Legal Notice & Compliance Policies

PRIVACY POLICY

Bullnet Capital (i.e. Bullnet Gestión SGEIC SA) is committed to protecting and respecting your privacy and the confidentiality of your personal data. This Privacy Policy sets out when and how we use the personal information that you provide to us, including through this website (the “Website”). It also describes what information we collect, how we use it, and the rights you have in relation to that collection and usage.

Whenever you provide Personal Information, we are legally obliged to use it in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 and the Organic Law 3/2018 of 5 December (LOPDGDD) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

Bullnet Capital is the Data Controller of your personal data. By “personal data” we refer to data collected by Bullnet Capital that identifies and relates to you as an individual.

This policy applies to Bullnet Capital and all venture capital companies managed by Bullnet Capital.

1. Who is responsible for processing your personal data?

Bullnet Gestión SGEIC SA, with registered office at Paseo del Club Deportivo 1, Edificio 3, Parque Empresarial La Finca, 28223 Pozuelo de Alarcón (Madrid), E-mail address info@bullnetcapital.com.

2. Which personal data do we process about you?

We collect and use your personal data to the extent necessary in the context of our activities. We may collect various types of personal data about you depending on the nature of the service, for example your name, date of birth, address, financial information, bank details, email-address, telephone number, etc. But we may also collect technical information about you when you visit our website like the IP address, cookies ID, etc.

3. On which basis do we process your data?

We always ensure that a lawful basis exists for all of the personal information we process at Bullnet Capital.

4. What do we use your personal data for?

We use your personal data to manage any request for specific information or service, but also for statistics and to comply with legal obligations.

5. How do we process your data?

We ensure that the processing of personal data is limited to the specific, explicit and legitimate purposes for those that were collected, and that will not be further processed in a manner incompatible with said purposes.

6. For how long do we store your data?

The personal data provided shall be stored for the period necessary for managing the requested service, and subsequently they shall be stored, but locked, for as long as necessary to formulate, exercise and defend any claims arising from the data processing.

7. To whom do we disclose your personal data?

No communication of personal data to third parties is foreseen except, if necessary and only after having signed a confidentiality and data processor contract required by current privacy regulation.

8. What are your rights when you provide us with your data?

In accordance with the applicable regulations, you have various rights, namely:

Right of access: You will be able to consult your personal data included in our files.

Right of rectification: You can modify your personal data when they are inaccurate.

Right to erasure: You may request your personal data be deleted.

Right to restrict: You may request the restriction of the processing of your personal data.

Right to object: You can object to the processing of your personal data, on grounds relating to your specific situation.

Right to data portability: Where legally applicable, you have the right to have the personal data you have provided to us be returned to you or, where technically feasible, transferred to a third party.

Right to withdraw consent: If you have given your consent to the processing of your personal data, you have the right to withdraw your consent at any time.

You may exercise the rights listed above by writing to Bullnet Capital info@bullnetcapital.com. This request shall contain the following information: name and surname, address for notification purposes, copy of your current ID or passport and the rights exercised. These rights can be exercised at no cost.

For information about cookies on our website which we use to collect user’s standard internet log information and behaviour information please read our Cookies Policy.

If you believe that your personal data have not been processed in accordance with the regulations, you are also entitled to submit a complaint to the Spanish Data Protection Agency www.aepd.es.

COOKIES POLICY

This Website uses cookies in order to facilitate the navigation, remembering the User´s preferences and improving the provision of our services.

By visiting our Website, and the acceptation of the Terms and Conditions, you accept and consent the installation of cookies.

1. What are cookies?

Cookies are small text files which are downloaded onto your computer, smartphone or other device when you visit websites. They are designed to store and provide information to the owner of the website about the navigation of its users (connection time, operation of the page …), and this in order to make statistics, improve the service offered, allow certain technical features and, sometimes, offer personalized advertising.

2. What cookies do we use and for what purpose?

Our website uses the following types of cookies:

3. Technical and personalization cookies

These cookies are essential in order to enable you to access and use the features of the secure areas of our website. Without these cookies, services you have asked for cannot be provided. You cannot opt out of these cookies.

