Privacy Policy

We collect your personal data when you interact with us—for example, as a prospective investor, applicant, or customer.
This includes, in particular, situations where you express interest in our services, register for our online offerings, contact us by email or telephone, or use our services as part of an existing business relationship.

We may process the following categories of personal data:

Personal Identification Data
For example, your first and last name, address, date and place of birth, nationality, identity card or passport number, email address, and telephone number.

Contract and Transaction Data
For example, your bank account or securities account number, IBAN, and payment transaction details.

Financial Information
For example, information about your existing financial investments or products, subscription amounts, payment delays, and income-related information.

Sociodemographic Information
For example, your marital status and family circumstances.

Information About Your Interests and Preferences
For example, information you provide to us during communications or interactions through our website.

Data Collection via Web Forms

If you request information through one of our website forms or register for an event using our online forms, you consent to your data being shared with the relevant business unit within the Alphawave Group.
Your data will be stored and used accordingly.
By submitting your request or registration, you agree that the Alphawave Group may send you information materials and updates regarding investment opportunities, company news, and upcoming events.

Your personal data will not be shared with third parties for marketing purposes beyond the scope described above.

You may withdraw your consent at any time with effect for the future.

Newsletter-Abonnement

By subscribing to our newsletter, you consent to the relevant company within the Alphawave Group using your data to send you the requested information and related communications.

Our newsletter provides insights into our company, developments in the financial markets, economic and political events, and the latest announcements regarding Alphawave events.

You may withdraw your consent at any time, for example by clicking the “Unsubscribe” link included in any of our newsletters.

Special categories of personal data—also referred to as “sensitive data”—such as information about your religious beliefs, are collected only where strictly necessary and permitted under applicable data protection laws.
Such data may, in exceptional cases, be required to comply with mandatory legal reporting obligations or tax deductions (e.g. church tax obligations in Germany).

Use of Your Data to Provide Our Services (Performance of a Contract)

We process your personal data to enable you to use our services and to fulfil our contractual obligations.
This also includes the processing of pre-contractual information, such as your address, telephone number, or email address, in order to communicate with you.

The purpose of the processing depends primarily on the specific service provided or the nature of the business relationship.
For example, we may process transaction-related data to execute financial transactions or settle securities transactions and, where necessary, transfer such data to the relevant paying agents or partner banks.

Legal Basis: Article 6(1)(b) GDPR – Processing necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract.

Improving Our Services and Offering Suitable Products (Legitimate Interests)

We may also process your personal data to better understand your needs, improve our services, and offer products or solutions that are relevant to you.

Strengthening Customer Relationships

From time to time, we may invite you to participate in surveys (e.g. to measure customer satisfaction or gather feedback on a service or product).
The results of these surveys help us improve our products, services, and the overall customer experience.

Direct Marketing

We may send you personalized letters or emails or, where appropriate, contact you by telephone.
You may also receive personalized offers through our website.

You have the right to object at any time to the processing of your personal data for the purposes of personalized direct marketing.

Legal Basis: Article 6(1)(f) GDPR – Processing based on our legitimate interests in maintaining and improving customer relationships and business operations.

Processing Based on Your Consent

Where you have given your consent for specific purposes, we process your personal data on the basis of that consent.
You may withdraw your consent at any time with effect for the future.

This also applies to any consent you granted prior to the GDPR coming into force on 25 May 2018.
Withdrawal of your consent does not affect the lawfulness of any processing carried out before the withdrawal.

Legal Basis: Article 6(1)(a) GDPR – Processing based on your consent.

Within the Alphawave Group

Within the Alphawave Group, only those departments and companies that require your personal data to fulfil our contractual and legal obligations or to protect our legitimate interests will receive it.

This may include, for example, internal teams responsible for client management, compliance, risk control, operations, and IT support.

Outside the Alphawave Group

We only disclose personal data to third parties where this is required by law or contract, where you have given your consent, or where we are legally permitted to obtain or exchange information, for example for compliance or due diligence purposes.

