Privacy Policy

Last updated May 25, 2021

PRIVACY POLICY

Thank you for choosing to be part of our community at Masawa Management GmbH, further referred to as “Masawa“, “we“, “us” and/or “our“. This privacy policy provides you with the information on how we process personal data. 

We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy policy, or our practices with regards to your personal information, please do not hesitate to contact us at hello@masawa.fund.

We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. If there are any terms or conditions in this privacy policy that you do not agree with, please terminate use of our website immediately.

Please read this privacy policy carefully as it will help you understand what we do with the information we collect.

Table of Contents

1. WHAT INFORMATION DO WE COLLECT?

 

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us, when you participate in events or activities on the website or when you otherwise contact us.

The personal information that we collect depends on the context of your interactions with us and the website, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal Information Provided by you, such as names; email addresses; and other similar information.

All personal information you provide must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

We automatically collect certain information when you visit, use or navigate the website. This information does not reveal your specific identity (like your name or contact information). However, it may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our website and other technical information. This information is primarily needed to maintain the security and operation of our website, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity on the website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet or another device you use to access the website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system and system configuration information.

Location Data. We collect location data, such as information about your device’s location, which can be precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the website. You can opt out of allowing us to collect this information by refusing access to the information or disabling location settings on your device.

 

2. HOW DO WE USE YOUR INFORMATION?

 

We use personal information collected through our website for the business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

To protect our services. We may use your information as part of our efforts to keep our website safe and secure (for example, for fraud monitoring and prevention).

To enforce our terms, conditions and policies for business purposes, comply with legal and regulatory requirements or in relation to our contract. 

To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

To send you marketing communications and promotional materials. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes if this corresponds to your marketing preferences. For example, when expressing an interest in obtaining information about us or our website, subscribing to our newsletter and marketing communications or otherwise contacting us, we will collect personal information from you. You can opt out of our marketing emails and our newsletter at any time by contacting us at hello@masawa.fund or clicking “unsubscribe” in the footer of any email you receive from us. See further information at “10. WHAT ARE YOUR PRIVACY RIGHTS?” below.

Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties to do so) tailored to your interests and/or location and to measure its effectiveness.

 

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

 

We may process or share your data that we hold based on the following legal basis:

Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.

Legitimate interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

Performance of a contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

Legal obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Other third-party service providers. We may share your data with service providers, contractors or other third parties who perform services for us or on our behalf and require access to such information to do that work. We may allow selected third parties to use tracking technology on the website, which will enable them to collect data on our behalf about how you interact with our website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this privacy policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

 

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

 

We only share and disclose your information with the following third parties. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section below titled “14. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?”.

Advertising, Direct Marketing, and Lead Generation

HubSpot CRM

Communicate and Chat with Users

HubSpot Email

Newsletter/Masawa Minute

HubSpot Email/Mailerlite

Content Optimization

Spotify Play Button widget and Google Fonts

Web and Mobile Analytics

Facebook Analytics, Google Analytics, HubSpot Analytics, All in One SEO, Yoast SEO

Website Hosting

WordPress.com

Website Testing

Autoptimize

Functionality & Infrastructure Optimization

Akismet Anti-Spam

 

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

 

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information to personalize the content, provide you with an improved Masawa experience, discover errors and improve the effectiveness of our website.

 

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

 

Our servers are located in the United States. If you are accessing our website from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above), in the United States, and other countries.

If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), the countries where the third parties are located may not necessarily have data protection laws or similar laws as comprehensive as those in your country. We will, however, take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.

European Commission’s Standard Contractual Clauses:

We have implemented measures to protect your personal information, including using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between our third-party providers and us. These clauses require all recipients to protect all personal information they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and can provide you with further details upon request.

 

7. HOW LONG DO WE KEEP YOUR INFORMATION?

 

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us to keep your personal information longer than Masawa is in operation.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

 

We have implemented appropriate technical and organizational security measures designed to protect any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, the transmission of personal information to and from our website is at your own risk. You should only access the website in a secure environment.

