Data Controller Identity

Controller: TESET CAPITAL, SGEIC, S.A. (hereinafter referred to as “TESET CAPITAL” or “TESET”)

Registered office: Calle del Monte Esquinza 35, piso 1º, 28010, Madrid

Tax ID (CIF): A01985969

Registration: Registered in the Commercial Registry of Madrid, Volume 40,984, Folio 91, Sheet M-726974

Website: www.tesetcapital.com

Contact email: info@tesetcapital.com

In accordance with current legislation on the protection of personal data and any other applicable and relevant regulations, Users are hereby informed that the personal data they provide will be processed by the data controller solely for the purposes described in the relevant form or contract.

Users are also informed that failure to provide the data requested in the forms on the Website will make it impossible to fulfil the purpose for which the data is collected.

Contact

If you have contacted TESET CAPITAL via the Website, we inform you that, pursuant to data protection legislation, the personal data you have provided will be processed in order to respond to your enquiry. TESET CAPITAL relies on your consent, given by submitting your communication and ticking the checkbox to accept the Privacy Policy.

Your personal data will be processed for as long as necessary to fulfil the purpose for which it was collected, unless you withdraw your consent or exercise your rights of objection or erasure. This is without prejudice to any data retention required by legal obligations applicable to TESET CAPITAL.

Investor Account

If you have completed the form to become an investor with TESET CAPITAL, your personal data will be processed for the purpose of managing your request. TESET CAPITAL relies on your consent, granted by completing and submitting the relevant form and by ticking the box to accept this Privacy Policy, as well as on the performance of pre-contractual measures. If the registration does not go ahead, your data will be deleted, subject to retention for any applicable legal obligations.

Furthermore, once you are registered as an investor with TESET CAPITAL, your personal data will be processed and retained for as long as the relationship with TESET CAPITAL is maintained, unless you withdraw your consent or exercise your rights of objection or erasure, and subject to any legal retention obligations.

Whistleblowing Channel

Personal data relating to whistleblowers will be processed by TESET CAPITAL solely for the purpose of managing and investigating reported irregularities. The legal basis for processing is compliance with a legal obligation and the public interest.

The data will be retained only for the necessary period. In any case, it will be deleted after three months, unless required by law. No data will be disclosed to third parties, except to judicial authorities, the Public Prosecutor’s Office, or other competent administrative authorities.

Data Sharing with Third Parties

To ensure the proper provision of its services, TESET CAPITAL may need to disclose certain personal data to third parties who provide services exclusively for the correct functioning of the company. In such cases, any data sharing is carried out under data processing agreements with these third parties, meaning they may access personal data solely to perform their services on behalf of TESET CAPITAL.

TESET CAPITAL has entered into the necessary data processing agreements with all such third parties, in compliance with applicable data protection laws.

Exercise of Rights

You are entitled to exercise your rights of access, rectification, erasure, objection, restriction of processing, and data portability in relation to your personal data. You may also withdraw your consent at any time. To do so, you must verify your identity and contact TESET CAPITAL at Calle Zurbano 76, 6º, 28010, Madrid, or via email at info@tesetcapital.com.

TESET CAPITAL is committed to responding to all requests submitted either by email or post. In accordance with applicable regulations, TESET CAPITAL will respond within one month of receiving the request. This period may be extended by a further two months depending on the complexity and number of requests. In such cases, the User will be informed within one month of the receipt of the request.

Finally, should you not be satisfied with the resolution of your request, you have the right to lodge a complaint with the national supervisory authority. In Spain, this is the Spanish Data Protection Agency (Agencia Española de Protección de Datos): www.aepd.es.

Data Maintenance

The data subject is responsible for keeping the personal data provided to TESET CAPITAL up to date. If the information provided is false, incomplete, outdated, or inaccurate, the data subject shall be liable for any damage—whether direct or indirect, material or immaterial—that such circumstances may cause to a third party or to TESET CAPITAL. The company reserves the right to suspend services or terminate any relationship with the data subject, without prejudice to any legal actions that may be pursued.

Use of Cookies

You may manage cookies or find more information in the Cookie Policy.

Data Security

TESET CAPITAL has implemented in its premises, systems, and communication infrastructure all security measures required by applicable data protection laws. Logical, physical, organisational, and contractual safeguards have also been put in place to prevent unauthorised access, destruction, alteration, reproduction, disclosure, transmission, or reuse of personal data.

However, any time you transmit personal information over the Internet, there is a risk that third parties—beyond the control of TESET CAPITAL—may intercept and use such information. While TESET CAPITAL makes every effort to protect your personal information and privacy, it cannot guarantee the security of any information disclosed online and you do so at your own risk.

In accordance with the GDPR, the Spanish Data Protection Act (LOPDGDD), and Law 10/2010 of 28 April on the prevention of money laundering and terrorist financing (LPBC-FT), TESET CAPITAL has conducted a Data Protection Impact Assessment (DPIA) regarding the processing of personal data of potential investors, to ensure compliance with its obligations under anti-money laundering regulations. The DPIA concluded that the processing does not pose a threat to the rights and freedoms of data subjects, and that the organisation’s security controls sufficiently mitigate the risks. For more information on the DPIA, you may contact TESET CAPITAL.

Validity and Modification of the Privacy Policy

The Privacy Policy established by TESET CAPITAL is effective from the date of its publication on the Website. Users may save and/or reproduce it.

This Privacy Policy may be amended due to changes in legal requirements, court decisions or case law, or changes in TESET CAPITAL’s business practices or strategy. Any such amendments will be published on this Website, and users shall be deemed to have accepted the new policy by continuing to use the Website after its publication. Relationships established prior to any changes will be governed by the version of the Policy in force at the time the relationship was established.

Last updated: 10 April 2025