Legal Obligations

A legal obligation to disclose personal data may arise, in particular, with respect to the following recipients:

Public authorities and government bodies, such as tax authorities, financial regulatory authorities, or social security institutions.

Law enforcement and judicial authorities, such as the police, public prosecutors, or courts.

Legal professionals, such as lawyers or notaries, for example in insolvency or contractual proceedings.

Auditors and other entities required by law or by regulatory authorities.

Business Partners and Financial Service Providers

To fulfil our contractual obligations, we work with other companies and financial institutions, including:

Paying agents – to execute transactions such as the purchase or sale of securities.

Clearing and settlement institutions – such as Clearstream, the European Banking Association (EBA), or local clearing systems – for the processing of domestic and international transactions and payments.

Service Providers Supporting Our Business Operations

We also engage carefully selected external service providers (data processors) to support us in carrying out our business activities, for example in IT operations, customer support, marketing, and data hosting.

These service providers are contractually bound by confidentiality obligations and may process personal data only on our instructions and in accordance with Article 28 GDPR.

Data Transfers Within the Alphawave Group

To provide you with the best possible service and ensure efficient internal processes, we may occasionally share data within the Alphawave Group.
Whenever such data transfers take place, we ensure that they fully comply with applicable data protection laws and that your personal data remains appropriately protected.

Data Transfers to Countries Outside the EEA

If your personal data is transferred to a country outside the European Economic Area (EEA) for which no adequacy decision has been adopted, we ensure appropriate safeguards in accordance with Article 46 GDPR, such as the use of Standard Contractual Clauses or equivalent legal mechanisms.

Important Notice

We ensure that third parties receive only the minimum amount of personal data necessary for the specific purpose. Under no circumstances do we sell or trade your personal data to third parties.

Protecting your personal data and respecting your rights are of the utmost importance to us.
We strive to respond to your requests as quickly as possible. However, depending on the complexity of your request and the applicable legal requirements, it may take up to one month to provide you with a complete response.
If we require additional time, we will inform you in advance of the reason for the delay and the expected timeframe.

In certain circumstances, we may be unable or not permitted to provide specific information, for example where doing so would infringe the rights of third parties or conflict with legal obligations. In such cases, we will inform you of the reason without undue delay, where permitted by law.
You have the right to lodge a complaint with a competent supervisory authority at any time.

The following rights are granted under Articles 15 to 21 of the EU General Data Protection Regulation (GDPR):

Right of Access, Information, and Rectification

You have the right to obtain confirmation as to whether we process personal data relating to you and, if so, to receive information about that data.
If your personal data is inaccurate or outdated, you have the right to request that it be corrected.
If your personal data is incomplete, you have the right to request that it be completed.

If we have disclosed your personal data to third parties, we will notify them of any correction or completion where required by law.

Legal Basis: Articles 15 and 16 GDPR.

Right to Erasure (“Right to Be Forgotten”)

You may request the immediate deletion of your personal data if one of the following grounds applies:

• The data is no longer necessary for the purposes for which it was collected.
• You withdraw your consent and there is no other legal basis for the processing.
• You object to the processing and there are no overriding legitimate grounds for continuing the processing.
• Your data has been processed unlawfully.
• Deletion is necessary to comply with a legal obligation.

Please note that your right to erasure may be limited where continued processing is necessary for legitimate legal reasons (e.g. to comply with statutory record retention obligations).

Legal Basis: Article 17 GDPR.

Right to Restriction of Processing

You have the right to request that we restrict the processing of your personal data in the following circumstances:

• You contest the accuracy of your personal data, for as long as we need to verify its accuracy.
• You contest the accuracy of your personal data, for as long as we need to verify its accuracy.
• The processing is unlawful, and you prefer restriction of processing instead of deletion.
• You have objected to the processing pending the verification of whether our legitimate interests override yours.

During a restriction period, your data will only be processed with your consent, or for legal claims or important public interests.

Legal Basis: Article 18 GDPR.

