Introduction
Welcome to Leva Capital Partners AG's and our affiliated companies ("Leva", "Company," "our," "us" or "we") Privacy Policy ("Privacy Policy").
Leva respects your ("you", "your", "User") privacy and personal data and is committed to protecting it when you visit our website, www.leva.pe (the "Website"); engage with our chat support feature; communicate with our employees and staff members; participate in our webinars (the "Webinar"); try our demo (the "Demo"); or create an account to use any features, services, products, or tools offered on our platform (the "Platform").
We ensure this protection in compliance with this Privacy Policy and applicable data protection laws, including Regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data, repealing Directive 95/46/EC (the "General Data Protection Regulation" or "GDPR"), and, in particular, the Swiss Federal Act on Data Protection of 25 September 2020 and its implementing ordinances (the "FADP").
References in this Privacy Policy to "Personal Data" refer to the term as defined in the FADP and GDPR. For the purposes of this Privacy Policy, the Website, Webinar, Demo, Cloud Services (as defined in the Terms of Service), and Platform are collectively referred to as the "Services".
This Privacy Policy applies to all our employees and staff members and governs all Personal Data collected by us at any time.
Leva is the data controller and responsible for your Personal Data, which means that we:
- "control" the Personal Data that you provide -- including making sure that it is kept secure.
- Make certain decisions regarding the use and protection of your Personal Data, but only to the extent that we have informed you about such use or are otherwise permitted to do so by law.
Please read this Privacy Policy carefully before you start using our Services to understand our policies and practices regarding your Personal Data and how we will treat it. If you do not agree with the policies and practices described in this Privacy Policy, you should not access or use our Services. By accessing or using our Services, whether by visiting our Website, participating in a Webinar, booking a Demo, or creating a profile on our Platform, you agree to this Privacy Policy.
1. What Personal do Data we collect?
1.1 Website, Webinar & Demo
Personal Data we collect are divided as follows:
Profile/Identity Data: first name, last name, date of birth, job title, LinkedIn URL, portfolio URL, profile picture or video.
Contact Data: postal address, phone number, email address.
Communications Data: your marketing, notification and communication preferences.
Technical Data: internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform, mobile carrier, hardware type, MAC address, IMEI, Advertiser ID, and other technologies on the devices you use to access our Website, participate in a Webinar, or try the Demo. It also encompasses information collected through browser or flash cookies, as well as data gathered from third-party plugins and websites, including but not limited to Salesforce, Asana, Slack, OneDrive, Zapier, MS Office Suite, Sumsub, password managers, account managers, Google, GitLab, Cloudflare, Studio 3T, Figma, and Highcharts. Each of these services has its own privacy policy.
Usage Data: information about how you use our Website or Demo, such as research criteria, list of the companies viewed on the Website, Users' navigation details on the Website, notably without limitation information about web pages Users visited and saved, and log files.
Customer Support Data: includes feedback and survey responses. If you engage in a web chat or contact us via email or live chat, we will retain a record of that conversation.
Job applicants and our current and former employees: Personal Data from job applications is processed only to the extent necessary for assessing an employment relationship or for the subsequent creation of an employment contract. The Personal Data required for the application process is derived from the information requested or communicated through, for example, a job description. Applicants may voluntarily provide additional information as part of their applications. For current employees, we process Personal Data to fulfill our contractual and legal obligations as an employer. Details regarding the Personal Data we collect, process, store, and delete will be outlined in your employment contract. Regarding former employees, we are legally obliged to retain Personal Data for tax purposes and will store only the minimum required to meet this obligation.
1.2 Platform
Personal Data we collect are divided as follows:
Profile/Identity Data: first name, last name, date of birth, job title, LinkedIn URL, Portfolio URL, profile picture or video.
Contact Data: postal address, phone number, email address.
Communications Data: your marketing, notification and communication preferences.
Technical Data: internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform, mobile carrier, hardware type, MAC address, IMEI, Advertiser ID, and other technologies on the devices you use to access our Website, participate in a Webinar, or try the Demo. It also encompasses information collected through browser or flash cookies, as well as data gathered from third-party plugins and websites, including but not limited to Salesforce, Typeform, Asana, Slack, OneDrive, Calendly, Zapier, Loom, Notion, MS Office Suite, Sumsub, password managers, account managers, Google, Hackolade, GitLab, SendGrid, Twilio, Cloudflare, Studio 3T, Figma, and Highcharts. Each of these services has its own privacy policy.
