Privacy Policy

1. Who we are

TheAngel operates theangel.app. This Privacy Policy explains how we collect, use, store, and share personal data when you use our Platform, register as an investor or founder, or otherwise interact with us. We process personal data in accordance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR) where it applies.

2. Data we collect

We may collect:

• Identity & contact data — name, email, phone, address, nationality, date of birth.
• KYC / AML data — government ID, proof of address, source of funds, accreditation status, and related verification information.
• Financial data — investment history on the Platform, wallet addresses, transaction records.
• Technical data — IP address, browser type, device information, cookies and similar technologies (see our Cookie Policy).
• Usage data — pages visited, features used, and interactions with the Platform.

3. How we use your data

We use personal data to:

• Provide and operate the Platform and related services.
• Complete KYC/AML checks and meet regulatory obligations.
• Process investments, allocations, and liquidity-window activity.
• Communicate with you about your account, offerings, and Platform updates.
• Improve security, prevent fraud, and enforce our terms.
• Comply with legal and regulatory requirements.

Where required, we rely on one or more of: performance of a contract, legal obligation, legitimate interests, or consent.

4. Sharing your data

We may share personal data with:

• Licensed management companies, administrators, and service providers supporting the Luxembourg structures.
• KYC/AML and identity verification providers.
• Professional advisers (legal, compliance, audit) under confidentiality obligations.
• Regulators and authorities where required by law.
• Technology and hosting providers who process data on our behalf under appropriate agreements.

We do not sell personal data.

5. International transfers

Data may be processed in the EU/EEA and, where necessary, in other jurisdictions. Where we transfer personal data outside the EEA, we use appropriate safeguards such as standard contractual clauses or equivalent mechanisms required by applicable law.

6. Retention

We retain personal data for as long as needed to provide the Platform, meet regulatory record-keeping requirements (including AML), and resolve disputes. Retention periods vary by data type and legal obligation.

7. Your rights

Depending on your jurisdiction, you may have the right to:

• Access, correct, or delete your personal data.
• Restrict or object to certain processing.
• Data portability.
• Withdraw consent where processing is based on consent.
• Lodge a complaint with a supervisory authority.

Some rights may be limited where we must retain data for legal or regulatory reasons (e.g. AML). To exercise your rights, contact privacy@theangel.app.

8. Security

We implement technical and organisational measures designed to protect personal data against unauthorised access, loss, or misuse. No method of transmission or storage is completely secure; we continuously improve our controls.

9. Changes

We may update this Privacy Policy from time to time. Material changes will be indicated by updating the "Last updated" date and, where appropriate, by additional notice on the Platform.

10. Contact

Privacy enquiries: privacy@theangel.app