Visa Innovation Program Europe – Southern Europe

Privacy Policy

Last Updated: May 2026

This Privacy Policy explains how personal data is collected, used, disclosed, and otherwise processed in connection with the Visa Innovation Program Europe – Southern Europe (“VIPE Southern Europe” or the “Program”).

The Program is jointly organized and operated by Tenity Innovation Ltd. (“Tenity”) and Eleven Ventures S.A. (“Eleven”) (together, “we”, “our”, or “us”), in collaboration with Visa (“Visa”), for participants located in or applying from Southern European markets, including operations coordinated through the Athens, Greece program hub.

This Privacy Policy applies to founders, startup representatives, applicants, mentors, speakers, partners, investors, and any other individuals participating in or interacting with the Program.

By applying to or participating in the Program, you acknowledge that you have read and understood this Privacy Policy.

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1. Data Controllers

For the purposes of applicable data protection laws, including the General Data Protection Regulation (“GDPR”), the following entities jointly act as data controllers for personal data processed in connection with the Program:

Tenity Innovation Ltd.

Level39, One Canada Square

E14 5AB London

United Kingdom

📧 [london@tenity.com]

Eleven Bulgaria AD

37 Benkovski Str., 1st floor

Sofia, Bulgaria

📧 [eleven@eleven.bg]

Tenity Innovation Ltd. and Eleven Bulgaria AD jointly organize and manage the Visa Innovation Program Europe – Southern Europe in collaboration with Visa.

The parties have entered into an arrangement in accordance with Article 26 GDPR regarding their responsibilities as joint controllers.

For any questions regarding this Privacy Policy or personal data processing activities, you may contact either controller using the contact details above.

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2. Scope of the Program

The Visa Innovation Program Europe – Southern Europe supports fintech and technology startups operating within the Southern European ecosystem.

This Privacy Policy applies specifically to participants of the Visa Innovation Program Europe for the territories of:

  • Bulgaria
  • Greece
  • Cyprus
  • Malta
  • Italy
  • Spain
  • Portugal
  • Türkiye

The Program is managed jointly by Tenity Innovation Ltd. and Eleven Bulgaria AD, with Visa Europe acting as Program partner and supporter.

The Program may include, among others, activities related to:

  • startup scouting and selection,
  • accelerator and mentorship activities,
  • workshops and design sprints,
  • networking and partnership facilitation,
  • proof-of-concept support,
  • investor and corporate introductions,
  • demo days and graduation events,
  • marketing and communication activities.

This Privacy Policy applies to all Program-related activities conducted online or offline.

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3. Categories of Personal Data We Collect

We may collect and process the following categories of personal data:

3.1 Identification and Contact Information
  • Full name
  • Company name
  • Job title and role
  • Email address
  • Phone number
  • LinkedIn profile
  • Country and city
  • Business address
3.2 Application and Business Information
  • Startup information
  • Company stage and business model
  • Team information
  • Product or service descriptions
  • Pitch decks and supporting documentation
  • Market and financial information voluntarily submitted during the application process
3.3 Program Participation Data
  • Attendance records
  • Workshop participation
  • Mentorship interactions
  • Networking participation
  • Event registrations
  • Demo Day participation
  • Feedback and survey responses
3.4 Technical and Website Usage Information

When visiting Program websites or platforms, we may automatically collect:

  • IP address
  • Browser type
  • Device information
  • Website usage analytics
  • Cookies and tracking information

Please also refer to the applicable Cookie Policy available on the Program website.

3.5 Audio, Video, and Media Content

During Program activities and events, photos, videos, recordings, and livestream content may be captured for communication and promotional purposes.

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4. How We Collect Personal Data

We collect personal data:

  • directly from applicants and participants,
  • through application forms,
  • during meetings, workshops, and events,
  • through communications with Tenity or Visa,
  • from publicly available professional sources (e.g. LinkedIn or company websites),
  • through website analytics and cookies,
  • through referrals or partner organizations.

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5. Legal Basis for Processing

We process personal data based on one or more of the following legal grounds under GDPR:

5.1 Performance of a Contract

Processing necessary to evaluate applications and manage participation in the Program.

5.2 Legitimate Interests

Processing necessary for:

  • operating and improving the Program,
  • facilitating startup-corporate collaboration,
  • ecosystem building,
  • conducting communication and outreach activities,
  • ensuring Program security and integrity,
  • measuring Program impact.
5.3 Consent

Where required, we rely on consent for:

  • marketing communications,
  • certain media usage,
  • optional surveys,
  • specific event recordings.

Consent may be withdrawn at any time.

5.4 Legal Obligations

Processing necessary to comply with applicable laws, regulations, or legal requests.

