The Current Privacy Statement (Privacy Statement) of Startup Fintech Solutions applies to all legal entities of Startup Fintech group (“FSG” as well as “we” and “us”), including but not limited to Fintech Solutions Holding, Fintech Solutions Ventures, Fintech Solutions Fintech 2, and displays how FSG processes Personal Data.
Startup Fintech Solutions reserves the right to amend this Privacy Statement. If the Privacy Statement is amended, a notification on our website shall be displayed in a clear, easily accessible manner and additionally the content of the amendment will be reflected in FSG Newsletter.

This Privacy Statement was last updated on 20th of June 2022.

FSG is committed to respecting each individual’s privacy and upholding it in line with applicable data protection laws, including but not limited to the General Data Protection Regulation (GDPR).
‘Personal Data’ as defined in the GDPR means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
The following Privacy Statement aims to display the manner in which FSG upholds the prescribed level of data protection as established by the GDPR and applicable national laws. This Privacy Statement is applicable to the FSG newsletter, to the use of this website (https://fintec.solutions/) and in relation to any involvement related to FSG during:
a) FSG programmes such as accelerator Programmes, bootcamps for acceleration Programmes or online acceleration Programmes;
b) Events hosted by FSG;
c) Recruiting executed by FSG.

1. Definitions

The following terms used in this Privacy Statement shall be defined as follows: ‘Accelerator Programme’ also as ‘Programme’ – a FSG accelerator Programme is a Programme which consists of a 3 to 4 months on-site focused on idea shaping and validation, pitching, business development, sales and fundraising for early stage startups, which requires the startup’s founders/key employees to relocate to the city where the Acceleration Programme, to which the respective startup applied to, takes place or at times FSG may collaborate with other third party entities to form a ‘Joint Programme’, the conditions and structure of these Joint Programmes vary, A Joint Programme must be treated in the same manner as the Programme unless clearly brought out otherwise .
‘Affiliates’ – a natural or legal person who, designated by FSG, represents the FSG with regard to their respective non-permanent obligations agreed upon between the Affiliate and FSG . It should be noted that an Affiliate may be referred to as a ‘Mentors’, ‘Partners’ and ‘Alumni’.
‘Aware’ – when a natural or legal person knows or realizes a certain situation or fact.
‘Become Aware’ – when a natural or legal person acquires information about a situation or fact they/he/she have not previously known of neither had the possibility of acquiring such knowledge.
‘Bootcamp’ – A pre-selection event organized by FSG, with a purpose to reach to where the decisions which startups to invite to a FSG Accelerator Programme.
‘Consent’ – any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to him or her.
‘Data Anonymization’ – a process where personal identity of a data subject can never be traced, or if the personal identity could be recreated only with an unreasonable amount of time, expense and labor. Unreasonableness shall be assessed on a case by case basis.
‘Data Controller’ – means the natural or legal person, public authority, agency or body which, alone or jointly with others determines the purposes and means of the Processing of Personal Data.
‘Filing System’ – also referred to as ‘archive’, means any structured set of Personal Data which are accessible according to specific criteria, whether centralized, decentralized or dispersed on a functional or geographical basis.
‘Main establishment’ – The place of central administration in the EU or place where Processing of Personal Data takes place in the EU.
‘Online Pre-accelerator’ – a FSG 6-week online program provided for early stage startups with workshops, webinars, and mentoring calls. The whole Online Pre-accelerator is conducted using online resources.
‘Participation’ – the action or state of taking part in an event or Programme and/ or Online Pre-accelerator organized by FSG, by FSG employees and/or Affiliates as well as natural persons taking part in an event or Programme by FSG, particularly, but not limited to, natural persons involved as Affiliates of a startup.
‘Personal Data breach’ – a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.
‘Processing of Personal Data’, ‘Processing’, ‘Processed’ – any process, with or without the use of automated systems, to collect, store, organize, retain, modify, query, use, forward, transmit, disseminate or combine and compare data. This also includes disposing of, deleting and blocking data and data storage media.
‘Pseudonymization’ – the Processing of Personal Data in such a manner that the Personal Data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the Personal Data are not attributed to an identified or identifiable natural person.
‘Recruitment’ – means the process of searching for prospective startups to apply to an Accelerator Programme and/or Online Pre-accelerator conducted by FSG and/or the process of evaluating the fit of startups which have applied to an Acceleration Programme conducted by FSG, on their competence to participate in a Programme.
‘Supervisory authority’ – an independent public authority which is established by a Member State pursuant to Article 51 of the GDPR, who supervises, through investigative and corrective powers the application of EU and applicable national data protection laws.
‘FSG’s portfolio companies’ – the startups which have participated in FSG Programme and/or the startups (companies) into which FSG has invested.
‘Term Sheet’ – the Term Sheet (“TS”) summarizes the principal terms under which FSG has proposed to provide investment and Acceleration Programme to the respective startup.
‘Third Party’ – a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process Personal Data.
‘You’, ‘Your’ – a natural person who participates in events, Programme, Online Pre-accelerator hosted by FSG, visits FSG’s website, is in contact with FSG as part of FSG’s recruiting process with the intention of participating in a Programme or Online Pre-accelerator, is an Affiliate of FSG.
Below, FSG will provide details on when, why and how Your Personal Data is processed and collected by FSG as the Data Controller, the conditions under which it is disclosed to other parties, for what purposes, and how we uphold to secure Your Personal Data.

