LEGAL

Privacy Policy

Last updated: 30 August 2026

Tier One GmbH ("Tier One", "we", "us", or "our") respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, disclose and protect personal data when you visit or use our website at www.tier1.ventures (the "Website"), communicate with us, subscribe to our communications, or otherwise interact with us in connection with our business.

Tier One GmbH is established in Germany and processes personal data in accordance with applicable data protection laws, including the EU General Data Protection Regulation (Regulation (EU) 2016/679 – "GDPR"), the German Federal Data Protection Act (Bundesdatenschutzgesetz – "BDSG"), applicable German telecommunications and cookie legislation, and, where applicable, the UK GDPR and the UK Data Protection Act 2018.

01

Data Controller

The controller responsible for processing your personal data is:

Tier One GmbH Germany Website: www.tier1.ventures Email: [INSERT PRIVACY EMAIL ADDRESS]

If you have any questions regarding this Privacy Policy or the processing of your personal data, please contact us using the details above.

If Tier One GmbH has appointed a Data Protection Officer, you may also contact our Data Protection Officer at:

Data Protection Officer: [INSERT IF APPLICABLE] Email: [INSERT IF APPLICABLE]

02

What Personal Data We Collect

2.1 Information you provide directly

This may include:

  • first and last name;
  • email address;
  • telephone number;
  • company name;
  • job title or professional role;
  • information contained in messages or enquiries you send to us;
  • information you provide when requesting information about our investment opportunities or services;
  • information you provide when subscribing to newsletters or other communications;
  • information you provide when registering for events, webinars or other activities;
  • any other information you voluntarily provide to us.

You are generally not required to provide personal data simply to browse the Website. However, certain information may be necessary if you wish to use particular services or contact us.

2.2 Information collected automatically

When you visit the Website, certain information may be automatically collected by our servers or technical systems, including:

  • IP address;
  • date and time of access;
  • browser type and version;
  • operating system;
  • device type;
  • screen resolution and other technical device information;
  • referring website or URL;
  • pages visited and the duration of your visit;
  • information about your interaction with the Website;
  • technical log and security information.

Some of this information may constitute personal data under applicable data protection law.

2.3 Cookies and similar technologies

We may use cookies and similar technologies to operate the Website, remember preferences, understand how visitors use the Website and, where applicable, support marketing activities.

Cookies that are strictly necessary for the operation, security and functionality of the Website may be used without consent where permitted by applicable law.

Non-essential cookies, including certain analytics, advertising or tracking technologies, will only be used where the applicable law requires your prior consent.

You can manage your cookie preferences through our cookie consent mechanism where available.

Further information about the specific cookies and similar technologies used on the Website should be provided in our Cookie Policy and/or cookie consent interface.

03

How We Use Personal Data

3.1 Operating and maintaining the Website

We process technical information where necessary to:

  • provide and operate the Website;
  • ensure the security and stability of the Website;
  • prevent fraud, abuse and malicious activity;
  • diagnose technical problems;
  • improve the functionality and performance of the Website.

3.2 Responding to enquiries

If you contact us, we may process your personal data in order to:

  • respond to your enquiry;
  • communicate with you;
  • provide information you have requested;
  • follow up on your enquiry where appropriate.

3.3 Investor and business communications

Where you request information from Tier One or otherwise engage with us in a professional or investment-related capacity, we may process your information to:

  • communicate with you regarding Tier One;
  • provide information regarding investment opportunities, companies, transactions or related activities;
  • manage our professional relationships;
  • administer our investor and business network;
  • coordinate meetings, calls, events and other communications;
  • maintain appropriate business records.

3.4 Newsletters and marketing communications

If you subscribe to our newsletter or other marketing communications, we may process your personal data to send you:

  • newsletters;
  • investment and market updates;
  • information regarding Tier One;
  • invitations to events;
  • information about relevant investment opportunities or activities;
  • other communications that may be relevant to your professional interests.

Where required by applicable law, we will obtain your prior consent before sending electronic marketing communications.

You can unsubscribe from marketing communications at any time by using the unsubscribe mechanism included in the relevant communication or by contacting us.

3.5 Events and meetings

If you register for or participate in an event, webinar, meeting or similar activity, we may process your personal data to:

  • register you;
  • communicate with you regarding the event;
  • administer attendance;
  • provide event-related information;
  • manage follow-up communications.

3.6 Business development and relationship management

We may process professional contact information for legitimate business development purposes, including identifying and communicating with potential investors, founders, operators, partners, service providers and other relevant business contacts.

Where we obtain professional contact information from publicly available sources or third parties, we will process such information in accordance with applicable data protection law and our legitimate interests, where applicable.

3.7 Legal and regulatory compliance

We may process personal data where necessary to:

  • comply with legal or regulatory obligations;
  • respond to lawful requests from public authorities;
  • establish, exercise or defend legal claims;
  • maintain business and financial records;
  • comply with applicable accounting, tax, anti-money laundering, sanctions or other legal requirements where applicable.
04

Legal Bases for Processing

4.1 Performance of a contract – Article 6(1)(b) GDPR

We may process personal data where processing is necessary to enter into or perform a contract with you, or to take steps at your request before entering into a contract.