Right to Object

You have the right to object at any time to the processing of your personal data based on our legitimate interests, including for direct marketing purposes.
Once you object, your personal data will no longer be processed for those purposes.

Please send your objection by post to:
Alphawave GmbH
Abteilung Datenschutz
Marienstraße 14
40212 Düsseldorf, Deutschland

or by email to:
info@alphawave.fund

Legal Basis: Article 21 GDPR.

Right to Data Portability

You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format and, where technically feasible, to transmit that data to another data controller.

Legal Basis: Article 20 GDPR.

Right to Lodge a Complaint

If you believe that your personal data has been processed unlawfully or that your rights have been infringed, you have the right to lodge a complaint with a supervisory authority.
The competent supervisory authority for Alphawave GmbH is the Data Protection Authority of the State of North Rhine-Westphalia (State Commissioner for Data Protection NRW) or any other supervisory authority of your choice within the European Union.

Legal Basis: Article 77 GDPR.

As part of our business relationship, we require the following categories of personal data from you:

• Data required to establish and maintain a business relationship.
• Data required to fulfil the contractual obligations associated with that business relationship.
• Data that we are legally required to collect.

Without this information, we are generally unable to enter into or perform a contract with you.

Statutory Identification Requirements

Under the German Money Laundering Act (GwG), we may be legally required to verify your identity before entering into a business relationship (e.g. by verifying an official identity document or using a postal identification procedure).

For this purpose, we collect and store your name, date and place of birth, nationality, address, and details of your identity document. If any of this information changes during the course of our business relationship, you are required to notify us without undue delay.

If you do not provide the required information and documentation, we may be unable to establish or continue the intended business relationship.

We retain your personal data only for as long as necessary to fulfil the respective purposes for which it was collected and processed.
Once your personal data is no longer required to fulfil contractual or legal obligations, it is routinely deleted unless continued retention is necessary for specific legal or legitimate reasons.

Continued retention may be necessary for reasons including, but not limited to:

• Compliance with Commercial and Tax Record Retention Requirements
  This includes obligations under the German Commercial Code (HGB), Fiscal Code (AO), Banking Act (KWG), Money Laundering Act (GwG), and Securities Trading Act (WpHG). The statutory retention and documentation periods prescribed by these laws generally extend for up to ten years.

• Preservation of Evidence for Legal Claims Within Statutory Limitation Periods
  Under German civil law, limitation periods may extend up to 30 years, although the standard limitation period is three years.

Once these retention periods have expired, your personal data will be deleted or anonymized unless further retention is required by law or justified by legitimate interests.

Through our newsletter, we keep our customers, investors, and prospective clients informed about current market developments and the latest company news.

You may unsubscribe from our newsletter at any time. An unsubscribe link is included in the footer of every email we send.

We use the Google Ads Remarketing service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).

Google Remarketing enables us to display targeted advertisements to users who have previously visited our website. As part of the Google advertising network, interest-based ads may then be displayed on other websites subsequently visited by the same user.

Google Remarketing uses cookies—small text files stored on your device—that enable an analysis of your use of our website.
These cookies allow visitors to be recognized when they visit other websites within Google’s advertising network. This makes it possible to display advertisements based on content that the user previously viewed on our website or on other websites using Google Remarketing.

For example, if you visit our website and later browse another website that participates in the Google Ads network, you may be shown advertisements for our products or services. The operators of those websites do not receive any information that identifies you as a visitor to our website.

According to Google, no personally identifiable information is collected during this process.
However, Remarketing may allow Google to associate your browser with a particular interest profile.

Legal Basis:
The use of Google Ads Remarketing is based on your explicit consent in accordance with Article 6(1)(a) GDPR and Section 25(1) of the German Telecommunications Digital Services Data Protection Act (TDDDG).
Personal data may be transferred to the United States. In such cases, Standard Contractual Clauses (SCCs) pursuant to Article 46 GDPR are used to ensure an adequate level of data protection.

To promote our website, we use the Google Ads advertising service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).
In connection with this, we also use Google’s Conversion Tracking service.

