UPDATED SEPTEMBER 10, 2020
Thank you for visiting the Accel website. Accel respects your privacy. Whether you deal with us as an investor, entrepreneur or member of the general public, you are entitled to the protection of your personal data.
The aim of this policy is to describe how and why we collect your personal data. We will also inform you of what we do with this data, with whom we share it, how we protect it and the choices you can make.
This policy applies to the processing of your personal data in the framework of various services, tools applications, websites and marketing actions which are provided or operated by us or on our behalf(collectively, the “Accel Platform”). This policy does not apply to the privacy practices of companies we do not control (including any portfolio companies),nor to any information obtained or collected in connection with a separate business relationship with Accel or its affiliates, including as an investor in an Accel investment funds, an employee of Accel’s portfolio companies or as a service provider. The policy will also contain general rules and explanations regarding this processing.
This Policy applies to all your personal data collected by (or on behalf of) Accel through Accel Platform, referred to in this Policy as “Accel”,“we”, “us” and “our”.
Who is responsible for the processing of your data?
We have offices in the United Kingdom, United States of America and India. Our UK office is our representative in the European Union and is registered with the UK supervisory authority, the Information Commissioners Office (ICO). We will be considered the Data Controller and our UK address is 1 New Burlington Place, Mayfair, London W1S 2HR United Kingdom.
Should you wish to contact our other offices, they may be found at:
US address: 500 University Avenue, Palo Alto, CA 94301, USA.
India address: 886/A, Confident Electra, 17th E Main Road, Koramangala, 6th Block, Bengaluru, Karnataka 560095, India
Who can you contact if you have questions or requests?
Our Data Protection Contact Point will handle any questions or requests relating to this policy, any specific privacy notice or your personal data and its processing.
For any questions, requests, complaints concerning the application of this policy, or to exercise your rights, as described in this policy, you may contact us at the Data Protection Contact Point:
Address: 1 New Burlington Place, Mayfair, London W1S 2HR. United Kingdom.
Phone: +44 20 7170 1000
We value the personal data entrusted to us and are committed to processing your personal data in harmony with the data protection laws and regulations to which Accel is subject, including the EU General Data Protection Regulation and the California Consumer Privacy Act (“Data Protection Laws”). The terms “personal data” and “personal information,” as used herein, refers specifically to information that identifies a visitor to the Accel Platform, or which (which may includes contact information and also any information referred to as “Personal Information” under the California Consumer Privacy Act (“CCPA”)).
We will aim to adhere to the following key principles:
Lawfulness: We will only collect your personal data in a fair, lawful and transparent manner.
Data minimization: We will limit the collection of your personal data to what is directly relevant and necessary for the purposes for which they have been collected.
Purpose limitation: We will only collect your personal data for specified, explicit and legitimate purposes and not process your personal data further in a way incompatible with those purposes.
Accuracy: We will keep your personal data accurate and up to date.
Data security and protection: We will implement technical and organizational measures to ensure an appropriate level of data security and protection considering, amongst other things, the nature of your personal data to be protected. Such measures provide for the prevention of any unauthorized disclosure or access, accidental or unlawful destruction or accidental loss, or alteration and any other unlawful form of processing.
Access and rectification: We will process your personal data in line with your legal rights.
Retention limitation: We will retain your personal data in a manner consistent with the applicable Data Protection Laws, and no longer than is necessary for the purposes for which they have been collected.
Protection for international transfers: We will ensure that any of your personal data transferred outside the EEA is adequately protected.
Safeguards towards third parties: We will ensure that personal data access by, and transfers to, third parties are carried out in accordance with applicable law and with suitable contractual safeguards.
Processing your personal data
Your name and contact details
We use your name and contact details, such as email, postal address and contact number to continue communications with you. We may also use your contact information to invite you to events we are hosting or to keep you updated with our news.
We may use your identity documentation to conduct mandatory legal checks such as anti-money laundering checks. You will be informed if your data is used in this way.
For special events, Accel may take photos and video recordings of you. We will always inform you if this is happening.
