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Privacy & Cookie Policy

Last updated: 23 June 2026

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Preamble

This Privacy & Cookie Policy ("Policy") describes how Octans Capital (Commercial Registry number: 156341701000), with registered office at 28i Oktomvriou, No. 11, Psychico, Attica, Greece ("Octans Capital", "we", "us", or "our"), collects, uses, stores, and protects personal data when you visit the website at octanscapital.io and any associated sub-domains (the "Website"), submit enquiries or venture applications through the Website, or otherwise interact with Octans Capital. Where the context requires, references to Octans Capital include OCTANS SYSTEMS and the Octans Group as a whole.

This Policy should be read alongside the Terms of Service of the Website. By using the Website or submitting any information to us, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, please do not use the Website or submit personal data to us.

1. Data Controller

1.1. The data controller responsible for the processing of personal data described in this Policy is:

Octans Capital

28i Oktomvriou, No. 11, Psychico, Attica, Greece

Website: octanscapital.io

Contact: octanscapital.io/contact

1.2. Octans Capital does not currently designate a formal Data Protection Officer (“DPO”), as it does not fall within the mandatory DPO designation thresholds set out in Article 37 GDPR. Data protection enquiries may be addressed to Octans Capital directly via the contact details above and will be handled by the individual responsible for legal and compliance matters within the firm.

2. Scope and Application

2.1. This Policy applies to all personal data processed by Octans Capital in connection with:

  • visits to and interactions with the Website;
  • submission of enquiries via the contact form;
  • submission of venture applications through the OCTANS SYSTEMS application portal at octanscapital.io/octanssystems/apply;
  • email and other correspondence initiated by data subjects; and
  • analytics and cookie data collected automatically during Website use.

2.2. This Policy does not apply to personal data processed in the context of an engagement agreement with a client of Octans Capital. Processing of personal data in that context is governed by the applicable engagement documentation and any separate data processing terms agreed between the parties.

2.3. The Website may contain links to third-party websites. This Policy does not apply to those external sites. Octans Capital is not responsible for the privacy practices of third-party websites and encourages users to review the privacy notices of any website they visit.

3. Categories of Personal Data Collected

3.1 Data Provided Directly by You

3.1.1. Octans Capital collects personal data that you actively provide when interacting with the Website. This includes:

  • Contact enquiries: name and email address submitted via the Website contact form, and the content of your message.
  • Venture applications: full name, email address, LinkedIn profile URL, venture title, and written responses to structured assessment questions submitted via the application form.

3.1.2. You are not legally obliged to provide the above data. However, failure to provide certain information may prevent Octans Capital from responding to your enquiry or evaluating your application.

3.2 Data Collected Automatically

3.2.1. When you visit the Website, certain technical data is collected automatically through cookies and similar technologies. This may include:

  • Device and browser information: browser type and version, operating system, device type, and screen resolution.
  • Usage data: pages visited, time spent on each page, referral source, click patterns, and navigation paths.
  • Technical identifiers: Internet Protocol (IP) address, cookie identifiers, and session identifiers.

3.2.2. This data is collected via Google Analytics, subject to your consent (see Section 5). Where IP anonymisation is enabled, full IP addresses are not stored by Octans Capital or transmitted to Google in identifiable form.

3.3 Data We Do Not Collect

3.3.1. Octans Capital does not intentionally collect or process special categories of personal data (as defined in Article 9 GDPR), including data revealing racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic or biometric data, health data, or data concerning a person's sex life or sexual orientation. If you inadvertently include such data in a communication or application, we will treat it with heightened confidentiality and will not process it for any purpose beyond handling your submission.

3.3.2. Octans Capital does not collect financial account credentials, payment card data, or government-issued identification numbers through the Website.

