Legal Notices

PRIIPS Regulation

Please find below key information documents according to Regulation (EU) No 1286/2014 on key information documents for packaged retail and insurance-based investment products (PRIIPs).

KID’s for Eleven Fund III Coöperatief U.A.:

English (download link)

Bulgarian (download link)

German (download link)

Hungarian (download link)

Slovak (download link)

SFDR

The European Sustainable Financial Disclosure Regulation ((EU) 2019/2088) requires Eleven Fund III Management to inform investors regarding the incorporation of ESG factors whilst investing, and report on ESG impact of the Fund. 

Eleven Fund III Management follows a code of conduct (including exclusion criteria with respect to a potential portfolio company’s business activity that are not eligible for investment) that is integrated in the investment processes. However, Eleven Fund III Management does not integrate sustainability risk nor adverse environmental and social impact effects of investments in its investment decisions because relevant information is not yet available for all securities. 

Eleven Fund III Management expects it will not consider these adverse effects in the near future because the relevant information for determining adverse impact needs to be available in the market. The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable investments.

As a manager of a qualifying venture capital fund as defined in article 3 (b) of the EuVECA Regulation, Eleven Fund III Management does not have, and does not need to have, a remuneration guideline or policy in accordance with the requirements of the EuVECA Regulation. Integration of sustainability risks whilst performing the specific tasks of the employees, is not a relevant factor, no key indicator nor a topic to be addressed in daily routine.

The Manager will not produce periodic reports in the annual account regarding sustainability and social impact of the investments.

Privacy Policy

This Privacy policy has been compiled to better serve those who are concerned with how their Personal Data or “Personally Identifiable Information” (PII) is being used online. Personal Data is any information, which can identify you as a person directly or indirectly, according to the definitions of the European data protection legislation. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our Privacy Policy carefully to get a clear understanding of what Personal Data we collect, why we collect it, what we do with it and what rights you have in protecting your privacy, as well as how we collect, use, protect or otherwise handle your Personal Data in accordance with our website.

This Privacy Policy applies to your Personal Data when you visit www.11.vc or send us information through gust.com, f6s.com, email, zoom, Eventbrite, Typeform, Mailchimp or through another channel. By using any of these channels you agree to have read and understood this Privacy Policy.

Who we are

The companies that process your personal data are:

Eleven Partners AD, represented by Martin Ouzounov,

And

Eleven Fund III Cooperatief U.A., represented by Marjolein Daamen (Director A of Eleven Fund Manager B.V) and Ivaylo Simov (Director B of Eleven Fund Manager B.V), 

And

Eleven Investments KDA, UIC 205173314, represented by Ivaylo Simov,

together hereinafter referred to as (“we”, “us”, “our”, the “joint controllers” or the “controller/-s”).

We, the aforementioned controllers, are jointly responsible for processing your personal data and have therefore concluded a specific and separate joint control agreement in accordance with art. 26 GDPR.

Although you can assert your rights mentioned below against each controller, we have set up the following central point of contact for your questions and suggestions:

address: Sofia, Bulgaria, 31 A. Malinov Blvd., 1st floor,

email: hello@11.vc

Contact person: Martin Ouzounov

Personal data we collect and how we use it

We take your right to privacy seriously and work continuously to keep the data we process minimized. Nevertheless, in order to be able to develop our network effectively in your favour, we need to process some Personal Data. We are unable to include you in our network and keep our engagements towards you unless we process some of your Personal Data as described herein.

We may process your Personal Data for the following purposes:

Personal data received from entrepreneurs (candidates for funding):

Categories of data subjects

• individuals – entrepreneurs;
• legal representatives of legal entities – entrepreneurs;
• employees or team of the entrepreneurs;
• contact persons of the entrepreneurs;
• founders, mentors, investors and partners of the entrepreneurs. 

Categories of Personal Data

• General personal data of the natural persons – first and last name, city and country of residence, birth date;
• Personal Data contained in the project for funding (Pitch Deck) – education, qualifications, work experience, skills, place of project development, names and companies of founders, mentors, investors and partners, as well as any other information, which the entrepreneurs may choose to include in their CV, Pitch Deck and/or accompanying documentation, such as diplomas, certificates, videos, pictures, etc;
• Contact details – Email addresses, phone number, skype ID, Google + ID, LinkedIn Profile.

Purpose for processing and legal basis

• Identifying the person as an entrepreneur;
• Completing and maintaining the relevant documentation related to the funding project;
• Evaluation of the project, provision of assistance by Eleven Investments KDA and finding of appropriate funding;
• Liaising with entrepreneurs and providing feedback, support, news and notices on the development and financing of their projects.