• _dc_gtm_UA-109487845-1:  This cookie is associated with using Google Tag Manager to load other scripts and code into a page. Where it is used it may be regarded as Strictly Necessary as without it, other scripts may not function correctly.
• devicePixelRatio: This cookie is used to know what kind of screen the user´ computer has, to display an image quality or another.

4. Analytics and advertising cookies

These cookies collect information about how you use our website.  This information is aggregated and therefore anonymous and it is only used to improve how our website works.

Google

• _ga, _gid: our site uses Google Analytics, an analysis service provided by Google Inc. to get statistical information of an aggregate type that are useful to assess the use of the website and the activities carried out by the user. It can use a set of cookies to collect information and provide statistics without personally identifying Google visitors.
• Advertising – Those cookies are used by Google for advertising. Those cookies are set up by doubleclick.net. DoubleClick uses cookies to improve advertising. Some common applications are to target advertising based on what’s relevant to a user, to improve reporting on campaign performance and to avoid showing ads that the user has already seen.

5. How can you disable the use of cookies?

If you do not wish to accept cookies you can amend your browser options on your computer or any other device.

The instructions to amend the browser settings are the following, depending on the browser used:

• Internet Explorer: Tools> Internet Options> Privacy> Configuration.
• Firefox: Tools> Options> Privacy> History> Custom Settings.
• Chrome: Settings> Show advanced options> Privacy> Content settings.
• Safari: Preferences> Security.

To prevent Google Analytics cookies being set, you may install the  Google Analytics Opt-out Browser Add-on.

6. Changes to the Cookies Policy

This Cookies Policy may be altered at any given time whenever required by current legislation or whenever there is a change to the type of cookies used.

7. Processing of personal data in connection with the use of cookies

 The use of cookies will involve the processing of personal data. In our Privacy Policy you can read about our processing of your personal data and your rights. Find out more about who we are, how to contact us and how we process personal data in our Privacy Policy.

RESPONSIBLE INVESTMENT POLICY

1. Introduction

Investors’ sentiment has experienced a powerful shift from companies with poor ESG ratings towards more responsible ones. There is also evidence that strong ESG performance serves to mitigate risks and enhance employee and structural efficiency.

At Bullnet Capital we are committed to integrating gradually ESG best practices into our operating philosophy and investment process. We do not only invest in companies that are financially rewarding but also environmentally oriented and socially responsible.

The integration of ESG factors into our investment decisions is an important part of fulfilling our mission to deliver strong returns to our investors. Analysing and mitigating sustainability risks is crucial for protecting our investments as well as our reputation and top position in the Spanish and European venture capital sector.

Bullnet Capital, through its investment activity, aims to comply with best practices and as responsible investor. Bullnet Capital commits to the United Nations Principles of Responsible Investment (UN PRI):

• Incorporate ESG issues into investment analysis and decision-making processes.
• Be active owners and incorporate ESG issues into our ownership policies and practices.
• Seek appropriate disclosure on ESG issues by the entities in which we invest.
• Promote acceptance and implementation of the Principles within the investment industry.
• Work together to enhance our effectiveness in implementing the Principles.
• Report on our activities and progress towards implementing the Principles.

Furthermore, Bullnet Capital has the opportunity to positively influence the companies we invest in by helping them not only to drive value and enhance returns but also to be more environmentally and socially oriented by helping them to achieve the Sustainable Development Goals (SDGs) and implement their own ESG policies and practices.

2. Purpose and Scope of Policy

At Bullnet Capital we believe that Environmental, Social and Governance (ESG) principles are not only crucial for shaping a better future for our planet and society but also for developing resilient companies and assets that deliver long-term value for our investors.

Our ESG Policy outlines our firm-wide approach to integrating ESG criteria into our investment analysis, decision-making processes and asset management practices.

3. Implementation Approach

Bullnet Capital’s approach is aimed at identifying and evaluating key ESG aspects of an investment from origination to exit. Additionally, we advocate the companies we invest in to incorporate ESG factors into their management practices to work towards implementing, measuring, and reporting on sustainability practices.

Specifically, Bullnet Capital aims to:

• Identify key material ESG risks and opportunities as part of the due diligence, investment decision and ownership phases of its investment process
• Map material ESG issues to the United Nations Sustainable Development Goals (“SDG”), and consider SDG alignment in its investment decisions; and
• Encourage implementation of ESG best practices and support the building of long-term sustainable businesses in an environmentally and socially responsible manner.