Usage Data: information about how you use our Website or Demo, such as research criteria, list of the companies viewed on the Website, Users' navigation details on the Website, notably without limitation information about web pages Users visited and saved, and log files.
Customer Support Data: includes feedback and survey responses. If you engage in a web chat or contact us via email or live chat, we will retain a record of that conversation.
Know Your Client (KYC) data: wealth, assets, income, indebtedness capacity, education, past investment experience, entities controlled by Users, portfolio data within Leva, certified ID copies, biometric data such as facial features etc.
Financial Data: financial qualification and billing information, such as billing name and address, credit card number, expiration date.
All Personal Data may be collected in an online or offline context. However, it does not include data where the identity has been removed ("Anonymous data"). We do not collect any Special Categories of Personal Data about you. This refers to data related to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, health information, or data concerning a natural person's sex life or sexual orientation, as well as data on administrative or criminal proceedings, convictions, sanctions, or offenses, except for biometric data such as facial features, which may be processed for KYC (Know Your Customer) purposes as outlined above.
While using our Services, you may not publish, submit, or otherwise distribute Personal Data belonging to others unless you have obtained their appropriate and legally valid consent. The nature of such consent may depend on applicable laws and the specific circumstances of data processing.
We are authorized to store client data and data from third-party sources, to process, edit, combine and use and create profiles from them.
The Platform may contain links to other websites. Leva is not responsible for the content, accuracy or opinions on such websites and such websites are not investigated, monitored or checked for accuracy or completeness.
2. Why do we collect Personal Data?
In general, we collect your Personal Data to provide you with the services you have requested.
We collect your Profile/Identity Data, Contact Data, (KYC) Data, and Financial Data to build a pipeline of potential customers and to create customer lists, documents, logos, and case studies for existing customers.
We collect your Technical Data to ensure the proper functioning of our Website. We also analyze the Website's usage to improve its usability and content. For more information, please refer to our Cookie Policy.
When you request a Demo through our Website or register as a participant in a Webinar, we collect your data to respond to your request and provide you with the service you require.
When you provide your express consent to receive marketing communications, we collect your data to inform you about new features, modifications, events, or other updates related to the product or service for which you requested a Demo.
In some cases, we collect your data to comply with our legal, statutory, and/or regulatory obligations, such as collecting KYC data.
We collect your Personal Data when you use our Platform to operate, maintain, and enhance the Platform's functionality. This includes providing users with access to investment opportunities and enabling them to raise funds through the Platform. We also collect Personal Data for correspondence and contractual purposes, particularly for financial transactions and listing opportunities on the Platform.
3. Legal grounds for collecting Personal Data
We rely on the following legal grounds for the corresponding purposes of our collecting:
Consent: We may collect your Personal Data with your explicit consent in specific circumstances. For example, when you affirmatively opt-in by checking a box to receive email newsletters, book a demo, register for a webinar, invest, or join a syndicate.
Contractual Necessity: We may process your Personal Data when it is necessary to fulfill our contractual obligations, such as providing services you have requested or agreed with us.
Legal Obligations: We are required by law to collect and process certain Personal Data to comply with legal and regulatory obligations. This may include data collection related to fraudulent activity, compliance with anti-money laundering regulations, or responding to legal inquiries.
Legitimate Interests: We may process your Personal Data to pursue our legitimate business interests, provided that such processing does not unduly affect your rights, freedoms, or interests. Legitimate interests may include managing our relationship with you (e.g., for accounting or auditing purposes), enhancing our services, providing training programs, ensuring security on our platforms, and monitoring compliance with our policies. Additionally, we may analyze user interactions, submissions, and system usage patterns to refine and optimize our technological infrastructure, improve automated processing, and enhance the relevance and accuracy of system-generated outputs.
Public Interest: In certain circumstances, we may process Personal Data to fulfill duties in the public interest, such as complying with regulatory requirements, conducting compliance checks, and preventing crime, fraud, or other unlawful activities.
4. How do we collect your Personal Data?
4.1 Direct Collection:
- When you or your organization use our Services;
- When you or your organization offer to provide, or provide, services to us;
- When you correspond with us electronically through our Website;
- When you or your organization browse, complete a form, make an inquiry, or otherwise interact with our Website.