2. Name and contact information of FSG

General e-mail: info@fintec.solutions
FSG’s point of contact in relation to data protection and privacy may be reached at info@fintec.solutions

3. Your rights as a data subject

You as data subject have following rights regarding how FSG handles Your personal data:
The right to obtain from FSG confirmation as to whether or not Personal Data concerning You is being Processed;
The right to obtain information about the purposes of the Personal Data Processing;
The right to obtain information about the categories of Personal Data being Processed;
The right to obtain information about the recipients or categories of recipients to whom the Personal Data have been or will be disclosed;
The right to obtain information about the period for which FSG will store the Personal Data;
Where the Personal Data are not collected from You, you have the right to obtain information about any available information as to their source;
The right to object in case Personal Data Processing is necessary for the purposes of the legitimate interests pursued by the FSG and/or is done for direct marketing purposes;
In case the legal basis of Processing Your Personal Data is Consent (i.e. in case of FSG newsletter), to withdraw that Consent at any time;
To ask for access to the Personal Data that FSG holds about You;
To ask FSG to erase Personal Data without delay in following cases:
a. if it is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
b. if the only legal basis of Processing is Consent and that Consent has been withdrawn and there is no other legal basis on which FSG can process that Personal Data;
c. if the data subject objects to Processing where the legal basis is the pursuit of a legitimate interest of FSG or the public interest and FSG cannot show any overriding legitimate grounds or interest;
d. if You have objected to Processing conducted by FSG for direct marketing purposes;
e. if the Processing is unlawful.
To ask FSG to rectify inaccurate personal data or to complete incomplete personal data;
To ask from FSG for a copy of the safeguards under which Personal Data is transferred outside of the EU;
The right not to be subject to decisions based solely on automated Processing, including profiling, except where necessary for entering into, or performing, a contract, with FSG; it is based on the data subject’s explicit Consent and is subject to safeguards; or is authorized by law and is also subject to safeguards;
To prevent Processing that is likely to cause damage or distress to You or anyone else;
To make a complaint to the Data Protection Authority;
In limited circumstances where it is reasonable and not burdensome on FSG, receive or ask for Your Personal Data to be transferred to a Third Party (e.g. another accelerator to which a startup is transferring) in a structured, commonly used and machine-readable format.
We will uphold Your rights under data protection laws and allow You to exercise Your rights over the Personal Data we hold about You. This Privacy Statement will acknowledge these rights and explain how You can exercise them. Most rights are not absolute, and You will be able to exercise them depending on the circumstances, and exemptions may apply in some cases. Any request in respect of these rights should preferably be made in writing to info@fintec.solutions.
There is no fee for facilitating a request unless it is manifestly unfounded or excessive, in which administrative costs can be recovered. This shall be determined on a case by case basis.
Requests that are manifestly unfounded or excessive can be refused. If FSG was to refuse such a request, it shall provide a reasoning for such denial, within one month of receiving such a request, in the same format as the request was communicated to FSG. Unless this format is of a redundant nature such as telefax, in which case FSG shall communicate with the requester in an online communication format.
We will respond to the request within 30 days of becoming Aware of the request, which shall be displayed through an email from info@fintec.solutions, signifying that we have received and are processing Your request, if the period of response has been exhausted and no response was communicated to the person we will inform in brief of the reasons for the delay and commence communication on the request with the data subject no later than 60 days from being Aware of the request.
FSG’s Data security upholding Your rights as a data subject
FSG will implement appropriate technical and organizational measures in an effective manner to ensure compliance with data protection principles and security standards such as privacy by design. Our website configuration utilizes a secure Transfer Layer Protocol (TLS) encryption standard to ensure that Your Personal Data is safeguarded. Please note the https:// at the beginning of our website’s Uniform Resource Locator (URL) ensuring compliance with the secure TLS standard. We aim to continuously improve our security strategy to ensure Your safeguard.
In case of queries in relation to this Privacy Statement or any document in relation to Startup Fintech Solutions’ Privacy Statement please contact info@fintec.solutions

