties in the following circumstances:

• Referrals: When a mutual contact refers you to us as a potential portfolio founder or industry contact, we may receive your contact information and a brief introduction.
• Professional networks: We may gather publicly available information from professional networking sites such as LinkedIn in the course of our investment research and due diligence activities.
• Data enrichment providers: We may use commercially available data enrichment services to supplement contact information for investment research purposes.
• Co-investors and industry contacts: Fellow investors or industry participants may share contact information or introductions for legitimate professional purposes.

3. How We Use Your Information

We use the personal information we collect for the following purposes, each supported by an appropriate legal basis:

3.1 Responding to Inquiries and Managing Relationships (Legitimate Interest / Contract)

We use your contact information and the details of your inquiry to respond to questions you submit through our contact form or via email. For founders who submit investment materials, we use your information to evaluate investment opportunities, conduct due diligence, and manage the relationship through the investment process. Our legitimate interest in maintaining efficient business communications and our potential contractual relationship with portfolio founders provides the legal basis for this processing.

3.2 Operating and Improving Our Website (Legitimate Interest)

We use automatically collected technical data to operate our website securely, troubleshoot technical issues, analyze usage patterns, and improve the quality and relevance of our content. Our legitimate interest in maintaining an effective and secure online presence provides the legal basis for this processing.

3.3 Sending Marketing Communications (Consent)

If you have opted in to receive our insights newsletter or other marketing communications, we use your email address to send you those communications. You may withdraw your consent and unsubscribe at any time using the unsubscribe link in any marketing email or by contacting us directly at privacy@elinuseai.org. Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal.

3.4 Legal Compliance and Enforcement (Legal Obligation / Legitimate Interest)

We may process personal information as necessary to comply with our legal obligations, including financial record-keeping requirements, anti-money laundering regulations applicable to our investment activities, and responses to lawful requests from competent authorities. We may also process information to establish, exercise, or defend legal claims.

3.5 Investment Research and Due Diligence (Legitimate Interest)

In the ordinary course of our venture capital activities, we collect and process information about founders, company executives, and other individuals in connection with potential investments. This includes information from public sources, materials submitted by companies seeking investment, and information gathered through reference checks. Our legitimate interest in conducting appropriate due diligence on investment opportunities provides the legal basis for this processing, subject to applicable data subject rights.

4. Data Sharing and Disclosure

4.1 Service Providers

We share personal information with trusted third-party service providers who assist us in operating our website and conducting our business. These service providers are contractually bound to use personal information only for the purposes for which we have engaged them and to implement appropriate security measures. Categories of service providers include: website hosting and infrastructure providers, email service providers, analytics services, customer relationship management software providers, and legal and accounting advisers.

4.2 Co-Investors and Fund Administrators

In connection with investment activities, we may share relevant information about founders or companies with our limited partners, co-investors, or fund administrators, to the extent necessary for legitimate fund administration and investment monitoring purposes. We require recipients to treat such information confidentially.

4.3 Legal Requirements

We may disclose personal information if required to do so by law, regulation, or court order, or if we believe in good faith that such disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

4.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or a portion of our assets, personal information held by us may be transferred to the acquiring entity. We will provide notice before personal information is transferred and becomes subject to a different privacy policy.

4.5 What We Do Not Do

We do not sell personal information to third parties. We do not share personal information with advertisers for the purpose of behavioral advertising. We do not use personal information for automated decision-making with legal or similarly significant effects without appropriate human oversight and safeguards.

5. International Data Transfers

Elinuse AI Capital is headquartered in Boston, Massachusetts, United States. If you are located in the European Economic Area, the United Kingdom, or another jurisdiction with data transfer restrictions, please be aware that your personal information may be transferred to and processed in the United States, which may not provide the same level of data protection as your home jurisdiction.

Where we transfer personal data from the EEA or UK to third countries, we implement appropriate safeguards including Standard Contractual Clauses approved by the European Commission, where required, to ensure adequate protection of transferred data.

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required by law. Specific retention periods include:

• Contact form inquiries and general correspondence: Three years from the date of last contact, unless an ongoing relationship develops.
• Investment materials and due diligence records: Seven years from the date of last contact or investment decision, to comply with applicable financial records requirements.
• Portfolio company records: Duration of the investment relationship plus seven years, in accordance with fund administration and regulatory requirements.
• Website analytics data: Twenty-six months from collection, in accordance with our analytics provider's standard retention periods.
• Marketing email records (consent records): Three years from the date consent was last confirmed or withdrawn.

When personal information is no longer needed, we delete or anonymize it in a secure manner, or, where deletion is not immediately possible, securely store and isolate it from further processing until deletion is possible.

7. Your Rights Under GDPR and Applicable Privacy Laws

If you are located in the European Economic Area or United Kingdom, you have the following rights with respect to your personal information, subject to applicable exceptions:

• Right of access: You have the right to request a copy of the personal information we hold about you and to receive information about how we process it.
• Right to rectification: You have the right to request correction of inaccurate or incomplete personal information we hold about you.
• Right to erasure: You have the right to request deletion of your personal information in certain circumstances, including where it is no longer necessary for the purposes for which it was collected.
• Right to restriction of processing: You have the right to request that we restrict the processing of your personal information in certain circumstances, such as while we are investigating a dispute about its accuracy.
• Right to data portability: You have the right to receive personal information you have provided to us in a structured, commonly used, machine-readable format, and to transmit that data to another controller, where technically feasible.
• Right to object: You have the right to object to processing of your personal information based on legitimate interests, including for direct marketing purposes. Where you object to processing for direct marketing, we will cease such processing immediately.
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing prior to withdrawal.
• Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority, including the data protection authority in your country of residence or the authority where the alleged infringement occurred.

To exercise any of these rights, please contact us at privacy@elinuseai.org. We will respond to requests within 30 days. We may need to verify your identity before processing your request.

8. Security

We implement appropriate technical and organizational measures to protect personal information against unauthorized access, loss, destruction, or alteration. These measures include encryption of data in transit and at rest, access controls limiting personal data access to authorized personnel, regular security assessments of our systems, and staff training on data protection obligations.

While we take all reasonable steps to protect your personal information, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee absolute security, but we are committed to continuously improving our security practices.

9. Children's Privacy

Our website and services are not directed at individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete it promptly. If you believe we may have collected information from a child, please contact us at privacy@elinuseai.org.

10. Links to Third-Party Websites

Our website may contain links to third-party websites, including the websites of our portfolio companies and business partners. These websites operate independently of us, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party websites you visit. The inclusion of a link to a third-party website does not constitute our endorsement of that website or its privacy practices.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will update the "Last updated" date at the top of this policy. If the changes are significant, we may also provide a more prominent notice, such as an email notification to individuals who have subscribed to our communications. We encourage you to review this policy periodically to stay informed about how we protect your information.

12. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please contact us:

• Email: privacy@elinuseai.org
• Post: Elinuse AI Capital, Attn: Privacy, Boston, MA, United States

We will respond to your inquiry within 30 days. For urgent privacy concerns or if you believe your rights have been violated, you may also contact the relevant data protection supervisory authority in your jurisdiction.