Privacy Policy

ANGELS WAY - FUNDO DE CAPITAL DE RISCO FECHADO, headquartered in Avenida Infante D. Henrique, 333 H, Escritório 17, 1800 - 282 Lisboa, with the Tax Registration Number 513494960 is the data controller of the personal data processed in connection with the use of the website angelsway.pt.

AS A DATA CONTROLLER, ANGELS WAY IS COMMITTED TO PROTECTING THE PRIVACY AND PERSONAL DATA OF ITS CUSTOMERS AND WEBSITE USERS AND HAS THEREFORE DEVELOPED AND ADOPTED THIS POLICY AND THE PRACTICES DESCRIBED HEREIN. THIS POLICY EXPLAINS HOW YOUR PERSONAL DATA IS COLLECTED AND PROCESSED, SO WE ADVISE YOU TO READ IT.

WHAT IS THIS POLICY ABOUT?
1. This Privacy Policy explains how we collect and process personal data that is necessary for the provision of services that are available through the website and describes the practices adopted for that purpose.
WHAT ARE PERSONAL DATA?
1. Personal data shall mean all information relating to an identified or identifiable individual, whatever the nature and support of the information, including sound and image of the individual.
2. An identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identification number or to other factors specific to his physical, physiological, mental, economic, cultural or social identity.
HOW DO WE USE YOUR PERSONAL DATA?
1. The personal data processing operations that we carry out are an essential tool for your satisfaction and for the activity of Angels Way and are performed in accordance with applicable law and best practices.
2. Your personal data will not be reused for other purposes that are not previously identified or that have no connection with those purposes for which they were initially collected.

WHAT ARE THE PURPOSES, LEGAL BASIS AND RETENTION PERIODS FOR THE DATA COLLECTED?

The personal data we process has specific bases, depending on the purposes for which they are intended, and will be kept for the time necessary for the respective purposes, as listed in this Privacy Policy.
The personal data collected are only those necessary and appropriate for the purposes indicated.

The following table shows the purposes of processing and data collected for these purposes, the respective grounds and the periods or criteria for storing data:

Purposes	Legal Basis	Collected Data	Retention Period
To analyze and process your application to invest in Angels Way.	Need in order to take steps at the request of the data subject prior into entering into a contract.	Name, email adress, phone Number (optional), LinkedIn profile, amount the data subject would like to invest.	For the period necessary to pursue this purpose. In case you are selected to be an investor in Angels Way, your data will be further retained for the duration of your contractual relationship with us.
For website management operations.	Consent for this specific purpose (cookies and analytics);
Legitimate interests pursued by Angels Way, namely OLISIPO WAY SGPS, S.A..	The creation of website access statistics that enable us to understand the characteristics of website visitors. However, this statistical information does not include any information that could be used to personally identify these visitors. The improvement of website personalization so that it adapts as much as possible to users' preferences and tastes, as inferred from the data collected.	For the period necessary to pursue this purpose.
For business purposes, such as data analysis, audits.	Consent for this specific purpose (cookies and analytics);
Legitimate interests pursued by Angels Way, namely OLISIPO WAY SGPS, S.A..	The creation of website access statistics that enable us to understand the characteristics of website visitors. However, this statistical information does not include any information that could be used to personally identify these visitors. The improvement of website personalization so that it adapts as much as possible to users' preferences and tastes, as inferred from the data collected.	For the period necessary to pursue this purpose.
For the adaptation, improvement and modification of services, namely by identifying usage trends.	Consent for this specific purpose (cookies and analytics);
Legitimate interests pursued by Angels Way, namely OLISIPO WAY SGPS, S.A..	The creation of website access statistics that enable us to understand the characteristics of website visitors. However, this statistical information does not include any information that could be used to personally identify these visitors. The improvement of website personalization so that it adapts as much as possible to users' preferences and tastes, as inferred from the data collected.	For the period necessary to pursue this purpose.

If the law provides for a specific or mandatory period, the data will be kept for that period. In all other cases, personal data will be kept for a maximum of the times indicated above, periods that Angels Wayconsiders sufficient to fulfil the purposes.
At the end of the conservation period, all personal data collected will be deleted.