4. Pre-Investment

Bullnet Capital seeks to ensure that material ESG risks and opportunities are considered as part of our evaluation of any prospective investment.

Each prospective investment is first reviewed against a set of excluded activities: pornography, weapons and ammunition (unless these activities are part or accessory to explicit European Union policies), betting and casinos, abusive finance or financial services, producing or promoting tobacco and distilled alcoholic beverages, related to any illegal economic activities and human cloning or GMOs. If revenues are derived from these activities, the investment opportunity is automatically rejected.

Bullnet has also incorporated the “do no significant harm” (DNSH) principle to our due diligence process. A DNSH certification is required, evidencing that the company’s activity contributes to the protection of the environment without causing any significant harm. This certification has to be issued by an independent certified firm,

During Bullnet Capital’s initial due diligence, early red flags relating to ESG are identified for each prospective investment, and a prospective investment’s potential alignment with Sustainable Development Goals is also highlighted.

Bullnet Capital’s investment due diligence process then includes assessment of the ESG risks and opportunities unique to each prospective investment. Prioritization is based on sector specific risks. Bullnet Capital gathers relevant information through posing questions to prospective investment companies.

Bullnet Capital’s Investment Committee considers findings from ESG related due-diligence in deciding whether to proceed with an investment, as well as in its determination of what post-acquisition processes and practices should be implemented in order to improve and properly manage ESG-related risks.

5. Post-Investment

During its investment ownership, Bullnet Capital seeks to ensure that ESG issues are regularly assessed through ongoing monitoring of ESG related information. Bullnet Capital engages regularly with the companies we invest in, in an effort to support them constructively on the effective management of ESG issues.

6. Transparency and Reporting

Bullnet Capital recognizes the benefits of transparency and is committed to continuously improving our ESG related disclosures and communication to all our investors. Presently, our ESG Investment Responsible Policy is available on our website.

WHISTLEBLOWER CHANNEL

1. Introduction

At Bullnet Capital, we are committed to promoting a culture of transparency, integrity, responsibility and ethical conduct across our organisation and professional relationships.

In line with this commitment, Bullnet Gestión SGEIC, S.A. has implemented an Internal Information System and a Whistleblower Channel to allow employees and other stakeholders to report, in good faith, any conduct that may constitute a breach of applicable law, internal policies or ethical principles.

The Whistleblower Channel is designed to ensure that potential irregularities can be reported safely, confidentially and, where appropriate, anonymously, without fear of retaliation. It forms part of Bullnet Capital’s broader commitment to good governance, regulatory compliance and responsible business practices.

This channel has been established in accordance with Spanish Law 2/2023, of 20 February, regulating the protection of persons who report regulatory breaches and the fight against corruption, which transposes Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law.

2. Purpose and Scope

The purpose of Bullnet Capital’s Whistleblower Channel is to provide a secure and effective mechanism for reporting actions or omissions that may constitute criminal offences, serious or very serious administrative infringements, breaches of European Union law, breaches of internal policies, or conduct contrary to Bullnet Capital’s ethical values.

The channel is available to individuals who have obtained information about potential infringements in a work-related or professional context, including employees and workers; self-employed collaborators and freelancers; shareholders, partners and members of management, supervisory or administrative bodies, including non-executive members; persons working under the supervision or direction of contractors, subcontractors or suppliers; former employees, volunteers, interns, trainees and candidates who obtained relevant information during a recruitment or pre-contractual process.

Reports must be made in good faith and should be based on concrete facts or reasonable indications. Whenever possible, the report should include a detailed description of the facts, the relevant area or regulation affected, supporting documentation and any other information that may help assess and investigate the matter.

3. Reportable Matters

The Whistleblower Channel may be used to report serious misconduct or suspected corruption related to Bullnet Capital’s activities, including matters concerning public procurement; financial services, products and markets, including prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation protection and nuclear safety; food and feed safety, animal health and animal welfare; public health; consumer protection; privacy, personal data protection, and security of network and information systems; protection of the financial interests of the European Union; internal market rules, including competition, State aid and corporate tax matters; criminal offences or serious or very serious administrative infringements; and serious breaches of labour law relating to health and safety at work.