4.2 Legal obligations – Article 6(1)(c) GDPR

We may process personal data where processing is necessary to comply with a legal obligation applicable to Tier One.

4.3 Legitimate interests – Article 6(1)(f) GDPR

We may process personal data where necessary for our legitimate interests or those of a third party, provided that those interests are not overridden by your fundamental rights and freedoms. Our legitimate interests may include:

  • operating and improving our business;
  • maintaining professional relationships;
  • communicating with existing and prospective business contacts;
  • protecting our Website and systems;
  • preventing fraud and abuse;
  • improving our services;
  • conducting business development activities;
  • establishing, exercising or defending legal claims.

Where we rely on legitimate interests, we consider and balance those interests against your rights and interests.

4.4 Consent – Article 6(1)(a) GDPR

Where required by law, we will process personal data on the basis of your consent.

You may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

4.5 Other applicable legal bases

Where applicable, we may rely on other legal bases available under the GDPR, BDSG or UK GDPR, including provisions concerning the establishment, exercise or defence of legal claims.

05

Personal Data Obtained from Other Sources

In certain circumstances, we may obtain professional or contact information from sources other than directly from you. These sources may include:

  • publicly available professional websites;
  • company websites;
  • publicly available professional profiles;
  • business directories;
  • industry databases;
  • event organisers;
  • business partners;
  • referrals;
  • other publicly available sources.

Where we obtain personal data indirectly, we will process it in accordance with applicable data protection law and provide the information required under Articles 13 and 14 GDPR where applicable.

06

Sharing Personal Data with Third Parties

We do not sell your personal data.

We may share personal data with third parties where necessary for the purposes described in this Privacy Policy.

These third parties may include:

6.1 Service providers

We may use external service providers to operate our business and Website, including providers of:

  • website hosting;
  • cloud infrastructure;
  • email and communications services;
  • customer relationship management systems;
  • newsletter distribution;
  • analytics;
  • IT security;
  • data storage;
  • event management;
  • professional services.

These providers may process personal data on our behalf and will generally act as processors under Article 28 GDPR where applicable.

6.2 Professional advisers

We may disclose personal data to professional advisers such as:

  • lawyers;
  • accountants;
  • tax advisers;
  • auditors;
  • compliance advisers;
  • other professional service providers.

6.3 Authorities and legal recipients

We may disclose personal data where required by law, court order, regulatory requirement or other lawful request, or where necessary to protect our legal rights.

6.4 Business transactions

If Tier One is involved in a merger, acquisition, restructuring, financing, sale of assets or similar transaction, personal data may be disclosed to relevant parties and advisers as reasonably necessary in connection with that transaction and subject to applicable confidentiality and data protection requirements.

07

International Transfers of Personal Data

Some of our service providers or business partners may process personal data outside the European Economic Area ("EEA") or the United Kingdom.

Where personal data is transferred outside the EEA or UK, we will take appropriate steps to ensure that the transfer is lawful under applicable data protection legislation.

Depending on the circumstances, this may include:

  • transferring data to a country recognised by the European Commission or relevant UK authority as providing an adequate level of protection;
  • using Standard Contractual Clauses approved by the European Commission;
  • using the UK International Data Transfer Agreement or UK Addendum where applicable;
  • implementing additional safeguards where required.

You may contact us using the details above if you would like further information regarding the safeguards applicable to a particular international transfer.

08

Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, unless a longer retention period is required or permitted by law.

The retention period depends on the nature of the information and the purpose for which it is processed.

For example:

  • Website technical and security information may be retained for a limited period necessary for security, troubleshooting and system administration;
  • enquiry and communication information may be retained for as long as necessary to handle the enquiry and, where appropriate, for a reasonable period afterwards;
  • marketing information may be retained until you unsubscribe or withdraw your consent, subject to applicable legal requirements;
  • contractual, accounting and tax records may be retained for the periods required under applicable German law;
  • information relevant to legal claims may be retained for as long as necessary to establish, exercise or defend those claims.

When personal data is no longer required, we will delete it or anonymise it unless we are legally required or permitted to retain it.

09

Your Data Protection Rights

Right of access

You may request confirmation as to whether we process personal data about you and, if so, request access to that data and certain additional information.

Right to rectification

You may request that inaccurate or incomplete personal data be corrected or completed.

Right to erasure

You may request deletion of your personal data in certain circumstances.

This right is not absolute. For example, we may need to retain certain information to comply with legal obligations or establish, exercise or defend legal claims.

Right to restriction of processing

You may request that we restrict the processing of your personal data in certain circumstances.

Right to data portability

Where applicable, you may request to receive certain personal data you have provided to us in a structured, commonly used and machine-readable format, or request that it be transmitted to another controller.