HOW DO WE COLLECT YOUR PERSONAL DATA?
1. We will collect your personal data through the forms on the website, but also through the website and the communication that it makes with your device and email messages that you send us.
2. Your personal data is collected through your equipment as follows:
  1. Through your browser;
  2. Through cookies;
  3. Through pixel tags and other similar technologies;
  4. IP Adress;
  5. Through your user data.
3. Angels Way will not sell, rent or share your personal data with third parties, except as clearly identified in this Privacy Policy (see Section 9 to understand how).
4. Angels Way’s services are not intended for minors and no personal details of minors are or will being processed intentionally.
WHAT ARE COOKIES?
1. Cookies are small information files that help you identify your browser and can store information, for example, User settings and preferences.
2. Angels Way will store cookies on your device to personalize and facilitate browsing as well as troubleshooting, statistics, quality assurance, and to monitor system security
3. With the exception of cookies specifically required for the performance of the website, the storage of other cookies will always depend on the acceptance and consent of the User, and this consent may be withdrawn at any time through specific browser tools.
4. To know more about the cookies we use please refer to our Cookies Policy.
HOW DO WE PROTECT YOUR PERSONAL DATA?
1. Your personal data is kept secure by adopting a variety of technical and organizational security measures to ensure that only those employees who are required to access the personal data in accordance with the access requirements and rules created for this purpose have access to it.
2. To protect your personal data, we only use data center providers that offer adequate and documented security measures, including guarantees that your personal data is stored on servers that are maintained in controlled environments with limited access.
3. Similarly, when you browse the website, we protect your data with encryption, such as Transport Layer Security (TLS, a security protocol that protects telecommunications over the internet).
4. Although we take all necessary precautions we deem appropriate to protect the personal data you provide and we collect, one must be aware that no security system is impenetrable.
HOW YOU CAN YOU EXERCISE YOUR RIGHTS:
1. Before we explain how you can exercise your rights, you should know what they are. Thus, the law gives you the right to ask us to exercise the following rights:
  1. Access: the right to obtain confirmation as to whether or not personal data concerning you are being processed and, if so, the right to access your personal data;
  2. Rectification: the right to obtain the rectification of inaccurate personal data concerning you and to have incomplete personal data completed;
  3. Erasure: the right to obtain the erasure of your personal data when one of the grounds listed in the legislation applies, namely where:
    1. the personal data is no longer needed in relation to the purposes for which they were collected;
    2. the data subjects withdraws consent on which the processing is based and there is no longer other legal ground for the processing;
    3. the data subjects objects to the processing and there are no overriding legitimate grounds for the processing;
    4. the personal data have been unlawfully processed;
    5. the personal data have to be erased for compliance with legal obligations;
    6. the personal data have been collected in relation to the offer of information society services.
  4. Restriction of processing: the right to obtain limitation of processing if one of the situations listed in the legislation applies, namely where one of the following applies:
    1. The accuracy of the personal data is contested by the data subject;
    2. The processing is unlawful and the data subject opposes the erasure of the personal data requesting the restriction of their use instead;
    3. The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
    4. The data subject has objected to processing related with automated individual decision-making.
  5. Objection: the right to object on grounds relating to data subject’s particular situation, at any time of the processing of personal data concerning him or her which is based on public interest or legitimate interests;
  6. Data portability: the right to receive personal data concerning him/her in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance from the controller to which the data have been provided where the processing is based on consent or on a contract or where the processing is carried out by automated means.
2. You also have the right to lodge a complaint with a supervisory authority (National Data Protection Commission at www.cnpd.pt).
3. For the purpose of exercising the rights above mentioned, you should contact Angels Way by the email **we@angelsway.pt.
4. If you request us to delete some or all of your personal data, some of the services you have requested may not be provided to you and Angels Way will retain only the personal data necessary to comply with its legal obligations.
WHEN DO WE COMMUNICATE DATA TO THIRD PARTIES?
1. Angels Way may use third parties to provide certain services, such as maintenance, technical support or marketing, which may have access to some personal data, in particular, data required for contractual purposes.
2. Angels Way ensures that the entities that have access to the data are credible and offer high guarantees of protection, and that that data will never be transmitted beyond what is necessary to provide for the contracted service, nevertheless Angels Way remains accountable for the personal data made available.
3. Angels Way may communicate the personal data collected and processed to entities that may be established in connection with Angels Way or that are related to it, such as the Venture Capital Fund and its Management Entity.
4. In addition, Angels Way may also transfer its position regarding the operation of the website and subsequent data processing, and in such an event, the data may be transmitted to the new controller and this policy will be updated accordingly.
5. Angels Way may also transmit data to third parties in the context of investigations, inquiries and judical and / or administrative proceedings or of similar nature, provided that it is duly ordered by a court.
THIRD PARTY WEBSITES.
1. The WEBSITE may contain links to other websites which may collect and process your personal data, and this processing is the sole responsibility of the owners of these websites, and Angels Way does not take any responsibility for its policies and / or practices.
DATA TRANSFERS OUTSIDE THE EUROPEAN UNION.
1. If data transfers may occur to third countries outside the European Union, Angels Way will make all reasonable efforts to ensure the suitability of the destination country with regard to the protection of personal data, the requirements that apply to such transfers, as well as the implementation of appropriate technical and organizational measures.
MINORS.
1. The WEBSITE is not intended for minors under the age of 18, thus, we request that minors do not provide us with personal information through the website, application, social media and/or emails.
SENSITIVE PERSONAL DATA.
1. We request you not to send or disclose to us any sensitive personal data, i.e. information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information, health data or data concerning a natural person's sex life or sexual orientation.
2. If you nevertheless send or make known such categories of personal data to us, it will be deleted immediately.
CHANGES TO THE PRIVACY POLICY.
1. Angels Way reserves the right to readjust or change this Cookies Policy at any time. These changes will promptly be made public.
CONTACT DETAILS.
1. If you have any questions about this Cookies Policy, please email us at we@angelsway.pt.
LAST REVIEW.
1. January, 2023. Lisbon (Portugal).