PRIVACY POLICY

I. Name and address of the controller

The controller within the meaning of the General Data Protection Regulation and other national data protection legislation of the member states as well as other data protection provisions is:

                                                                                                                     

Nuventura GmbH

represented by the managing directors Egbert Alberts and Manjunath Ramesh

Wollenberger Str. 4f
13053 Berlin

Email: legal@nuventura.com

Web: www.nuventura.com

Data Protection Officer:
Christoph Najberg

Email: cnj@dercounselor.de

II. General use of the website

1. Scope of processing personal data

We only process the personal data of our users if this is necessary to provide a

functional website as well as our content and services. The personal data of our users

are processed regularly only once the user has given consent. An exception applies in

cases in which it is not possible to obtain consent in advance for practical reasons and

data processing is permitted by law.

We generally only collect personal information about users of our website in

connection with enquiries about our services, e.g. via the ‘Contact’ page.

If you contact us, we store your information to process the enquiry as well as in case

any follow-up questions arise. We only store other personal data if you consent to

this or this is permitted by law without explicit consent.

Additional to our usual services we also offer Webinars frequently. In case you wish

to participate at a Webinar by signing up, you provide to us personal data. To prepare

and realize the Webinars, it is necessary to process these personal data and store

them temporarily.

2. Legal basis for processing personal data

The legal basis for obtaining the consent of the data subject to process personal data

is point (a) of Art. 6 (1) EU General Data Protection Regulation (GDPR).

The legal basis for processing personal data required to fulfil a contract, with the data

subject being one of the contracting parties, is point (b) of Art. 6 (1) GDPR. This also

applies to processing operations that are required to perform pre-contractual

measures.

The legal basis for processing personal data required to fulfil a legal obligation to

which our company is subject is point (c) of Art. 6 (1) GDPR.

The legal basis for vital interests of the data subject or another natural person making

the processing of personal data necessary is point (d) Art. 6 (1) GDPR.

The legal basis for data processing being required to maintain a legitimate interest of

our company or a third party and this not being outweighed by the interests, basic

rights and fundamental freedoms of the data subject is point (f) of Art. 6 (1) GDPR.

3. Data erasure and storage duration

Personal data of the data subject will be erased or blocked once the purpose of

storage no longer applies. The data may be stored for longer if this is stipulated by

European or national legislators in European regulations, laws and other provisions to

which the controller is subject. The data are blocked or erased once a retention period

prescribed by the stated regulations expires unless it is necessary to continue storing

the data to enter into or fulfil a contract.

4. Webinars

If you register for one of our webinars, we process the personal data you provide (e.g.

name, email address, company) for the purpose of organising and conducting the

webinar. The legal basis is Art. 6 (1)(b) GDPR (pre-contractual/contractual measure)

or, where no contract is intended, Art. 6 (1)(f) GDPR (legitimate interest in event

organisation). Webinars are conducted using a third-party webinar and videoconferencing

platform; a data processing agreement pursuant to Art. 28 GDPR is in

place with the provider. Registration data is stored for as long as necessary to

organise and follow up on the webinar, and is erased once this purpose no longer

applies, unless a longer retention period is required for follow-up communication you

have separately consented to or to comply with a legal obligation.

III. Application Data

1. Nature of the processing data

By using our contact form or in all other ways of contacting us regarding to an

application, we store all therefore necessary personal data provided by you.

2. Legal basis for data processing

The processing of your data is carried out for the purpose of processing your

application and deciding on establishing an employment relationship according to

Section 26 BDSG.

3. Duration of storage

We store the data collected for the duration of the application process and, in the

event of non-employment, for a period of six months from the date of rejection and,

in the event of employment, for a period of three years after the end of employment.

IV. Providing the website and creating log files

1. Description and scope of data processing

Every time our website is accessed, our system automatically records data and information from the accessing computer system.

When accessing our website www.nuventura.com, information is automatically sent to the server of our website by the browser used on your mobile device. This information is temporarily stored in a so-called log file. The following information will be recorded without any action on your part and stored until it is automatically erased:

  • IP address of the requesting computer,
  • Date and time of access,
  • Name and URL of the retrieved file,
  • Website from which our site is accessed (referrer URL),
  • Browser used and possibly the operating system of your computer as well as the name of your access provider.
2. Legal basis for data processing

Legal basis for the temporary storage of data and the log files is point (f) of Art. 6 (1) GDPR.

3. Purpose of data processing

The temporary storage of the IP address by the system is necessary to transmit the

website to the user’s computer. The IP address of the user must be stored for the

duration of the session. These purposes are in line with our legitimate interest in data

processing according to point (f) of Art. 6 (1) GDPR.