The legal basis for this processing is the performance of pre-contractual and contractual obligations of Eleven Investments KDA in relation to the submitted project for funding and the evaluation of the project.

Personal data received from our contact form for ‘big companies’:

Categories of data subjects

• legal representatives of legal entities – ‘big companies’;
• contact persons of ‘big companies’.

Categories of Personal Data

• First and last name;
• Position;
• Email addresses, phone number.

Purpose for processing and legal basis

• Identifying the person as a legal representative/contact person of the ‘big company’;
• Providing business consultation services for ‘big companies’;
• Liaising with ‘big companies’ and providing feedback, support, news and notices.

The legal basis for this processing is the performance of pre-contractual and contractual obligations of Eleven Investments KDA in relation to the provision of business consultation services.

Personal data of our mentors, investors and partners:

Categories of data subjects

• individuals – mentors, investors and partners;
• legal representatives of legal entities – mentors, investors and partners; 

Categories of Personal Data

• First and last name;
• Email addresses, phone numbers.

Purpose for processing and legal basis

• Identifying the person as a mentor, investor and/or partners;
• Participation in funding-related activities;
• Liaising with mentors, investors and/or partners and providing feedback, support, news and notices on the projects, which they are involved in or may be interested in.

The legal basis for this processing is the performance of pre-contractual and contractual obligations of Eleven Investments KDA in relation to the participation of mentor, investor and/or partners in funding-related activities.

Storage of personal data

As the evaluation, developing, supporting and financing a project as well as developing the perfect network and environment is a time-consuming process, we shall keep the Personal Data collected for a period of ten years.

Method of collection

We shall not use any Personal Data, unless it has been voluntarily provided, entered or uploaded personally by the data subject. You are not allowed to enter third party Personal Data, including sign up a third party (partners, mentors, advisors, employees, etc.), without due authorization by such third party. It is the entering persons’ sole responsibility to provide and guarantee that the processing Personal Data activities performed and the provision of third party Personal Data are compliant with the requirements of the applicable data protection legislation.

How we protect your information

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential and that they are properly trained and authorised. We also take appropriate technical and organisational measures to protect your Personal Data against loss or other forms of unlawful processing.

Processors

For providing effective communication we engage from time to time third party service providers – processors, carefully selected according to their capacity for Personal Data protection and processing in compliance with applicable data protection legislation. None of our processors has the right to use your personal information beyond what is necessary to assist us in making our work possible. When we cooperate with third parties and they process your Personal Data on our behalf, we make sure your Personal Data is being handled with the same integrity and security as we do. Some of our service providers might be based or their servers might be co-located in the United States of America (USA). After the Court of Justice of the EU abolished the EU-US Privacy Shield in July 2020, the USA are regarded as a third party not ensuring an adequate level of protection. Any transfer of Personal Data outside the European Economic Area is done by us only under strict compliance with the GDPR. We ensure the third-party recipients in non-adequate countries conclude the EU standard contractual clauses (EU SCC) with us or follow appropriate safeguards pursuant to art. 46 GDPR. EU SCC are now concluded with all above US-based subprocessors or recipients (such as Google, Mailchimp, Facebook, Microsoft).      

For communication purposes we use the platforms of MailChimp (USA), Dynamo (USA) and Pipedrive (USA). For structuring project information, we use the platforms of Gust (USA) and F6S (USA). For email exchange and document storage we use the platform of Google (USA). For project management we use Trello (USA). For data storage we use Dynamo (USA) and Data Site (USA). We may replace our processors from time to time following the above rules of strict selection. Updated information about the list of current processors may be found at all times in our Privacy policy or we may inform you about such updates via email.

Information we share

We do not share personal information with companies, organizations and individuals unless one of the following circumstances applies:

1. At explicit instructions – as we are entrusted with the development and funding of projects, entrepreneurs’ contacts, such as names, phone numbers and email address may be provided to the respective mentors and investors, who may contribute upon explicit consent.
2. For making some services possible – to third party processors, as described above.
3. For legal reasons – we will share personal information, if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
   a) meet any applicable law, regulation, legal process or enforceable governmental request.
   b) including investigation of potential violations.
   c) detect, prevent, or otherwise address fraud, security or technical issues.
   d) protect against harm to the rights, property or safety of our team, company or affiliates, as required or permitted by law.

We may share non-personally identifiable information publicly and with our partners. For example, we may share information publicly to show trends about the general development of our activities.

We do not sell, trade, or otherwise transfer to outside parties your Personal Data.

