Kvanted Oy (“Kvanted”)

Updated: 25.9.2024

Kvanted knows that you care about your personal data and how it is used. Kvanted is committed to handling personal information with due care and in compliance with relevant data protection regulations. This privacy policy (“Policy”) will help you to understand what personal data Kvanted collects and specifies the recipients of such information in connection with the services offered by Kvanted, why it is collected and what Kvanted does with it. Additionally, the Policy outlines what rights you have regarding your own personal information.

The Policy does not address, and Kvanted is not responsible for the privacy practices of any third parties, also when services include hyperlinks or other links to third parties’ websites or services. This Policy is updated as needed to reflect relevant changes in data processing practices and the latest version can be found on Kvanted’s website.

Please take a moment to familiarize yourself with Kvanted’s privacy practices and do not hesitate to contact

us via hello@kvanted.com if you have any questions.

WHAT IS PERSONAL DATA?

To provide Kvanted’s services and Kvanted’s website, Kvanted must collect, share and process certain

personal data about you. Personal data is any information that relates to you or can be linked to you either

directly or indirectly by your name or another identifier, such as a phone number or an email address

("Personal Data"). The processing of Personal Data is done in accordance with the General Data Protection

Regulation ("GDPR").

WHAT PERSONAL DATA IS BEING COLLECTED?

Kvanted processes the following types of Personal Data:

• Personal details, such as name and contact information

• Investor information, such as financial circumstances, tax residence, profession, income, assets and

liabilities

• Invoicing and billing information

• KYC information required by applicable Anti-Money Laundering or Counter Terrorism Financing

legislation

• Data collected automatically from the use of our website

The specifics of the processing and of the Personal Data vary depending on your role and whether you’re

an individual investor, act on behalf of a company or are a website visitor. The data is collected primarily

from yourself or from your employer. Website usage data is collected automatically.

Providing Personal Data to Kvanted is in most instances required in case you’re an investor or act on behalf

of one, as we have a legal obligation to process such data.

Kvanted’s customers include its fund investors, portfolio companies, and other potential investors and/or

investee companies. This Policy addresses natural people representing or working for the aforementioned.

Employee information and employee candidate information are also addressed.

WHAT PURPOSE DOES KVANTED USE YOUR DATA FOR?

Kvanted processes your Personal Data for the following purposes:

• To provide Kvanted’s services and to carry out Kvanted’s contractual obligations

• To manage Kvanted’s relationships with investors and other stakeholders

• To provide and administer Kvanted’s website

• To comply with Kvanted’s legal obligations

In most cases, Kvanted relies on legitimate interests for processing your Personal Data. Such a legitimate

interest exists, for example, when you work for a company Kvanted is doing business with or email or contact

us through our website. This legal ground is used where it is necessary to achieve Kvanted’s legitimate

interest and does not outweigh your rights as an individual.

Kvanted processes your Personal Data to perform a contract to which you are or will be a party.

Kvanted also processes your Personal Data when Kvanted has a legal obligation (e.g., tax or social security

obligations) to perform such processing.

WHO WILL IT BE SHARED WITH?

Kvanted discloses personal information to third parties only, if necessary, due to legislation, or authorities.

Additionally, Kvanted has agreed with certain service providers to share data and allow them to process

Personal Data on our behalf. For example, Kvanted shares your Personal Data with companies that host orKvanted Fund I Ky 2

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operate Kvanted’s website. These companies process Personal Data necessary to perform their functions

but may not use it for other purposes. Further, they must process this Personal Data in accordance with

Kvanted’s instructions and as permitted by GDPR. Kvanted may also share Personal Data with other third

parties, for example in case of business transfers or a legal disclosure.

Kvanted will primarily share your Personal Data with companies located within the EU/EEA. If Personal Data

is transferred to companies located outside of the EU/EEA, Kvanted will make sure that it is protected in the

same way as if it was being used in the EU/EEA. Kvanted will use one of the following safeguards:

• Transfer to a non-EU/EEA country whose privacy legislation ensures an adequate level of protection

of Personal Data to the EU/EEA one;

• Put in place a contract with the foreign third-party that means they must protect Personal Data to

the same standards as the EU/EEA; or

• Transfer Personal Data to organizations that are part of specific agreements on cross-border data

transfers with the EU (e.g., EU-U.S. Data Privacy Framework).

Access to information is restricted to individuals for whom access is necessary.

WHAT ARE YOUR RIGHTS?

Where Kvanted processes your Personal Data, you have several rights over how the data is processed and

can exercise these rights at any point. Kvanted has provided an overview of these rights below together with

what this entails for you. You can exercise your rights by sending an email to hello@kvanted.com. Please

note that in some instances, the use of these rights may be limited or subject to certain circumstances.

• The right to access and rectification. You have the right to access, correct or update your Personal

Data at any time. Kvanted understands the importance of this and should you want to exercise your

rights, please contact us.

• The right to data portability. The Personal Data you have provided Kvanted with is portable. This

means it can be moved, copied or transmitted electronically under certain circumstances.

• The right to be forgotten. You have the right to request that Kvanted deletes your Personal Data. If

you wish to delete the Personal Data, we hold about you, please contact Kvanted and reasonable

steps will be taken to respond to your request in accordance with legal requirements. If the Personal

Data Kvanted collects is no longer needed for any purposes and Kvanted is not required by law to

retain it, Kvanted will do what it can to delete, destroy or permanently de-identify it.

• The right to restrict processing. You have the right to request that we restrict the processing of your

Personal Data.

• The right to object. You have the right to object to certain types of processing, including processing

for direct marketing.

• The right to lodge a complaint with a Supervisory Authority. You have the right to lodge a complaint

directly with the relevant data protection authority about how Kvanted processes your Personal

Data. In Finland the authority is The Office of the Data Protection Ombudsman

(https://tietosuoja.fi/en).

• The right to withdraw consent. If you have given your consent to anything Kvanted does with your

Personal Data you have the right to withdraw your consent at any time (although if you do so, it does

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not mean that anything Kvanted has done with your Personal Data with your consent up to that

point is unlawful).

COOKIES

Kvanted’s website uses functional cookies to enhance site performance, such as remembering user

preferences and choices, including language preferences and customized settings. These session cookies

are temporarily stored on your device during your visit and are automatically deleted when you close your

browser. The website also may use performance & analytics or advertising cookies for analysis purposes,

with the user having a right to opt out of the usage. Please be aware that some parts of the website may not

function properly if the usage of cookies is refused.

HOW LONG DOES KVANTED KEEP YOUR PERSONAL DATA?

Kvanted will keep your Personal Data for as long as we need it for the purpose it is being processed for and

does not store it for longer than legally permitted. Kvanted will actively review the Personal Data he ld and

delete it securely, or in some cases anonymize it, when there is no longer a legal, business or consumer

need for it to be retained. The length of the storage period will vary depending on the type of information.

CONTACT INFORMATION

If you have any questions about the Privacy Policy, the handling of Personal Data, or wish to exercise your

rights, do not hesitate to contact us via hello@kvanted.com.

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Bulevardi 2-4 A

00120 Helsinki

www.kvanted.com