Legitimate Interest Statement

1. About this statement

Dealroom.co B.V. (Dealroom.co, we) processes information about people in the start-up and investment ecosystem on the basis of legitimate interest (Article 6(1)(f) GDPR), as described in our Privacy Policy. This statement summarises our assessment of that processing, following the three steps in the European Data Protection Board's Guidelines 1/2024: is our interest legitimate, is the processing necessary, and is it not overridden by your interests and rights?

2. Profiles of people on our platform

Step	Assessment
Interest	Providing transparency on the start-up and venture capital ecosystem. Investors use it to find companies, companies to find investors and partners, and governments and researchers to understand and support their ecosystems.
Necessity	The ecosystem cannot be mapped without the people who found, lead, and fund companies. We limit ourselves to professional information relevant to that role. Asking every person for consent in advance is not possible at this scale and would leave the picture incomplete. Automated tools, including AI, are needed to keep this information accurate and current.
Balancing	The information is professional and largely published by the people themselves, their companies, the press, or public registers. Founders, executives, and investors have public-facing roles and can expect them to be reported on. The main risks are inaccurate information and unwanted contact. Our scores and rankings are opinions based on professional track record, and no decisions with legal or similarly significant effects are taken on their basis.
Safeguards	No special categories of data, home addresses, or private contact details. Collection from public professional sources only, with human review of data quality. Profile claiming to correct information, and removal of the profile on objection. Customers may use the data only as permitted by our Terms & Conditions, may not resell it, and need their own legal basis for any outreach.

3. Business email addresses

Step	Assessment
Interest	Enabling professional contact within the ecosystem, such as investors reaching founders.
Necessity	Professional contact requires a way to reach someone. We use business email addresses only, obtained from licensed data providers.
Balancing	The impact is higher than for other profile data, because it enables direct and possibly unwanted contact.
Safeguards	No private email addresses. Available to paying customers only, not on our public website. Customers must comply with e-marketing rules and have their own legal basis for outreach. You can remove only your email address and keep your profile.

4. Gender, nationality, and age

Step	Assessment
Interest	Producing statistics on diversity in the ecosystem, such as the share of funding going to companies with female founders, which governments, investors, and researchers use to design and evaluate policies and programmes.
Necessity	These statistics cannot be produced without information on the people they describe. Gender is shown on a profile only where the person stated it publicly; estimated gender is used only for company tags and statistics. Age is estimated and used only for statistics.
Balancing	None of this is special category data under the GDPR, but estimates can be wrong, and an incorrect gender attribution can be hurtful.
Safeguards	Estimated gender and age are never shown on individual profiles. We do not use photos to estimate gender, and never use any data to estimate ethnic origin. Statistics are published in aggregated form only. You can ask us to correct or remove your gender, nationality, or age, or a company tag based on it, at any time.

5. Your right to object

You can object at any time through our Privacy Request Form or by emailing [email protected]. If you object to your profile, we remove it. Other legitimate interests we rely on, such as marketing and security, are described in our Privacy Policy.