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Privacy Policy

Last Updated: 29/7/2026
 

1. Introduction

Welcome to the privacy policy of Philotimo Ventures (the "Company," "we," "us," or "our"). We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This Privacy Policy is designed to comply with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and applicable data protection laws of the Grand Duchy of Luxembourg.
 

2. Data Controller

Philotimo Ventures, headquartered at 412F, Route d’Esch, L-1471, Luxembourg, Grand Duchy of Luxembourg, is the controller and responsible for your personal data. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out in Section 13 below.

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3. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data: includes first name, last name, username or similar identifier, title, and organization/company name.

  • Contact Data: includes corporate address, email address, and telephone numbers.

  • Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

  • Usage Data: includes information about how you use our website and services.

  • Communications Data: includes your preferences in receiving communications from us and our third parties and your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

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4. How Is Your Personal Data Collected?

We use different methods to collect data from and about you, including through:

  • Direct Interactions: You may give us your Identity and Contact Data by filling in forms (e.g., the "Contact" form) or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you request information about our investment strategies, subscribe to our publications, or request marketing to be sent to you.

  • Automated Technologies or Interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.

  • Third Parties or Publicly Available Sources: We may receive personal data about you from various third parties and public sources, such as analytics providers (e.g., Google Analytics) based inside or outside the EU, or identity and contact data from publicly available sources like corporate registries or professional networks (e.g., LinkedIn).
     

5. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Performance of a Contract: Where we need to perform the contract we are about to enter into or have entered into with you or your organization.

  • Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This includes improving our website, services, and corporate communications.

  • Legal Obligation: Where we need to comply with a legal or regulatory obligation (e.g., anti-money laundering (AML) or "Know Your Customer" (KYC) requirements).

  • Consent: Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
     

6. Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes outlined in Section 5:

  • Internal Third Parties: Other companies within the Philotimo Ventures group or affiliates acting as joint controllers or processors.

  • External Third Parties:

    • Service providers acting as processors who provide IT and system administration services.

    • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in Luxembourg, Greece, or other relevant jurisdictions.

    • Regulators, tax authorities, and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
 

7. International Transfers

We may transfer your personal data outside the European Economic Area (EEA) if required for our business operations. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

  • Where we use certain service providers, we may use specific contracts approved by the European Commission (Standard Contractual Clauses) which give personal data the same protection it has in Europe.
     

8. Data Security

We have put in place appropriate technical and organizational security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
 

9. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personal data, and applicable legal requirements.
 

10. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

  • Request access to your personal data (commonly known as a "data subject access request").

  • Request correction of the personal data that we hold about you.

  • Request erasure of your personal data (the "right to be forgotten").

  • Object to processing of your personal data where we are relying on a legitimate interest.

  • Request restriction of processing of your personal data.

  • Request the transfer of your personal data to you or to a third party (data portability).

  • Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact us. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
 

11. Cookies

Our website uses cookies and similar tracking technologies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
 

12. Changes to the Privacy Policy

We keep our privacy policy under regular review. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.
 

13. Contact Details

If you have any questions about this privacy policy or our privacy practices, please contact us in writing at:

Philotimo Ventures Data Protection Inquiry 412F, Route d’Esch, L-1471, Luxembourg, Grand Duchy of Luxembourg Email: info@philotimo.vc

You have the right to make a complaint at any time to the National Commission for Data Protection (Commission Nationale pour la Protection des Données - CNPD), the Luxembourg supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the CNPD, so please contact us in the first instance.

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