TERMS OF SERVICE

Thank you for your interest in SME New Capital. Please review the following Terms of Service, which will govern your registration with and use of the SME New Capital platform (‘Platform’).

By registering with and using the Platform, you agree to the terms and conditions (‘Terms of Service’) contained in this document (‘Agreement’) as well as to the terms of the SME New Capital Privacy Policy. You agree to accept these Terms of Service electronically. If you do not want to be bound by the Terms of Service, you should not make use of the Platform.

DEFINITIONS

‘Investor’ means any person or Organisation which commits capital with the expectation of financial returns.

‘Company’ means any type of enterprise that engages in legitimate business endeavours (such as start-up, SME, corporate, partnership etc.)

‘Company Owner’ means any person or Organisation that owns part or all shares of a Company.

‘Content’ means all information and content made available by Users to SME New Capital and which is available on the Platform (includes: ‘User Content’ – content provided by a User to SME New Capital and/or content uploaded by a User on the Platform, ‘SME New Capital Content’ – User Content processed by the SME New Capital or by the Platform and uploaded on the Platform by the SME New Capital) and its ‘look and feel’ including but not limited to trademarks, logos, service marks, copyrighted works, text, graphics, button icons, images, audio/video clips, data compilations and software, and the compilation and organization thereof.

‘Investment Presentation’ means a document generated by the Platform and intended for perusal by Investors. Investment Presentation is part of SME New Capital Content.

‘Organisation’ means a private equity investor (such us Venture Capital, Private Equity, Family Offices etc.) as well as businesses (such as SMEs, corporates, holding companies etc.) and financial institutions (such as banks).

‘SME New Capital’ or ‘We’ means the business line of MIF advisory Ltd. (a limited liability company, 20-22 Wenlock Road, N1 7GU London, UK), responsible for the functioning of the Platform. For the purpose of this Agreement, SME New Capital includes and fully covers MIF advisory Ltd.

‘Services’ refers to all resources and services provided to the User by SME New Capital through the Platform.

‘User’ or ‘You’ shall mean any user or person who registers with the Platform, has access to the Content and interacts with the Content via the Platform.

DESCRIPTION OF THE PLATFORM

We have built the Platform to meet the needs of the Companies, Companies Owners, Organisations and Investors. The Platform offers resources and services offered to Users by SME New Capital and its affiliates. This includes:

For Companies and Companies Owners

• support in gathering the Content,

• support in developing Investment Presentation,

• access to any and all of the Content of that User,

• services related to the Content storage, collaboration emails, professional services, and collaboration services,

• support in reaching out to potential Investors, and

• making connection with potential Investors

For Investors

• support in browsing the Content,

• support in making connections with Companies and Companies Owners,

• support in deal flow management, and

• support in deal collaboration

The SME New Capital services related to support in due diligence (e.g. preparation, facilitation, investigation) and support in deal structuring/negotiation (e.g. structuring, term sheet analysis, expectations-gap breaching instruments, negotiations) are not part of the Platform services, however can be separately purchased by the User from SME New Capital and its affiliates.

SME New Capital does not verify any User Content, and does not and cannot guarantee that any Content is accurate or complete. In order to use the Platform, you must use one of the supported Internet browsers. Additionally, you are required to register your User information with SME New Capital. SME New Capital does not provide internet access, and you are responsible for all fees associated with you internet connection and with the use of the Platform.

Users

Company or Company Owner: If you are a User who is a Company or a Company Owner, you may upload information about your business to the Platform (i.e. the Content). However, be aware that SME New Capital will make the Content fully available to Investors (those registered on the Platform and also Investors who are not yet registered on the Platform). Moreover SME New Capital has no control over the actions of Investors. Also, though we take all reasonable steps in accordance with industry standards to prevent it, we cannot guarantee that the Platform will never suffer from a software bug or a hacker attack that will allow unauthorized viewing of the Content, or that any Investor will not share the Content with 3^rd parties. Consequently, you understand and accept that the Content might be disclosed outside the Platform and you acknowledge, accept and agree that neither SME New Platform nor any of its directors, employees, owners, third party service providers and affiliates will be liable for any damages (direct and indirect), including lost business opportunities, related to such disclosures (even if the Content contained information you consider confidential).

Investors: If you are classified by SME New Capital as an Investor User, you will have an access to the Content including access to Companies and Companies Owners confidential information. Consequently, you should use your discretion in how you handle that information.

General Users: All Users will be overseen by SME New Capital administrator, who will determine membership and set rules and parameters as provided on the Platform for that User.

SME New Capital shall have no obligation to participate or assist in any way in the event of any dispute between Users.

Notwithstanding the above or anything to the contrary set forth in the Terms of Service, SME New Capital shall have the absolute and unlimited rights: to reject any User, to terminate the account of any User, to delete any User Content, to use any User Content to develop SME New Capital Content or to publish any Content, including for the purposes of marketing the Platform.

License to Use

Subject to the terms of these Terms of Service, which constitute the agreement between SME New Capital and you, the User, SME New Capital grants to you a non-exclusive, revocable, non-transferable license to use the Platform. All right, title, and interest in and to the Platform (excluding User Content) is and will remain the exclusive property of SNE New Capital.

User Diligence

All Users of the Platform are advised that SME New Capital does not take any steps to verify the information provided to us by the Users. Each Investor is solely responsible for conducting diligence on any Company and/or Company Owner and each Company and/or company Owner is solely responsible for conducting diligence on any Investor with whom they interact on the Platform. Further, Users may be located in different countries with different laws and regulations. SME New Capital does not verify the compliance of Users with the applicable accounting and securities laws in their home jurisdiction and relies solely on their self-certification that they are in compliance with applicable laws.

Transactions

By using the Platform you understand and agree that you will be solely responsible for complying with all applicable law regarding any transaction in which you may engage.

SME New Capital does not recommend any investments, does not verify or review User Content (including documents and communications), and does not give business advice, financial advice, investment advice, tax advice or legal advice. SME New Capital does not claim to be and is not registered as a broker-dealer and investment advisor. Nothing on this Platform is intended to be or shall constitute or be construed as a sale or purchase or offer to sell or purchase or a recommendation of any securities.

How it works (Companies and Companies Owners)

The Companies and Companies Owners are able to use the Platform in the following way:

1. Registration – the initial step in accessing the Platform:

   • you are required to provide registration information related to the Company and yourself;

   • you need to choose a subscription related to the period of time you intend to use the Platform;

   • you are prompted to pay for the chosen subscription and the registration is completed and account is activated once the payment for the subscription is executed;

   • although your account is active, the Company is not visible to Investors until the Investment Proposal is published;

2. Creation of Investment Proposal – the process of creating the information that will be made visible to Investors:

   • you are prompted to provide User Content related to a Company you want to introduce to the Platform (i.e. Company information details, business overview, shareholder structure description, management team description, financial information, financing/selling motivation and reasons, upload additional documents). The User Content can be provided in your native language;

   • once all the User Content has been provided and the Platform shows all green ticks (no red crosses) and you are be able to submit the User Content to SME New Capital;

   • SME New Capital processes the User Content and interacts/checks with you in case obvious errors have been spotted by SME New Capital or important information is missing or is not clear;

   • following checks with you, SME New Capital finalises development of the SME New Capital Content (including the Investment Proposal) related to the Company you have introduced. The SME New Capital Content (including the Investment Proposal) is always in English language;

   • SME New Capital uploads the SME New Capital Content (including the Investment Proposal) on the Platform and publishes it to make it available for Investors to view;

   • SME New Capital sends the Investment Proposal to other Investors, not yet registered with the Platform.

