Below you will find the general policies of NordicNinja VC:
ESG – Environmental, social and governance
NordicNinja is committed to transparency and disclosure on sustainability-related disclosures, see our investment decision-making process.
Privacy policy
JB Nordic Ventures Oy and NordicNinja VC (“JB Nordic” or “we”) values and respects the right to privacy and data protection provided by applicable laws whenever we process personal data pertaining to our stakeholders. JB Nordic strives to process personal data in a transparent way, with due care and always in compliance with our obligations arising out of applicable privacy and data protection legislation.
This Privacy Policy is applicable to the processing activities of JB Nordic as data controller concerning personal data collected through our website www.nordicninja.vc, including any subdomains thereof (the “Website”) as well as any of our services or web-based applications provided on or through the Website from time to time. The Website and services thereof are hereinafter collectively referred to as the “Services”.
This Privacy Policy describes why and how we process personal data concerning the visitors to and users of our Services (“User” or “you”) as data controller in accordance with the informing obligations set forth in articles 13 and 14 of the EU general data protection regulation 2016/679.
This Privacy Policy may be subject to changes from time to time if required due to changes in data processing practices or otherwise. The current version can be found on the Website. No material changes shall be made without providing a notice thereof.
Kindly note that this Privacy Policy only applies to processing of personal data by JB Nordic as data controller. To the fullest extent permitted under applicable laws, we shall hereby disclaim all responsibility for the processing carried out by third parties including where the Services include hyperlinks or other links to websites or services of third parties.
CONTACT DETAILS
Name: JB Nordic Ventures Oy and NordicNinja VC
Company ID: 2947095-4
Address: c/o Maria 01, Lapinlahdenkatu 16, 00180 Helsinki
You may contact us by email at for information about processing your personal data.
what kind of personal data we process and from where do we obtain such data
Personal data of Users
Our Services may collect three (3) types of information concerning the Users: (i) User Data; (ii) Technical Data; and (iii) Analytics Data.
User Data is primarily received directly from you either in connection with your use of the Services (for example when you fill out any forms available on the Website or subscribe to our newsletter) or in connection with your interaction with us.
The categories of User Data we may collect and process, depending on the Services, include: (i) phone number; (ii) full name; (iii) e-mail address; or (iv) data from your feedback or other interaction with us.
Technical Data is collected automatically by our Website and may include the following: (i) IP address; (ii) language preferences; (iii) browser type; (iv) operating system; or (v) parts visited on our Services. Individuals cannot by default be identified from Technical Data. However, on some occasions individuals may be, either directly or in conjunction with other data, recognizable. In such case, Technical Data shall be considered personal data, and we shall process it in accordance with this Privacy Policy and applicable laws.
COOKIES and ANALYTICS TOOLS
In addition to User and Technical Data, we may from time to time use different technologies to collect and store Analytics Data pertaining to the use of the Services, including cookies. Analytics Data is primarily processed in order for us to analyze the use of and to develop our Services as well as engage in marketing activities. For detailed information about the use of cookies, analytics tools and social media plugins concerning the Services, please refer to our Cookie Policy
for what PURPOSES AND under which legal bases may we process PERSONAL DATA OF USERS
Purposes of processing
To provide the Services and carry out our contractual obligations (legal ground: performance of a contract and legitimate interest)
Our processing of your personal data is primarily based on the provision of the Services. We may process personal data to be able to provide essential functionalities for and access to the Services for Users and to personalize the user experience or enhance the quality of the Services. In some cases, personal data may be processed for the purpose of carrying out contractual obligations towards the User. Further, if you contact our customer service, we may use the provided information for answering questions and solving possible issues.
To fulfill our legal obligations (legal ground: compliance with a legal obligation)
We may need to process personal data to fulfill our legal obligations, such as our bookkeeping obligations or to provide information to competent authorities (e.g. tax authorities).
For statistical and analytical purposes (legal ground: legitimate interest)
We may gather Analytics Data and other anonymous data in an aggregated form to generate reports and statistics and further use such reports and statistics for marketing purposes. By default, such reports or statistics do not include any personal data.
For communication and marketing (legal ground: legitimate interest)
We may process personal data for the purpose of contacting our Users regarding our Services and for informing Users of changes in our Service. We may also process personal data to market our Services, for example in the form of sending newsletters or analyzing the User’s activities within our Services to customize our marketing efforts.
Explaining the legal bases for processing
To the extent personal data is processed based on a contract between us and the User, the legal basis shall be performance of contractual obligations. We may also process personal data based on our legal obligations or other legitimate interests, for example in connection with quality improvement, analytics, marketing and legal processes. Whenever using your data based on our legitimate interest, we shall carefully weigh our interest against your right to privacy.
