‍1. Applicability.
1.1.  This privacy policy (“​Privacy Policy​”) explains how Flori Ventures Fund I, and/or any of its affiliates and/or any of its brand names (“Flori”) collect, use, store and share your (“​User​”) data through Flori’s website at https://floriventures.com/ (the “​Site​”) and constitutes an integral part of the Terms of Use at floriventures.com/terms-of-use (“​TOU​”).
1.2.  By making any attempt to use the Site, or any part thereof, User agrees ​to be bound by the terms set forth hereunder.

1.3.  Flori may update this Privacy Policy from time to time. Flori will notify User of any changes by posting the new Privacy Policy on the Site. If Flori makes any changes to this Privacy Policy that materially affect Flori’s practices with regard to the personal data Flori previously collected from User, Flori will endeavor to provide User with notice in advance of such change by highlighting the change on the Site. User is advised to consult this Privacy Policy regularly for any changes. Flori will seek User’s prior consent to any material changes, if and where this is required by applicable data protection laws.

2. Data collected by Flori. The data Flori collects may consist of both personal identifiable information (“​PII​”) and data which does not constitute PII (“​Non-PII​”).

3. Personal Identifiable Information.
3.1.  PII provided by the User is comprised of information User provides Flori with on the Site, when sending Flori a CV under the “contact” section, or when contacting Flori via the contact@floriventures.com, addresses, and may include information such as User’s first name, last name, e-mail address, professional background and any additional information provided via the “Contact Us” field.

3.2.  User is under no legal obligation to submit personal data to Flori. However, in case User chooses not to submit personal data to Flori, User may not be able to use certain services provided by Flori.

4. Data collected by Third Parties.
4.1. The Site may contain links to certain third party services, websites, articles, links, icons, ads, videos, graphics, and/or any other content that is offered by third parties (“​Third Party Content​”). This Privacy Policy does not apply to any Third Party Content. Flori has no control over such third parties’ privacy practices, or the technology used by such third parties in order to collect any PII or Non-PII. Each User is advised to thoroughly review the third parties’ privacy policies before making any use of such Third Party Content.

4.2. By clicking on a link to a third-party website or service, a third party may transmit cookies to User. This Privacy Policy does not cover the use of cookies by any third parties, and Flori is not responsible for such third parties’ privacy policies and practices.

5. Google Analytics. Flori uses Google Analytics. Please click on www.google.com/policies/privacy/partners/ in order to find out how Google Analytics collects and processes data.

6. Flori’s Usage and Sharing of the collected Information.
6.1. PII and Non-PII may be used by Flori and/or anyone on its behalf as follows:

6.1.1.  For everyday business purposes, such as to process transactions, manage and administer Flori’s business and records and carry out Flori’s obligations arising from any contracts entered into between Flori and such User and to provide such User with the Site;

6.1.2.  Provide User with information about other services Flori offers that are similar to such services that User have already used or enquired about and which might interest User;

6.1.3.  Administer Flori’s Site, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

6.1.4.  Notify User(s) about changes to the Site;

6.1.5.  Undertake market research, including research and development research in connection with Flori’s technology and/or the Site; and

6.1.6.  To prevent fraud, abuse, and other actual and potential prohibited or illegal activities; to comply with legal, and regulatory requirements, security and processing requirements, and to respond to court orders and legal investigations; and

6.1.7.  Otherwise with consent or as permitted or required by applicable law.

6.2. In the following cases Flori discloses, without notification, PII, Non-PII, any communications sent or received by each User, and any other information that Flori has collected and/or was provided with:

6.2.1.  If required to do so by law according to its understanding of such law (including, but not limited to, in cases of court orders or subpoenas);

6.2.2.  To verify the information obtained by Flori;

6.2.3.  To prevent or investigate suspected fraud, or any activity that Flori believes may be illegal or may expose Flori to legal liability;

6.2.4.  Events involving potential threats to the physical safety of any person or property if Flori believes that User’s information in any way relates to that threat;

6.2.5.  If Flori believes that User’s conduct on or in connection with the Site is inappropriate and inconsistent with generally accepted norms of behavior;

6.2.6.  In addition, Flori may be required to disclose PII and Non-PII to relevant national, state and local law enforcement authorities, whom may further disclose the PII and Non-PII.

6.2.7.  In the event that Flori, or any of its businesses, are sold or disposed of, whether by merger, sale of assets or otherwise, PII and Non-PII collected hereunder may be one of the assets sold or merged in connection with such transaction. PII and Non-PII collected hereunder may also be disclosed in connection with a commercial transaction where Flori or any of its businesses are seeking financing, investment, and support or funding.

