Privacy Policy

Legal Entity: Actaware Inc., Primary Jurisdiction: Delaware, U.S.A., Contact Email: contact@actaware.com

If required under applicable law, we act as a "data controller" (or equivalent term) with respect to your personal data.

This Privacy Policy applies to:

• Visitors to our website
• Individuals submitting forms, inquiries, or communications
• Customers, investors, partners, and prospective clients
• Users interacting with our digital services

3.1 Information You Provide

• Name, email, phone number
• Company name, job title
• Investment or business inquiry details
• Any information submitted via forms, email, or meetings

3.2 Automatically Collected Data

• IP address
• Device and browser information
• Referring URLs
• Pages viewed, time on site, interactions

3.3 Cookies and Tracking Technologies

We use:

• Essential cookies (site functionality)
• Analytics cookies (e.g., Google Analytics)
• Marketing/advertising cookies (where applicable)

You can manage preferences via our cookie banner or browser settings.

3.4 Sensitive Data

We do not intentionally collect sensitive personal data unless required for a specific purpose and lawful basis (e.g., explicit consent).

We may use trusted third-party service providers, including:

• Analytics providers (e.g., Google Analytics)
• CRM and marketing platforms (e.g., HubSpot, Salesforce)
• Cloud hosting and infrastructure providers (e.g., AWS, Azure)
• Communication tools (e.g., email platforms)

These providers process data under contractual obligations, including Data Processing Agreements (DPAs).

We process personal data based on:

• Consent (e.g., marketing communications, cookies)
• Contractual necessity (e.g., responding to inquiries)
• Legal obligations
• Legitimate interests, including:
  • Business development and relationship management
  • Website improvement and analytics
  • Fraud prevention and security

We use personal data to:

• Respond to inquiries and provide services
• Manage investor, client, or partner relationships
• Operate and improve our website
• Conduct analytics and performance tracking
• Send marketing communications (subject to consent/opt-out rights)
• Comply with legal and regulatory obligations

We may share personal data with:

• Service providers and vendors
• Affiliates and related entities
• Advisors (legal, financial, tax)
• Regulators or authorities where required

No Sale of Personal Data

We do not sell personal data in the traditional sense.

CCPA "Sharing" for Advertising

If applicable, we may engage in limited "sharing" (as defined under CPRA) for analytics or advertising purposes. Users may opt out (see Section 11).

Your data may be transferred to jurisdictions outside your country, including the United States.

Where required, we implement safeguards such as:

• Standard Contractual Clauses (SCCs)
• UK International Data Transfer Addendum
• Adequacy decisions

We retain personal data only as long as necessary for:

• Business and contractual purposes
• Legal and regulatory compliance
• Dispute resolution and enforcement

Retention periods are determined based on data type, purpose, and legal requirements.

Depending on your jurisdiction, you may have rights to:

• Access your personal data
• Correct inaccuracies
• Delete your data
• Restrict processing
• Object to processing
• Data portability
• Withdraw consent

To exercise rights, contact: contact@actaware.com

If you are a California resident, you have the right to:

• Know what personal data we collect and how it is used
• Request deletion
• Request correction
• Opt out of "sale" or "sharing"
• Limit use of sensitive data (if applicable)
• Non-discrimination

Do Not Sell or Share My Personal Information

To opt out, please:

• Click the "Do Not Sell or Share My Personal Information" link on our website, or
• Email: contact@actaware.com

We will verify your request consistent with legal requirements.

Where required, we obtain prior consent before placing non-essential cookies.

Users in the EU/UK will see a cookie banner allowing them to:

• Accept all cookies
• Reject non-essential cookies
• Customize preferences

We implement appropriate technical and organizational measures, including:

• Encryption where appropriate
• Access controls
• Vendor due diligence
• Monitoring and incident response procedures

Our services are not directed to individuals under 16 (or applicable age). We do not knowingly collect children's data.

Our website may link to third-party sites. We are not responsible for their privacy practices.

We may update this Privacy Policy periodically. Updates will be posted with a revised effective date.

Actaware Inc.
contact@actaware.com

We may provide additional disclosures where required, including for:

• Canada (PIPEDA)
• Brazil (LGPD)
• Australia (Privacy Act)
• Other applicable jurisdictions

Where relevant (e.g., real estate, infrastructure, investment activities), personal data may be processed in connection with:

• Investor relations and communications
• Due diligence and transaction processes
• Business development and deal sourcing

Such processing is conducted with appropriate confidentiality and safeguards.