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Privacy Policy

Last updated: November 15, 2025  |  Effective date: January 1, 2025

1. About This Policy

This Privacy Policy describes how Sooiv Capital ("Sooiv," "we," "us," or "our") collects, uses, processes, discloses, and retains personal information about individuals who interact with our website at sooiv.com (the "Website"), submit investment inquiries, correspond with us by email, or otherwise engage with us in connection with our venture capital activities.

We are committed to handling personal information responsibly and in compliance with applicable data protection laws, including but not limited to the UAE Federal Law No. 45 of 2021 on the Protection of Personal Data (the "UAE PDPL"), the DIFC Data Protection Law (DIFC Law No. 5 of 2020), and, where applicable, the General Data Protection Regulation (EU) 2016/679 ("GDPR") in respect of data subjects located in the European Economic Area or United Kingdom.

Please read this policy carefully before submitting personal information to us. By using our Website or otherwise interacting with us, you acknowledge that you have read and understood this policy. If you do not agree to the terms of this policy, please do not submit personal information to us or use our Website.

2. Data Controller Identity

The data controller responsible for your personal information is:

Sooiv Capital
DIFC Gate Building, Gate District 3, Level 4
Dubai International Financial Centre
Dubai, UAE 116842
Email: privacy@sooiv.com
Phone: +971 4 456 7890

Sooiv Capital is a registered fund manager operating within the Dubai International Financial Centre (DIFC), regulated by the Dubai Financial Services Authority (DFSA). Where we process personal data of individuals located in the EEA or UK, we act as a data controller within the meaning of the GDPR and UK GDPR respectively.

3. Information We Collect

3.1 Information You Provide Directly

We collect personal information that you provide to us directly, including:

• Contact information: Your name, email address, phone number, and postal address when you submit an inquiry through our contact page, send us an email, or otherwise reach out to us.
• Professional information: Your company name, job title, LinkedIn profile, and professional background when you submit a founder pitch, investment inquiry, or partnership proposal.
• Business information: Information about your company, business model, market, financial performance, and other details you choose to share with us in connection with an investment inquiry.
• Communications: The content of emails, letters, and other communications you send to us, including any attachments such as pitch decks, financial models, or business plans.
• Event information: Contact details and other information you provide when registering for events organized or co-organized by Sooiv.

3.2 Information We Collect Automatically

When you visit our Website, we automatically collect certain technical and usage information through cookies and similar technologies, including:

• Device and browser information: Your browser type and version, operating system, device type, screen resolution, and language settings.
• Usage data: The pages you visit on our Website, the time and duration of your visits, the links you click, and the content you view.
• Connection data: Your IP address, approximate geographic location (derived from IP address), internet service provider, and referring URL.
• Cookie data: Information stored in cookies and similar tracking technologies as described in Section 11 of this policy.

3.3 Information from Third Parties

We may receive information about you from third parties, including:

• Business referrals: When a co-investor, advisor, or portfolio company refers you to us, they may provide us with your contact information and a brief description of your business.
• Public sources: We may collect publicly available information about founders and companies from sources such as company registries, professional networking platforms, news publications, and press releases in connection with our investment diligence processes.
• Analytics providers: We may receive aggregated and anonymized analytics data from third-party analytics services.

4. How We Use Your Information

We use personal information for the following purposes:

• Responding to inquiries: To respond to investment inquiries, contact form submissions, press inquiries, and other communications you direct to us.
• Investment evaluation: To evaluate whether a founder or company is a suitable investment candidate for Sooiv, including conducting background research and diligence.
• Portfolio management: To manage our relationships with portfolio companies and provide support to portfolio founders, including sharing information with our limited partners, advisors, and co-investors as necessary for these purposes.
• Website operation: To operate, maintain, and improve our Website, including analyzing usage patterns and troubleshooting technical issues.
• Legal compliance: To comply with applicable laws and regulations, including anti-money laundering (AML), know your customer (KYC), and regulatory reporting requirements applicable to our fund management activities.
• Communications: To send you our Insights publications and other content that may be of interest to you, where you have consented to receive such communications or where we have a legitimate interest in doing so.
• Dispute resolution: To establish, exercise, or defend legal claims.
• Security: To protect the security and integrity of our systems, Website, and business operations.

5. Legal Basis for Processing

Where the GDPR or UK GDPR applies, we rely on the following legal bases for processing your personal information:

• Contract performance: Where processing is necessary to perform a contract with you or to take steps at your request before entering into a contract.
• Legitimate interests: Where processing is necessary for our legitimate interests, including evaluating investment opportunities, managing our portfolio, operating and improving our Website, and communicating with founders, investors, and business contacts. We ensure that our legitimate interests do not override your fundamental rights and freedoms.
• Consent: Where you have explicitly consented to the processing, such as subscribing to our Insights publications or accepting non-essential cookies.
• Legal obligation: Where processing is necessary to comply with a legal obligation, including regulatory requirements applicable to our licensed fund management activities.

