ACT Venture Partners Coöperatief U.A. ("ACT Venture Partners") is committed to ensuring that the privacy of users ("Users") is protected and complies with the General Data Protection Regulation ("GDPR").

This privacy policy ("Privacy Policy") explains the types of personal data ("Personal Data") collected and processed by ACT Venture Partners, the purposes and legal bases of the processing, and the rights of the individuals concerned.

This Privacy Policy refers only to ACT Venture Partners' communication channels and www.actvp.vc ("Website") and does not cover any third-party websites that Users may access using the links found on this Website or other communication channels.

Personal Data may be accessed by authorised personnel of ACT Venture Partners and, where necessary, disclosed to service providers, professional advisers, fund administrators, financial institutions, regulatory or public authorities and other recipients involved in ACT Venture Partners' activities. Personal Data will only be disclosed where there is an appropriate legal basis and subject to applicable confidentiality and data protection requirements.

Where Personal Data is transferred outside the European Economic Area, ACT Venture Partners will ensure that the transfer is made in accordance with applicable data protection law and that appropriate safeguards are applied where required. Further information concerning the applicable safeguards may be requested using the contact details below.

We collect and process Personal Data that Users provide to us when they contact us via various communication tools such as e-mail or social media for job applications, investment opportunities, gathering information, sharing an investment proposal, or subscribing to our newsletter.

The Personal Data we collect may include:

• Users' contact information includes full name, email address, mobile phone number, and address.
  
• Users' education, occupation and professional qualifications, diplomas/certificates, and references.
  
• Users' postings on any social media applications and services that we provide.
  
• Users' account security credentials, such as username and passwords.
  
• KYC information documentation as required by Anti-Money laundering directives and legislation and, if applicable, additional information for any individual regarded as a politically exposed person.
  
• Users' device and its software information such as Users' IP address, browser type, Internet service provider ("ISP"), platform type, device type, operating system, date and time stamp, and a unique ID that allows us to uniquely identify Users' browser, mobile device or account, and other such information.
  
• Information about the way Users use our website, such as; the site from which Users came and the site to which User is going when they leave our Website, the pages Users visit, the links Users click, how frequently Users access the Website, and other actions Users take on the Website.
  
• User's communication preferences.
  
• Other similar information.
  

More detailed information can be provided on request.

ACT Venture Partners does not generally seek to collect or process special categories of Personal Data, such as information concerning racial or ethnic origin, religious beliefs, trade union membership, health or sexual orientation. Where such information is received or processing is otherwise necessary, it will only be processed in accordance with applicable data protection law.

We encourage you to carefully read this Privacy Notice. From time to time, we may need to update this Privacy Notice regarding internal and external changes in Personal Data Management. In the event that the Privacy Notice will materially and/or substantially change, we will actively inform you of this change and provide you with the new version of the Privacy Notice, which will always be available on www.actvp.vc.

ACT Venture Partners may also receive Personal Data from portfolio companies, prospective investments, members of Managed Funds, professional advisers, service providers, public sources and other business contacts.

Depending on the relevant processing activity, ACT Venture Partners processes Personal Data on one or more of the following legal bases:

• the consent of the individual, including where consent is used for newsletters or other communications;
  
• the performance of a contract or steps taken at the request of an individual before entering into a contract;
  
• compliance with legal and regulatory obligations, including tax, corporate, accounting and anti-money laundering requirements; and
  
• ACT Venture Partners' legitimate interests in evaluating investment opportunities, managing investor and business relationships, operating and protecting its Website and systems, administering its activities and communicating with relevant stakeholders, provided that those interests are not overridden by the rights and interests of the individual concerned.
  

ACT Venture Partners processes Personal Data for the following purposes:

• To communicate regularly on its latest news.
  
• To provide relevant content and communications.
  
• To invite Users to participate in the events it organises.
  
• To improve, test, and monitor the effectiveness of our services.
  
• To keep our website safe and up to date.
  
• To monitor metrics such as the total number of visitors and traffic.
  
• To manage Investor, financial and business relations with the Fund and our affiliated companies.
  
• To manage human resources.
  
• To answer questions and to provide relevant information.
  
• To comply with legal and regulatory obligations such as tax obligations and AML requirements.
  

More detailed information can be provided on request.

ACT Venture Partners does not sell Personal Data or use Personal Data for third-party advertising purposes.

ACT Venture Partners uses reasonable physical, technical, and organisational measures to ensure that all personal data collected and processed is kept secure and protected from unauthorised or illegal processing and accidental loss, destruction or damage. However, Users are informed that no system is impenetrable, and ACT Venture Partners does not guarantee the security of its system. If any information under our control is compromised due to a security breach, we will take reasonable steps to investigate the situation and, where appropriate, notify Users whose information may have been compromised and take appropriate action by laws and regulations.

Personal Data will not be retained for longer than necessary for the purposes for which it was collected and processed. In determining the applicable retention period, ACT Venture Partners will take account of the nature and purpose of the processing, applicable legal and regulatory retention requirements, contractual obligations and the establishment, exercise or defence of legal claims. Personal Data will be deleted or anonymised when it is no longer required, unless continued retention is permitted or required by law.

Under the GDPR, Users may have the following rights in relation to their Personal Data:

• the right to receive information about how their Personal Data is processed;
  
• the right to request access to their Personal Data;
  
• the right to request the correction of inaccurate or incomplete Personal Data;
  
• the right to request the deletion of their Personal Data, where applicable;
  
• the right to request the restriction of processing, where applicable;
  
• the right to receive Personal Data in a structured, commonly used and machine-readable format and to request its transfer to another controller, where applicable;
  
• the right to object to processing based on legitimate interests or for direct marketing purposes;
  
• the right to withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal;
  
• the right not to be subject to a decision based solely on automated processing, including profiling, where such decision produces legal effects or similarly significantly affects the User; and
  
• the right to lodge a complaint with the Autoriteit Persoonsgegevens or another competent supervisory authority.
  

Requests to exercise these rights may be submitted to info@actvp.vc. ACT Venture Partners may request information reasonably necessary to verify the identity of the person making the request.

ACT Venture Partners does not undertake automated decision-making or profiling that produces legal effects or similarly significantly affects Users.