3. Changes to the Investment Proposal – the process of changing the Investment Proposal

   • once the SME New Capital Content (including Investment Proposal) has been published, you will not be able to change the Content related to the Company you have introduced for a period of 3 months from the date of the publishing;

   • once the 3 months period elapses and your subscription is still valid, the Platform will allow you to provide changes to the User Content,

     • once all the changes to the User Content has been provided, you need to submit the new version of User Content to SME New Capital;

     • SME New Capital processes the User Content and interacts/checks with you in case obvious errors have been spotted by SME New Capital or important information is missing or is not clear;

     • following checks with you, SME New Capital finalises development of the SME New Capital Content (including the Investment Proposal) related to the Company you have introduced. The SME New Capital Content (including the Investment Proposal) is always in English language;

     • SME New Capital uploads the SME New Capital Content (including the Investment Proposal) on the Platform and publishes it to make it available for Investors to view;

   • publishing of the new version of SME New Capital Content (including new Investment Proposal) automatically deletes the related old version of the SME New Capital Content (including old Investment Proposal). Only one version can be published at the time with the new version always overwriting the old version;

   • in case of the errors, you will be able to amend the published SME New Capital Content (including Investment Proposal) at anytime by contacting us on support@smenewcapital.com.

4. Extension of the subscription to use the Platform – you will be able to extend the period of time you intend to use the Platform:

   • you can purchase extension subscription by logging in into your account and choosing the extension you require;

   • in case you have still valid subscription, the extension will start from the date the still active subscription expires (subscriptions stacking-up process).

5. Expiry of the subscription – when your subscription expires:

   • you are informed about the approaching expiration of your subscription;

   • at the end of the day of the expiration of the subscription, the SME New Capital Content (including Investment Proposal) related to your account is de-published (meaning, is not visible to Investors anymore) and consequently Investors cannot see your Company on the Platform anymore;

   • you are informed that the subscription expired;

   • your account is considered in-active, however you can log-in to your account.

6. Termination of the subscription – your subscription can be terminated before expiration date:

   • you can terminate your subscription by contacting us on support@smenewcapital.com. The processing of the termination can take up to 3 calendar days;

   • your subscription is terminated by SME New Capital immediately in case of you breaching this Terms of Use;

   • in case of termination of your subscription, the remaining time of the subscription is lost and no refunds/payments are provided to you by SME New Capital and its affiliates.

   • upon termination of your subscription, the SME New Capital Content (including Investment Proposal) related to your account is de-published (meaning, is not visible to Investors anymore) and consequently Investors cannot see your Company on the Platform anymore;

   • your account is considered in-active, however you can log-in to your account.

7. Deletion of your account – your account can be deleted:

   • you can delete your account from the Platform by contacting us on support@smenewcapital.com:

     • if you have active subscription at the time you request deletion of the account, your subscription will be terminated within 3 calendar days, the remaining time of the subscription will be lost and no refunds will be provided to you by SME New Capital and its affiliates;

     • the processing of the deletion can take up to 3 calendar days;

   • SME New Capital might decide to delete your account in case it is in-active for a period of 3 calendar months.

   • upon deletion of your account, the Content related to your account will be purged from the Platform and consequently Investors will not be able to see your Company on the Platform anymore;

   • you will be informed in case your account is about to be deleted and also once the account has been deleted;

   • once the account is deleted, you will not be able to log-in to the Platform and in case you wish to start again using the Platform, you will need to register to the Platform as a new User (following point 1 above)

How it works (Investors)

The Investors are able to use the Platform in the following way:

1. Registration – the initial step in accessing the Platform.

   • you are required to provide registration information related to your business and yourself

   • SME New Capital briefly checks your information and interacts with you in case of errors or if additional information is necessary

   • your account is activated as soon as SME New Capital’s check is positive

2. Browsing of Investment Proposal – you are able to search through Investment Proposal once your account is active:

   • you can define your search parameters;

   • the search engine will provide you with matching Investment Proposals;

   • you can read Investment Proposals of positive matches;

   • you can select the Investment Proposals that match your interest so that you can review them in the later stage;

3. Contact the Company or Company Owner – you are able to contact the Company or Company Owner:

   • in case the Investment Proposal caught your interest, you can indicate to the Company or Company Owner intention to get in touch;

   • SME New Capital will facilitate initial contact/introduction;

4. Deletion of your account – your account can be deleted:

   • you can delete your account from the Platform by contacting us on support@smenewcapital.com. The processing of the deletion can take up to 3 calendar days;

   • SME New Capital might decide to delete your account in case it fails registration procedure or in case SME New Capital notices that you have not logged-in to the Platform for a period of 3 calendar months;

   • upon deletion of your account, the Content related to your account will be purged from the Platform;

   • you will be informed in case your account is about to be deleted and also once the account has been deleted;

   • once the account is deleted, you will not be able to log-in to the Platform and in case you wish to start again using the Platform, you will need to register to the Platform as a new User (following point 1 above)

Purchases

The Platform resources and services provided to Companies and Companies Owners are chargeable by SME New Capital. The fees for chargeable services are charged during User’s registration process and during subscription extension process.

The Platform resources and services provided to Investors are free of charge.

Features of resources and services of the Platform, including availability and price, are subject to change at any time, without notice and without liabilities to us. We reserve the right, with or without prior notice and without liabilities to us, to limit the availability of or to discontinue any resource or service; to impose conditions on any promotion; to bar any User from making any purchase; and/or to refuse to provide any User with any resource or service.

You authorize SME New Capital to charge you for all resources and/or services purchased by you through the Platform, to the payment method you provide. ‘Charge’ shall indicate either a charge or a debit, as applicable, against your payment method. You represent that you have the legal right to use any payment method that you submit to us. There will be no refunds or credits for prior months of service, partial months of service, upgrade/downgrade refunds, or refunds for months unused with an open account. In order to treat everyone equally, no exceptions will be made. Prices are in EURO unless otherwise stated and are subject to change.

All registration orders placed through the Platform are subject to our acceptance. We reserve the right at any time after receipt of your registration order to accept or decline your registration order for any or no reason and without liability to us, you or anyone else. We may require verification of information prior to the acceptance and/or fulfilment of any registration order. Once the registration order is accepted and account activated, the registration order cannot be declined.

