Privacy Policy

A. Introduction

This policy is a statement by EVERCURIOUS VC DIACHEIRISIS AMOIVAION KEFALAION EPICHEIRIMATIKON SYMMETOCHON SOCIETE ANONYME, operating under the commercial title Evercurious VC (hereinafter referred to as "the Company"), to comply with Articles 13 and 14 of the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679). It provides information on the processing of personal data and the rights of data subjects. This policy is intended for employees, limited partners, regulatory bodies, and other interested parties.

Evercurious VC is a société anonyme established under the laws of Greece and acts as a management company for Venture Capital Funds (hereinafter referred to as "Fund" or "Funds") in accordance with Article 7 of Law 2992/2002.

B. Company Statements

The Company takes all reasonable technical and organizational measures to ensure the confidentiality and security of data processing, protecting data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or unauthorized access. Personal data will not be processed for any purpose other than those outlined herein without prior notice and/or consent from the data subject.
Evercurious VC is a société anonyme established under the laws of Greece and acts as a management company for Venture Capital Funds (hereinafter referred to as "Fund" or "Funds") in accordance with Article 7 of Law 2992/2002.

C. Data We Process

As a Data Controller under Article 4(7) of the GDPR, Evercurious VC processes electronic and/or physical files containing personal data of:

1. Shareholders, management members, employees, and suppliers of the Company.
2. Unitholders of the Funds it manages, their legal representatives, and beneficial owners.
3. The custodian of the Venture Capital Funds managed by the Company.
4. Shareholders, partners, legal representatives, beneficial owners, employees, suppliers, and customers of companies in which the Fund invests.

Categories of personal data processed may include:

• Personal Information: Name, date and place of birth, nationality, identification documents (e.g., ID card, passport), VAT number, tax residence, and contact details.
• Financial Information: Bank account details and financial/investment profile.
• Employment Information: CVs, references, diplomas, past employment records, social insurance details, and marital status.

The Company may also process personal data based on explicit consent, in which case subjects will be informed about the data processed, the purpose, retention period, and any relevant disclosures.

D. Legal Basis for Processing

The legal bases for processing personal data include:

1. Contract Performance (Article 6(1)(b) GDPR): For fulfilling contractual obligations with data subjects, including fund management and service agreements.
2. Legal Obligations (Article 6(1)(c) GDPR): Compliance with tax, insurance, anti-money laundering laws, and other legal requirements.
3. Legitimate Interests (Article 6(1)(f) GDPR): Protecting the legal rights of the Company or third parties.
4. Consent (Article 6(1)(a) GDPR): For specific processing activities based on explicit consent, which may be withdrawn at any time.

Data processing related to minors is conducted only with the prior consent of their legal representatives.

E. Purposes of Processing

The Company processes personal data for the following purposes:

• Managing agreements for fund establishment and operation.
• Evaluating investment opportunities and conducting due diligence.
• Complying with legal and regulatory obligations, including anti-money laundering checks.
• Managing employment relationships and fulfilling contractual obligations.
• Protecting the Company’s legal rights in judicial or administrative proceedings.