Automatically collected information
Accel may collect information during your visit to the Accel Platform through automatic data collection tools, which may include cookies (see below for more information on cookies) and other commonly used information-gathering tools. These tools collect certain information that your browser sends to our website such as your browser type and language, access times, and the address of the website from which you arrived at the Accel Platform. They may also collect information about your Internet Protocol (IP) address and clickstream behavior (i.e. the pages you view, the links you click, and other actions you take in connection with the website), geolocation data, and information about your device. Accel may also share this information in aggregate form (i.e., that cannot reasonably identify a particular individual) with third parties for business purposes, such as service providers and consultants to Accel.
Legal basis for processing
Please note that in accordance with applicable Data Protection Law, your personal data can be processed if:
• you have given us your consent for the purposes of the processing; or
• it is necessary for the performance of a contract to which you are a party; or
• we have a legitimate interest that is not outbalanced by your privacy rights; or
• it is required under a legal obligation to which we are bound.
For the avoidance of doubt, you will always have the right to withdraw your consent at any time.
How long we keep your personal data
We will only keep your personal data for as long as necessary for the purposes for which we process your personal data or to comply with the law. For information on how long certain personal data is likely to be kept before being removed from our systems and databases, please contact us at the Data Protection Contact Point.
Protecting your personal data
We have a set of reasonable technical and organizational security measures in place to protect your personal data against unlawful or unauthorized access or use, as well as against accidental loss or damage to its integrity. They have been designed by taking into account our IT infrastructure, the potential impact on your privacy, the costs involved and the current industry standards and practice.
Our data security procedures include: access security, backup systems, monitoring, review and maintenance, management of security incidents and continuity. Your personal data will only be processed by a third-party Data Processor if they agree to comply with those technical and organizational data security measures.
Disclosure of personal data & third parties
Depending on the purposes for which we collect your personal data, we may disclose it to the following categories of recipients, which will then process your personal data only within the framework of these purposes:
• authorized staff members of Accel.
• entities and persons affiliated with the Accel family of funds, and their related management companies and other affiliated entities
We do not sell or rent your personal information for valuable consideration.
Transfers outside the EEA
Accel has locations in the UK, USA and India. Personal data is routinely shared internally between these locations. We have internal agreements to ensure the protection of your data.
Your personal data will be processed outside the EEA. When there is any transfer of your personal data to countries outside the EEA that do not generally offer the same level of data protection as that within the EEA, Accel will implement appropriate specific measures to ensure an adequate level of protection of that personal data. As an example, these measures can include agreeing on binding contractual clauses with recipients that guarantee adequate levels of protection.
Your choices and rights
We want to be as transparent as possible with you, so that you can make meaningful choices.
Under Data Protection Law, you are entitled to the following:
• a right of access to your personal data;
• a right to object to the processing of your personal data in certain circumstances;
• a right to rectify any information which is inaccurate;
• a right to the erasure of your personal data (also known as the “right to be forgotten”); provided that Accel may retain your information only if it necessary to provide you with services you requested or for our internal analytical use
• a right to data portability when the processing activity is based on consent or under a contract with the you, i.e. the right to receive your data or to have the data transmitted to a third party;
• a right to ask us to restrict the processing of your personal data if you have challenged the accuracy of your data, or if you have objected to the use of your data. You may also ask us to limit the use of your data where your feel we may have processed your data unlawfully, or where you want us to keep your personal data in order to create, exercise or defend legal claims; and
• a right to not be discriminated for exercising your rights under the Data Protection Laws.
If personal information is being processed with your consent, you may withdraw this at any time. You also have the right to lodge a complaint with the supervisory authority or seek judicial remedy. These rights can be exercised verbally or in writing by emailing firstname.lastname@example.org.
If you are not happy with the way we manage your data, disagree with a decision we have made in respect to your individual rights, or you have any other type of concern, you may raise a complaint by contacting us.
If you are dissatisfied with the way your issue was dealt with, you may also lodge an official complaint with the Information Commissioners Office (ICO) who can be contacted directly on +44 303 123 1113 or by visiting https://ico.org.uk/make-a-complaint/.
We may occasionally make alterations to this policy which will reflect how we process and look after your data. This is to ensure we honor our commitment to you to protect your information and uphold your rights. If important changes are made to this policy, we will draw your attention to them by making this clear on our website, through our services or by another means of communication, such as email. This will allow you to assess the changes in light of the data that we might be holding.