Our Proprietary Rights

We own the information and materials made available through the Platform, excluding User Content. Such information and materials are often protected by copyright, trademark, patent and/or other proprietary rights and laws. Subject to your compliance with this Agreement, and solely for so long as you are permitted by us to access and use the Platform, you may access, view and print of any content on the Platform to which we provide you access hereunder, solely for your personal, internal business and non-commercial purposes, provided that you keep intact all copyright and other proprietary notices. Other than exercising rights you may have to documents provided to you by another User through the Services, or except as expressly authorized in advance by us in writing, you agree not to reproduce, modify, rent, lease, loan, sell, distribute, or create derivative works based on all or any part of the Content or any information or materials made available through the Platform.

Our trade names, trademarks and service marks include, without limitation, SME New Capital, the Platform and any affiliated or associated logos. All trademarks and service marks on the Platform not owned by us are the property of their respective owners. You may not use our trade names, trademarks or service marks in connection with any product or service that is not ours, in any manner that is likely to cause confusion. Nothing contained on the Platform should be construed as granting any license or right to use any trade names, trademarks or service marks without the express prior written consent of the owner.

Eligibility

In order to access and use most of the Platform, you must register for an account. If you are under the age of 18, please do not sign up for an account. Additionally, if you wish to use the Platform, you represent to SME New Capital that you have all necessary authorisations required by law to use the Platform.

Limitations on Use

In order to best serve our Users, and to comply with applicable laws, SME New Capital has a limited number of rules which govern how you may behave while interacting with the Platform and other Users. Please review the rules below carefully, since your violation of them may result in the termination of your access to the Platform in SME New Capital’s sole discretion at any time and without prior notice and without liabilities to us.

Limitations on Service

While it is our goal at SME New Capital to provide you with a useful, stable and available service, we cannot guarantee that there will be no unforeseen difficulties, technical or otherwise, which may, in rare cases, result in service interruptions or loss of data. For this reason, the Platform and all Content and services on it are provided strictly on an 'as is' basis. By accepting these Terms of Service, you agree that neither SME New Capital nor any of its third party service providers and affiliates will be held accountable for any delays in transmission of your data, data loss, service interruptions or retention of User settings. For a brief overview of our policies regarding the safeguarding of your data, please view our Privacy Policy.

SME New Capital reserves the right to change or discontinue, either temporarily or permanently, any part of the Platform or any or all of its services at any time and without prior notice. You agree that neither SME New Capital nor any of its third party service providers and affiliates will be liable for any damages (direct and indirect), including lost business opportunities, should such discontinuance occur.

Data Accuracy

We ask that any registration data you provide to SME New Capital is true, current and complete. In the event any of this information changes, please update it on your personal profile page. For details on how you can access your stored data, please refer to our Privacy Policy.

Passwords

During your registration you will set your account access login and password. You are responsible for maintaining the confidentiality of this information and are responsible for any and all activities and postings that are made using your account.

Please notify SME New Capital immediately if you suspect that an unauthorized person has accessed your account. Should you misplace or forget your password, please click on the ‘forgot password’ link. If you continue to have problems, please contact our technical support staff at support@smenewcapital.com.

Compliance with Applicable Laws

You agree to use the Platform only as provided for in these Terms of Service. You also agree not to use the Platform in any way that is in conflict with the law in your jurisdiction. Further, you may not use the Platform for the transmission of any information that is obscene, libellous, harassing, abusive, threatening, invasive of a User's privacy, or in violation of any other individual's intellectual property rights.

Email

Please use the email features of the Platform responsibly. You may not use the Platform to send unsolicited commercial email ('spam') or unsolicited mass distribution of files. In order to enforce this provision, SME New Capital may establish additional policies regarding the use of email features, including, but not limited to, maximum retention times of messages, maximum number of messages sent per day, or a maximum size of a message.

You agree not to use or launch any automated system, including without limitation, “robots,” “spiders,” “offline readers,” etc., that access the Platform in a manner that sends more request messages to SME New Capital’s servers in a given period of time than a human can reasonably produce in the same period by using a conventional on-line web browser. Notwithstanding the foregoing, SME New Capital grants the operators of public search engines permission to use spiders to copy materials from the site for the sole purpose of creating publicly available searchable indices of the materials, but not caches or archives of such materials. SME New Capital reserves the right to revoke these exceptions either generally or in specific cases. You agree not to collect or harvest any personally identifiable information, including account names, from the Platform, nor to use the communication systems provided by the Platform for any commercial solicitation purposes.

If you receive any email through the Platform that you believe is not in compliance with the above provision, please notify us by forwarding the email, along with an explanatory note, to support@smenewcapital.com.

Privacy

SME New Capital is committed to protecting the privacy of its Users and has developed a detailed Privacy Policy that describes our practices and procedures regarding your data. Please review the Privacy Policy before accepting this Agreement.

By registering with or using the Platform, you consent to the collection and use of your personal information and the transfer of this information within the EU or other countries outside EU for processing and storage by SME New Capital.

A User may elect to make certain confidential, personal or private information viewable through the Platform. You may not disclose information obtained in this manner to any 3^rd parties without first obtaining permission from that User. You agree not to collect or aggregate User information accessible through the Platform for commercial use or redistribution, including the targeted marketing of non-SME New Capital services to individual Users. SME New Capital reserves the right to immediately terminate, without notice, the account of any User found to have violated this rule in the sole and absolute discretion of SME New Capital.

All of the data for each respective User is exclusively entered and maintained by the User. Each User may (but does not have to) opt-in to publishing this information and always has the power to remove it from the public domain by un-publishing it. You accept and agree that:

• all of the data entered on the Platform by you (you being Company or Company Owner) is shared with all Investors,

• all of the data entered on the Platform by you (you being an Investor) is shared only with Companies or Companies Owners selected by you,

• all of the data entered on the Platform by you (all Users) is shared with SME New Capital, its 3^rd party suppliers and affiliates

Prohibited Activities

In general, as a condition to your continued use of the Platform, you agree that you will not use the Platform for any purpose that is unlawful or prohibited by these Terms of Service. In the access or use of the Platform, you shall comply with these Terms of Service and the special warnings or instructions for access or use posted on the Platform. You shall act always in accordance with the law, custom and in good faith. You may not make any change or alteration to the Platform or any Content or services that may appear on the Platform and you may not impair in any way the integrity or operation of the Platform. Without limiting the generality of any other provision of these Terms of Service, if you default negligently or willfully in any of the obligations set forth in these Terms of Service, you shall be liable for all the losses and damages that this may cause to SME New Capital, our affiliates, partners or licensors.

