BlackCap Equity Management ApS (”BlackCap” or ”we”) respects the need to protect natural per- sons’ fundamental rights and freedoms. The protection of personal data is a priority, and we pro- cess the personal data that we are entrusted with in a proper and responsible manner.

This Privacy Policy describes how we handle the personal data that we process when you visit our website or otherwise share your personal data with us.

In the following GDPR is short for General Data Protection Regulation (EU) 2016/679 of 27 April 2016.

1. Data Controller and Contact Information

BlackCap is a data controller in relation to your personal data. If you have any questions regarding our processing of your personal data, please contact:

BlackCap Equity Management ApS
CVR-no. 42564176
Vandtårnsvej 77
2860 Søborg
info@blackcapequity.com

2. Types of Personal Data Collected

BlackCap collects personal data in connection with our overall business activities, including data from individuals representing business partners, service providers, and investors as well as advisors, board members and employees.

We may process personal data such as name, email address, telephone number, home address, gender, photographic and other identity data, position, educational background, professional in- formation, financial and payment information, and other information required for our business re- lation.

In some cases, BlackCap collects personal data from third parties via publicly accessible databases and via external business partners, including suppliers, investors and advisors.

3. Purpose of Processing Personal Data

The collected data will be used for the following purposes:

• Provide information about our services, including news or personalized information re- quested by you.

• Administer, operate, maintain, and improve our services and business relationships.

• Process and analyze statistics relating to our business.

• Comply with applicable laws and regulation, including complying with our obligations under the Danish Anti-Money Laundering Act, especially investor due diligence procedures under the anti-money laundering rules (KYC).

4. Legal Basis of Processing Personal Data

BlackCap may process personal data based on the following provisions:

• When it is necessary for the performance of a contract or in order to take steps on your request prior to entering into a contract (GDPR, Article 6 (1), litra b).
• When you have given your consent to the processing of your personal data for specific purposes (GDPR, Article 6 (1), litra a).
• When it is necessary for the purposes of the legitimate interests pursued by BlackCap or by a third party (except when such interests are overridden by your fundamental rights and freedoms) (GDPR, Article 6 (1), litra f).
• When it is necessary for compliance with a legal obligation (GDPR, Article 6 (1), litra c).

5. Disclosure of Personal Data

BlackCap may disclose your personal data to our affiliates, business partners and suppliers. For ex- ample, our IT service providers, provider of CRM-system, providers of file storage platforms, legal advisors, and other professional service advisors.

When business partners process information on behalf of BCE, they must act according to our in- structions and are not allowed to use personal information for their own purposes.

BlackCap may disclose your personal data to external third parties if we are directed to do so or if it is part of our services provided to you. For example, legislation may require us to disclose personal data to the police, tax authorities, or other public authorities.

6. Transfer of Personal Data outside the EU

In certain situations, your personal data may be transferred to a country outside the EU. Such trans- fers will be subject to the applicable data protection regulation in force at any given time. For ex- ample, the transfer may take place if BlackCap ensures that the recipient enters into the EU stand- ard contractual clauses.

7. Security

We do our best to protect the quality and integrity of your personal data. We have implemented security measures to ensure a high level of security.

8. Storage and Erasure

In general, we store personal data necessary for the performance of our services for as long as it is required to serve the purpose(s) for which the data are processed or for regulatory reasons, includ- ing the Danish Limitation Act (forældelsesloven). BlackCap has an annual clean-up procedure where irrelevant personal data is deleted, including data collected in connection with the development of BlackCap’s network and potential business relationships. However, any personal data included in bookkeeping records will be stored for 5 years as from expiry of the financial year. Personal data collected by us according to the Danish Anti-Money Laundering Act is stored for 5 years after the end of the investor relationship.

9. Your Rights

You have certain rights as a data subject. However, the exercise of these rights is subject to the provisions of GDPR. If you have any questions regarding your rights or want to exercise your rights, please contact us.

As a rule, you have the right to be informed of the personal data that we process about you. You have the right to rectification of your personal data. Under certain circumstances, you have the right to request that we erase the personal data that we have registered about you, the right to have the processing of your data restricted and the right to object to the collection and further processing of your personal data. In certain circumstances you have the right to receive your per- sonal data in a structured, commonly used, and machine-readable format and the right to have this personal data transmitted to another data controller. If the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time. If you choose to withdraw your consent, this will not affect the legality of the processing performed prior to the withdrawal of your consent.

You may read more about your rights on www.datatilsynet.dk

10. Our Website

BlackCap only uses one cookie at blackcapequity.com. This is a so-called technical cookie which is used to read your screen size, so that the pictures on the website are transmitted as compressed as possible. It is a session cookie which means that it is deleted again when you close your browser.

Technical cookies have no bearing on your privacy as they do not register what you are looking for on other websites. It is not a requirement that websites provide information about the use of tech- nical cookies or ask for your consent to use them.

11. Complaints

If you do not agree with the way we process your personal data, you are welcome to contact us. You may also file a complaint with The Danish Data Protection Agency (Datatilsynet). You will find their contact data on www.datatilsynet.dk

12. Effective Date

BlackCap reserves the right to update the Privacy Policy without notice. This Privacy Policy v.1 is effective of the 1 June 2022.