Privacy policy: Grounded Investment Company

Version 1.0 October 2023

We are Grounded Investment Company B.V. (Netherlands registration number 863567721, website address https://groundedinvestmentcompany.com) and this is our plan of action when it comes to protecting your privacy. We respect your privacy and take the protection of personal information very seriously.

The purpose of this policy is to describe the way that we collect, store, use, and protect information that can be associated with you or another specific natural or juristic person and can be used to identify you or that person (personal information).

  1. Audience
    1. This policy applies to you if you are a visitor to our website.
  2. Personal information
    1. Personal information includes:
      1. certain information that we collect automatically when you visit our website;
      2. certain information collected on form submission; and
      3. optional information that you provide to us voluntarily (see below);
        But excludes:
      4. information that has been made anonymous so that it does not identify a specific person;
      5. permanently de-identified information that does not relate or cannot be traced back to you specifically;
      6. non-personal statistical information collected and compiled by us; and
      7. information that you have provided voluntarily in an open, public environment or forum including any blog, chat room, community, classifieds, or discussion board (because the information has been disclosed in a public forum, it is no longer confidential and does not constitute personal information subject to protection under this policy).
      8. Personal information includes information we collect automatically when you visit our website, on submission, and from you voluntarily. It excludes anonymous, de-identified, non-personal statistical, and public information.
      9. Common examples of the types of personal information which we may collect and process include your:
        1. identifying information – such as your name;
        2. contact information – such as your phone number or email address;
        3. address information – such as your physical or postal address;
        4. organisation information – such as your company name and address.
  3. Acceptance
    1. Acceptance required: You are deemed to accept all the terms of this policy when you submit a form or email us directly. 
    2. Legal capacity: You may not access our website or request our services if you are younger than 18 years old or do not have legal capacity to conclude legally binding contracts.
    3. Deemed acceptance: If you accept (or are deemed to accept this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.
    4. Your obligations: You may only send us the personal information of another data subject where you have their permission to do so.
  4. Changes
    1. We may change the terms of this policy at any time by updating this web page. We will notify you of any changes by placing a notice in a prominent place on the website or by sending you an email detailing the changes that we have made and indicating the date that they were last updated.
    2. If you do not agree with the changes, then you must stop using the website.
    3. If you continue to use the website following notification of a change to the terms, the changed terms will apply to you and you will be deemed to have accepted those updated terms.
  5. Collection
    1. From browser: We collect certain information from your web browser, including your Internet usage information when you visit our website.
      1. We automatically receive and record Internet usage information on our server logs from your browser, such as your Internet Protocol address (IP address), browsing habits, click patterns, version of software installed, system type, screen resolutions, colour capabilities, plug-ins, language settings, cookie preferences, search engine keywords, JavaScript enablement, the content and pages that you access on the website, and the dates and times that you visit the website, paths taken, and time spent on sites and pages within the website (usage information).
      2. Please note that other websites visited before entering our website might place personal information within your URL during a visit to it, and we have no control over such websites. Accordingly, a subsequent website that collects URL information may log some personal information.
    2. Cookies: We collect certain information from cookies that we may send to your computer to try and give you a personalised experience.
      1. We may place small text files called ‘cookies’ on your device when you visit our website. These files do not contain personal information, but they do contain a personal identifier allowing us to associate your personal information with a certain device. These files serve a number of useful purposes for you, including:
        1. tailoring our website’s functionality to you personally by letting us remember your preferences;
        2. improving how our website performs;
        3. allowing third parties to provide services to our website; and
        4. helping us deliver targeted advertising where appropriate in compliance with the applicable laws.
      2. Your internet browser generally accepts cookies automatically, but you can often change this setting to stop accepting them. You can also delete cookies manually. However, no longer accepting cookies or deleting them will prevent you from accessing certain aspects of our website where cookies are necessary. Many websites use cookies and you can find out more about them at www.allaboutcookies.org.
      3. Third party cookies: Some of our business partners use their own cookies or widgets on our website. We have no access to or control over them. Information collected by any of those cookies or widgets is governed by the privacy policy of the company that created it, and not by us.
      4. Web beacons: Our website may contain electronic image requests (called a single-pixel gif or web beacon request) that allow us to count page views and to access cookies. Any electronic image viewed as part of a web page (including an ad banner) can act as a web beacon. Our web beacons do not collect, gather, monitor or share any of your personal information. We merely use them to compile anonymous information about our website.
      5. Optionals details: You may also provide additional information to us on a voluntary basis (optional information). This includes content or documents that you decide to upload or download from our website or when you leave comments, fill in contact forms, respond to surveys, or otherwise use the optional features and functionality of our website.
