At ICLUB Global, your privacy matters to us, and are we committed to protecting it. This privacy policy (further referred to as “Privacy Policy”) explains what information we collect about you and why. Please read it carefully to understand what rights you have and how you can control how we handle your personal data.

WHO WE ARE & HOW THIS PRIVACY POLICY APPLIES

The ICLUB group is made up of different legal entities. In this regard, whenever dealing with one of the ICLUB group companies (the “Company”), the controller of your Data will be the company that determines the "means" and the "purposes" of any processing activities that it carries out.

1. For the management of the Website, the controller of your personal data is TA VENTURES SWISS HOLDING GmbH, a legal entity established and registered under the laws of Switzerland and having its registered address at с/o Grant Thornton AG Claridenstrasse, 35, 8002, Zurich, Switzerland identification number CHE-116.263.623;
2. For the management of the mobile applications, the controller of your personal data is TA Ventures Series LLC, registered under the laws of Delaware, file No. 7958486; (Collectively - "We", “we”, “us” and “ICLUB”, as applicable).

ICLUB group companies may share your personal data with each other and if they do so, they will use it consistently with this Privacy Policy.

This Privacy Policy is part of our Terms of Use. Unless otherwise specified, the terms used in this policy shall have the same meaning as in the Terms of Use. This Privacy Policy applies to all personal data collecting and processing activities carried out by us, across platforms, websites, and mobile applications. To the extent that you are a customer or user of our services, this Privacy Policy applies together with any terms of business and other contractual documents, including but not limited to any agreements we may have with you.

When we process your personal data, we act as a controller for such personal data processing and are regulated by the Swiss Federal Act on Data Protection, and in case of applicability the General Data Protection Regulation (which applies across the European Economic Area), or another regulation that may apply in specific cases.

By applying a check into the box next to the statement that “I agree to the Terms of Use and Privacy Policy of ICLUB” on our Website or mobile application, you provide an express consent to be legally bound by the terms and conditions of this Privacy Policy & Cookie Policy, including any amended or modified versions as may occur in the future.

ICLUB refers to an ecosystem comprising of our website (iclub.vc) (further referred to as “Website”), and mobile applications that are developed to offer ICLUB services.

WHAT PERSONAL DATA WE COLLECT

When you access and use ICLUB Website, mobile applications, and / or services, ICLUB collects the following personal data: a. full name, address, nationality, and date of birth; b. an identity document and a document proving the residential address; c. payment information (bank name; bank account owner full name; bank account owner address; account number; bank account country; IBAN; BIC/SWIFT; etc.) d. Know Your Client (KYC) data, such as wealth, income, education, previous investment experience, entities controlled by you, information about the family status, etc.); e. photographs with identifiable individuals; f. phone number, emails, and other contact information; g. other information as may be legally requested by regulatory authorities in specific cases; h. social media links; i. usage statistics of the Website, IP address, information on the device, and its location.

USE OF COLLECTED PERSONAL DATA

We will collect your personal data for the following purposes:

I. “SERVICE DELIVERY”, which means: the enforcement of the Terms of Use; the performance of the Terms of Use and the provision of the ICLUB services, research, and development to improve our services as well as the layout of and content on the Website, mobile applications.

II. “REGULATORY COMPLIANCE”, which means: activities and actions including without limitation due diligence and record-keeping to enable compliance with anti-money laundering and anti-terrorist financing compliance with the Swiss, EU, US, and global anti-money laundering and anti-terrorist financing regulations; activities and actions including without limitation record keeping to enable data privacy compliance in compliance with any applicable data privacy laws; tax compliance to enable tax compliance with Swiss tax laws; and activities and actions to enable compliance with proper requests from regulatory agencies, courts, law enforcement and other bodies and authorities where such is a legal requirement under the applicable jurisdiction.

III. “SALES AND MARKETING”, which means, subject to your explicit consent: sending you marketing and promotional materials via email, Website, or other online communication tools; to provide you with certain business management tools that improve your experience with ICLUB and our services.

IV. “STATISTICAL”, which means, subject to your explicit consent: improving your experience with a Website or our services, or more provide marketing adjusted to your preferences.

Personal data set out in para. a-g in Section “What personal data we collect” is strictly necessary for the purposes of ICLUB “Services Delivery” and / or “Regulatory Compliance”. You can object or restrict in certain cases to such processing of personal data but please note that such data processing is strictly necessary to provide you with our services, and in this case, ICLUB will not be able to perform our services in a proper manner. In such case, ICLUB may terminate your use and / or access to all or part of our services without incurring any liability whatsoever.

Additionally, ICLUB collects personal data mentioned in para. f, h in Section “What personal data we collect” for the “Sales and Marketing” purposes and personal data mentioned in para. i for “Statistical” purpose subject to your explicit, informed, and unambiguous consent. You can withdraw your consent at any time for such specific data processing if you send the request to legal@taventures.vc.