By way of example, and not limitation, you agree not to:

• post, transmit, or otherwise make available through or in connection with your use of the Platform:

• any information or materials that are or may be, or the posting, transmission or use of which is or may be: (a) threatening, harassing, degrading, hateful or intimidating; (b) defamatory or libellous; (c) fraudulent or tortious; (d) obscene, indecent, pornographic or otherwise objectionable; or (e) protected by copyright, trademark, trade secret, right of publicity or privacy or any other proprietary right of any third party;

• any material that would give rise to criminal or civil liability; that encourages conduct that constitutes a criminal offense; or that encourages or provides instructional information about illegal activities or activities such as “hacking,” “cracking,” or “phreaking”;

• any virus, worm, Trojan horse, Easter egg, time bomb, spyware, or other computer code, file, or program that is harmful or invasive or that may or is intended to damage, hijack, disable, interfere with, or disrupt the operation of, or monitor the use of, any hardware, software or equipment;

• any unsolicited or unauthorized advertisements, promotional material, “junk mail,” “spam,” “chain letter,” “pyramid scheme” or investment opportunity, or any other form of solicitation that is not expressly approved in writing by SME New Capital in advance;

• any personally identifiable information of another individual, without the prior consent of such individual;

• any material, non-public information about a company, without the proper authorization to do so.

• Use the Platform for any fraudulent or unlawful purpose.

• Use the Platform if you are a competitor of the Company, or for reasons that are in competition with the Company.

• Use the Platform to defame, abuse, harass, stalk, threaten or otherwise violate the legal rights of others, including without limitation others’ privacy rights or rights of publicity, or to harvest or collect information about Users of the Platform.

• Impersonate any person or entity, including without limitation any representative of SME New Capital or any company; falsely state or otherwise misrepresent your affiliation with any person or entity in connection with the Platform; or express or imply that SME New Capital endorses any statement you make.

• Interfere with or disrupt the operation of the Platform or the servers or networks used to make the Platform available; or violate any requirements, procedures, policies or regulations of such networks.

• Restrict or inhibit any other person from using the Platform (including without limitation by hacking or defacing any portion of the Platform).

• Reproduce, duplicate, copy, sell, resell, link to or otherwise exploit for any commercial purposes, any portion of, use of, or access to, the Platform.

• Modify, adapt, translate, reverse engineer, decompile or disassemble any portion of the Platform.

• Remove any copyright, trademark or other proprietary rights notice from the Platform or materials originating from the Platform.

• Frame or mirror any part of the Platform.

• Create a database by downloading and storing the Content.

• Use any robot, spider, site search/retrieval application or other manual or automatic device to retrieve, index, “scrape,” “data mine” or in any way the Content or reproduce or circumvent the navigational structure or presentation of the Platform without SME New Capital’s express prior written consent.

User Submissions

We do not accept unsolicited suggestions and/or ideas. All inquiries, feedback, suggestions, ideas or other information any User provides to SME New Capital concerning the Platform (collectively, “Submissions”) will be treated as non-proprietary and non-confidential. By transmitting or posting any Submission, the User hereby grants SME New Capital full ownership of the Submission as if SME New Capital had created, developed and posted the Submission for its own purposes. Please note this is different from User Content and SME New Capital Content, which are addressed below. SME New Capital reserves the right to copy, use, reproduce, modify, adapt, translate, publish, license, distribute, IP register, sell or assign the Submission in any way as it sees fit, including but not limited to copying in whole or in part, creating derivative works from, distributing and displaying any Submission in any form, media, or technology, whether now known or hereafter developed, alone or as part of other works, or using the Submission within or in connection with SME New Capital’s products or services. User also acknowledges that User Submissions will not be returned and SME New Capital may use Submissions, and any ideas, concepts or know-how contained therein, without payment of money or any other form of consideration, for any purpose including, without limitation, developing, manufacturing, distributing and marketing products. For clarification, deal documents and emails or other communications between Users are not considered Submissions and SME New Capital claims no right, title or interest in such documents or communications.

If a User makes a Submission, the User represents and warrants that the User owns or otherwise control the rights to the Submission. User further represents and warrants that such Submission does not constitute or contain software viruses, commercial solicitation, chain letters, mass mailings, or any form of “spam.” Users may not use a false email address, impersonate any person or entity, or otherwise mislead SME New Capital as to the origin of any Submission. The User agrees to indemnify SME New Capital for all claims arising from or in connection with any claims to any rights in any Submission or any damages arising from any Submission.

User Content and SME New Capital Content

The Platform permits the submission of content or communications submitted by Users (“User Content”) and the hosting, sharing, and/or publishing of such User Content.

SME New Capital does not and will not claim any ownership over or rights to User Content other than a license to develop a derivative works (i.e. SME New Capital Content) and display the User Content and related SME New Capital Content on the Platform. User understands that whether or not such User Content and related SME New Capital Content is published, SME New Capital does not guarantee any confidentiality with respect to any User Content or related SME New Capital Content.

User shall be solely responsible for own User Content and also for related SME New Capital Content derived from the User Content and the consequences of posting or publishing them. In connection with User Content, User affirms, represents, and/or warrants that: (i) User owns or has the necessary licenses, rights, consents, and permissions to use and authorize SME New Capital to use all patent, trademark, trade secret, copyright or other proprietary rights in and to any and all User Content to enable inclusion and use of the User Content in the related SME New Capital Content and in the manner contemplated by the Platform and these Terms of Service; and (ii) User has the written consent, release, and/or permission of each and every identifiable individual person in the User Content to use the name or likeness of each and every such identifiable individual person to enable inclusion and use of the User Content in the related SME New Capital Content and in the manner contemplated by the Platform and these Terms of Service.

By submitting the User Content to the Platform, User hereby grants SME New Capital a worldwide, non-exclusive, royalty-free, sublicenseable and transferable license to use, reproduce, distribute, prepare derivative works of, display, and process the User Content in connection with the Platform and SME New Capital’s (and its successor’s) business, including without limitation for promoting and redistributing part or all of the Content (and derivative works thereof) in any media formats and through any media channels. In the event it does so, SME New Capital will seek to maintain the confidentiality of User Content and related New SME Capital Content, but once again cannot guarantee any such confidentiality. User also grants each User of the Platform a non-exclusive license to access the User Content of that User and the SME New Capital Content related to that User Content through the Platform, and to use, reproduce, distribute, prepare derivative works of, display and perform such User Content and related SME New Capital Content as permitted through the functionality of the Platform and under these Terms of Service. The foregoing license granted by User terminates once User or SME New Capital removes or deletes any User Content or related SME New Capital Content from the Platform.

User agrees that User will not: (i) submit material that is copyrighted, protected by trade secret or otherwise subject to third party proprietary rights, including privacy and publicity rights, unless User is the owner of such rights or have permission from their rightful owner to post the material and to grant SME New Capital all of the license rights granted herein; (ii) publish falsehoods or misrepresentations that could damage SME New Capital or any third party; (iii) submit material that is unlawful, obscene, defamatory, libelous, threatening, pornographic, harassing, hateful, racially or ethnically offensive, or encourages conduct that would be considered a criminal offense, give rise to civil liability, violate any law, or is otherwise inappropriate; (iv) post advertisements or solicitations of business; (v) impersonate another person.