4. Duration of storage

The data will be erased once they are no longer required to achieve the purpose for

which they were collected. This is the case when each session ends if data are

collected to provide the website.

5. Option to object and appeal

It is necessary to collect data to provide the website and to store data in log files to operate the website. The user cannot object to this.

V. Use of cookies

1. Description and scope of data processing

Our website uses cookies. Cookies are text files that are stored on the Internet

browser or by the Internet browser on the user’s computer system. If a user accesses

a website, a cookie can be stored on the user’s operating system. This cookie contains

a string of characters that allows the browser to be clearly identified when the

website is accessed again.

Like many other websites, we use so-called cookies on various pages in order to make

the visit to our website attractive and to allow you to use certain functions. These are

small text files that are placed on your computer and allow your use of the website to

be analysed. Most of the cookies we use are deleted from your hard drive once the

browser session ends (so-called session cookies). Other cookies remain on your

computer and allow us to recognise your computer the next time you visit our

website (so-called persistent cookies). Our partner companies are not permitted to

use cookies to collect, process or use personal data via our website. By using our

implemented Cookies-banner you are able to choose, which cookies may be allowed

to be activated, as well as withdraw the permission for activating certain cookies at

any time.

2. Legal basis for data processing

Insofar as we or third parties store information or access information already stored

on your terminal device (e.g. cookies), this additionally requires your consent pursuant

to Section 25 (1) TTDSG (Telecommunications-Telemedia Data Protection Act), unless

such storage or access is strictly necessary to provide a service you have explicitly

requested (Section 25 (2) TTDSG). Where consent is required, the legal basis for the

related processing of personal data is Art. 6 (1)(a) GDPR; consent can be withdrawn at

any time via our cookie banner with effect for the future. For cookies that are strictly

necessary to operate the website, the legal basis is our legitimate interest pursuant to

Art. 6 (1)(f) GDPR.

3. Purpose of data processing

Cookies are used in order to make the use of our website more comfortable for you.

We use so-called session cookies to recognise that you have already visited individual

pages of our website. These are erased automatically when you leave our website.

Furthermore, we also use temporary cookies to improve user friendliness, which are

stored on your mobile device for a certain period of time. If you visit our site again to

use our services, it is automatically recognised that you have visited us before and

which entries and settings you specified so that you do not have to enter this again.

We also use cookies to collect statistics about the use of our website and to analyse

the use to improve our offer for you. These cookies allow us to automatically

recognise that you have already visited our site when you visit again. These cookies

are automatically erased after a certain period of time.

These purposes are in line with our legitimate interest in processing personal data

according to point (f) of Art. 6 (1) GDPR.

4. Duration of storage, option to object and appeal

Cookies are stored on the user’s computer, which transmits them to our website.

Therefore, you as the user have full control over the use of cookies. By changing the

settings in your Internet browser, you can disable or limit the transfer of cookies.

Cookies that are already stored can be erased at any time. This can also be carried out

automatically. If cookies are disabled for our website, it is possible that you cannot

use all of the functions of the website in full.

VI. Tracking

1. Google Analytics

For the purposes of advertising, market research and to design the website to meet

the user’s needs, we also use the tracking system Google Analytics, a web analysis

service of Google Inc. (‘Google’). Google Analytics uses cookies that allow your use of

the website to be analysed. The information generated by the cookie about your use

of this website (including your IP address) is transferred to a Google server in the USA

and stored there. Google will use this information to analyse your use of the website

in order to compile reports about the website activities for the website operators and

in order to provide other services associated with the use of the website and Internet.

Google may also transmit this information to third parties where required by law or if

third parties process this data on Google’s behalf. In no case will Google associate

your IP address with other Google data. As already explained, you can prevent the

installation of cookies by adjusting the settings of your browser software. However,

we would like to point out that if you do so, you may not be able to use all functions

of this website. As Google LLC is based in the USA, personal data may be transferred

to a third country. This transfer is based on the EU-U.S. Data Privacy Framework

pursuant to the European Commission's adequacy decision of 10 July 2023 (Art. 45

GDPR), under which Google LLC is a certified participant.

2. Legal basis for processing personal data

The legal basis for setting the Google Analytics cookie is your consent pursuant to Art.

6 (1)(a) GDPR in conjunction with Section 25 (1) TTDSG, obtained via our cookie

banner before Google Analytics is activated. Google Analytics is not activated until

such consent is given.