4. Purposes and Legal Bases for Processing

4.1. Octans Capital processes personal data only where a valid legal basis under Article 6 of the General Data Protection Regulation (EU) 2016/679 ("GDPR") exists. The following table sets out the purposes for which we process personal data and the corresponding legal bases:

  • Responding to contact enquiries: Legal basis: legitimate interests (Art. 6(1)(f) GDPR); specifically, the interest in responding to persons who have reached out to us, where such interests are not overridden by the interests or rights of the data subject.
  • Evaluating venture applications: Legal basis: legitimate interests (Art. 6(1)(f) GDPR); being the interest in assessing investment and advisory mandates; and, to the extent a specific engagement may result, pre-contractual measures at the request of the data subject (Art. 6(1)(b) GDPR).
  • Maintaining internal records and compliance documentation: Legal basis: legitimate interests (Art. 6(1)(f) GDPR) and, where applicable, compliance with a legal obligation (Art. 6(1)(c) GDPR).
  • Website analytics (Google Analytics): Legal basis: consent (Art. 6(1)(a) GDPR). Analytics cookies are deployed only where you have provided explicit consent via the cookie consent interface. You may withdraw consent at any time (see Section 5.4).
  • Essential website functionality (session and preference cookies): Legal basis: legitimate interests (Art. 6(1)(f) GDPR), being the interest in ensuring the basic functionality and security of the Website.

4.2. Where Octans Capital relies on legitimate interests as a legal basis, it has assessed that those interests are not overridden by the rights and freedoms of data subjects, having regard to the nature of the data processed, the reasonable expectations of data subjects in the relevant context, and the safeguards applied.

5. Cookies and Tracking Technologies

5.1 What Are Cookies

5.1.1. Cookies are small text files placed on your device by a web server when you visit a website. They allow the website to recognise your device and remember certain information about your visit. References to "cookies" in this Policy encompass all such technologies unless otherwise indicated.

5.2 Categories of Cookies Used

5.2.1. Octans Capital uses the following categories of cookies on the Website:

  • Essential cookies and local preferences: These are strictly necessary for the operation of the Website. They enable core functions such as page navigation, security, and remembering your cookie consent choice in localStorage (key octans_cookie_consent_v1). Without these, services you have requested cannot be provided. They are deployed on the basis of legitimate interests and do not require your consent.
  • Analytics cookies (Google Analytics): These cookies are set by Google Analytics (a service provided by Google Ireland Limited for users in the EEA) and allow us to understand how visitors interact with the Website and from which sources they arrive. The data collected is aggregated and anonymised to the extent technically possible (including through IP anonymisation). Analytics cookies are set only upon your explicit consent and may be declined without affecting your ability to use the Website.

5.2.2. Octans Capital does not use advertising cookies, behavioural profiling cookies, cross-site tracking technologies, social media tracking pixels, or any cookies designed to build profiles of users for commercial targeting purposes.

5.3 Managing and Withdrawing Consent

5.3.1. When you first visit the Website, a cookie consent banner is displayed. You may accept all cookies, reject non-essential cookies, or customise your preferences. Your choice is stored locally in your browser (localStorage key octans_cookie_consent_v1).

5.3.2. You may withdraw or modify your consent to analytics cookies at any time by:

  • clicking Customize on the cookie consent banner to reopen your preferences; or
  • adjusting your browser settings to block or delete cookies; or
  • installing the Google Analytics Opt-out Browser Add-on, available at tools.google.com/dlpage/gaoptout.

5.3.3. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to withdrawal.

5.4 Google Analytics

5.4.1. Octans Capital uses Google Analytics under a data processing agreement with Google Ireland Limited. Data collected through Google Analytics may be transferred to and stored on servers located in the United States or other countries outside the European Economic Area. Google acts as a data processor on our behalf and is contractually required to process such data only in accordance with our instructions and applicable data protection law. Where applicable, transfers are made pursuant to standard contractual clauses approved by the European Commission. For further details on Google's data practices, please refer to Google's Privacy Policy at policies.google.com/privacy.

6. Data Sharing and Third-Party Processors

6.1. Octans Capital does not sell, rent, license, or otherwise transfer your personal data to third parties for their own commercial purposes.

