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Privacy Policy

Last Modified: April 17th, 2025

This Privacy Policy of R11N Ventures GmbH ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services").

Understanding this Privacy Statement will give you clarity about your privacy protections and available options. As the entity determining how your personal data is handled, we take responsibility for its processing and protection. Should you find yourself uncomfortable with these data handling practices, we encourage you to refrain from utilizing our platform and associated features. For any privacy-related inquiries or clarifications, our Data Protection team is available to assist you via privacy@r11n.io.

Data controller and responsible body: R11N Ventures GmbH, Glasbläserallee 6, 10245 Berlin

Duly represented by Philipp Triebel / Data Protection Officer: dpo@r11n.io

1. Information collected

Personal information disclosed by you

We gather personal information that you voluntarily submit when requesting details about our organization, products, or Services, engaging with platform features, or initiating contact with us.

Sensitive Data Processing: Our systems do not process sensitive personal information.

Automatically collected information

During your interaction with our platform, our systems automatically gather technical data about your visit and usage patterns. The collected technical details include your device specifications, system settings, browsing habits, and network identifiers - such as operating system version, language settings, IP address, browser type, entry pages, and timing of platform usage. While this technical data does not directly identify you as an individual, it helps us ensure platform security, maintain stable operations, analyze usage patterns, and generate internal reports.

Additionally, we employ standard web tracking methods, including cookies and related technologies, to collect usage data.

The information we collect includes:

Log and Usage Data: Our servers track and store technical data when you use our platform. These system records capture performance metrics, service diagnostics, and interaction patterns. Your digital footprint may include: network identifiers, hardware details, browser configuration, timestamp data of platform activities (including viewed content, and feature utilization), plus system behavior logs and technical issue reports, including debugging information.

Device Specifications: When connecting to our platform, we receive technical details about your access device, whether it's a desktop computer, smartphone, or tablet. This encompasses: network routing data, unique device markers, app identifiers, web browser details, internet connectivity provider information, operating system specifics, and system settings.

Geo data: We process geographic location information that may range from general area indicators to specific coordinates. The precision depends on your device type and settings. For instance, we may determine your general area through IP address mapping. While you can prevent location tracking by adjusting device permissions or settings, some platform features may become unavailable without location access.

2. How we process your information

Your data enables us to provide our services in the following ways:

Service Provision: We handle your information to fulfill your service requests and ensure proper platform functionality.

Promotional Communication: With your consent and preference settings, we process your data to share relevant updates and offers.

Quality Improvement: We analyze your input to enhance our services and may contact you to gather platform feedback.

Security Measures: Your data helps maintain platform integrity through security monitoring and fraud prevention protocols.

Platform Enhancement: We examine usage patterns to optimize features and improve user experience.

Safety Protocols: When necessary, we process data to prevent harm and protect vital interests of platform users.

3. Overview of Tracking Use

Essential > Security Monitoring and Hosting

Purpose: We use a web application firewall to keep our services and users protected from malicious activity.

Data Processor: Vercel Inc., 440 N Barranca Avenue #4133, Covina, CA 91723, United States

Location of processing: Global (depending on your location)

Data Categories: IP address, timestamps, device information, traffic information, cookie identifiers

Duration: 7 days

Legal basis: Article 6(1)(f) - Legitimate Interest

Anonymous Cookie-less Usage Analytics

Purpose: Improve the user experience and detect issues with the platform (without IP addresses)

Data Processor: PostHog, Inc., located at 2261 Market Street #4008, San Francisco, California 94114 United States of America

Data Categories: Pageviews, Usage data, geo information, A/B test interaction

Duration: 1 Year

Legal basis: Article 6(1)(f) - Legitimate Interest

Location of processing: Frankfurt, Germany (using PostHog EU Cloud and proxied through first-party domain)

4. Legal Basis

This section applies to you, when located in the EU or UK:

Under data protection laws, including European and UK regulations, we must establish valid legal grounds for processing your personal data. Our processing activities are based on and are referenced with the respective activity:

Performance of a Contract: We process data necessary to deliver our services and meet our contractual commitments to you, including pre-contract preparations at your request.