4.2 Indirect Collection:
- Public Sources: Personal Data may be obtained from public registers (such as commercial registers), news articles, sanctions lists, or through internet searches;
- Business Customers: Our customers may engage us to perform professional services, during which they may share Personal Data they control with us as part of that engagement;
- Third Parties: We may receive Personal Data about you from third parties, such as analytics providers (e.g., Google), advertising networks (e.g., LinkedIn and Google), and financial or transaction data from payment and delivery service providers (e.g., Stripe).
4.3 Automatic Collection:
- As you interact with our Website, Webinar, Demo, Cloud Services, or Platform, we automatically collect Technical Data about your equipment, browsing actions, and patterns. This Personal Data is collected through cookies and similar technologies. Please refer to our Cookie Policy for more information.
5. Where do we store your Personal Data and whom do we share it with?
All Personal Data is securely stored in a data center located in Zurich, Switzerland.
We retain your Personal Data only for as long as necessary to fulfill the purposes for which it was collected, or until you revoke your consent, unless a longer retention period is required by law. For instance, we must retain contracts made on our Platform for record-keeping purposes. Similarly, profile information must be retained to ensure the correct association between profiles and companies. Conversely, communications through email or live chat will be retained only while the matter is active. Once resolved, such records may be deleted. After the applicable storage period, your Personal Data will be blocked and may only be retained until the expiration of any legal limitation periods to respond to legal actions arising from its processing. Once these limitation periods expire, your data will be permanently deleted.
In the event of a complaint or if litigation appears likely in relation to our interactions with you, we may retain your Personal Data for a longer period6. We may share non-personal data with third parties for purposes such as improving our services and enabling data aggregation, as described above.
We may share your Personal Data with subcontractors (where necessary and with your consent), affiliates (who are subject to confidentiality obligations and must use the data solely for the purposes for which it was disclosed), or third parties whose services we require to operate our business. In the event that Leva anticipates a change in control, the acquisition of all or part of our business, or the licensing of our technology, we may share your Personal Data with interested parties. If Leva is sold or undergoes a transfer, we may transfer, sell, or assign your Personal Data to a third party as part of the transaction. Upon such transfer, the acquiring entity’s privacy policy may govern the use of your Personal Data. In all other instances, your Personal Data will remain protected in accordance with this Privacy Policy (as amended from time to time).
We may disclose your Personal Data if required for legal reasons or to enforce our Terms of Website Use, Terms of Services, or this Privacy Policy. Your Personal Data may be transferred to countries where our recipients are located. If data is transferred to a country without adequate legal protection, we will take reasonable steps to ensure such transfers are carried out in compliance with this Privacy Policy and applicable data protection laws.
We may be legally required to disclose Personal Data to courts, arbitral tribunals, or authorities in the context of legal or administrative proceedings. Where possible, we will inform you of such disclosures.
Please note that our Website and Platform may contain links to third-party websites and services not owned or controlled by Leva. We are not responsible for the privacy practices or content of these third-party sites, and your use of such sites is at your own risk.
6. How do we keep your Personal Data secure?
Leva is committed to ensuring the security, integrity, and privacy of your Personal Data. We have implemented technical and organizational measures to prevent the alteration, loss, unauthorized access, or unlawful processing of your Personal Data, taking into account the state of the art, the nature of the data, and the risks to which it may be exposed.
All Personal Data collected by Leva is stored behind secure networks and is accessible only to a limited number of authorized employees who have special access rights. These employees are bound by strict confidentiality obligations. In cases where we engage subcontractors to store your data, Leva will retain full control over your Personal Data and will take measures to avoid exposing it to risks that would not exist if the data remained under our direct control. However, please be aware that no method of transmission over the internet is entirely secure. Unauthorized third parties, beyond the control of Leva, may unlawfully intercept or access transmissions or private communications. While we endeavor to protect your Personal Data, we cannot guarantee the absolute security of any data transmitted to us, and any transmission is at your own risk. If you believe your interaction with us is no longer secure, please contact us immediately.
The security of your Personal Data also depends on you. If we have provided you with (or you have chosen) a password to access certain areas of the Platform, you are responsible for keeping this password confidential. Passwords registered on our Platform are encrypted to ensure protection against unauthorized access. We ask that you do not share your password with anyone.