The channel is not intended for purely interpersonal disputes, matters already fully available to the public, mere rumours, or issues outside the scope of the applicable whistleblower protection regulations.

4. How to Submit a Report

Reports may be submitted through the following channels:

Online Whistleblower Channel

Email: compliance@bullnetcapital.com

Postal mail: Bullnet Gestión SGEIC, S.A., Parque Empresarial La Finca, Paseo del Club Deportivo 1, Edificio 3, 28223 Pozuelo de Alarcón, Madrid, Attn.: Responsable del Sistema Interno de Información.

Reports may also be submitted through a face-to-face meeting, upon request by the reporting person, which will take place within the legally established timeframe.

Reports may be submitted anonymously. Where the reporting person chooses to identify themselves, Bullnet Capital will protect their identity and ensure confidentiality in accordance with applicable law.

5. Management of Reports

The Whistleblower Channel is managed by the person responsible for Bullnet Capital’s Internal Information System, together with any duly authorised delegates or case managers appointed where necessary.

Once a report is received, it will be registered securely and assigned an identification code. Bullnet Capital will acknowledge receipt within seven calendar days, unless the reporting person has expressly waived the right to receive communications or where doing so could compromise confidentiality.

Reports will be analysed to determine whether they fall within the material and personal scope of the applicable whistleblower regulations. Where admitted, they will be investigated impartially, confidentially and independently.

As a general rule, the investigation will be completed within a maximum period of three months. In particularly complex cases, this period may be extended for up to an additional three months.

Where the facts reported may constitute a criminal offence, Bullnet Capital will immediately refer the matter to the Public Prosecutor’s Office. Where the facts affect the financial interests of the European Union, the matter will be referred to the European Public Prosecutor’s Office.

6. Protection of Whistleblowers

Bullnet Capital expressly prohibits any form of retaliation, threat of retaliation or attempted retaliation against persons who submit reports in accordance with applicable law.

Retaliation may include dismissal, suspension of employment, disciplinary measures, demotion, denial of promotion, substantial modification of working conditions, reputational damage, economic loss, coercion, intimidation, harassment, discrimination, blacklisting, denial of training, or any other unfavourable treatment linked to the report.

Whistleblower protection may also extend to persons who assist the reporting person, colleagues or family members who may suffer retaliation, and legal entities for which the reporting person works or with which they maintain a professional relationship.

Bullnet Capital will take appropriate measures to protect reporting persons acting in good faith and to ensure that reports are handled with independence, confidentiality and respect for the rights of all parties involved.

7. Rights of Persons Affected

Persons affected by a report are entitled to the presumption of innocence, the right of defence and the right of access to the file under the terms established by applicable law.

Bullnet Capital will also preserve the confidentiality of the identity of affected persons and any third parties mentioned in a report, ensuring that all investigations are conducted fairly, objectively and with due respect for the rights of all individuals involved.

8. Confidentiality and Data Protection

All personal data processed through the Whistleblower Channel will be handled in accordance with applicable data protection legislation, including Regulation (EU) 2016/679, Spanish Organic Law 3/2018 on Personal Data Protection and Digital Rights, and Spanish Law 2/2023.

The identity of the reporting person will remain confidential and may only be disclosed to judicial authorities, the Public Prosecutor’s Office or the competent administrative authority where legally required in the context of a criminal, disciplinary or sanctioning investigation.

Access to information submitted through the Whistleblower Channel is strictly limited to authorised persons responsible for managing and investigating reports. Personal data that is not relevant to the investigation will not be collected and, if collected accidentally, will be deleted without undue delay.

Data subjects may exercise their rights of access, rectification, erasure, restriction, portability and objection, where legally applicable, by contacting: info@bullnetcapital.com.

Data subjects also have the right to lodge a complaint with the Spanish Data Protection Agency.

9. Communication and Review

Bullnet Capital is committed to communicating this policy to employees and relevant stakeholders and to promoting awareness of the Internal Information System and the protections available to reporting persons.

This policy will be reviewed and updated periodically, at least every three years, and whenever necessary to reflect regulatory changes, practical experience or recommendations issued by the competent authorities.