Angelwise Privacy Policy

Last updated: 24/01/2024

Background

This policy is based on Angelwise Management BV, located at Hendrik van Veldeksingel 150/7, 3500 Hasselt, with company number 0778.700.261, and the funds managed by it (collectively referred to as "Angelwise," "we," or "us"). References to "you" and "your" pertain to individuals outside Angelwise, including but not limited to users of our website, (potential) investors, portfolio companies, prospects, suppliers, and applicants.

This Privacy Policy applies solely to the processing of Personal Data of natural persons, not legal entities, and is intended to inform you about the processing of your Personal Data (as described below) occurring through the Angelwise website (www.angelwise.be) ("website") or through the use of our contact details (i.e., email, phone, post).

The protection of your Personal Data is crucial to us. We ensure that your Personal Data is processed securely and lawfully, always in accordance with applicable data protection laws, particularly the General Data Protection Regulation ("Regulation"). This Privacy Policy explains how we use the Personal Data we collect about you.

Data Controller

Angelwise is the data controller for the processing of your Personal Data, as defined by the Regulation.

Personal Data

"Personal Data" includes all data that identifies you or that we can otherwise link to you. The Personal Data we collect includes your name, first name, postal address, email address, phone number, company name, company structure, job title, business relationships, and your preferred language.

We collect your Personal Data voluntarily provided by you, for example, when:

(i) you communicate with us via email or other channels;

(ii) you sign up for or request certain information from us; and/or

(iii) you register for an event or spontaneously submit an investment dossier to us (via email, website, third-party pitching events, etc.).

In some cases, your Personal Data may be supplemented with information from other sources, including searches through publicly accessible search engines, industry-specific newsletters, and social media.

Processing of Personal Data – Purposes and Legal Basis

Communication

We process your Personal Data for communication purposes, including:

• sending you information sheets, newsletters, and other information related to Angelwise;

• sending you invitations to events and conferences;

• maintaining our contact list; and

• answering your inquiries.

We process this Personal Data based on our legitimate interests in maintaining business relationships and communicating with you as a business contact about Angelwise activities and events. We believe that our legitimate interests are in line with the Regulation and your legal rights and freedoms. You can object to this processing of Personal Data at any time according to Article 6.

To enter into agreements with you and/or provide you with our services

We process your Personal Data to enter into agreements with you and fulfill them, including providing services you have requested. For this purpose, we may process Personal Data such as your name, first name, job title, company name, address, email address, and billing and payment information. We process this data to perform the contract with you. Without your Personal Data, we cannot execute the contract and provide you with our services.

To comply with our legal and regulatory obligations

If you are a business contact of Angelwise, we must comply with certain legal and regulatory obligations, including but not limited to anti-money laundering laws according to Article 7 and tax and accounting obligations. For this purpose, we may process Personal Data such as your name, first name, postal address, email address, phone number, your correspondence with Angelwise, and your financial information such as the origin of your funds and assets. The processing of your Personal Data for this purpose is based on the necessity for Angelwise to comply with a legal obligation.

Handling our own disputes

We may process your Personal Data to handle our own disputes and protect and enforce our rights. For this purpose, we may process Personal Data such as your name, first name, postal address, email address, phone number, your correspondence with Angelwise, and your financial information. The processing of your Personal Data for this purpose is based on our legitimate interests in being able to protect our rights in case of a dispute.

Access to your Personal Data

For the purposes mentioned above, we may store your Personal Data with third parties (software and cloud providers, email providers, and file storage systems).

For the purposes mentioned above, we may also share your Personal Data with affiliated companies. We will ensure that, where applicable, contractual safeguards are implemented to ensure the protection of your Personal Data when transferring it.

As a general rule, we do not share your Personal Data as outlined above with parties located in countries outside the European Union that may offer a lower level of data protection. However, this may be different in cases where there is a (legitimate) reason to provide data to parties located outside the European Union. In such cases, appropriate measures will be taken to ensure adequate protection of your Personal Data in accordance with applicable data protection laws.