Legitimate Interest: When our legitimate operational needs don't override your fundamental rights, we may process data to:

Provide promotional offers and service updates

Create relevant user content and advertising

Evaluate and enhance service performance

Conduct marketing initiatives

Maintain technical functionality

Prevent misuse

Improve user experience through platform analysis

Legal Obligations: We handle data as required by applicable laws, including cooperation with authorities, protection of legal interests, and participation in legal proceedings.

Vital Interests: Processing may occur to protect essential individual interests during safety-critical situations.

This section applies to you, when located in Canada:

Your personal information may be processed based on either explicit authorization (express consent) or reasonably presumed permission (implied consent) for specified purposes. You maintain the right to revoke such consent at any time.

Applicable law permits certain exemptions where we may process your information without obtaining consent, including but not limited to:

Emergency situations where obtaining consent is impracticable and collection serves individual interests

Detection, prevention, and investigation of fraudulent activities

Qualified business transactions meeting statutory requirements

Insurance claim processing requiring witness statement evaluation

Emergency contact and identification of individuals in medical distress or deceased

Reasonable suspicion of financial exploitation or abuse

Investigative purposes where consent requirements would impair information integrity or availability regarding contract breaches or legal violations

Compliance with judicial orders, warrants, subpoenas, or court-mandated record production

Professional or business records collected within scope of original purpose

Legitimate journalistic, artistic, or literary endeavors

Publicly accessible information as defined by regulatory provisions

5. Sharing of Personal Information

In connection with corporate transactions, we reserve the right to transfer your personal data as part of any merger, asset sale, financing arrangement, or acquisition, whether during preliminary negotiations or upon completion of such transactions, where your information may be among the transferred business assets or be subject to ownership changes.

6. Use of Tracking and Cookies

Our platform employs cookies and related tracking mechanisms (including but not limited to web beacons and pixel tags) to collect usage data during your interaction with our Services. Certain tracking technologies are essential for maintaining platform security, preventing system failures, addressing technical issues, retaining user preferences, and enabling core functionality.

We additionally authorize third-party service providers to deploy tracking technologies across our Services for analytical and advertising purposes. Such technologies enable these providers to manage advertisement delivery, and implement remarketing campaigns (subject to your communication preferences). These authorized providers utilize their proprietary technologies to deliver relevant advertisements about products and services, which may appear within our Services or across other digital properties.

Please review the specific tracking and cookie use under Section 1.3. and 2.3. depending on your data subject group.

What are Cookies: Cookies are small text files that websites place on your device to store information about your preferences, improve your experience, and help the website operator understand how people use their site. Similar tracking technologies like web beacons, pixels, and tags work in comparable ways.

Cookie Management: You can control cookies through your browser settings:

Block all cookies

Allow only first-party cookies

Delete cookies when closing your browser

Accept cookies from specific websites

Popular browsers provide these controls at:

Chrome: Settings > Privacy and Security > Cookies and other site data

Firefox: Options > Privacy & Security > Enhanced Tracking Protection

Safari: Preferences > Privacy > Cookies and website data

Edge: Settings > Cookies and site permissions

Please note that blocking certain cookies may impact website functionality.

Each third-party partner processes data according to their own privacy policies, which we encourage you to review.

7. How long we keep personal information

Your personal information shall be retained only for the duration necessary to fulfill the purposes outlined in this Privacy Notice, except where extended retention periods are mandated or permitted by law, including but not limited to tax regulations, accounting requirements, or other legal obligations. The purposes described herein do not necessitate retention of your personal information beyond a period of two years.

Upon cessation of legitimate business necessity for processing your personal information, we shall either permanently delete or irreversibly anonymize such data. In instances where immediate deletion or anonymization is not technically feasible (such as data stored in backup systems), such personal information shall be securely maintained in isolation from active processing until permanent deletion becomes technically practicable.

8. Security

Our organization maintains comprehensive technical and organizational security protocols designed to safeguard all personal information under our control. These security measures are regularly evaluated and updated to protect data during processing, transmission, and storage.