When you reach our website through a Google advertisement, a conversion cookie is stored on your device. Cookies are small text files saved on your computer by your browser. These cookies expire after 90 days and are not used to identify you personally.
If you visit certain pages of our website while the cookie is still active, both Google and we can determine that you clicked on one of our advertisements and were redirected to our website.

The information collected through the conversion cookie enables Google to generate visitor and conversion statistics for our website.These statistics allow us to determine the total number of users who clicked on our advertisements and which pages of our website they subsequently visited.Neither we nor other Google Ads advertisers receive any information that could be used to personally identify individual users.

Neither we nor other Google Ads advertisers receive any information that could be used to personally identify individual users.

For more information, please refer to Google’s Privacy Policy at:
https://services.google.com/sitestats/en.html

Legal Basis:
The use of Google Ads Conversion Tracking is based on your consent in accordance with Article 6(1)(a) GDPR and Section 25(1) of the German Telecommunications Digital Services Data Protection Act (TDDDG).
Personal data may be transferred to the United States. Such transfers are safeguarded by Standard Contractual Clauses (SCCs) in accordance with Article 46 GDPR.

You may withdraw your consent at any time with effect for the future.

We use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

Google Analytics uses cookies—small text files stored on your device—to analyze how users interact with our website.
The information generated by these cookies about your use of the website (including your IP address) is generally transmitted to and stored on a Google server in the United States.

This website uses Google Analytics with IP anonymization enabled.
This means that your IP address is shortened by Google within Member States of the European Union or in other countries that are party to the Agreement on the European Economic Area before it is transmitted.
Only in exceptional cases is the full IP address transmitted to a Google server in the United States and shortened there.
Google processes this information on our behalf to evaluate the use of our website, compile reports on website activity, and provide us with additional services related to website and internet usage.
The IP address transmitted by your browser as part of Google Analytics is not combined with other data held by Google.

Legal Basis:
The processing of data through Google Analytics is based on your consent in accordance with Article 6(1)(a) GDPR and Section 25(1) of the German Telecommunications Digital Services Data Protection Act (TDDDG).
Any transfer of personal data to the United States is safeguarded by Standard Contractual Clauses (SCCs) in accordance with Article 46 GDPR.

You may withdraw your consent at any time with effect for the future through our Cookie Settings.
You can also prevent Google from collecting and processing your data by downloading and installing the browser add-on available here:
https://tools.google.com/dlpage/gaoptout

For more information about how Google processes personal data, please refer to Google’s Privacy Policy:
https://policies.google.com/privacy

Our website uses features of the LinkedIn network, which is provided by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland (“LinkedIn”).

When you visit a page on our website that contains LinkedIn features, a connection to LinkedIn’s servers is established.
LinkedIn may receive information that you have visited our website using your IP address.
If you are logged into your LinkedIn account and interact with LinkedIn features (for example, by clicking the “Recommend” button), LinkedIn may associate your visit to our website with your LinkedIn user profile.

Please note that, as the operator of this website, we have no control over the scope or further use of the data collected by LinkedIn.
For information about the purpose and scope of LinkedIn’s data collection, the further processing of your data, and your rights and options for protecting your privacy, please refer to LinkedIn’s Privacy Policy:
https://www.linkedin.com/legal/privacy-policy

Legal Basis:
The use of LinkedIn features is based on your consent in accordance with Article 6(1)(a) GDPR and Section 25(1) of the German Telecommunications Digital Services Data Protection Act (TDDDG).
Personal data may be transferred to the United States (via LinkedIn Corporation, 1000 W Maude Ave, Sunnyvale, CA 94085, USA). Such transfers are safeguarded by Standard Contractual Clauses (SCCs) in accordance with Article 46 GDPR.

You may withdraw your consent at any time with effect for the future.

This Privacy Policy was last updated on: 14 October 2025

We may update this Privacy Policy from time to time. The latest version is always available on our website and is identified by the date of its most recent update.

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