SME New Capital does not endorse any User Content and related SME New Capital Content or any opinion, recommendation, or advice expressed therein, and expressly disclaims any and all liability in connection with User Content and related SME New Capital Content. SME New Capital does not knowingly permit infringement of intellectual property rights on its Platform, and will remove all User Content and related SME New Capital Content if properly notified that such User Content and related SME New Capital Content infringe on another’s intellectual property rights. SME New Capital reserves the right to remove User Content and related SME New Capital Content without prior notice. SME New Capital will also terminate User’s access to its Platform, if a User is determined to be a repeat infringer. SME New Capital also reserves the right to decide whether User Content and related SME New Capital Content is appropriate and complies with these Terms of Service for violations other than copyright infringement and violations of intellectual property law, such as, but not limited to, pornography, obscene or defamatory material, or excessive length. SME New Capital may remove such User Content and related SME New Capital Content and/or terminate a User’s access for uploading such material in violation of these Terms of Service at any time, without prior notice and at its sole discretion.

If you are a copyright owner or an agent thereof and believe that any User Content or related SME New Capital Content or other Content infringes upon your copyrights, you may submit a notification pursuant to the Information Society Directive (‘InfoSoc Directive’) by providing our legal team (by e-mail to legal@smenewcapital.com) with the following information in writing:

• a physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed;

• identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works at a single online site are covered by a single notification, a representative list of such works at that site;

• identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled and information reasonably sufficient to permit the service provider to locate the material;

• information reasonably sufficient to permit the service provider to contact you, such as an address, telephone number, and, if available, an electronic mail;

• a statement that you have a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law; and

• a statement that the information in the notification is accurate, and under penalty of perjury, that you are authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

Notices and counter-notices must meet the then-current statutory requirements imposed by the InfoSoc Directive. SME New Capital suggests that you consult your legal advisor before filing a notice. Please be aware that there are penalties for false claims under the InfoSoc Directive. Any other feedback, comments, requests for technical support, and other communications should be directed to our support team through support@smenewcapital.com. You acknowledge that if you fail to comply with all of the requirements of this Section, your InfoSoc Directive notice may not be valid.

You understand that when using the Platform, you may be exposed to User Content and related SME New Capital Content from a variety of sources, and that SME New Capital is not responsible for the accuracy, usefulness, safety, or intellectual property rights of or relating to such User Content and related SME New Capital Content. You further understand and acknowledge that you may be exposed to User Content and SME New Capital Content that are inaccurate, offensive, indecent, or objectionable, and you agree to waive, and hereby do waive, any legal or equitable rights or remedies you have or may have against SME New Capital with respect thereto, and agree to indemnify and hold SME New Capital, its owners/operators, affiliates, and/or licensors, harmless to the fullest extent allowed by law regarding all matters related to your use of the Platform.

Intellectual Property

All information and Content available on the Platform and its ‘look and feel’, except all User Content (as defined herein), including but not limited to trademarks, logos, service marks, copyrighted works, text, graphics, logos, button icons, images, audio/video clips, data compilations and software, and the compilation and organization thereof is the property of SME New Capital, its affiliates, partners or licensors, or is used with consent of the owner, and is protected by European Union and international laws, including laws governing copyrights and trademarks. The reproduction and use of any of these by you is prohibited unless specific permission is provided on the Platform or otherwise. Any unauthorized use may violate copyright laws, trademark laws, privacy and publicity laws, and/or communications regulations and statutes of the European Union and foreign laws and international conventions.

The trademarks, service marks, logos, and other indicia, including of SME New Capital (collectively the ‘Trademarks’) which appear on the Platform are registered and/or unregistered trademarks of SME New Capital and others. Nothing contained on the Platform should be construed as granting, by implication or otherwise, any right, license or title to any of the Trademarks without the advance written permission of SME New Capital or such third party as may be appropriate. All rights are expressly reserved and retained by SME New Capital. Your misuse of any of the Trademarks displayed on the Platform, or any other Content on the Platform, except as provided in these Terms of Service, is strictly prohibited. You are also advised that SME New Capital considers its intellectual property to be among its most valuable assets, and will aggressively enforce its intellectual property rights to the fullest extent of the law.

Both the Platform and the Content of the Platform are provided “AS IS” for Users information and personal use only and may not be used, copied, reproduced, distributed, transmitted, broadcast, displayed, sold, licensed, or otherwise exploited for any other purposes whatsoever without the prior written consent of the respective owners. SME New Capital reserves all rights not expressly granted in and to the Platform and the Content. User agrees to not engage in the use, copying, or distribution of any of the Content other than expressly permitted herein, including any use, copying, or distribution of User submissions of third parties obtained through the Platform for any commercial purposes. If User downloads or prints Content for personal use, User must retain all copyright and other proprietary notices contained therein. User agrees not to circumvent, disable or otherwise interfere with security related features of the Platform or features that prevent or restrict use or copying of any Content or enforce limitations on use of the Platform or the Content thereon. SME New Capital does not make any representations or warranties, whether express or implied, regarding or relating to the Platform or any associated hardware or software, including the Content or operations of either.

Disclaimers

NONE OF SME NEW CAPITAL, ITS AFFILIATES, THEIR RESPECTIVE MEMBERS, OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, SUPPLIERS, OR LICENSORS (COLLECTIVELY, THE ‘SME NEW CAPITAL PARTIES’ ) MAKES ANY WARRANTIES OR REPRESENTATIONS ABOUT THE SME NEW CAPITAL PLATFORM OR ITS CONTENTS, INCLUDING BUT NOT LIMITED TO THEIR ACCURACY, RELIABILITY, COMPLETENESS, OR TIMELINESS, OR RELIABILITY. NONE OF THE SME NEW CAPITAL PARTIES SHALL BE SUBJECT TO LIABILITY FOR TRUTH, ACCURACY, OR COMPLETENESS OF ANY INFORMATION MADE AVAILABLE ON OR THROUGH THE SME NEW CAPITAL PLATFORM OR FOR ERRORS, MISTAKES OR OMISSIONS THEREIN OR FOR ANY DELAYS OR INTERRUPTIONS OF THE DATA OR INFORMATION STREAM FROM WHATEVER CAUSE. YOU AGREE THAT YOU USE THE SME NEW CAPITAL PLATFORM SOLELY AT YOUR OWN RISK.