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6. Purposes of Processing

We use personal data for the following purposes:

  • evaluating and processing Program applications,
  • selecting participating startups,
  • managing Program operations,
  • facilitating mentorship and networking,
  • organizing workshops, events, and meetings,
  • enabling collaboration opportunities with Visa and partners,
  • communicating Program updates and logistics,
  • preparing reports and internal analytics,
  • promoting the Program and ecosystem success stories,
  • improving Program quality and participant experience,
  • ensuring compliance and security.

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7. Sharing of Personal Data

We may share personal data with:

7.1 Visa Europe and Program Partners

The Visa Innovation Program Europe is a collaborative initiative supported by Visa Europe.

Personal data and application-related information may be shared with Visa Europe and relevant Program partners for purposes directly related to:

  • Program operations,
  • startup evaluation,
  • selection processes,
  • mentorship and networking,
  • collaboration opportunity assessment,
  • proof-of-concept discussions.

Where personal data is shared with Visa, such processing will be handled in accordance with Visa’s applicable privacy policies and legal obligations.

Information shared publicly or with partners will generally be limited to business-related and non-sensitive information unless otherwise required for Program operations.

7.2 Service Providers

We may share data with third-party service providers supporting:

  • event management,
  • communication tools,
  • CRM systems,
  • cloud hosting,
  • analytics,
  • marketing automation,
  • video conferencing platforms.

Such providers are contractually obligated to protect personal data.

7.3 Investors, Mentors, and Corporate Participants

Where relevant and necessary for Program participation, limited participant information may be shared with:

  • mentors,
  • investors,
  • corporate innovation teams,
  • ecosystem partners.
7.4 Legal or Regulatory Authorities

We may disclose personal data where required by applicable law or regulatory obligations.

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8. International Transfers

Personal data may be transferred and processed outside the European Economic Area (“EEA”), including in the United Kingdom, the United States, and other countries where Tenity, Eleven, Visa, or service providers operate.

Where international transfers occur, appropriate safeguards will be implemented in accordance with applicable data protection laws, including:

  • Standard Contractual Clauses,
  • adequacy decisions,
  • contractual and technical safeguards.

Some service providers used for communication, CRM, analytics, file storage, application management, or marketing purposes may process data outside the EEA.

All such transfers are conducted in compliance with GDPR requirements.

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9. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, including:

  • Program administration,
  • legal and regulatory compliance,
  • reporting obligations,
  • dispute resolution,
  • legitimate business purposes.

Application data for non-selected startups may be retained for future Program consideration unless deletion is requested.

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10. Your Rights

Under applicable data protection laws, you may have the right to:

  • access your personal data,
  • correct inaccurate data,
  • request deletion of your data,
  • restrict processing,
  • object to processing,
  • withdraw consent,
  • request portability of your data,
  • lodge a complaint with a supervisory authority.

Requests may be submitted to:

📧 [istanbul@tenity.com]

We may request verification of identity before responding to certain requests.

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11. Security Measures

We implement appropriate technical and organizational measures to protect personal data against:

  • unauthorized access,
  • accidental loss,
  • misuse,
  • alteration,
  • disclosure,
  • destruction.

However, no method of transmission or storage is completely secure.

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12. Marketing and Communications

Participants may receive Program-related communications necessary for participation.

Where legally required, marketing communications will only be sent based on consent or applicable lawful basis.

You may unsubscribe from marketing communications at any time through the unsubscribe link or by contacting us directly.

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13. Media and Publicity

During Program participation, photos, videos, livestreams, and recordings may be created during:

  • workshops,
  • networking events,
  • Demo Days,
  • Graduation events,
  • public Program activities.

These materials may be used by Tenity, Visa, and Program partners for:

  • Program promotion,
  • ecosystem communications,
  • social media,
  • reports,
  • websites,
  • press materials.

If you do not wish to appear in certain media materials, please inform the Organizer in writing prior to the relevant event whenever possible.

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14. Third-Party Links

Program websites or communications may contain links to third-party websites or services.

We are not responsible for the privacy practices of third-party platforms.

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15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

Updated versions will be published on the Program website together with the revised “Last Updated” date.

Continued participation in the Program after updates constitutes acknowledgment of the revised Privacy Policy.

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16. Southern Europe Program Applicability

This Privacy Policy applies specifically to the Visa Innovation Program Europe – Southern Europe and its related markets and operational activities.

Applicable local legal requirements may vary depending on the country of participation.

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17. Contact

For questions regarding this Privacy Policy or personal data processing activities, please contact:

Tenity Innovation Ltd.

Level39, One Canada Square

E14 5AB London

United Kingdom

📧 [london@tenity.com]

Eleven Bulgaria AD

37 Benkovski Str., 1st floor

Sofia, Bulgaria

📧 [eleven@eleven.bg]