6.2. We may share personal data with third parties only in the following circumstances:

  • Service providers and data processors: Octans Capital engages certain trusted third-party service providers to assist in operating the Website and delivering its services. These providers act as data processors under written agreements that require them to process personal data only on our instructions and in accordance with applicable data protection law. They are not permitted to use your data for their own purposes.
  • Professional advisors: Where necessary, we may share information with legal advisors, auditors, or other professional advisors who are subject to professional confidentiality obligations.
  • Legal and regulatory obligations: We may disclose personal data where required to do so by applicable law, regulation, or court or regulatory order, including to respond to lawful requests from public authorities.
  • Business transfers: In the event of a merger, acquisition, restructuring, or sale of all or a material part of Octans Capital's business or assets, personal data held by Octans Capital may be transferred to the relevant acquirer or successor entity, subject to appropriate confidentiality protections.

6.3. In each case, Octans Capital takes appropriate contractual, technical, and organisational measures to ensure that personal data shared with third parties is protected in a manner consistent with this Policy and applicable law.

7. International Transfers of Personal Data

7.1. Octans Capital is based in Greece, an EU Member State, and primarily processes personal data within the European Economic Area (EEA). Where personal data is transferred outside the EEA, Octans Capital ensures that such transfers are carried out on the basis of one of the transfer mechanisms recognised under Chapter V GDPR, including:

  • an adequacy decision adopted by the European Commission in respect of the receiving country; or
  • standard contractual clauses approved by the European Commission; or
  • other appropriate safeguards as permitted under Article 46 GDPR.

7.2. You may request further information about the specific transfer mechanisms applicable to processing activities that involve transfers outside the EEA by contacting us at the details provided in Section 13.

8. Data Retention

8.1. Octans Capital retains personal data only for as long as is necessary for the purposes for which it was collected, or as required or permitted by applicable law. The following indicative retention periods apply:

  • Contact enquiries: Retained for the period necessary to respond to the enquiry and for a further period of up to twelve (12) months for internal reference, unless a longer period is required by the nature of the matter.
  • Venture applications: Retained for a period of up to three (3) years from the date of submission. This reflects the possibility that an application initially declined may become relevant in a later assessment cycle, and the need to maintain records of engagements considered. Upon expiry, data is securely deleted or anonymised.
  • Analytics data: Google Analytics data is retained for a period of fourteen (14) months in accordance with Octans Capital's analytics configuration, after which it is automatically deleted.
  • Cookie consent records: Retained for twelve (12) months, after which your cookie preferences will be re-requested.

8.2. At the end of the applicable retention period, personal data is securely deleted, anonymised, or de-identified in accordance with Octans Capital's internal data governance procedures. Where a legal obligation requires retention beyond the above periods, the data will be retained only for the minimum period necessary to fulfil that obligation.

8.3. You may at any time request deletion of your personal data ahead of the applicable retention period (see Section 9), subject to any overriding legal obligation that requires us to retain the data.

9. Your Rights as a Data Subject

9.1. Under the GDPR and applicable national law, you have the following rights in relation to your personal data processed by Octans Capital:

Right of access (Art. 15 GDPR): You have the right to obtain confirmation as to whether Octans Capital processes personal data about you and, if so, to receive a copy of that data together with supplementary information about the processing.

Right to rectification (Art. 16 GDPR): You have the right to request the correction of inaccurate personal data and the completion of incomplete personal data.

Right to erasure (Art. 17 GDPR): You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent (and no other legal basis applies), where you have successfully objected to processing, or where the data has been unlawfully processed.

Right to restriction of processing (Art. 18 GDPR): You have the right to request that Octans Capital restricts the processing of your personal data in certain circumstances, for example where you contest the accuracy of the data or where you have objected to processing pending verification of whether legitimate grounds override your objection.

Right to data portability (Art. 20 GDPR): Where processing is based on consent or contract and carried out by automated means, you have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, and to transmit it to another controller.