3. Purpose of data processing

The processing of the user’s personal data allows us to analyse the surfing behaviour

of our users. By analysing data we obtain, we can compile information about the use

of individual components of our website. This helps us to constantly improve our

website and its user friendliness. These purposes are in line with our legitimate

interest in data processing according to point (f) of Art. 6 (1) GDPR. Anonymising the

IP address adequately takes the user’s interest in protecting their personal data into

account.

4. Duration of storage

The data is erased once they are no longer required for our recording purposes.

5. Option to object and appeal

Cookies are stored on the user’s computer, which transmits them to our website.

Therefore, you as the user have full control over the use of cookies. By changing the

settings in your Internet browser, you can disable or limit the transfer of cookies.

Cookies that are already stored can be erased at any time. This can also be carried out

automatically. If cookies are disabled for our website, it is possible that you cannot

use all of the functions of the website in full.

VII. Social plug-ins LinkedIn

On our website, we give you the option of using so-called ‘social plugins’ of the

LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA.

The plug-in on the website is only shown as a graphic that contains a link to the

corresponding website of the plug-in provider. Clicking on the graphic forwards you

to the services of the provider. Only then will your data be sent to the respective

service provider. If you do not click on the graphics, no data will be exchanged

between you and the social networks above.

VIII. Rights of the data subject

If your personal data is processed, you are a data subject within the meaning of the GDPR and have the following rights with regard to the controller:

1. Right to access

You have the right to obtain from the controller confirmation as to whether or not

your personal data are being processed.

Where that is the case, you can request access to the following information from the

controller:

(1) the purposes of the processing;

(2) the categories of personal data concerned;

(3) the recipients or categories of recipient to whom the personal data have been or

will be disclosed;

(4) where possible, the envisaged period for which your personal data will be stored,

or, if not possible, the criteria used to determine that period;

(5) the existence of the right to request from the controller rectification or erasure of

personal data or restriction of processing of your personal data or to object to such

processing;

(6) the right to lodge a complaint with a supervisory authority;

(7) where the personal data are not collected from the data subject, any available

information as to their source;

(8) the existence of automated decision-making, including profiling, referred to in Art.

22 (1) and (4) GDPR and, at least in those cases, meaningful information about the

logic involved, as well as the significance and the envisaged consequences of such

processing for the data subject.

You shall have the right to be informed if your personal data are transferred to a third

country or to an international organisation. In this context, you shall have the right to

be informed of the appropriate safeguards pursuant to Art. 46 GDPR relating to the

transfer.

2. Right to rectification

You shall have the right to have personal data rectified and/or completed by the

controller if the personal data about you is incorrect or incomplete. The controller

shall rectify the data without undue delay.

3. Right to restriction of processing

You shall have the right to obtain from the controller restriction of processing where

one of the following applies:

(1) the accuracy of the personal data is contested by you, for a period enabling the

controller to verify the accuracy of the personal data;

(2) the processing is unlawful, and you oppose the erasure of the personal data and

request the restriction of their use instead;

(3) the controller no longer needs the personal data for the purposes of the

processing, but they are required by you for the establishment, exercise or defence of

legal claims;

(4) you have objected to processing pursuant to Art. 21(1) GDPR pending

the verification whether the legitimate grounds of the controller override yours.

Where processing has been restricted, such personal data shall, with the exception of

storage, only be processed with your consent or for the establishment, exercise or

defence of legal claims or for the protection of the rights of another natural or legal

person or for reasons of important public interest of the Union or of a Member State.

If you have obtained restriction of processing pursuant to the requirements above,

you shall be informed by the controller before the restriction of processing is lifted.

4. Right to erasure
a) Erasure obligation

You shall have the right to obtain from the controller the erasure of personal data

concerning you without undue delay and the controller shall have the obligation to

erase personal data without undue delay where one of the following grounds applies:

(1) the personal data about you are no longer necessary in relation to the purposes

for which they were collected or otherwise processed;

(2) you withdraw consent on which the processing is based according to point (a) of

Article 6 (1), or point (a) of Art. 9 (2), and where there is no other legal ground for the

processing;

(3) you object to the processing pursuant to Art. 21(1) GDPR and there are

no overriding legitimate grounds for the processing, or you object to the processing

pursuant to Art. 21(2) GDPR;

(4) your personal data have been unlawfully processed;

(5) the personal data have to be erased for compliance with a legal obligation in

Union or Member State law to which the controller is subject;

(6) your personal data have been collected in relation to the offer of information

society services referred to in Art. 8(1) GDPR.

b) Information to third parties

Where the controller has made the personal data public and is obliged pursuant to

Art. 17 (1) GDPR to erase the personal data, the controller, taking account of available

technology and the cost of implementation, shall take reasonable steps, including

technical measures, to inform controllers which are processing the personal data that

you as the data subject have requested the erasure by such controllers of any links to,

or copy or replication of, those personal data.