SME NEW CAPITAL PROVIDES THIS SME NEW CAPITAL PLATFORM AS A RESOURCE FOR USERS INVOLVED WITH INVESTING IN COMPANIES BUT SME NEW CAPITAL DOES NOT GIVE BUSINESS ADVICE, INVESTMENT ADVICE, TAX ADVICE OR LEGAL ADVICE TO ANYONE USING THE SME NEW CAPITAL PLATFORM. SME NEW CAPITAL DOES NOT CLAIM TO BE AND IS NOT A BROKER, DEALER OR INVESTMENT ADVISOR AND NOTHING HEREIN SHALL CONSTITUTE A SALE OR OFFER TO BUY OR SELL OR RECOMMEND ANY SECURITIES. SME NEW CAPITAL DOES NOT MAKE INVESTMENTS. EACH USER OF THE SME NEW CAPITAL PLATFORM MAKE HIS OR HER OWN INVESTMENT DECISIONS BASED UPON HIS OR HER PERSONAL DUE DILIGENCE INVESTIGATION AND OTHER PERSONAL INVESTMENT CRITERIA. SME NEW CAPITAL IS NOT RESPONSIBLE FOR AND SHALL HAVE NO LIABILITY WITH RESPECT TO THE ACTIONS OR OMISSIONS OF ANYONE USING THE SME NEW CAPITAL PLATFORM. AS A CONDITION TO YOUR USE OF THE SME NEW CAPITAL PLATFORM, YOU HEREBY WAIVE AND RELEASE ANY AND ALL CLAIMS, CAUSES OF ACTION OR OTHER RIGHTS THAT YOU MIGHT HAVE AGAINST ANY OF THE SME NEW CAPITAL PARTIES ARISING OUT OF OR RELATING TO THE SUBMISSION AND REVIEW OF ANY MATERIALS MADE AVAILABLE ON OR THROUGH THE SME NEW CAPITAL PLATFORM.

SME NEW CAPITAL DOES NOT AGREE TO ANY OBLIGATIONS OF CONFIDENTIALITY, NONDISCLOSURE OR NONUSE, EXCEPT AS EXPLICITLY PROVIDED FOR IN OUR PRIVACY POLICY.

IN NO EVENT SHALL ANY SME NEW CAPITAL PARTY BE LIABLE FOR ANY DAMAGES WHATSOEVER (INCLUDING, WITHOUT LIMITATION, INCIDENTAL AND CONSEQUENTIAL DAMAGES, LOST PROFITS, OR DAMAGES RESULTING FROM LOST DATA OR BUSINESS INTERRUPTION) RESULTING FROM EITHER A PERSON OR ENTITY'S USE OR INABILITY TO USE THE SME NEW CAPITAL PLATFORM, OR THE SUBMISSION OF ANY MATERIALS VIA THE SME NEW CAPITAL PLATFORM, WHETHER BASED ON WARRANTY, CONTRACT, TORT (INCLUDING NEGLIGENCE), OR ANY OTHER LEGAL THEORY, EVEN IF A SME NEW CAPITAL PARTY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

Indemnification

At SME New Capital's request, User agrees to defend, indemnify and hold harmless SME New Capital, its shareholders, partners, affiliates, directors, officers, subsidiaries, employees, agents, licensees, distributors and content providers from all damages, liabilities, claims and expenses, including without limitation attorneys' fees and costs, arising from or related, directly or indirectly, to any misuse of the Platform or breach of this Agreement by User.

Termination

SME New Capital reserves the right to suspend or terminate these Terms of Service and/or any User’s access to the Platform at any time and without notice in its sole discretion.

Entire Agreement/Severability

These Terms of Service, together with the Privacy Notice and any other legal notices published by SME New Capital on the Platform, shall constitute the entire agreement between you and SME New Capital concerning the Platform. If any provision of these Terms of Service is deemed invalid by a court of competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of these Terms of Service, which shall remain in full force and effect. No waiver of any term of this these Terms of Service shall be deemed a further or continuing waiver of such term or any other term, and SME New Capital’s failure to assert any right or provision under these Terms of Service shall not constitute a waiver of such right or provision.

Arbitration

You agree that: (i) the Platform shall be deemed solely based in London, United Kingdom; and (ii) the Platform shall be deemed a passive website that does not give rise to personal jurisdiction over SME New Capital, either specific or general, in jurisdictions other than London, UK. These Terms of Service shall be governed by and constructed in accordance with English Law. All disputes arising out of or relating to this Agreement shall be finally resolved in accordance with the Arbitration Rules of the London Court of International Arbitration. Both parties shall bear equally the cost of arbitration (exclusive of legal fees and expenses). All decisions of the arbitrator(s) shall be final and binding on both parties and enforceable in any court of competent jurisdiction.

Modifications to the Terms of Service

SME New Capital may change these Terms of Service at any time and in its sole discretion. The modified Terms of Service will be effective immediately upon posting and you agree to the new posted Terms of Service by continuing your use the Platform. SME New Capital will provide at least 10-days' notice before any material changes take effect. If you do not agree with the modified Terms of Service, your only remedy is to discontinue using the Platform. Notwithstanding the foregoing, any changes to this Agreement shall not apply to any dispute between you and us arising prior to the date of such posting or other notification. We may, at any time, temporarily or permanently modify or discontinue all or part of the Platform, with or without notice and/or offer opportunities to some or all Users of the Platform. You agree that the Platform shall not be liable to you or to any third party for any modification, suspension or discontinuance of the Platform, in whole or in part, or of any Service, content, feature or product offered through the Platform. You agree that we may, at any time, charge fees in connection with the use of all or part of the Platform and/or for certain features of the Services and that you will be responsible for all such charges (including any applicable tax). You will be notified in advance of any such charges and you will have an option to not pay such charges by cancelling your registration with the Platform prior to the charges becoming due.

USER ACKNOWLEDGES THAT USER HAS READ THIS AGREEMENT, UNDERSTANDS IT, AND AGREES TO BE BOUND BY ITS TERMS AND CONDITIONS. USER FURTHER AGREES THAT IT IS THE COMPLETE AND EXCLUSIVE STATEMENT OF THE AGREEMENT BETWEEN USER AND SME NEW CAPITAL WHICH SUPERSEDES ANY PROPOSAL OR PRIOR AGREEMENT, WRITTEN OR ORAL, AND ANY OTHER COMMUNICATION BETWEEN USER AND SME NEW CAPITAL RELATING TO THE SUBJECT MATTER OF THIS TERMS OF SERVICE.

Should you have any questions concerning these Terms of Service, please e-mail us on support@smenewcapital.com. 

PRIVACY POLICY

Scope of this Privacy Policy 

SME New Capital respects your privacy and is committed to protecting it. This privacy policy applies to SME New Capital platform (‘Platform’) owned and operated by SME New Capital (business line of MIF advisory Ltd., a limited liability company, 20-22 Wenlock Road, N1 7GU London, UK) and/or its owners and/or its affiliated entities (collectively, ‘SME New Capital’ or ‘We’)).  This Privacy Policy describes SME New Capital’ policies and procedures on the collection, use, retention, protection and disclosure of your personal data when you use the Platform. It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal data. This Privacy Policy does not apply to information we collect from other sources. Also information which you provide to us may be publicly available and disclosed. Capitalized terms that are not defined in this Privacy Policy have the meaning given them in SME New Capital’s Terms of Service. 

By registering to and using the Platform, you are accepting the terms of this Privacy Policy and our Terms of Service, and you are consenting to our collection, use, disclosure, retention and protection of your information as described in this Privacy Policy

The Platform 

The Platform offers a set of resources and services to Companies, Companies Owners and Investors.