4. Processing Your Personal Data and its purpose

a) When You visit FSG’s website
What category of Personal Data is Processed –
When visiting startupwiseguys.com You are not prompted to disclose any personal information related to You, except Your public Internet Protocol (IP) address.
For what purpose is the Personal Data Processed –
This is an automatic feature of any web communication protocol and is done by Your terminal machine to establish a connection with the FSG websites server.
How long is the Personal Data collected retained –
The IP of the machine You use to access the FSG website is not processed or retained by us at any point.
b) When You register to the FSG newsletter
We provide You an option to subscribe to FSG’s newsletter,
What category of Personal Data is Processed –
The information needed to provide You this service (FSG newsletter) is solely Your email address. After submitting Your email address, You will receive an email from FSG prompting You to accept the registration to the FSG newsletter, which aids us in confirming that it is in fact You who Consents and wishes to be subscribed to FSG’s newsletter. The email address You have provided in order to obtain the FSG monthly newsletter is managed by Third Party applications, namely Sendgrid (Twilio) and Mailchimp, please get acquainted with their privacy statements at https://www.twilio.com/legal/privacy and https://mailchimp.com/legal/privacy/ for information on their means of Processing Your personal data.
For what purpose/on what basis is the Personal Data Processed –
The email is a mandatory requirement to be able to provide You with the newsletter. The display of a mandatory requirement such as the email address shall be accompanied by a distinctive sign such as a * next to the required field of an information form on the FSG website. We Process your Personal Data only if you Consent to subscribe to FSG’s newsletter.
How long is the Personal Data collected retained –
The Personal Data You provide is retained for as long as you Consent to receiving FSG’s newsletter.
How to unsubscribe from receiving FSG newsletter’s and withdraw Your Consent for FSG to Process Your Personal Data –
It must be noted that You have the right at any time to unsubscribe from the newsletter in two possible ways as follows:
By clicking on the appropriate link assigned for unsubscribing in FSG’s newsletter email (it is situated at the bottom of the email), and/or By contacting us at gdpr@startupwiseguys.com with the request of unsubscribing Your email address from the listed subscribers of FSG newsletters.
After withdrawing Your Consent, we shall automatically delete Your email from the list of subscribed persons if done through the first of the aforementioned ways. If Your choice of unsubscribing is through contacting us by email (the second way), You shall be unsubscribed no later than 7 days from the date of the request.
c) When You participate in events hosted by FSG
What category of Personal Data is Processed –
FSG Processes Personal Data particularly, multimedia such as photos of You during Your Participation in events organized or Participated by FSG, such as (but not limited to) –
Your Participation in FSG’s acceleration Programme and events organised within and related to the Programme;
Your Participation in FSG Bootcamp and events organised within and related to the Bootcamp;
Your Participation in FSG’s online acceleration Programme.
For what purpose/on what basis is the Personal Data Processed –
This retention is done on one of the following legal basis (a) Your written Consent to Process and/or publish such Personal Data, and/or (b) when it has been manifestly clear arising from the particular situation that Your Personal Data is Processed (Consent)
How long is the Personal Data collected retained –
You are free to withdraw the Consent to utilize Your Personal Data at any time You please. After withdrawing from Your Consent, we shall delete all Your Personal Data that You requested to be removed from our website or social media pages within 30 days of becoming Aware of the request, which shall be displayed through an email from gdpr@startupwiseguys.com, signifying that we have received and are processing Your request.
d) When You or Your company is displayed on the FSG website
What category of Personal Data is Processed –
FSG’s portfolio companies’ founder(s) full name(s) and Mentors full names, photos and occasionally Linkedin profiles are Processed and displayed on FSG’s website.
For what purpose/on what basis is the Personal Data Processed –
This Processing is done on the basis of Your Consent to publish such Personal Data
How long is the Personal Data collected retained –
You are free to withdraw the Consent to utilize Your Personal Data at any time You please. In case we displayed your personal data based on legitimate interest, You have the right to request FSG to delete Your personal data. After withdrawing Your Consent, we shall delete all data relating to the portfolio company information that You requested to be removed from our website within 30 days of becoming Aware of the request, which shall be displayed through an email from gdpr@startupwiseguys.com, signifying that we have received and are processing Your request.
e) When Your personal data is included in FSG’s social media posts
What category of Personal Data is Processed –
FSG’s marketing team regularly posts updates and information on current events and progress.
These posts include startups and businesses and may include Your Personal Data such as Your full name or a photo of You. You can find such publishing on sites such as but not limited to Linkedin, Twitter, Facebook, Instagram and Medium. This retention is done on one of the following legal basis (a) Your written Consent to Process and/or publish such Personal Data, and/or (b) when it has been manifestly clear arising from the particular situation that Your Personal Data is Processed (Consent)
