Privacy Policy

Abacus Advisory S.A.R.L., along with our affiliates and group companies, (collectively, “212”) knows how important privacy is to our customers and wish to ensure you are informed about the manner in which we collect, use and share your personal data. The protection of your privacy is of the utmost importance to us, so it goes without saying that we comply with the legal stipulations on data protection.

In this notice, “212,” “our”, “we” or “us” refers to the organization of the member firms of 212, each of which is a separate legal entity, or refers to one or more of those group companies. The controllers of your personal data are one or more of the 212 group companies listed here:

  • Abacus Advisory S.A.R.L. Türkiye (İstanbul) İrtibat Bürosu

The following privacy notice (the “Privacy Notice“) sets out our policy for processing your personal data that we collect through our website at https://212.vc/  (“Website”)

212 marketing subscription

212 sends periodic emails to our newsletter and blog subscribers, but we won’t send emails every single day. You can unsubscribe from any of our subscription emails anytime by getting in touch, or simply clicking the “unsubscribe” link at the bottom of all our marketing emails. We take data matters very seriously, and will only contact our subscribers with their clear and voluntary consent. See below how we view and deal with data.

Type of Information We Collect

We process personal data for a variety of purposes which are stated below. Personal data is all information about an identified or identifiable person. This includes the following categories of personal data that we process:

  • Your contact details (such as first and last name, address, e-mail address, phone number)
  • Your correspondence with us
  • Log files with information about your visit to our Website
  • Online identifiers (such as cookie IDs, IP addresses, unique device identifier advertising IDs)
  • Job applicants
  • Usage, viewing, technical, and device data when you visit our sites, use our tools, or open emails we send, or connect with our wireless Internet access services and other similar technologies.

Thus, whenever you interact with our Website, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, "cookie" information, the type of browser and/or device you're using to access our Services, and the page or feature you requested.

Please note that we ask you not to send us or disclose any special category of personal data on or through our Website or otherwise to us.

For Which We Process Your Data

We process your data for the following purposes:

  • To respond to your inquiries, questions and comments and fulfil your requests.
  • To send administrative information to you, such as for example information regarding the Website, changes to our terms and conditions, and changes to this Privacy Notice.
  • For advertising purposes such as our newsletter
  • On quality assurance and statistics
  • In order to provide our service
  • For your participation in our competitions
  • For your participation in our events
  • For your participation in our surveys
  • To consider your job application
  • Operate, understand, optimize, develop, or improve our Website
  • Detect, investigate and prevent activities that may violate our policies, be fraudulent or illegal
  • Notify you of product recalls or safety issues.
  • In order to improve our service

We will ensure that your consent is freely given, specific, informed and unambiguous and the processing of your information, whether based on consent or any other legal ground, satisfies the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, and confidentiality. Where personal information is collected and further processed based on consent, you may withdraw your consent at any time. However, the withdrawal of consent won’t affect the lawfulness of such processing before your withdrawal.

You may exercise your right to be forgotten where your personal information is no longer necessary, your consent has been effectively withdrawn, you have objected to the processing, or your personal information has been unlawfully processed, has to be erased under a legal obligation or it relates a child being offered information society services. Where the processing is based on your consent or for the performance of a contract you may exercise your right to data portability in respect of data you have provided to us.

Cookies

212 Website uses “cookies”, which are small text files containing a unique identifier that we, or one of our partners, or even a third-party analytics provider, transfer to your computer through the web browser you use. Cookies help us understand our visitors’ interests, so we use that information to improve our services and our Website. cookies" are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device's acceptance of cookies, but this may prevent you from taking advantage of some of our features.

If you click on a link to a third party website or service, a third party may also transmit cookies to you. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor "Do Not Track" requests you have set using your browser or device. We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services -- for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.

Storage Period

The Privacy Policy is to retain personal data only for as long as it is needed for the purposes described in the section “FOR WHICH WE PROCESS YOUR DATA.” Please note that retention periods vary in different jurisdictions and are set in accordance with local regulatory and professional retention requirements.