HOW LONG YOUR PERSONAL DATA WILL BE KEPT

We will hold all the information referenced above that we collect in support of Regulatory Compliance for 5 years, or for as long as necessary to comply with the applicable regulations.

Personal data collected for other purposes (except for the Regulatory Compliance purpose) for as long as necessary to ensure the completion of such applicable purposes.

COOKIES

ICLUB also uses cookies to provide, promote, or measure traffic and usage of our services. More information on the use of cookies is set forth below in the Cookies Policy.

YOUR RIGHTS

According to an applicable data protection regulation (the Swiss Federal Act on Data Protection, the General Data Protection Regulation, etc., depending on where you live), you have a range of important rights that you may exercise anytime and free of charge:

1. fair processing and transparency over how we use and receive your personal data;
2. have access to your personal data and receive your personal data in a structured, commonly used, and machine-readable format and have the right to transmit those data to a third party in certain situations;
3. require us to correct any mistakes in personal data we collected or require the erasure of personal data concerning you in certain cases;
4. object at any time to the processing of your personal data in case of direct marketing;
5. object to decisions being taken by automated means which produce legal effects for you or affect you in any substantial way;
6. object or restrict in certain cases our processing of your personal data as well as claim compensation for damages caused by our violation of any data protection laws.
7. If you would like to exercise any of those rights, please contact us at legal@taventures.vc. After we identify you in a sufficient manner, we will provide you with your personal data as requested within 3 business days.

KEEPING YOUR PERSONAL DATA SECURE

We are committed to protecting the security of your personal data. ICLUB has appropriate technical and organizational measures to prevent and avoid data breaches or any other unauthorized access and / or disclosure of your personal data.

We also have necessary data breach response plans to deal with any suspected violations. We will make sure to notify you and / or any respective regulatory authority of such a data breach if we are legally required to do so. We will also provide information on further protective steps.

THIRD-PARTY SERVICE PROVIDERS

Some third-party services that work with us can ask for your approval to access your personal data. Please consider if you give your consent for such access, as any personal data collected by third-party service providers are subject to the policies of such third-party service providers.

Our Website or mobile application may also contain links to other websites. Please take into account that this Privacy Policy is not applicable to such websites, and ICLUB is not responsible for any privacy practice or personal data processing conducted by such websites and / or third-party providers.

We may share your personal data with third parties if we believe that sharing your personal data is in accordance with, or required by, any contractual relationship with you or us, applicable law, regulation or legal process. The third-party service providers only have access to personal information needed to perform their functions but may not use it for other purposes. Further, they must process the personal information in accordance with our contractual agreements and only as permitted by applicable data protection laws. In particular, we employ the following third-party provider for the purposes of ensuring KYC and AML compliance: Sumsub (Sum and Substance Ltd.). For your convenience please find their privacy policy by the link https://sumsub.com/privacy-notice-service.

INTERNATIONAL DATA TRANSFERS

Within ICLUB, access to your personal data is provided only to fulfill our contractual and legal obligations, preserve legitimate interests, or provide our services in a proper manner. For other cases, we make sure to obtain your consent before sharing your personal data with others.

Access to any personal data is permitted only by legal entities of ICLUB, its affiliates or subsidiaries worldwide, and third-party service providers located in:

1. Switzerland;
2. countries offering an adequate level of data protection as specified in the list of countries published by the Swiss Federal Data Protection and Information Commissioner.
3. selected jurisdictions: Ukraine, the USA, Cyprus.

ICLUB, its affiliates, and our third-party service providers are required by law and / or contract to keep your personal data confidential unless other is required by law. We make sure to provide technical and organizational measures to safeguard your personal data from potential data breaches and misuse.

GOVERNING LAW AND JURISDICTION

This Privacy Policy shall be governed by Swiss law (including, the Swiss Federal Act on Data Protection) at the exclusion of any provisions of the conflict of law rules that might lead to the application of other than Swiss law.

We hope to resolve any of your concerns regarding this Privacy Policy or our use of data. You also have a right to lodge a complaint with a supervisory authority, depending on where you live (the Federal Data Protection and Information Commissioner in Switzerland, or a respective data protection supervisory authority in the EU, if you are an EU resident, etc.).

You irrevocably agree to the exclusive jurisdictions of the competent court of Switzerland in case of any conflict arising in connection with this Privacy Policy.

AMENDMENTS TO THIS PRIVACY POLICY

This Privacy Policy was updated on 6 December 2024.

ICLUB keeps evolving, and we may need to update this Privacy Policy in the future to keep it in line with our services, applicable laws, or regulations. In case of any substantial changes to this Privacy Policy that will have an impact on your rights, we will make sure to notify you by email or other any other convenient way.

Please note that if you continue using ICLUB Website or mobile application and services after any changes, it means that you agree and provide consent to any such changes. If you disagree with any changes, please stop using our website, mobile application and services.

HOW TO CONTACT US

Please contact legal@taventures.vc if you have any questions concerning this Privacy Policy or personal data we hold about you.