How long is the Personal Data collected retained –
You are free to withdraw the Consent to utilize Your Personal Data by us in such online publishing at any time You please. After withdrawing Your Consent, we shall delete all data relating to the information that You requested to be removed from our website or online publishing within 30 days of becoming Aware of the request, which shall be displayed through an email from info@fintec.solutions, signifying that we have received and are processing Your request.
f) When FSG Transfers Your Personal Data to third parties
Except for the aforementioned points of Processing provided in this document, we share Your Personal Data to third parties only if:
It is necessary for the performance of a contractual obligation between FSG and You;
A statutory obligation exists for transferring, pursuant to compliance with a legal obligation to which the controller is subject to; and/or You have given Your freely given, specific, informed and unambiguous Consent.
g) When You enable cookies on our website
h) When You apply to a FSG Programme and/or Online Pre-accelerator
When You apply to a FSG Programme and/or Online Pre-accelerator You are subject to FSG’s Recruiting process. During the Recruiting process concluded by FSG members, third parties in particular, Google Hangouts and Whereby shall be utilized to initiate communication between persons applying to Programmes provided by FSG and a member of the FSG team. If You are concerned by how Your Personal Data is handled by these third parties, please refer to their privacy statements –
https://policies.google.com/privacy?hl=en-US
https://whereby.com/information/tos/privacy-policy/
What category of Personal Data is Processed –
When considered to be invited to any of our FSG programme of any kind, You as a data subject shall be prompted to fill out an application on a third-party application, StartupIncluder. In this application, You shall be prompted for
Your full name
Your email
Your Linkedin profile
Additionally You shall be prompted to share a pitch deck included in Your StartupIncluder profile, this pitch deck often contains Personal Data such as photos of a data subject. Also, During the Recruiting process comments by members of FSG are made regarding Yourself
For what purpose/on what basis is the Personal Data Processed & for how long is the Personal Data retained –
The Personal Data shared to FSG is based on Your Consent; please note that You may withdraw Consent to share Your personal information. We shall delete Your Personal Data if requested within 30 days of becoming Aware of the request. During the Recruiting process comments by members of FSG are made regarding Yourself based on the legitimate interest to evaluate Your company’s fit for collaboration with us. Please note that if prompted by You to provide access to any Personal Data collected by us, we shall execute Your request within 30 days of becoming Aware of the request and provide Your Personal Data collected in an understandable and easily accessible format. If You have prompted to have Your Personal Data deleted we shall execute Your request within 30 days of becoming Aware of the request. Please note that FSG acts as a joint data controller simultaneously with StartupIncluder, we acknowledge and agree to be joint controllers with StartupIncluder. The joint data controllership covers determining the creation, structure and aggregation of Your application on StartupIncluder. For any other purpose and means of processing of Your personal data on StartupIncluder, FSG and StartupIncluder shall act as separate and independent data controllers.
i) When You participate in a FSG Bootcamp
During the Bootcamp, the data subject participates as a member of a startup invited to the Bootcamp.
What category of Personal Data is Processed –
The data subject’s Personal Data is collected about their position at their team, their email and phone number, and Personal Data related to FSG’s due diligence process. Additionally during the Bootcamp, Mentors shall be present and in contact with teams in order to give written feedback on teams and at times Personal Data about specific team members.
The data subject has a right to request any comments from Mentors that are pertaining to himself/herself/themselves as a data subject.
For what purpose/on what basis is the Personal Data Processed & for how long is the Personal Data retained –
If the team during the Bootcamp is not accepted to the Programme following the Bootcamp, the data subject’s Personal Data shall be deleted within two weeks of the end date of the Bootcamp.
If the data subject’s team is accepted for the Programme, the provided personal information shall be retained on the basis of contractual obligation between FSG and Yourself in relation to due diligence requirements set forth by FSG typically included into a Term Sheet. This retained information shall be kept for no longer than the appropriate time established on a case by case basis (not later than FSG is not anymore, a shareholder of the startup in question).
j) When You participate in a FSG Programme
1. Your Rights and Data Processing
FSG shall process the data subjects Personal Data for the purpose of fulfilling pre-contractual obligations established in a Term Sheet signed between FSG and the data subject or data subjects, or contractual obligations agreed upon between parties in an investment agreement or to meet respective national anti-money laundering laws or FSG’s contractual obligations with third parties or as part of the investment process related to the Data Subject. After the conclusion of the Programme, each data subjects Personal Data may be utilized by FSG on the basis of legitimate interest for statistical and analytical purposes and placed within the FSG Filing System, this data shall be pseudo- anonymized within a reasonable period of time, yet no later than three years from the official end date of the Programmme.