Notwithstanding these protective measures, please be advised that no method of electronic transmission or digital storage system can ensure absolute security. While we employ industry-standard protections, we cannot guarantee complete immunity from unauthorized access, acquisition, or alteration of your information by third parties who may circumvent our security infrastructure. Therefore, any transmission of personal information in connection with our Services carries inherent risks. We recommend accessing our Services only through secure networks and environments to minimize potential vulnerabilities.

9. Collection of information of minors

Our Services are intended solely for users aged 18 and above. We neither intentionally gather information from nor direct marketing activities toward individuals under 18 years of age. Furthermore, we do not engage in the sale of personal information belonging to minors under 18.

Your use of our Services constitutes an affirmation that you have reached the age of majority (18 years) or are a parent/legal guardian consenting to a minor dependent's use of the Services. Upon discovery of any personal information collected from users under 18, we shall promptly terminate the associated account and implement reasonable procedures to delete such data from our systems. Please notify our Data Protection team at dpo@r11n.io if you become aware of any information we may have inadvertently collected from individuals under 18.

10. Data Subject Rights

Residents of certain jurisdictions (including the EEA, UK, Switzerland, and Canada) are entitled to specific rights under their respective data protection laws. These rights encompass: accessing and obtaining copies of your personal information; requesting corrections or deletion; limiting information processing; exercising data portability where applicable; and exemption from automated decision-making. To exercise these rights, contact us through the methods outlined in our "Contact Information" section.

Each request will be evaluated and addressed in compliance with applicable data protection regulations.

EEA and UK residents may file complaints with their respective data protection authorities (EU and for UK) if they believe our processing activities violate applicable laws. Swiss residents may seek recourse through the Federal Data Protection and Information Commissioner.

Withdrawing consent: Where consent forms the basis of processing, whether expressed or implied as permitted by law, you maintain the right to withdraw such consent. Contact us via the methods detailed in our "Contact Information" section to withdraw consent. Note that withdrawal of consent: (1) does not impact the legitimacy of prior processing activities, and (2) where legally permitted, does not affect processing conducted under alternative legal bases.

Opting out of marketing and promotional communications: You may discontinue receipt of marketing communications by utilizing the unsubscribe mechanism in our emails or by contacting us directly. While marketing communications will cease, we reserve the right to send administrative messages necessary for account management, service delivery, or other non-promotional purposes.

Cookie Management: Browser settings typically accept cookies by default. You may modify these settings to remove or reject cookies, though this may impact service functionality.

Direct privacy-related inquiries to dpo@r11n.io.

11. Do-not-track Features

We acknowledge that various web browsers, mobile operating systems, and applications offer Do-Not-Track ("DNT") functionality to indicate your tracking preferences for online activities. However, due to the current absence of a standardized implementation protocol for DNT signals across the digital ecosystem, our systems do not presently recognize or process such signals. Should industry-wide standards for DNT signal processing be established and legally mandated, we will update our practices accordingly and notify you through revisions to this Privacy Notice.

Specific to California privacy regulations, we are required to disclose our response to DNT browser signals. Given the lack of established industry or legal standards regarding DNT signal recognition and processing, we do not currently alter our data collection practices in response to these signals.

12. Policy Updates

This Privacy Notice may be periodically revised to reflect changes in our practices. Material updates will be indicated by a new "Last Modified" date at the beginning of this Notice. We reserve the right to notify you of significant changes either through prominent website notifications or direct communications. Regular review of this Privacy Notice is recommended to stay informed about our data protection practices and your privacy rights.’

13. Review, Edit or Delete Personal Information

Subject to the privacy laws of your jurisdiction (country or U.S. state of residence), you may be entitled to: request details about your personal information in our systems, understand our processing activities, rectify inaccurate data, obtain copies of your information, or request its deletion. Additionally, you may have the right to revoke previously granted authorization for processing your personal information. Please note that certain legal restrictions may limit the exercise of these rights.

To exercise your data privacy rights or manage your personal information, please submit your request to dpo@r11n.io.