In certain cases, you may be requested to grant your consent for the processing of your personal data. In this event, the legal ground for such processing is your consent. You may withdraw your consent at any time.
We do not under any circumstances process Users’ personal data for the purposes of automated individual decision-making, including profiling.
INTERNATIONAL TRANSFERS
We strive to keep all personal data subject to this Privacy Policy within the European Economic Area. However, we do have service providers engaged in the operation of the Website in several geographic locations, such as Google Analytics. As such, we and our service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area or outside of your domicile.
In these situations, we shall ensure that your personal data is subject to adequate level of protection regardless of the jurisdiction. This happens by concluding a series of agreements with our service providers based on the Standard Contractual Clauses or through other appropriate safeguards under chapter V of the EU General Data Protection Regulation (2016/679).
PERSONAL DATA RECIPIENTS
We shall not share your personal data within our organization, unless strictly necessary to perform our Services. We shall further not share personal data with any third party, unless one of the following circumstances apply:
It is necessary for the purposes set out in this Privacy Policy
To the extent that third parties need access to personal data to ensure the performance of the Services, we have taken appropriate contractual and organizational measures to ensure that personal data is being processed exclusively for the purposes specified in this Privacy Policy and in accordance with all applicable laws and regulations.
For legal reasons
We may share personal data with third parties outside of our organization if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, properties or safety of JB Nordic, our Users or the public in accordance with the law. When possible, we will inform you about such transfer and processing.
To authorized service providers
We may share personal data to authorized service providers who perform services for us (including data storage, marketing and support services). Our agreements with our service providers include commitments that the service providers agree to limit their use of personal data and to comply with privacy and security standards at least as stringent as the terms of this Privacy Policy.
For other legitimate reasons
To the extent JB Nordic is involved in a merger, acquisition or asset sale, we may transfer personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to those concerned when the personal data are transferred or become subject to a different privacy policy as soon as reasonably possible.
With explicit consent
We may share personal data with third parties outside of our organization for other reasons than the ones mentioned above, when we have your explicit consent to do so. You have the right to withdraw your consent at any time.
STORAGE PERIOD
Your personal data shall not be stored by us any longer than necessary for the purposes of providing the Services or parts thereof, or for another individual purpose for which your data is being processed hereunder. The exact storage period depends on the nature of the information and the purposes of processing. Hence, the maximum storage period may vary per use case.
Generally, personal data of Users is deleted within a reasonable time after the User no longer uses any part of the Services or when the User requests the deletion of such personal data, unless we are obligated to store the data for longer periods due to applicable law.
YOUR RIGHTS
Right to access
You have the right to access your personal data processed by us. You may contact us and we shall inform what kind of personal data we have collected and processed regarding you.
Right to withdraw consent
In case the processing is based on a consent you have granted us, you may withdraw the consent at any time. Withdrawing your consent may lead to fewer possibilities to use our Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to rectify
You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us.
Right to erasure
You may also ask us to erase your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.
Right to object
You have the right to object to certain use of your personal data if such data is processed for other purposes than necessary for the performance of the Services or for compliance with a legal obligation. If you object to the further processing of your personal data, this may lead to fewer possibilities to use our Services.
Right to restriction of processing
You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use our Services.
Right to data portability
You have the right to receive your personal data from us in a structured and commonly used format and to independently transmit that data to a third party.
How do you use your rights hereunder
The abovementioned rights may be used by sending a letter or an e-mail to us on the addresses set out above, including the following information: full name, address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm your identity.
We reserve the right to reject requests that are unreasonably repetitive, excessive, or manifestly unfounded.
INFORMATION SECURITY
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience, and ability to restore the data. We regularly test our systems, and other assets for security vulnerabilities.
Should despite of the security measures, a security breach occur that is likely to have negative effects on your privacy, we will inform you and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as reasonably possible.
LODGING A COMPLAINT
In case you consider our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection.
In Finland, the local supervisory authority is the Data Protection Ombudsman (https://www.tietosuoja.fi).
DISCLOSURES
As Japanese investors invest in our fund, please note that our fund is in compliance with the Financial Instruments and Exchange Act in Japan (the “FIEA”). Please click the following link to view the public disclosure required by the FIEA with respect to the Specially Permitted Business for Qualified Institutional Investors, etc. of the following entities:
JB Nordic General Partner S.à.r.l.
Notification Form for Specially Permitted Businesses for Qualified Institutional Investors, etc.(FIEA Article 63(2)) (Form20-2).
Explanatory document (FIEA Article 63-4(3)) (Form21-3).
NordicNinja Fund II General Partner S.à.r.l.
Notification Form for Specially Permitted Businesses for Qualified Institutional Investors, etc.(FIEA Article 63(2)) (Form20-2)