Right to object (Art. 21 GDPR): You have the right to object at any time to processing of your personal data based on legitimate interests (Art. 6(1)(f) GDPR). Octans Capital will cease processing unless it can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or unless the processing is necessary for the establishment, exercise, or defence of legal claims.

Right to withdraw consent (Art. 7(3) GDPR): Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

Right not to be subject to automated decision-making (Art. 22 GDPR): Octans Capital does not make decisions based solely on automated processing (including profiling) that produce legal or similarly significant effects on you.

9.2. To exercise any of the above rights, please submit a request to Octans Capital using the contact details in Section 13. We will respond to your request within one (1) month of receipt, or within three (3) months where the request is particularly complex or we have received a high volume of requests (in which case we will notify you of the extension within the first month). Requests are handled free of charge unless manifestly unfounded or excessive, in which case we reserve the right to charge a reasonable fee or decline the request.

9.3. We may request that you provide reasonable evidence of your identity before processing your request, in order to ensure that personal data is not disclosed or altered in response to a fraudulent request.

9.4. If you are not satisfied with how Octans Capital handles your personal data or responds to your request, you have the right to lodge a complaint with the competent supervisory authority. In Greece, the supervisory authority is the Hellenic Data Protection Authority (“HDPA”), reachable at www.dpa.gr. If you are resident in another EU Member State, you may alternatively lodge a complaint with the supervisory authority of your country of residence or place of work.

10. Security Measures

10.1. Octans Capital implements appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access, having regard to the state of the art, the costs of implementation, and the nature, scope, context, and purposes of processing, as well as the risk to the rights and freedoms of natural persons.

10.2. These measures include, as appropriate:

  • encryption of data in transit via Transport Layer Security (TLS) protocols;
  • access controls limiting access to personal data to authorised personnel on a need-to-know basis;
  • secure storage of application and enquiry data in controlled infrastructure environments;
  • regular review of access rights and security practices.

10.3. Notwithstanding the above, no method of transmission over the internet or method of electronic storage is completely secure. Octans Capital cannot guarantee the absolute security of personal data and, accordingly, cannot accept unlimited liability for breaches that result from circumstances beyond its reasonable control. In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, Octans Capital will notify you without undue delay in accordance with its obligations under Article 34 GDPR.

11. Minors

11.1. The Website is not directed at, and Octans Capital does not knowingly collect personal data from, individuals under the age of eighteen (18). If you are under 18, please do not submit any personal data to us through the Website.

11.2. If Octans Capital becomes aware that it has inadvertently collected personal data from a person under the age of 18, it will take reasonable steps to delete such data without undue delay. If you believe that we may have collected personal data from a minor, please contact us at the details provided in Section 13.

12. Changes to This Policy

12.1. Octans Capital reserves the right to update or amend this Policy at any time to reflect changes in our data processing practices, applicable law, or the structure of our Website and services. The updated Policy will be published on the Website with a revised "Last updated" date at the top of the document.

12.2. Where changes are material, Octans Capital will take reasonable steps to bring them to your attention. Continued use of the Website after publication of an updated Policy constitutes acceptance of the revised terms.

12.3. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

13. Contact

13.1. For any questions, requests, or complaints relating to the processing of your personal data or this Policy, please contact:

Octans Capital

28i Oktomvriou, No. 11, Psychico, Attica, Greece

Website: octanscapital.io

Data protection enquiries: octanscapital.io/contact

14. Governing Law

14.1. This Policy and any dispute arising in connection with it shall be governed by and construed in accordance with the laws of the Hellenic Republic and applicable European Union law, including the GDPR and Greek Law 4624/2019. The competent courts of Athens, Greece shall have jurisdiction over any dispute arising in connection with this Policy, subject to your right as an EU consumer to bring proceedings before the courts of your country of habitual residence.

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ΓΕΜΗ: 156341701000  |  28ΗΣ ΟΚΤΩΒΡΙΟΥ 11, ΨΥΧΙΚΟ 15452