2. Your Obligations
During the program, data subjects have an obligation to not hinder the rights of other persons in the program as established by the GDPR.
k) When You are a Mentor during FSG programmes or events
1. Your Rights
Mentors or other private persons known as Affiliates affiliated with FSG are also treated as data subjects under this Privacy Statement. We may process and distribute these person’s Personal Data, in particular their full name and contact information, to our customers and third-parties. These actions by FSG are done under a contractual obligation, achieved either through written or oral communication, and shall be clearly established between the Mentor and FSG. If such contractual obligations do not exist, the basis for Processing of Personal Data shall be the legitimate interest in the aid provided to our customers. This Processing and transfer of Personal Data shall be done solely when a Mentor has Consented to such action or actions. After withdrawing Your Consent we shall delete all data relating to the press kit or portfolio company information that You requested to be removed from our website within 30 days of becoming Aware of the request, which shall be displayed through an email from gdpr@startupwiseguys.com, signifying that we have received and are processing Your request. Additionally, we ask for certain feedback from team members of the startups participating in the Programme and/or Online Pre-accelerator with whom the Mentors are in direct contact on the performance of the Mentor during the workshops and one-on-one meetings conducted with participating startups, known as Mentor feedback. You are free to withdraw the Consent to utilize Your Personal Data at any time You please. You as a Mentor also have the right to request the Mentor feedback pertaining to You to be sent in an accessible and understandable format, we uphold to provide the requested information within 30 days of becoming Aware of the request, which shall be displayed through an email from gdpr@startupwiseguys.com, signifying that we have received and are processing Your request.
2. Your Obligations
Mentors have an obligation to uphold the standards on Personal Data of actors to who it pertains on the basis of the GDPR. By collecting and entering into contact with customers or affiliates of FSG, You as a Mentor have an obligation to not collect, share or transmit any information pertaining to a data subject’s Personal Data without either a legal basis to do so or the Consent of the data subject. In particular but not limited to, Mentors should be Aware of such an obligation when capturing information of a video, audio or photographic nature. Additionally what must be duly noted is the transmission of Personal Data of a data subject to third parties not employed or under the instruction of FSG.
l) When You participate in a FSG Online Pre-accelerator
1. Your Rights
For the Online Pre-accelerator ( also referred to as “OPA”), data subjects firstly apply to the program through a platform called StartupIncluder. On the platform FSG collects Personal Data of data subjects, in particular the full name, email, LinkedIn profile, pitch deck which may include photos of persons and additionally a short description of the startup pertaining to the data subject which may include information about the data subject him/her/themselves. After the conclusion of the online program, each data subject’s Personal Data may be utilized by FSG for statistical and analytical purposes and placed within the FSG Filing System, this data shall be pseudo-anonymized within a reasonable period of time, yet no later than three years from the official end date of the program. Additionally, sessions of the communication between FSG and their Partners and the data subjects of the OPA are recorded on the basis of legitimate interest to allow the facilitation of analysis about the data subjects. These sessions are done through various methods of online call communication. These recordings, either video or audio are deleted no later than 3 weeks after the conclusion of the Online Pre-accelerator Programme. All the collection of the aforementioned Personal Data in particular, the recordings of the data subject are solely done with the clear and specific Consent of the person, in relation to which this data is collected. Additionally any Personal Data that is otherwise collected other than on the basis of Consent shall be collected on the basis of legitimate interest of the ability of FSG to provide a better service to the participants of the online pre accelerator. When a company is rejected for the online pre accelerator, their Personal Data that they have provided may be stored on a third-party application, StartupIncluder, for a period of up to 1 year after the date of submitting the application by the person applying. The reason for storing this Personal Data is based on the legitimate interest for FSG to have the ability, yet not the obligation to contact the person for further business collaboration.
2. Your Obligations
The data subject during the OPA has an obligation to inform other data subjects who participate in the OPA about the Personal Data he/she/themselves collects about them, especially when doing group recordings; usually voicing his/her/their actions at the commencement of such a recording is sufficient, if none of the parties of the recording have objected. The data subject should bear in mind the regulation of collecting and Processing of other data subjects under the GDPR.