Retention and Security of Personal Data

Your Personal Data will be stored for the specific purposes mentioned above as long as you are a business contact of ours (i.e., as long as the business or contractual relationship lasts). Your Personal Data will be deleted when they are no longer reasonably necessary for the specific purposes mentioned above, when you withdraw your consent (if applicable), or when we are not legally obligated or otherwise allowed to continue storing such data.

You can unsubscribe at any time if you no longer wish to receive communications and invitations from Angelwise. If you choose to unsubscribe, we will cease sending such communications and invitations. Angelwise has implemented appropriate technical and organizational security measures to help protect your Personal Data from loss, destruction, alteration, and unauthorized access.

Rights and Exercise of These Rights

• You have the right to know what Personal Data we process about you and can request a copy to review the information we hold.

• You also have the right to correct inaccurate Personal Data about you, allowing you to rectify or supplement incorrect or incomplete Personal Data that we process about you.

• You have the right to have your Personal Data deleted in some cases, allowing you to permanently delete the Personal Data we process about you. Angelwise is only obligated to delete your Personal Data in cases and to the extent provided by law.

• You have the right to restrict the processing of your Personal Data. This allows you to temporarily suspend our use of your Personal Data without the need to delete it. Angelwise is only obligated to restrict the processing of your Personal Data in cases and to the extent provided by law.

• You have the right to object to the processing of certain Personal Data, allowing you to object to the further processing of your Personal Data. Angelwise is only obligated to accept your objection in cases and to the extent provided by law.

• You have the right to withdraw your consent when the processing of your Personal Data is based on your consent. The withdrawal of your consent does not affect the lawfulness of the processing that occurred based on your consent before the withdrawal.

• You have the right to receive your Personal Data in a machine-readable format. This allows you to transfer, copy, or move the Personal Data to another data controller. This right only applies if the processing of your Personal Data was based on your consent.

You can address your requests based on the above rights and your complaints to contact@angelwise.be.

If you disagree with how we process your Personal Data, you also have the right to lodge a complaint with the competent supervisory authority in the place where you reside. For Belgium, this is the Belgian Data Protection Authority. They can be reached by mail at Drukpersstraat 35, 1000 Brussels, Belgium, through the website at https://www.gegevensbeschermingsautoriteit.be/, and by phone at +32 2 274 48 00.

Personal Data of Our Investors

Angelwise Management BV, as a fund manager, is subject to preventive anti-money laundering legislation, among other regulations. This obliges us to request various identification data and documents from our investors (KYC or Know Your Customer). By doing so, we fulfill a task of public interest within the meaning of the GDPR (Article 64, § 1, preventive anti-money laundering legislation, and Article 6 GDPR). The data obtained in this way can only be used to fulfill our obligations under this preventive anti-money laundering legislation. We will not use it for commercial purposes, for example, as per Article 64, § 2, preventive anti-money laundering legislation. The rights you can exercise regarding the personal data processed in this context are also limited in accordance with legal provisions.

Preventive anti-money laundering legislation thus obliges us to identify our investors, their possible representatives, and ultimate beneficiaries and to verify their identity through reliable and independent sources of information (Articles 21 to 24, preventive anti-money laundering legislation).

Article 29 of the preventive anti-money laundering legislation specifically requires us, when entering into a new business relationship with an investor-legal entity that must register its ultimate beneficiaries in the UBO register, to obtain proof of that registration or an extract from the UBO register. The same article stipulates that we must not solely rely on an extract from the UBO register to determine and verify the identity of the ultimate beneficiaries. In practice, this generally means that we compare the information stated on an extract from the UBO register with a copy of a shareholder register or the attendance list at the last general meeting minutes. Other supporting documents may also be considered but must be assessed on a case-by-case basis.

Similar legal obligations may require us to process personal data to a greater or lesser extent concerning our investors to gain insight into their characteristics and personal situation.

Changes to Privacy Policy

This Privacy Policy was last updated on the date mentioned at the top. We may make improvements, additions, or changes to this policy at any time for various reasons. The most current version is always available on our website.

We recommend checking for changes regularly.

Contact

If you have questions about how we process your Personal Data, feel free to contact us at contact@angelwise.be.