2. Who we are

Caribou Digital (UK) is a Limited Company registered in England and Wales with registered number 09241564 and registered offices at 56 Echo Barn Lane, Wrecclesham, Farnham, Surrey, GU10 4NF. We are committed to protecting and respecting your privacy.

The Company is registered as a data controller in the Data Protection Register of the UK Information Commissioner’s Office (ICO) with Registration Number ZB053921.

The Company is acting as the Fund Manager and Grant Administrator on behalf of the Mastercard Impact Fund.

Any information we obtain from you in relation to the Innovation Fund, whether through our online application platform, publicly sourced information, communication via email, at events or elsewhere, will be managed according to this policy. This includes where we collect information that is personal data and subject to data protection legislation.

This policy is written to comply with both the General Data Protection Regulation (EU 2016/679), (“GDPR”) and the UK Data Protection Act 2018 (“UK GDPR”).

3. Type of information we collect about you and how it is collected

We may collect personal data including your name, email address, postal address, and landline or mobile number. We may collect this personal data when:

• You apply for an Innovation Fund Grant and you create an account and input data using the Strive EU Innovation Fund Application Portal (“Portal”), owned by Submittable Holdings, Inc. Any data you save, even if not submitted, will be shared with the Company.
• You participate in, access, or sign up to any of our services, including social media; our website, Caribou Digital; subscribe to our newsletters; or register for our events.
• You otherwise correspond with us.

During an Innovation Fund application process we will not ask you about special category data. If at a later date we would like to collect special category data, we will seek your consent and state the purpose of doing so. Special category data includes your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and data concerning your health, sex life, or sexual orientation.

Innovation Fund applications that are successful are subject to due diligence. As part of this process we may obtain additional information in connection to key stakeholders listed in your application (board members, shareholders, senior management, and key project personnel). This additional information may be gathered from the internet and/or third-party due diligence software, or requested from you directly. This information will only be used for due diligence checks.

Depending on the activity, during an Innovation Fund process we may also obtain information about your business. For example, when applying for an Innovation Fund grant via the Portal, we may collect information including the name and type of your business and its address, as well as company policies, shareholder information, and financial records. Some of this information, including your project ideas, may be confidential information or commercially sensitive. While this information does not fall under the remit of GDPR or UK GDPR, we will protect the confidentiality of your information in accordance with our normal procedures and legal requirements. We will not use it for any purposes other than those set out in this policy.

We use cookies and collect IP addresses to analyze our website traffic. This information may be shared with a third party, such as a digital media agency or analytics partner.

When you sign up for our newsletter, we collect your name and email address. We collect this information directly from you when you provide it to us by filling in the “Sign up to our newsletter” form on our website.

When you contact us via email, records of your correspondence (including your email address) will be held by the Company.

4. How we use your information and why we can use it

We collect and process data, including personal data, in the following ways:

• In order to review and assess your Innovation Fund application, complete eligibility checks and due diligence, enter into grant-making contracts, and for internal administration and grant support.
• For statistical information, reporting, and evaluations. This includes analyzing the data for research purposes and to incorporate it into our databases for general research and analysis purposes. Anonymized aggregated data may be shared with external companies for analysis for monitoring and evaluation purposes.
• To assess the effectiveness and success of the Innovation Fund application and grant-making process or the efficacy of communications campaigns.
• To comply with compliance and audit-related activities.
• To comply with the contractual obligations between the Company and Mastercard Impact Fund.
• To comply with our legal obligations including detection of fraud, anti-money laundering, and sanctions checks.
• To facilitate events (face to face, virtual, or hybrid) you have indicated you may attend.
• To send you newsletters, promotional materials, information on events, or other communications that you have consented to receive.

Under both GDPR and UK GDPR, the lawful bases we rely on for processing this information are:

• Your consent. You are able to remove your consent at any time. You can do this by contacting info@CaribouDigital.net with a request to delete your personal information. You can unsubscribe from our email newsletter at any time.
• We have a contractual obligation.
• We have a legal obligation.
• We have a legitimate interest.

5. How we store your information and for how long

5.1 For the Innovation Fund:

• Your data is securely stored on the application Portal, hosted by Submittable Holdings, Inc.
• We may download the data and store it on an encrypted cloud workspace. Your personal data will not be stored beyond 31 December 2030 and will be securely erased from our systems.

5.2 For email newsletter sign ups:

• Your data is stored in Mailchimp, the platform we use for newsletter management. Learn more about Mailchimp’s privacy practices.

5.3 For website analytics:

• Aggregated analytical data is stored in Google Workspace.

6. Who we share your information with

6.1 General Use

We will not share your information without obtaining your consent unless:

• We have to disclose or share it in order to comply with our legal obligations, including audit, fraud prevention, anti-money laundering, and sanctions.
• We need to share it for a legal contract with you.
• It is necessary to protect our rights, property, or safety of our employees or others.

6.2 The Innovation Fund and third parties

By submitting an application via the Portal, you consent to your data being processed by the Company, including its contractors, in order to assess your application.

In accordance with our contractual obligations, information may be shared with the Innovation Fund donor, Mastercard Impact Fund, or their affiliate, Mastercard Center for Inclusive Growth. Mastercard’s Global Privacy Notice covers both entities. Sharing information with Mastercard employees involves the transfer of your data outside of the European Economic Area, for which we have a legally binding agreement to protect the transfer of your data.

Applicants who are shortlisted will be invited to complete a mini proposal. This proposal will be shared with a technical review panel consisting of 4 to 6 people, who will assess the application.

A summary of applications that progress to the final stage will be shared with the Strive EU Small Business Council, who will determine the eventual winners. The Small Business Council will consist of 10 to 12 people from European companies.

By submitting an application via the Portal, you consent to the terms and conditions set out by the Portal owner, Submittable Holdings, Inc., 101 E. Front St, Suite #500, Missoula, MT, 59802. We are not responsible or liable for data collected or processed by Sumittable. Learn more about Submittable’s privacy policy and Submittable’s approach to GDPR.

7. Access to your information, portability, correction and erasure

You have the right to request a copy of the information that we hold about you. You can also request that we transfer your personal data to another organization. If you would like a copy of some or all of your personal information, or to request a data transfer to another organization, please email or write to us at the address below.

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove (erase) any personal information.

You also have the right to ask us to restrict the processing and/or object to the processing of your personal information in certain circumstances.

8. How to contact us or make a complaint

Questions, comments, or requests concerning this privacy policy or data protection matters are welcome and should be addressed to us at:

Caribou Digital UK Ltd, 56 Echo Barn Lane, Wrecclesham, Farnham, Surrey, GU10 4NF

Email: info@cariboudigital.net

You can also complain to the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your data. The ICO’s address is:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

END.