EU compliance

SME New Capital is committed to be compliant with the data protection rules in the EU including the General Data Protection Regulation (EU) 2016/679 (GDPR) and their respective successors, applicable to the protection of natural persons with regard to the processing of personal data and on the free movement of such data.. The full regulation, in all EU languages is provided in the following link: EU Regulation.

In compliance with the EU regulation, SME New Capital commits to resolve your complaints about our collection or use of your personal information. SME New Capital has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved complaints.  If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint.  The services of EU DPAs are provided at no cost to you.

This Privacy Policy applies only to your relationship with SME New Capital. It does not apply to the interactions that you have with any other individual, entity, Investor or other group through the Platform or outside the Platform. For example, an Investor has the ability to disclose or share internally and externally any information that you submit to the Platform and to us. SME New Capital has no control over this disclosure or sharing, and is not responsible for it. The protection of your personal data from the disclosure by an Investor is governed solely by any agreements that you may enter into with that Investor and is beyond the scope of this Privacy Policy. 

This Privacy Policy describes the types of information we may collect from you or that you may provide when you use the Platform, and our practices for collecting, using, maintaining, protecting and disclosing that information.

This Privacy Policy applies to information we collect:

•        on the Platform;

•        in e-mail, text and other electronic messages between you and SME New Capital, on the Platform or otherwise; and

•        when you interact with us (including verbal communication through the phone or any other communication channels).

It does not apply to information collected by:

•        us offline or through any other means, including on any other website operated by any third party (including our affiliates); or  

•        any third party (including our affiliates), including through any application or content (including advertising) that may link to or be accessible from or on the Platform.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Platform. By accessing or using the Platform, you explicitly agree to this Privacy Policy. 

What is “personal data”? 

"Personal data" is any data that (1) is recorded in any form, (2) is about or pertains to a specific individual and (3) can be linked to that individual. For example, and without limitation, your first and last names, address, email address, telephone number, and other contact information, and the deals in which you have participated are "personal data."

What kind of personal data is collected? 

We collect personal data at different stages of your use of the Platform.

•       When you visit the Platform - If you visit the Platform or use an interface which interacts with the Platform, whether or not you sign-in as a registered user, we collect your IP address, the location of your Internet Service Provider, the type and version of Internet browser that you are using, and the website from which you came. We also collect information regarding your site usage, such as the time spent on a page and the number of pages you viewed. 

•      When you set up an account - When you set up your account, you will be required to provide certain personal data including your name, your phone, your address, email address and your job title. 

•        When you interact with the Platform and with us -We also collect personal data that you provide when you interact with the Platform and with us such as, for example, by sending a message or uploading documents, or when exchanging correspondence with us such as through support emails. 

•        When you use your account - We collect information that you provide or create when you use your account: 

‐          If you are an Investor, you may record in your profile your interest and investment focus. 

‐          If you are a Company or Company Owner, and you represent a Company that is seeking Investors or you represent yourself to sell shares in a Company, you may record information about yourself, your Company, and your Company’s management team. You may also include a video recordings or pictures. 

If you provide any information about or personal data of a third party (such as a person's name, persons biography or photograph), you are representing to SME New Capital that you have all necessary authority and/or have obtained all necessary consents from such individual to enable SME New Capital to collect, use and disclose his or her personal data as set forth in this Privacy Policy. If we receive a written complaint or direction from the person, we will take down his or her information and notify you that we have done so. 

How is personal data collected? 

We collect personal data directly from you when you provide it through your use of the Platform or though interaction with us (also verbally). We also use cookies that are sent to your computer, or action tags that are placed on the Platform. 

For what purpose will my personal data be used? 

SME New Capital uses your personal data to maintain your account and to provide you the resources and services offered through the Platform. We also use your personal data to meet our legal obligations and to respond to requests that you make of us, and to contact you and to provide you with information that we believe may be of interest to you.

We may also use your name and contact information to make queries to social networking and other sites, such as LinkedIn, for a variety of purposes, including, but not limited to, verifying your identity.

Your personal data may also be shared with affiliates and owners of SME New Capital or to third parties as described below.

Can third parties see my personal data? 

•        If you are an Investor - the default setting of the Platform is that your information is not disclosed to other Users of the Platform. However, on your request or with your approval, we might share your personal information with certain other Users of the Platform. 

•        If you are a Company or Company Owner - you have uploaded information to the Platform (or provided us with the information directly) about you and your Company’s management team. This information is disclosed to Investors on the Platform and outside the Platform. 

With whom may SME New Capital share personal data? 

Under certain business or legal conditions, SME New Capital may have to disclose your personal data to others as follows:

•        Within the SME New Capital Family– SME New Capital may now or in the future have a parent, subsidiary or related company or companies within the SME New Capital family of companies. SME New Capital has the right to share all personal data with all such affiliated companies. 

•        Service Providers – SME New Capital may engage other companies and individuals to perform necessary business functions on behalf of SME New Capital (e.g. customer services, IT support, IT platform provider, legal services, digital and social media services, data analytics services, payment processing services, accounting services or email provider). If it is necessary to perform these functions, these companies or individuals may have access to personal data of our users. These service providers have agreed not to use the personal data for any other purpose other than providing the required services. 

•        Legally Required Disclosure - under certain circumstances, disclosure of your personal data may be required by law. SME New Capital may disclose your personal data (1) if, in its own best judgment, it is required by law to do so in order to comply with a facially valid judicial or governmental subpoena, warrant, bankruptcy proceedings, or other order, or (2) to a government institution that has asserted its lawful authority to obtain the information, or (3) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud. 

•        Change of Ownership - if ownership of SME New Capital changes as a result of a merger, acquisition, or transfer to another company, your personal data may be transferred to the successor entity. If such transfer takes place, you will be notified of any material changes to the Privacy Policy and provided with the ability to opt-out of the transfer of your personal data to the successor entity. 

Sharing with 3^rd Parties 

3^rd Parties are companies unaffiliated with the Platform and excluding Investors (registered and not registered with the Platform).  We may share your personal data with 3^rd Parties, if given permission by you, so that they can market their products or services to you. If you do not want us to share your personal data with 3^rd parties after giving us permission to do so, contact us at support@smenewcapital.com.  

Can I access or change my personal data? 

If your personal data changes, you may correct, update, or amend it by making the change directly on your account or by emailing us on support@smenewcapital.com. In case you request us to change the data by sending us an e-mail, we will respond to your request within 3 calendar days.

Data Retention

We will retain your information for as long as your account is not deleted to provide you services.  We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

For auditing and security purposes, SME New Capital keeps a log of all Users' activities, which is retained in its archives as necessary for SME New Capital to fulfil its obligations. Users may have access to the personal data that pertain to them. However, because the administrative and technical burden associated with the retrieval of these archived data is substantial, SME New Capital charges a fee for this effort in a manner that is consistent with its own costs. In addition, each User's right of access may be limited to the extent that providing access might infringe on a third party's privacy rights. Requests for access to this archived information are handled on a case-by-case basis, after SME New Capital has verified the identity of the requestor and the need for the information. Inquiries should be made through email to support@smenewcapital.com.