      6. Purpose for collection: We may use or process any information that you provide to us for the purposes that you indicated when you agreed to provide it to us. Processing includes gathering your personal information, disclosing it, and combining it with other personal information. We generally collect and process your personal information for various purposes, including:
        1. respond to general enquiries – such as contact form submissions;
        2. respond to funding applications;
        3. business purposes – such as business planning, joint ventures, or other proposed and actual transactions; and
        4. legal purposes – such as complying with regulations, or pursuing good governance.
          We may use your usage information for the purposes described above and to:
        5. remember your information so that you will not have to re-enter it during your visit or the next time you access the website;
        6. monitor website usage metrics such as total number of visitors and pages accessed; and
        7. track your entries, submissions, and status in any activities in connection with your usage of the website.
      7. Consent to collection: We will obtain your consent to collect personal information:
        1. in accordance with applicable law;
        2. when you provide us with any information.
  6. Use
    1. Our obligations: We may use your personal information to fulfil our obligations to you.
    2. Messages and updates: We may send administrative messages and email updates to you about the website. In some cases, we may also send you primarily promotional messages. You can choose to opt-out of promotional messages.
  7. Disclosure
    1. Sharing: We may share your personal information with third parties for the purposes of fulfilling our obligations to you among other purposes.
      1. We may share your personal information with:
        1. other divisions or companies within the group of companies to which we belong so as to provide joint content and services, for transactions and support, to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our communications (they will only use this information to send you marketing communications if you have requested their goods or services);
        2. an affiliate, in which case we will seek to require the affiliates to honour this privacy policy;
        3. our goods or services providers under contract who help provide certain goods or services or help with parts of our business operations (our contracts dictate that these goods or services providers only use your information in connection with the goods or services they supply or services they perform for us and not for their own benefit);
        4. credit bureaus to report account information, as permitted by law;
        5. banking partners as required by credit card association rules for inclusion on their list of terminated merchants (in the event that you utilise the services to receive payments and you meet their criteria);
        6. our third party suppliers who provide us with their goods; and
        7. other third parties who provide us with relevant services where appropriate.
      2. Regulators: We may disclose your personal information as required by law or governmental audit.
      3. Law enforcement: We may disclose personal information if required:
        1. by a subpoena or court order;
        2. to comply with any law;
        3. to protect the safety of any individual or the general public; and
        4. to prevent violation of our customer relationship terms.
      4. No selling: We will not sell personal information. No personal information will be disclosed to anyone except as provided in this privacy policy.
      5. Marketing purposes: We may disclose aggregate statistics (information about the customer population in general terms) about the personal information to advertisers or business partners.
      6. Employees: We may need to disclose personal information to our employees that require the personal information to do their jobs. These include our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel.
      7. Change of ownership: If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we may assign our rights to the personal information we process to a successor, purchaser, or separate entity. We will disclose the transfer on the website. If you are concerned about your personal information migrating to a new owner, you may request us to delete your personal information.
  8. Security
    1. We take the security of personal information very seriously and always do our best to comply with applicable data protection laws. Our hosting company will host our website in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. We authorise access to personal information only for those employees who require it to fulfil their job responsibilities. We implement disaster recovery procedures where appropriate.
  9. Accurate and up to date
    1. We will try to keep the personal information we collect as accurate, complete and up to date as is necessary for the purposes defined in this policy. From time to time we may request you to update your personal information on the website. You are able to review or update any personal information that we hold on you by emailing us (gic@grounded.co.za). Please note that in order to better protect you and safeguard your personal information, we take steps to verify your identity before granting you access to your personal information or making any corrections to your personal information.
  10. Retention
    1. We will only retain your personal information for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless:
      1. retention of the record is required or authorised by law; or
      2. you have consented to the retention of the record.
    2. During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your personal information.
    3. We may retain your personal information in physical or electronic records at our discretion.
  11. Transfer to another country
    1. We may transmit or transfer personal information outside of the country in which it was collected to a foreign country and process it in that country. Personal information may be stored on servers located outside the country in which it was collected in a foreign country whose laws protecting personal information may not be as stringent as the laws in the country in which it was collected. You consent to us processing your personal information in a foreign country whose laws regarding processing of personal information may be less stringent.
  12. Updating or removing
    1. You may choose to correct or update the personal information you have submitted to us by contacting us via email (gic@grounded.co.za).
  13. Limitation
    1. We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third-party websites.
  14. Enquiries
    1. If you have any questions or concerns arising from this privacy policy or the way in which we handle personal information, please contact us via email (gic@grounded.co.za).