In order to meet our professional and legal requirements, to establish, exercise or defend our legal rights, and for archiving and historical purposes we need to retain information for significant periods of time.

We store your data,

  • if you have consented to the processing, at most until you revoke your consent;
  • if we need the data for the execution of a contract, at most for as long as the contractual relationship with you exists;
  • if we use the data on the basis of a legitimate interest, at most for as long as your interest in deletion or anonymisation does not outweigh the data;
  • insofar as statutory storage obligations exist, until the end of the storage periods.

Data Transfer

We operate globally and may transfer your personal information to group companies of 212 or third parties in locations around the world for the purposes described in the Privacy Policy. Wherever your personal information is transferred, stored or processed by us, we will take below-mentioned reasonable steps to safeguard the privacy of your personal information.

212 discloses your personal data (i) where this is appropriate for the purposes described in the section “FOR WHICH WE PROCESS YOUR DATA,” including within the 212 Group Companies itself, (ii)if required, by applicable law, (iii) in connection with a reorganization or combination of 212, (iv) if we believe that such disclosure is appropriate to enforce or apply terms of engagement, and other agreements, (v) in order to comply with a judicial proceeding, court order, regulatory inquiry or other legal obligation and (vi) with your explicit consent

Third-party recipients of personal data include:

  • Stakeholders
  • The courts, police and law enforcement agencies (if requested)
  • Government departments and agencies (if requested)

When processing your data, we work together with the following service providers who have access to your data:

  • Provider of web analysis tools
  • Web hosting and web development providers
  • Service provider for IT development services
  • Marketing and advertising agencies
  • E-mail and newsletter provider
  • Service provider for editing and translations
  • CRM system service provider
  • Cloud services
  • Conference and Webinar Software
  • Service provider for online surveys
  • Service provider for chat software
  • Social media platforms
  • Professional advisors, such as law firms, tax advisors or auditors
  • Insurers
  • Audit regulators

Transfer to Third Countries

Data is being transferred to countries outside the European Economic Area. We only transfer personal data to third countries where the EU Commission has confirmed an adequate level of protection or where we can ensure the careful handling of personal data by means of contractual agreements or other suitable guarantees, such as certifications or proven compliance with international security standards.

  • TURKEY (Cryptology and the SCC)

Your Rights

As 212 is a B2B company we will only accept requests on conditions where we are responsible for data.

As a data subject, you have the following rights:

  • To request information about the processing of your data, as well as to receive a copy of your personal data. You may request information on, among other things, the purposes of the processing, the categories of personal data processed, the recipients of the data (if a transfer is made), the duration of the storage or the criteria for determining the duration;
  • To receive personal data relating to you in a structured, common and machine-readable format or to transfer it to another person in charge
  • To correct your data. If your personal data is incomplete, you have the right to complete the data, considering the purposes of the processing;
  • To have your data deleted or blocked.
  • To have the processing restricted;
  • To object to the processing of your data;
  • To revoke your consent to the processing of your data for the future and
  • To complain to the responsible supervisory authority about unauthorized data processing.

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to privacy@212.vc and we will try to resolve your concerns.

Legal Basis of Data Processing

We base the processing of your data on the following legal bases:

  • Your consent, if you have given us such consent (Art. 6 para. 1 lit. a) GDPR)
  • The initiation or execution of a contract with you (Art. 6 para. 1 lit. b) GDPR)
  • The implementation of our legitimate interests (Art. 6 para. 1 lit. f) GDPR)

Legitimate Interests

When processing your data, we pursue the following legitimate interests:

  • The improvement of our offer
  • Protection of our systems against misuse
  • On the production of statistics
  • For the storage of our correspondence with you

Changes to this Privacy Policy

Abacus Advisory S.A.R.L., drafted this Privacy Policy to inform you. Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any Privacy Policy changes and updates on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes).

Status of this privacy policy:15/01/2022