6.3.  When Flori shares User’s data with third parties as specified above, Flori requires such recipients to agree to only use the personal data Flori shares with them in accordance with this Privacy Policy and Flori’s contractual specifications and for no other purpose than those determined by Flori in line with this Privacy Policy.

6.4.  It is clarified that Flori is under no obligation to exercise its rights hereunder and shall not incur any liability with such exercise or lack of exercise of its rights.

7. Access to Information.
7.1.  Depending on applicable laws, each User may have the right to access PII and Non-PII held with respect to such User. Each User’s right of access can be exercised in accordance with the relevant data protection legislation. Any request for access may be subject to a fee to meet Flori’s costs in providing such User with details of the PII and Non-PII Flori holds on User.

7.2.  Flori will take reasonable steps to verify User’s identity before granting User access or enabling User to make corrections.

7.3.  Flori will retain PII only for the time period needed for business purposes or as required by the applicable law and will securely destroy such information thereafter.

8. Data Security. ​Flori has taken appropriate technical and organizational measures to protect any information Flori collects about User from loss, misuse, unauthorized access, disclosure, alteration, destruction, and any other form of unauthorized processing. User should be aware, however, that no data security measures can guarantee 100% security.

9. Preventing Identity Theft. ​Each User is requested to pay attention and not to be misled by emails that appear to be from Flori and ask for PII. If User receives a suspicious email requesting User’s PII, User is requested to forward such email immediately to contact@floriventures.com and specify in the subject line “Suspicious email”.

10. Users in the European Economic Area (EEA)
10.1. Legal Basis for Processing of Personal Data
Flori will only process User’s personal data if it has one or more of the following legal bases for doing so:

10.1.1. Contractual Necessity: processing of personal data is necessary to enter into a contract with User, to perform Flori’s contractual obligations to User under the TOU, to provide the Services, to respond to requests from User, or to provide User with customer support;

10.1.2. Legitimate Interest: Flori has a legitimate interest to process User’s personal data;

10.1.3. Legal Obligation: processing of User’s personal data is necessary to comply with relevant law and legal obligations, including to respond to lawful requests and orders; or

10.1.4. Consent: processing of User’s personal data with User’s consent.
10.2. User’s Rights regarding Personal Data

10.2.1. Subject to applicable law, User has certain rights with respect to User’s Personal Data, including the following:

10.2.2. User may ask whether Flori holds personal data about User and request copies of such personal data and information about how it is processed if such data is stored by Flori;

10.2.3. User may request that inaccurate personal data is corrected;

10.2.4. User may request the deletion of certain personal data;

10.2.5. User may request Flori to cease or restrict the processing of personal data where the processing is inappropriate;

10.2.6. When User consents to processing User’s personal data for a specified purpose by Flori, User may withdraw User’s consent at any time, and Flori will stop any further processing of User’s data for that purpose.

10.2.7. In certain circumstances, Flori may not be able to fully comply with User’s request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, however, in those circumstances, Flori will still respond to notify User of such a decision.

10.2.8. User can exercise User’s rights of access, rectification, erasure, restriction, objection, and data portability by contacting Flori at contact@floriventures.com​. In some cases, Flori may need User to provide Flori with additional information, which may include personal data, if necessary to verify User’s identity and the nature of User’s request.

10.3. Transfer of User’s Personal Data outside of the EEA

10.3.1. Flori currently stores User data in Google Cloud servers.

10.3.2. When transferring personal data from the EEA to the US, we rely on the EU-US Privacy Shield.

11. Compliance with Children’s Online Privacy Protection Act. ​The Site is not intended for use by minors. Flori will not knowingly collect PII and Non-PII from children, who it positively knows are under the age of 18 without the consent of a parent or a legal guardian.

12. International Storage. Each User is advised to be aware that PII Flori collects may be transferred to, processed and stored outside User’s jurisdiction , and that data protection laws in such jurisdiction where the information is collected stored and/or processed may differ from User’s jurisdiction. Each User hereby gives User’s consent to this transfer, processing and storage of User’s information outside its jurisdiction (e.g. outside the EU and/or the United States of America).

13. Law and jurisdiction. This Privacy Policy and any dispute or claim arising out of it is governed by USA law. Any dispute or claim arising out of or in connection with the Privacy Policy will be subject to the jurisdiction of the courts of Delaware, USA.
14. Contact Us. For any question with respect to this Privacy Policy, Flori’s privacy practices, or in connection with the Site, User is invited to contact Flori at contact@floriventures.com.

Dated December 2021