Minors

We allow our network to be used only by persons aged 18 and over. If we obtain actual knowledge that we have collected Personal Data from a person under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. Please, contact us, if you believe that we have mistakenly or unintentionally collected information from a person under the age of 18.

Your rights

You have the right to request a copy of your personal details at any time, to check the accuracy of the information held and/or to correct or update this information. You may ask your personal information to be deleted completely, if no enquiry from you is in progress. You also have the right to complain when your Personal Data protection rights have been violated. We will make commercially reasonable efforts to provide you with reasonable access to any of your personal information we maintain or correct it within 30 days of receipt of your request. We will comply with your instructions for deletion of Personal Data as soon as reasonably practicable and within a maximum period of 30 days, unless EU or Bulgarian law requires further storage. Please, note that we may keep that information for legitimate business or legal purposes or be required (including by contract or GDPR) to keep certain of information and not delete it (or to keep this information for a certain time, in which case we will comply with the deletion request only after we have fulfilled such requirements). Please, note that after deleting your information, you shall not be able to use our network any more.

If you wish to access, delete (when applicable) or correct your personal information please, address your requests and complaints to: Sofia, Bulgaria, 37 Benkovski Str., 1st floor or hello@11.me Please state clearly in the subject that your request concerns a privacy matter, and more specifically whether it is a request to access, correction, deletion or else. Bear in mind that we may ask for additional information to determine your identity.

We may reject requests that are unreasonably repetitive, require disproportionate technical effort, risk the privacy of others, or would be extremely. Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort.

Supervisory authority

If you think we have infringed your privacy rights, you can lodge a complaint with the supervisory authority of Bulgaria, which is the Commission for Personal Data protection. More information can be found at: www.cpdp.bg

You can also lodge your complaint in particular in the country where you live, your place of work or place where you believe we infringed your right(s).

US Regulations

California Online Privacy Protection Act

CalOPPA is the first state law in the USA to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically target children under the age of 13 years old, as stated above.

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. We collect your email address in order to send required information, respond to inquiries, and/or other requests or questions.

If at any time you would like to unsubscribe from receiving future emails, you can email us at hello@11.vc and we will promptly remove you from correspondence, when applicable.

Last updated: 01.10.2024

Cookie Policy

Our Privacy Policy also explains the principles when it comes to the collection, processing, and storage of your information. This policy specifically explains how we, our partners, and users of our services deploy cookies, as well as the options you have to control them.

What are cookies

Cookies are small pieces of data, stored in text files, that are stored on your computer or other device when websites are loaded in a browser. They are widely used to ‘remember’ you and your preferences, either for a single visit (through a ‘session cookie’) or for multiple repeat visits (using a ‘persistent cookie’). They ensure a consistent and efficient experience for visitors, and perform essential functions such as allowing users to register and remain logged in. Cookies may be set by the site that you are visiting (known as ‘first party cookies’), or by third parties, such as those who serve content or provide advertising or analytics services on the website (‘third party cookies’).

Cookies used on our website

We use cookies for a number of different purposes. Some cookies are necessary for technical reasons; some enable a personalized experience for both visitors and registered users; and some allow the display of advertising from selected third party networks. Some of these cookies may be set when a page is loaded, or when a visitor takes a particular action (clicking the ‘like’ or ‘follow’ button on a post, for example).
Below the different categories of cookies set by https://11.vc/ are outlined, with specific examples detailed in the tables that follow. This includes their name and purpose. Certain cookies are only set for logged in visitors, whereas others are set for any visitors, and these are marked below accordingly. Where a cookie only applies to specific subdomains, they are included under the relevant header.

Necessary: Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

Statistics: Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.

Tracking: These are set by trusted third party networks (e.g. Google Analytics) to track details such as the number of unique visitors, and page views to help improve the user experience.

Controlling cookies

Visitors may wish to restrict the use of cookies, or completely prevent them from being set. Most browsers provide for ways to control cookie behavior such as the length of time they are stored – either through built-in functionality or by utilizing third party plugins.

To find out more on how to manage and delete cookies, visit aboutcookies.org. For more details on advertising cookies, and how to manage them, visit youronlinechoices.eu (EU based), or aboutads.info (US based).

Some specific opt-out programs are available here:

Google Analytics – https://tools.google.com/dlpage/gaoptout

It’s important to note that restricting or disabling the use of cookies can limit the functionality of sites, or prevent them from working correctly at all.

Whistleblowing Reporting

Please find below key information documents on the conditions and procedure for internal reporting of whistleblowing cases.

1. Information About The Conditions And Procedure For Internal Reporting Of Whistleblowing Cases (download link)
2. Notification on the Protection of Personal Data When Submitting Reports on Violations (download link)