c) Exceptions

The right to erasure shall not apply to the extent that processing is necessary:

(1) for exercising the right of freedom of expression and information;

(2) for compliance with a legal obligation which requires processing by Union

or Member State law to which the controller is subject or for the performance of a

task carried out in the public interest or in the exercise of official authority vested in

the controller;

(3) for reasons of public interest in the area of public health in accordance with points

(h) and (i) of Art. 9 (2) as well as Art. 9 (3) GDPR;

(4) for archiving purposes in the public interest, scientific or historical research

purposes or statistical purposes in accordance with Art. 89 (1) GDPR in so far as the

right referred to in section a) is likely to render impossible or seriously impair the

achievement of the objectives of that processing; or

(5) for the establishment, exercise or defence of legal claims.

5. Right to information

If you have exercised your right to rectification, erasure or limitation of processing

against the controller, the controller shall communicate any rectification or erasure of

personal data or restriction of processing carried out to each recipient to whom the

personal data have been disclosed, unless this proves impossible or involves

disproportionate effort. The controller shall inform you about those recipients if you

request it.

6. Right to data portability

You shall have the right to receive your personal data, which you have provided to a

controller, in a structured, commonly used and machine-readable format and have the

right to transmit those data to another controller without hindrance from the

controller to which the personal data have been provided, where:

(1) the processing is based on consent pursuant to point (a) of Art. 6 (1) GDPR or point

(a) of Art. 9 (2) GDPR or on a contract pursuant to point (b) of Art. 6 (1) GDPR; and

(2) the processing is carried out by automated means.

In exercising this right to data portability, you shall have the right to have the personal

data transmitted directly from one controller to another, where technically feasible.

This right shall not adversely affect the rights and freedoms of others.

The right to data portability shall not apply to processing necessary for the

performance of a task carried out in the public interest or in the exercise of official

authority vested in the controller.

7. Right to object

You shall have the right to object, on grounds relating to your particular situation, at

any time to processing of your personal data which is based on point (e) or (f) of Art. 6

(1) GDPR, including profiling based on those provisions.

The controller shall no longer process your personal data unless the

controller demonstrates compelling legitimate grounds for the processing which

override your interests, rights and freedoms or for the establishment, exercise or

defence of legal claims.

Where personal data are processed for direct marketing purposes, you shall have the

right to object at any time to processing of your personal data for such marketing,

which includes profiling to the extent that it is related to such direct marketing.

Where you object to processing for direct marketing purposes, your personal data

shall no longer be processed for such purposes.

In the context of the use of information society services, and notwithstanding

Directive 2002/58/EC, you may exercise your right to object by automated means

using technical specifications.

8. Right to withdraw the declaration of consent under data protection law

You shall have the right to withdraw you consent at any time. The withdrawal of

consent shall not affect the lawfulness of processing based on consent before its

withdrawal.

9. Automated individual decision-making including profiling

You shall have the right not to be subject to a decision based solely on automated

processing, including profiling, which produces legal effects concerning you or

similarly significantly affects you. This shall not apply if the decision:

(1) is necessary for entering into, or performance of, a contract between you and the

data controller;

(2) is authorised by Union or Member State law to which the controller is subject, and

which also lays down suitable measures to safeguard your rights and freedoms and

legitimate interests;

(3) is based on your explicit consent.

These decisions shall not be based on special categories of personal data referred to

in Art. 9 (1) GDPR, unless point (a) or (g) of Art. 9 (2) GDPR applies and suitable

measures to safeguard your rights and freedoms and legitimate interests are in place.

In the cases referred to in points (1) and (3), the data controller shall implement

suitable measures to safeguard your rights and freedoms and legitimate interests, at

least the right to obtain human intervention on the part of the controller, to express

his or her point of view and to contest the decision.

10. Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you shall have the

right to lodge a complaint with a supervisory authority, in particular in the Member

State of your habitual residence, place of work or place of the alleged infringement if

you consider that the processing of your personal data infringes the GDPR.

The supervisory authority with which the complaint has been lodged shall inform the

complainant on the progress and the outcome of the complaint including the

possibility of a judicial remedy pursuant to Art. 78 GDPR.

IX. Data transfer within corporate group

Reports derived from personal data collected via this website are, in most cases,

anonymized before being provided upstream to Lucy Electric UK Limited, a company

registered in the United Kingdom and part of the Lucy Group. Where such reports are

not fully anonymized and contain personal data, this transfer is covered by the

European Commission's adequacy decision for the United Kingdom pursuant to Art.

45 GDPR.

Status as of July 2026