7. Your rights
You have the following rights:
Right of Access: You have the right to confirmation as to whether we are processing your Personal Data, and, if so, access to the data along with additional information, such as the purposes of processing, the categories of Personal Data involved, and the recipients of the data. Provided that the rights and freedoms of others are not adversely affected, we will supply you with a copy of your Personal Data. The first copy will be provided free of charge, though a reasonable fee may apply for excessive, repetitive requests or your request requires additional copies.
Right to Rectification: You have the right to request the correction of any inaccurate Personal Data concerning you. Additionally, taking into account the purposes of processing, you may request the completion of any incomplete Personal Data.
Right to Erasure: In certain circumstances, you have the right to request the deletion of your Personal Data without undue delay. These circumstances may include when: the Personal Data is no longer necessary for the purposes for which it was collected or processed; you withdraw your consent (where processing is based on consent); you object to the processing (in accordance with data protection laws); the Personal Data was unlawfully processed; or the data must be erased to comply with a legal obligation. However,
this* right is subject to certain general exclusions, such as when processing is necessary for exercising the right to freedom of expression and information, for legal compliance, or for the establishment, exercise, or defense of legal claims.Right to Restriction of Processing: In certain cases, you have the right to request a restriction on the processing of your Personal Data. This right applies where: you contest the accuracy of the data; the processing is unlawful, but you oppose erasure; we no longer need the data, but you require it for the establishment, exercise, or defense of legal claims; or you have objected to processing, pending the verification of that objection. Where
processing is restricted, we may still store your data but will only process it with your consent, for legal claims, to protect the rights of another person, or for reasons of public interest.Right to Object to Processing: You have the right to object to our processing of your Personal Data on grounds relating to your particular situation, when the legal basis for processing is that it is necessary for: the performance of a task carried out in the public interest or the exercise of official authority vested in us, or our legitimate interests (or those of a third party). If you object, we will stop processing your data unless we can demonstrate compelling legitimate grounds that override your rights and interests, or if the processing is for the establishment, exercise, or defense of legal claims.
Right to Object to Processing for Marketing Purposes: You have the right to object to the processing of your Personal Data for direct marketing purposes (including profiling for marketing). Upon objection, we will immediately cease processing your data for such purposes.
Right to Complain to a Supervisory Authority: If you believe our processing of your Personal Data violates data protection laws, you have the right to lodge a complaint with the relevant supervisory authority responsible for data protection.
Right to Withdraw Consent: Where the legal basis for processing your Personal Data is your consent, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing prior to the withdrawal.
Right to Data Portability: Where the legal basis for processing your Personal Data is consent or contractual necessity, and the processing is carried out by automated means, you have the right to receive your Personal Data in a structured, commonly used, and machine-readable format. This right is subject to the condition that it does not adversely affect the rights and freedoms of others.
You can exercise your rights by sending us an email at the following email address: DPO@levamail.com
8. Privacy Policy changes
We reserve the right, at our discretion, to modify the terms of this Privacy Policy at any time. The date of the most recent update to this Privacy Policy is indicated by the "Last Modified" legend at the top of this document. We may provide you with notice of any material changes to the Privacy Policy as appropriate under the circumstances. Unless otherwise specified, any changes to this Privacy Policy will take effect immediately upon posting on our Website and Platform. We recommend bookmarking the Privacy Policy for easy access and review. Your continued access to or use of our Services shall constitute your express acceptance of any modifications made to this Privacy Policy.
9. Governing Law and Jurisdiction
This Privacy Policy, along with all matters arising out of or relating to it, shall be governed by Swiss law, excluding any conflict of law provisions that may lead to the application of laws other than Swiss law. Users irrevocably submit to the exclusive jurisdiction of the competent courts in Zurich, Switzerland, for any disputes arising from or in connection with this Privacy Policy.
10. Questions and Contact Information
Questions, comments and requests for further information regarding this Privacy Policy, including any requests to exercise your legal rights surrounding your personal data are welcomed, and should be addressed to us:
In writing: Leva Capital Partners AG, Bernapark 1, 3066 Stettlen, Switzerland
Via email: DPO@levamail.com
We will inform you if, for individual cases, other parties shall be responsible for the collecting or processing of Personal Data.