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Privacy Policy

How we handle personal data on this website and in our activity as a fund management company. Each section starts with a plain-language summary; the full text prevails.

Issued by

Bitizenship Capital, SCR, S.A.

Version

June 2026

Supervision

CMVM, Portugal

01

Who Is Responsible for Your Data

In short

Bitizenship Capital, SCR, S.A., based in Porto, is the data controller.

Bitizenship Capital, SCR, S.A., with registered office at Rua Dom Pedro V, 410, 2.º, 4050-015 Porto, Portugal, is the controller of the personal data processed through this website within the meaning of Regulation (EU) 2016/679 (GDPR). You can reach us at hi@bitizenshipcapital.com.

02

What Data We Process

In short

Only what you give us when you contact us, plus what the law requires if you invest.

When you contact us, we process the identification and contact data you provide, such as your name, email address and the content of your message.

If you subscribe or express interest in subscribing units in a fund under management, we process the data required by applicable law, including identification, financial and suitability information and the documentation required by anti-money laundering and counter-terrorist financing legislation.

This website uses only strictly necessary cookies by default; see the cookie policy for details.

03

Why We Process It and on What Legal Basis

In short

To answer you, to comply with the law, and to manage the investor relationship.

Responding to enquiries. Legal basis: our legitimate interest in responding to you, or pre-contractual steps taken at your request.

Regulatory compliance. Compliance with the legal and regulatory obligations applicable to fund management companies, including AML/CFT duties, reporting to the CMVM and record-keeping. Legal basis: legal obligation.

Investor relationship. Management of subscriptions, participation and reporting to investors. Legal basis: performance of a contract.

04

How Long We Keep It

In short

Only as long as needed, or as long as the law requires.

Personal data are retained only for as long as necessary for the purposes for which they were collected, or for the periods required by applicable law, including statutory retention periods under anti-money laundering and securities legislation (generally seven years from the end of the business relationship).

05

Who We Share It With

In short

Service providers, authorities when required, and fund administration entities. We do not sell data.

Data may be shared with service providers acting on our behalf, with supervisory and judicial authorities where legally required, and with entities involved in the administration of the funds the Company manages or plans to manage (such as the depositary and the auditor), always within the limits of applicable law. We do not sell personal data. Where data are transferred outside the European Economic Area, we ensure appropriate safeguards under Chapter V of the GDPR.

06

Your Rights

In short

Access, correction, deletion, restriction, portability, objection, and complaint to the CNPD.

You may exercise your rights of access, rectification, erasure, restriction, portability and objection by writing to hi@bitizenshipcapital.com. We respond within the deadlines set by the GDPR.

You also have the right to lodge a complaint with the Portuguese supervisory authority, the Comissão Nacional de Proteção de Dados (CNPD), www.cnpd.pt.

07

How We Protect It

In short

Technical and organisational measures appropriate to the risk.

We apply technical and organisational measures appropriate to the risk of the processing, including access controls, encryption in transit and staff confidentiality duties. Access to personal data is limited to those who need it for the purposes described above.

08

Updates to This Policy

In short

We may update this policy; the published version applies.

This policy may be updated from time to time, for example to reflect legal or organisational changes. The version published on this website at the time of your access applies, and material changes will be reflected in the "last updated" date above.

Questions

For any question about this document, write to hi@bitizenshipcapital.com or contact Bitizenship Capital, SCR, S.A., Rua Dom Pedro V, 410, 2.º, 4050-015 Porto, Portugal.

This document is published in English. Bitizenship Capital, SCR, S.A. is registered with the Commercial Registry under NIPC 519343018 and is supervised by the Comissão do Mercado de Valores Mobiliários (CMVM).