Can I have my personal data deleted? 

You can delete any personal data that is recorded in the profile. However, if you decide to delete majority of the personal data, we might decide to deactivate your account.

Social Media Widgets

Our Web site might include Social Media Features, such as the Facebook and Twitter button. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Testimonials

We may display testimonials of satisfied customers on our site in addition to other endorsements.  With your consent we may post your testimonial along with your name.  If you wish to post, update or delete your testimonial, you can contact us at support@smenewcapital.com.  

What is Aggregated Data, and how is it used? 

Data aggregation is a process in which information is gathered and expressed in a summary form for purposes such as statistical analysis, in order to obtain information about a particular group based on specific variables. Data used for aggregation purposes are collected in a form that removes all identifiers, and may be combined with other data for which all identifiers have also been removed. SME New Capital uses aggregated data to generate accurate metrics about the status of private equity industry.

Aggregated data are packaged and licensed to third parties such as governments, economic development agencies and financial institutions. Examples of aggregated data may include:

•        data about the private equity space, such as number of deals in a month-to-month or quarter-to-quarter basis at various generic stages of the funding process (e.g. new deals, in-progress deals, inactive deals, and invested deals).

•        data about industries and geographies related to companies seeking investors and those successfully obtaining investments.

What is Website Data, and how is it used? 

Website data is aggregated data about the overall traffic to, and usage of the Platform. Examples include the number of visitors to the Platform and the number of registered users of the Platform. SME New Capital may extract and use website data for internal purposes, in order to analyse the performance of the Platform and applications. For example, we may use these data for traffic analysis and business decision making, in order to determine how we can improve the Platform and/or its functionalities.

The statistics generated in this manner contain no personal data and cannot be used to gather any information about individual visitors to the Platform.

Cookies and other Tracking Technologies

We and our partners use cookies or similar technologies to analyse trends, administer the website, track Users’ movements around the Platform, and to gather demographic information about our User base as a whole:

•        Cookies – SME New Capital uses 'cookies.' A cookie is a small amount of data sent to a User's web browser from a web server, which is then stored on the User's hard drive. Cookies are used to make site navigation easier, and can help recognize a returning visitor. SME New Capital's cookies do not generate any personal data, do not read personal data from your computer, and are not tied to any personal data. Most browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies, or to prompt you before accepting cookies from the sites that you visit. If you decide not to accept our cookies, some or all features of the site may not be available because navigation on the site is facilitated by cookies. You can delete cookies from your computer at any time.

•        Action Tags – SME New Capital uses action tags. An action tag is a small piece of code that is placed on a webpage or in an email in order to track the pages viewed or the messages opened, the date and time when someone visited our website, the website from which the visitor came, the type of browser used, and the domain name and address of the user's Internet Service Provider. Action tags allow us to better understand how users and visitors use our site or browse through our pages, so that we can improve access to and navigation through the site, add or modify pages, according to our User's patterns. Action tags cannot be removed or deleted by our Users, because they are part of the programming of a webpage.

•        Log Files – Log file information is automatically reported by your browser each time you access a web page. When you use the Platform, our servers automatically record certain information that your web browser sends out whenever you visit any website. These server logs may include information such as your web request, IP address, browser type, referring/exit pages, operating system, date/time stamp, the files viewed on our site (e.g., HTML pages, graphics, etc.) and URLs, number of clicks, domain names, landing pages, pages viewed, and other similar information.

•        Web Beacons – When you use the Platform, we may employ web beacons, which are used to track the online usage patterns of Users anonymously. No personal data from your account is collected using these beacons. In addition, we may also use web beacons in HTML-based emails sent to Users to track which emails are opened by recipients.

•        Behavioral Targeting – We might partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests.

•        Do Not Track Signals – SME New Capital does not track or use Do Not Track signals.  

The use of cookies or similar technologies by our partners is not covered by our Privacy Policy.  We do not have access or control over these cookies or similar technologies.

What security measures are in place to protect my personal data? 

SME New Capital uses physical, technical, and administrative procedures in order to safeguard and protect personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, while we do our best to implement reasonable security measures, we do not guarantee that our safeguards will always work.

SME New Capital uses industry-standard technological means to protect your personal data while in transit through the Internet. We use encryption and a comprehensive authentication protocol to provide reasonable security. However, please remember that no security system on the Internet is perfect.  If you have any questions about security on our Web site, you can contact us at support@smenewcapital.com.

What about Uploaded Documents? 

Documents that are uploaded to the Platform for sharing are stored at a third party data-storage service. All uploads and downloads are transmitted through the web between Users and the data storage service using the same encryption techniques as those that are used with personal data. However, uploaded documents are neither stored redundantly, nor backed up. Therefore, we recommend that Users keep back-up copies of their documents if they upload them to the Platform.

When will SME New Capital contact me? 

SME New Capital will communicate with you in response to your requests for service or customer support. We will contact you by phone and/or by email.

SME New Capital will send you service-related emails if it becomes necessary to do so. SME New Capital may send you an email in order to notify you of updates to our Privacy Policy, Terms of Service, or other agreement that you have with SME New Capital.  SME New Capital may also send you an email in order to notify you of new products, or services or features. If you do not want to receive any emails from SME New Capital, this might lead to deactivation of your account, since we need to stay in touch with you for a proper functioning of the Platform. If you have any questions regarding contacting you, please send us an e-mail on support@smenewcapital.com.

Links to other websites 

SME New Capital may provide links to other websites. We are not responsible for the privacy practices or content of these sites. In order to safeguard your privacy, please review the privacy policies of any sites that you may visit before providing any personal data to these third party sites.

Limitation of Liability 

SME New Capital exercises reasonable efforts to safeguard the security and confidentiality of your personal data; however, transmissions protected by industry standard technology and administered by humans cannot be guaranteed to be secure. SME New Capital will not be liable for any disclosure of personal data that occurs through no fault of SME New Capital including, but not limited to, errors in transmission, access to your account by anyone using your user ID and password, your failure to comply with your security obligations, and the unauthorized acts of SME New Capital's employees.

Choice 

If at any time SME New Capital wishes to disclose, or use your personal data in a way, or for a purpose other than as described in this Privacy Policy or Terms of Service, SME New Capital will give you the opportunity to choose (opt out) whether your personal data (1) may be disclosed to a third party and (2) may be used for a purpose other than the purposes that are set forth in this Privacy Policy. 

Changes to the Privacy Policy 

From time to time, SME New Capital may update this Privacy Policy in order to reflect changes in its practices. Whenever such changes are made, SME New Capital will post an updated Privacy Policy on its website and may email registered Users. We encourage you to periodically review this page for the latest information on our privacy practices.

All changes will apply to the personal data that are already collected, and to personal data that are collected after the effective date of the revised Privacy Policy, and will become effective when posted.

You will have the right to terminate your account at any time.

Contacting SME New Capital

If you have any questions about this Privacy Policy, or believe that its terms have not been complied with, please email SME New Capital at:  support@smenewcapital.com.