6. Sharing and Disclosure

We do not sell, rent, or trade your personal information. We may share your personal information with:

• Service providers: Third-party vendors who provide services to us, such as website hosting, email delivery, analytics, and legal services. These providers are contractually bound to use your information only as necessary to provide services to us and to maintain appropriate security standards.
• Co-investors and advisors: In connection with investment diligence and portfolio management, we may share information about founders and companies with our co-investors (including Battery Ventures), advisory board members, and external experts. We will notify founders when we intend to share their confidential business information with third parties and obtain appropriate consents where required.
• Regulatory authorities: We may disclose information to the DFSA, UAE financial authorities, or other regulatory bodies when required by law or regulation, or when necessary to protect our legal rights.
• Professional advisors: Our lawyers, accountants, auditors, and other professional advisors who provide services to us in connection with our business operations.
• Business transfers: In connection with a merger, acquisition, restructuring, or sale of all or part of our business, personal information may be transferred to the acquirer or successor entity.
• Legal requirements: We may disclose personal information where required by law, court order, legal process, or governmental regulation, or where disclosure is necessary to protect our rights, property, or safety, or the rights, property, or safety of others.

7. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this policy, unless a longer retention period is required or permitted by law. Our general retention periods are:

• Investment inquiries not resulting in investment: Five years from the date of our last communication, to support potential future investment discussions and to comply with AML record-keeping requirements.
• Portfolio company information: For the duration of our investment and for a period of seven years after the conclusion of the investment relationship, to comply with regulatory record-keeping requirements.
• Website analytics data: Up to twenty-six months from collection, or as configured in our analytics platform settings.
• General correspondence: Three years from the date of correspondence, unless the correspondence is relevant to an ongoing investment relationship or legal matter.
• Marketing preferences: Until you unsubscribe or withdraw consent.

When personal information is no longer required for the purpose for which it was collected, we will securely delete or anonymize it in accordance with our data retention procedures.

8. Your Rights

Depending on your location and applicable law, you may have the following rights with respect to your personal information:

• Right of access: The right to request a copy of the personal information we hold about you, along with information about how we process it.
• Right to rectification: The right to request that we correct inaccurate or incomplete personal information.
• Right to erasure: The right to request that we delete your personal information in certain circumstances, including where it is no longer necessary for the purpose for which it was collected.
• Right to restriction: The right to request that we restrict the processing of your personal information in certain circumstances, such as while we investigate a complaint about accuracy.
• Right to data portability: Where processing is based on consent or contract performance, the right to receive your personal information in a structured, commonly used, and machine-readable format, and to transmit it to another data controller.
• Right to object: The right to object to our processing of your personal information based on legitimate interests, including for direct marketing purposes.
• Right to withdraw consent: Where processing is based on consent, the right to withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact us at privacy@sooiv.com. We will respond to your request within thirty days. In some cases, we may need to verify your identity before responding to your request. We will not charge a fee for responding to rights requests unless the request is manifestly unfounded or excessive.

If you are dissatisfied with our handling of your request or with our data practices generally, you have the right to lodge a complaint with the relevant data protection supervisory authority. In the DIFC, the relevant authority is the DIFC Commissioner of Data Protection.

9. Security

We implement appropriate technical and organizational measures to protect personal information against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include encryption of data in transit using TLS/SSL, access controls limiting access to personal information to authorized personnel, regular security assessments of our systems and processes, and staff training on data protection and information security.

While we take these precautions, no transmission of data over the internet or electronic storage system is completely secure. We cannot guarantee the absolute security of personal information, and you submit information at your own risk. If you believe your personal information has been compromised, please contact us immediately at privacy@sooiv.com.

10. International Data Transfers

Sooiv Capital is based in Dubai, UAE. If you are located outside the UAE, your personal information may be transferred to and processed in the UAE. The UAE has enacted data protection legislation through Federal Law No. 45 of 2021, and the DIFC has its own data protection law providing standards recognized as adequate for transfers from the EU under certain circumstances.

Where we transfer personal information to co-investors or advisors located outside the UAE, we implement appropriate safeguards such as standard contractual clauses or equivalent protections to ensure that your personal information remains protected to the standards required by applicable data protection law.

11. Cookies and Tracking Technologies

We use cookies and similar tracking technologies on our Website. Cookies are small text files placed on your device that help us operate and improve our Website, analyze usage patterns, and remember your preferences. For detailed information about the cookies we use and your choices regarding cookies, please see our Cookie Policy.

You can control cookies through the cookie consent banner that appears when you first visit our Website, and you can withdraw your consent at any time by clearing your browser's local storage or adjusting your browser settings.

12. Children's Privacy

Our Website and services are directed at adults and are not intended for children under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18 without verified parental consent, we will take steps to delete that information promptly. If you believe we may have collected personal information from a child, please contact us at privacy@sooiv.com.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. When we make material changes to this policy, we will update the "Last updated" date at the top of this page and, where appropriate, provide additional notice through our Website or by email. We encourage you to review this policy periodically to stay informed about how we process your personal information.

Your continued use of our Website or engagement with us following the posting of changes to this policy constitutes your acceptance of those changes.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Data Protection Enquiries
Sooiv Capital
DIFC Gate Building, Gate District 3, Level 4
Dubai International Financial Centre
Dubai, UAE 116842
Email: privacy@sooiv.com
Phone: +971 4 456 7890

We aim to respond to all privacy-related enquiries within 30 days of receipt. For urgent matters, please indicate the urgency in your subject line.