Right to object

You may object to processing based on our legitimate interests in certain circumstances.

You may also object at any time to the processing of your personal data for direct marketing purposes.

Right to withdraw consent

Where we process personal data based on your consent, you may withdraw your consent at any time.

Withdrawal does not affect the lawfulness of processing carried out before your withdrawal.

Rights relating to automated decision-making

Where applicable, you may have rights relating to decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects.

We do not currently intend to make decisions producing legal or similarly significant effects about individuals solely through automated processing.

10

How to Exercise Your Rights

To exercise any of your rights, please contact us at:

[INSERT PRIVACY EMAIL ADDRESS]

We may need to request additional information from you to verify your identity and protect against unauthorised disclosure of personal data.

We will generally respond to valid requests within one month of receiving the request, subject to any applicable extensions or exceptions under data protection law.

You will generally not have to pay a fee to exercise your data protection rights.

11

Right to Lodge a Complaint

If you believe that we have processed your personal data unlawfully or have otherwise violated applicable data protection law, you have the right to lodge a complaint with a competent data protection supervisory authority.

For Tier One GmbH, the competent supervisory authority will generally be the German data protection supervisory authority responsible for our registered establishment.

You may also contact another supervisory authority where permitted under the GDPR, for example the authority in the country where you live, work or believe that an infringement occurred.

Information about German data protection authorities is available from the Federal Commissioner for Data Protection and Freedom of Information:

Federal Commissioner for Data Protection and Freedom of Information (BfDI)

If you are located in the United Kingdom and the UK GDPR applies to the processing of your personal data, you may also have the right to complain to the Information Commissioner's Office (ICO). The ICO provides guidance confirming that individuals have the right to complain regarding how an organisation handles their personal data.

Information Commissioner's Office (ICO)

We encourage you to contact us first so that we have an opportunity to address your concerns, although this does not limit your right to complain to a supervisory authority.

12

Cookies

Our Website may use cookies and similar technologies. Cookies may be used for different purposes, including:

  • strictly necessary Website functionality;
  • security;
  • remembering preferences;
  • analytics;
  • measuring Website performance;
  • marketing and advertising.

Where required by applicable law, we will ask for your consent before placing or accessing non-essential cookies.

You can withdraw or change your cookie preferences through the cookie consent mechanism available on the Website.

You may also be able to control cookies through your browser settings. However, disabling certain cookies may affect Website functionality.

Because the exact cookies and third-party technologies used on the Website may change, we recommend maintaining a separate Cookie Policy that identifies the specific technologies currently deployed.

13

Third-Party Websites and Services

The Website may contain links to third-party websites, platforms or services.

We are not responsible for the privacy practices, content or security of third-party websites.

When you follow a link to a third-party website, we recommend reviewing that website's privacy policy before providing personal data.

This Privacy Policy applies only to personal data processed by Tier One in connection with the Website and our own activities.

14

Social Media and External Platforms

We may maintain profiles or pages on third-party platforms such as LinkedIn or other professional and social media networks.

When you interact with us through such platforms, the relevant platform may process your personal data independently as a separate controller.

The privacy policies of those platforms govern their processing of your personal data.

Where appropriate, we may receive information from those platforms regarding interactions with our pages or content, subject to the platform's settings and applicable law.

15

Security

We take reasonable technical and organisational measures to protect personal data against:

  • accidental or unlawful destruction;
  • loss;
  • alteration;
  • unauthorised disclosure;
  • unauthorised access;
  • other unlawful forms of processing.

The specific security measures we use depend on the nature and sensitivity of the personal data and the risks associated with processing.

However, no method of transmitting or storing information can be guaranteed to be completely secure.

16

Children's Data

Our Website and services are intended for adults and business users.

We do not knowingly collect personal data from children.

If you believe that a child has provided us with personal data, please contact us. If we become aware that we have collected personal data from a child where collection was not appropriate, we will take reasonable steps to delete it.

17

Automated Decision-Making and Profiling

We do not currently use personal data to make decisions based solely on automated processing, including profiling, that produce legal effects or similarly significant effects on individuals.

We may, however, use ordinary analytics or segmentation technologies to understand Website usage, communications and professional interests.

Where such processing constitutes profiling under applicable law and requires additional safeguards, we will provide the information and rights required by applicable law.

18

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

  • changes to our business;
  • changes to the Website;
  • changes to the technologies or services we use;
  • changes in applicable law or regulatory requirements;
  • changes to our data processing activities.

The updated version will be published on this page with a revised "Last updated" date.

Where required by law, we will provide additional notice or obtain consent before introducing material changes to how we process personal data.

19

Contact Us

If you have questions about this Privacy Policy, our use of personal data, or wish to exercise your data protection rights, please contact:

Tier One GmbH Germany Website: www.tier1.ventures Email: [INSERT PRIVACY EMAIL ADDRESS]

© 2026 Tier One GmbH · tier1.ventures

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