1. Introduction

This Privacy Policy explains how The Calçotada Company ("the Company," "we," "our," or "us") collects, uses, and protects the personal information of users ("you," "your") when they access our fundraising platform at www.theonionmemorandum.org (the "Platform"). You agree to the terms set out in this policy by using the Platform.

2. Company Information

The Calçotada Company is registered in the Netherlands under the Dutch Chamber of Commerce number 93484739, with a registered office at Torenallee 42-28, 5617BD Eindhoven, The Netherlands. We are committed to protecting the privacy of all visitors and users of our Platform.

3. Data We Collect

We may collect the following types of personal data:

  • Personal Information: Name, address, email, phone number, birth date, nationality, and other information provided during the registration or investment process.
  • Transaction Information: Information about your investments, payment details, and any communications with us regarding these transactions.
  • Usage Information: Data regarding your interaction with the Platform, such as your IP address, browser type, and website activity.

4. How We Use Your Data

We use your data for the following purposes:

  • To Facilitate Investments: We process your data to facilitate your participation in the fundraising activities, including managing and verifying your investments.
  • Legal Compliance: We may process your information to comply with legal obligations, including financial regulations and reporting to relevant authorities.
  • Communication: We use your contact details to provide updates regarding your investments, notifications about the fundraising round, and other Platform-related communications.
  • Security and Fraud Prevention: To ensure the safety and security of our Platform and your data, we may monitor your usage and prevent unauthorized access or fraudulent activity.

We process your data on the following legal bases:

  • Consent: Where you have consented to processing your data for specific purposes.
  • Contract: Processing necessary for the performance of a contract, such as the terms of participation in the fundraising activities.
  • Legal Obligation: To comply with legal obligations under Dutch and European regulations.
  • Legitimate Interest: To protect the company's legitimate business interests, such as safeguarding the security of our Platform.

6. Data Sharing

We may share your data with:

  • Third-Party Service Providers: Companies that help us operate our Platform, including payment processors, communication providers, and legal advisors, in compliance with GDPR.
  • Regulatory Authorities: Where law requires, we may share your data with regulatory or government bodies in the Netherlands or other jurisdictions.
  • Other Investors: Limited information may be shared with other investors to facilitate transparency in the fundraising process.

7. Data Retention

We retain your data for as long as necessary to fulfill the purposes for which it was collected or to comply with legal obligations. When your data is no longer needed, we will securely delete or anonymize it.

8. Data Security

We implement appropriate technical and organizational measures to protect your data from unauthorized access, disclosure, alteration, and destruction. However, no system is entirely secure, and we cannot guarantee the absolute security of your data.

9. Your Rights

Under GDPR, you have the following rights regarding your data:

  • Access: Request access to your data.
  • Rectification: Request correction of any incorrect or incomplete data.
  • Erasure: Request deletion of your data under certain conditions.
  • Objection: Object to the processing of your data for specific purposes.
  • Data Portability: Request transfer of your data to another entity.
  • Withdraw Consent: You may withdraw your consent to data processing at any time, though this may affect your ability to participate in the fundraising activities.

10. International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA). Where this occurs, we ensure that appropriate safeguards, such as Standard Contractual Clauses, are in place to protect your data.

11. Updates to this Policy

We reserve the right to update this Privacy Policy as necessary. Any changes will be posted on this page, and we encourage you to review this policy periodically.

12. Contact Information

For any questions or concerns regarding this Privacy Policy or your data, please get in touch with us at:

The Calçotada Company
Torenallee 42-28
5617BD Eindhoven
The Netherlands


Email: legal@theonionmemorandum.org

  • Last update
  • 24 September 2024