Dear user,

the Italian privacy legislation (D. Lgs. 196/03) defined how to be compliant with regards to the processing of personal user data. The set of norms, with have a common EU origin, aim to guarantee that personal data is processed in way which respects freedom and dignity of persons, with specific attention to confidentiality and personal identity.

Holder of data processing rights

By using the web portal www.investprive.com and accepting its Privacy Policy, some personal data can be stored and processed with respect to the identified or identifiable persons. The holder of the rights of data processing is Gut Capital srl, headquartered in Largo Gallarati Scotti, 1 – 20123 Milan, Italy.

Purpose of data treatment

In respect of the above cited law, the processing of the personal data will be always performed with maximum correctness and transparency, ensuring confidentiality and respect of Privacy rights. More specifically, the limited set of data collected, none of which is of sensitive nature as defined in the above mentioned law, are stored and processed to allow the subscription of the user to a private email list. In case of being explicitly and separately agreed upon, the user’s email address could be added to a mailing list with commercial purposes or it can be transferred to third parties for that same purpose, in accordance with the law (art. 16 comma 1 lett.b del D.lgs. 196/2003).

Type of data collected and processed

The information and technology systems which enable the workings of the web portal www.investprive.com can collect, at some point, some personal data of the user whose transmission is implicit in the usage of the communication protocols of the Internet. This set of data may comprise, without being exhaustive, IP addresses or computer domain names used by the portal users, URI notation addresses (Uniform Resource Identifier) of requested resources, time of requests, method used to make the server request, response file sizes, numerical codes for server responses (e.g., errors) and other parameters related to the operating system and information ecosystem of the user. These data is collected and analyzed only to make anonymous statistics about portal usage correct functioning.

Voluntary data inputs

The input of the limited non anonymous set of data, and the corresponding acceptance of Privacy Policy, is completely voluntary. Such data can include First Name, Last Name, Email Address and other pieces of information requested in the web forms whose submission, and hence collection, can only take place by accepting the portal’s Terms and Conditions and Privacy Policies. Rejecting to do so won’t enable Gut Capital srl to collect, store and process any non anonymous data, thus Gut Capital srl won’t subscribe the user to its private mailing list.

Cookies

A cookie is a small ‘data file’ which some websites send to the computer which is visiting them with the aim to track the user behavior and navigation in an anonymous fashion but still making it possible to customize the web portal’s user experience. For such reason, www.investprive.com can exchange cookies with the user terminals. An user can however activate cookies alerts in his web browser to decide on a time by time basis whether to accept or not the cookie. The blocking of cookies could however result in the inferior usage of the portal, or even make it impossible to use it altogether.

Types of processing

Personal data can be processed either with automatic or manual systems for the time which is strictly necessary to reach the purpose for which they were collected. Beyond the usage of data to perform the subscription to Gut Capital srl’s mailing list, the processing of personal data may be done for commercial purposes, such as direct selling or market surveys if a separate explicit consensus has been collected. Also, if a separate consensus has been explicit, the data can be transmitted to third parties with which Gut Capital srl conducts business. These third parties are active in the production, sale, offer of various services or maintenance, rental, installation of various products in fields of the economy solely attributable to the following categories: finance, insurance, brokerage, insurance brokerage, publishing, clothing, motor vehicles, automotive, furniture, services for the web, watches, IT equipment and services, office equipment and office machines, services related to real estate, electrical/electronic/hydraulic/fire/telephone supplies for domestic use, electrical/electronic/hydraulic/fire/telephone supplies for industrial use, products and services for domestic hygiene and industrial cleaning, products and services for private and public events, catering services, landline phone and mobile services, translation/training/management/computer science/linguistics services, comparison of services via web.

User rights

The user whose Personal Data has somehow been collected, have the right in any moment to obtain the the confirmation of the existance of such data, the content and the origin of the data, verify the exactness or even demand the completion or update or rectification of the data as has been established in the Italian privacy law (rule 7).

The user can also ask to have his data erased, transformed into anonymous mode or oppose his data processing. Such requests can be done by sending an email to the following address: dealflow@investprive.com.

Who we are

The web portal www.investprive.com, managed by Gut Capital srl, aims to create a platform to host a community of select investors interested in start-ups or even later stage companies, often called ‘Angel investors’ or ‘early stage’ investors or just ‘investors’.

Its initial form of participation is that of a mailing list. The participation of a candidate in such a community is only possible by invitation, through an introduction of a member or by completing and submitting a web form placed in www.investprive.com.

The acceptance of the participation, or even permanence of the member in the mailing list, is exclusively decided by Gut Capital srl, headquartered in Largo Gallarati Scotti, 1 – 20123 Milan, Italy.

What we do

The web portal www.investprive.com will serve as the place where select investors can apply to join the community, their acceptance into it made on the basis of business experience, academic credentials or broadly speaking their intrinsic member value. We hope this angel mailing list will evolve to be a vivid platform to exchange ideas or even become a Think Tank for start-up policy.

What we don’t do

The web portal www.investprive.com does not offer any advisory services to the investors members of the mailing list. In particular, www.investprive.com is not to be considered an economic or financial advisor, not even an intermediary between the mailing list members and the companies or opportunities that may be discussed, but rather a mere platform where investment ideas can be discussed only by qualified investors.

How does it work

If an user wants to become a candidate for www.investprive.com membership, he can fill-in the form in the portal to request an invitation. The form will require a limited set of profiling data, such as an email address. To complete the application the applicant may have to submit other data by email if so is requested to him. Acceptance of applications is done on a case by case basis. In case of a successful application, the user will start receiving the exclusive email communications. It will be possible for any user to request the unsubscription of the service at any moment.

Release of responsibility

Gut Capital srl does not assume any responsibility for the damages, direct or indirect, of monetary nature or any other source, which any user may encounter by benefiting of the service, be it deal flow alerts, information or ideas exchanged in the mailing list, platform or community.

Applicable law and competent jurisdiction

The portal www.investprive.com will always comply with the Italian law and so users, by accepting these Terms and Conditions, explicitly accept to set the Italian law as the applicable law to discipline the portal usage and the user relationship with the portal’s managing company Gut Capital srl. Any disputes arising from the portal usage or in connection with its Terms and Conditions or its Privacy Policy conditions shall be resolved in the ordinary courts of Milan.