 

9. DO WE COLLECT INFORMATION FROM MINORS?

 

We do not knowingly solicit data from or market to children under 18 years of age. By using the website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the website. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to delete such data from our records promptly. If you become aware of any data we may have collected from children under age 18, please contact us at hello@masawa.fund.

 

10. WHAT ARE YOUR PRIVACY RIGHTS?

 

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below (14. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?). We will consider and act upon any request per applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you are a resident in the EEA or UK and believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our website. To opt out of interest-based advertising by advertisers on our website, visit http://www.aboutads.info/choices/.

 

11. CONTROLS FOR DO-NOT-TRACK FEATURES

 

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

 

12. CALIFORNIA PRIVACY RIGHTS

 

This section applies only to users based in California. It describes how we collect, use, and share California users’ personal information in our role as a business and the rights of such residents. The California Consumer Privacy Act (“CCPA”) requires businesses to disclose whether they sell personal data. Masawa is a business and does not sell personal data of any kind. We may share personal data with third parties if those third parties are authorized service providers or business partners who have agreed to our contractual limitations regarding their retention, use, and disclosure of such Personal Data.

If you are under 18 years of age, reside in California, and have a registered account with the website, you have the right to request the removal of unwanted data that you publicly post on the website. To request the removal of such data, please contact us using the contact information provided below (14. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?), and include the email address associated with your account and a statement that you reside in California. We will ensure the data is not publicly displayed on the website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

What categories of personal information do we collect?

We have collected the following statutory categories of Personal Information in the past twelve (12) months:

Identifiers, such as name, e-mail address, mailing address, and phone number. We collect this information directly from you or third-party sources.

Personal information categories listed in the California Customer Records statute such as name, contact information, education, employment, employment history and financial information

Protected classification characteristics under California or federal law such as gender and date of birth

Internet or other similar network activity such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements.

Geolocation data, such as IP address. We collect this information from your device.

Other personal information, in instances when you interact with us online, by phone or mail in the context of receiving help; participation in customer surveys or contests.

How do we use and share your personal information?

Masawa Management GmbH collects and shares your personal information through:

  • Targeting cookies/Marketing cookies
  • Social media cookies
  • Email-Marketing

You can find more information about our data collection and sharing practices in this privacy policy.

You may contact us by email at hello@masawa.fund or by referring to the contact details at the bottom of this document (14. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?).

If you are using an authorized agent to exercise your right to opt out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers according to a written contract between each service provider and us. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as undertaking internal research for technological development and demonstration. This is not considered the “selling” of your personal data.

Masawa Management GmbH has not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Masawa Management GmbH will not sell personal information in the future belonging to website visitors, users and other consumers.

Your rights concerning your personal data

Right to request deletion of the data – request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

Right to be informed – request to know

Depending on the circumstances, you have a right to know whether we collect and use your personal information; the categories of personal information that we collect; the purposes for which the collected personal information is used; whether we sell your personal information to third parties; the categories of personal information that we sold or disclosed for a business purpose; the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling personal information.

Per applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination when exercising a consumer’s privacy rights

We will not discriminate against you if you exercise your privacy rights.

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use the personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information to verify your identity and for security or fraud prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

To exercise these rights, you can contact us by email at hello@masawa.fund or by referring to the contact details at the bottom of this document (14. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?). If you have a complaint about how we handle your data, we would like to hear from you.

 

13. DO WE MAKE UPDATES TO THIS PRIVACY POLICY?

 

We may update this privacy policy from time to time. The updated version will be indicated by the updated date, and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you by prominently posting a notice of such changes or directly sending you a notification. We encourage you to frequently review this privacy policy to be informed of how we protect your information.

 

14. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?

 

If you have questions or comments about this policy, you may email us at hello@masawa.fund or by post to:

Masawa Management GmbH

Rheinsberger Straße 76/77

10115 Berlin, Germany

 

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

 

Based on the laws in force in your country, you have the right to have the personal information we have collected deleted. To delete your personal data, please contact us via email: hello@masawa.fund.

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