POLICIES & REGULATIONS

This document explains how and why cookies are used on the Magnify Capital Partners website and applies to both clients and non-clients.

1. As the owner and operator of its website (Website), MAGNIFY uses the following cookies to monitor website traffic and record information:
   1. Session cookies: Used for the functioning of the website. These are essential cookies.
   2. Security cookies: Used for security purposes. These are essential cookies.
   3. Preference cookies: Used to remember user preferences and settings. These are non-essential cookies.
      
2. Essential cookies are crucial for enabling the normal use of the website and are stored on your personal device only for the time necessary to fulfill their intended purpose.
   
   
3. Cookies not labeled as essential can only be used by MAGNIFY with your consent and are stored on your personal device only for the time necessary to fulfill their intended purpose.
   
   
4. The cookies used by MAGNIFY do not collect personal data and do not allow the identification of the user.
   
   
5. MAGNIFY does not share the information collected with third parties.
   
   
6. You can give and withdraw your consent regarding the cookies used on the website by accessing https://magnify.partners.
   
   
7. By accessing and using the website, you acknowledge and accept this Cookie Policy.
   
   
8. To learn more about how MAGNIFY collects and processes your personal data on the website, please refer to our Privacy Policy.
   
   
9. To learn more about how the website operates, please refer to the Website Terms and Conditions.

This document explains the reasons for collecting and processing your personal data through the website of Magnify Capital Partners – SOCIEDADE DE CAPITAL DE RISCO, S.A. (MAGNIFY), as well as how your personal data is used and how you can exercise your rights in relation to it, in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016 (GDPR), and other applicable data protection legislation.

This privacy policy only concerns personal data collected through MAGNIFY’s website and applies to both clients and non-clients.

In the collection and processing of your personal data, MAGNIFY ensures the security and confidentiality of such data, complying with the applicable data protection legislation.

1. Data Controller
   
   The personal data collected is processed by Magnify Capital Partners – Sociedade de Capital de Risco, S.A., tax identification number 515510190, headquartered at Avenida Eng. Duarte Pacheco Amoreiras, Torre 2, Piso 14-L, 1070-101 Lisbon.
   MAGNIFY can be contacted through the following details:
   1. Email: info@magnify.partners
   2. Phone: +351 919 455 221
   3. Headquarters: Avenida Eng. Duarte Pacheco Amoreiras, Torre 2, Piso 14-L, 1070-101 Lisbon
      
2. Personal Data Collected: Purpose and Legal Basis for Processing
   
   MAGNIFY collects personal data through its website in the following contexts and conditions:
   
   1. Personal data provided by the user
      Following interaction with MAGNIFY through the email addresses provided on the website, MAGNIFY collects the personal data provided by the user in that email, including identification and contact details such as name, nationality, email address, home address, and phone number.
      
      This personal data is used to respond to requests made to MAGNIFY, and we assume MAGNIFY’s legitimate interest as the legal basis for processing the personal data provided in these communications and interactions. We consider that MAGNIFY has a legitimate interest in collecting and processing relevant data if you initiate correspondence with MAGNIFY through the email addresses provided on the website.
      
   2. Usage data
      MAGNIFY also collects the following data from all visitors to its website: IP address, date, time, accessed pages, and the type of browser used by the visitor. These data are not subject to any analysis, except in the case of security incidents, where, after analysis, they are reported to the competent authorities.
      
      The collection of this data is for the purpose of detecting, preventing, and addressing technical issues, and to fulfill the legal obligation to ensure the security of information systems as stipulated in Article 32(1) of the GDPR.
      
      MAGNIFY does not expect to receive any personal data related to children, as the website is not intended for that age group, and therefore MAGNIFY does not intentionally collect such data.
      
3. Data Storage
   
   MAGNIFY collects personal data through its website in the following contexts and conditions:
   1. Personal data provided by the user
      Personal data provided by the user in the context of email communications are retained for a maximum period of one (1) year after the conclusion of the matter underlying the respective email chain, unless the relationship with MAGNIFY continues concerning other matters.
      
   2. Usage data
      The personal data collected from all website visitors are retained for a maximum period of one (1) year.
      
4. Data Sharing
   
   MAGNIFY does not share the personal data collected with third parties.
   
   
5. Data Subject Rights
   
   Under the GDPR, particularly Articles 15 to 22, and other applicable data protection legislation, data subjects may exercise their rights of access, rectification, erasure, objection, and restriction of processing of their personal data, where applicable.
   
   You may exercise these rights in writing using MAGNIFY’s contact details mentioned in section 1 above.
   
   
6. Complaints
   
   If you believe that your rights under the GDPR have not been respected, you have the right to file a complaint with the National Data Protection Commission (www.cnpd.pt), the Portuguese supervisory authority for personal data. However, we would greatly appreciate the opportunity to address your concerns before contacting the National Data Protection Commission, and you can reach out to us first using MAGNIFY’s contact details mentioned in section 1 above.
   
   
7. Changes and Updates
   
   This Privacy Policy may be modified or updated in response to new legal or regulatory requirements, as well as changes to the services provided and contracted by MAGNIFY. Any changes to this Privacy Policy will be duly publicized on the website.

Magnify has a Complaints Handling Policy in place, which sets out the procedures for the adequate and efficient handling of complaints from investors. Magnify’s Complaints Handling Policy is available here: [PDF LINK FOR THE DOCUMENT ATTACHED].

Complaints from investors can be lodged through the following channels:

1. Letter addressed to:
   Magnify Capital Partners – Sociedade de Capital de Risco, S.A.
   Avenida Eng. Duarte Pacheco Amoreiras, Torre 2, Piso 14 – L,
   1070-101 Lisbon
2. E-mail to: info@magnify.partners
3. Complaints book available at Magnify’s offices
4. Electronic complaints book, available at: https://www.livroreclamacoes.pt/Inicio/

15 business day upon lodging a complaint with Magnify, investors may also file a complaint with the CMVM, through CMVM’s Investors Portal (available at: https://investidor.cmvm.pt/PInvestidor/).

Finally, for any matters not exceeding a value of €30,000.00, non-professional investors may also resort to alternative dispute resolution mechanisms, pursuant to a protocol entered into between Magnify and the CMVM. Within the scope of such protocol, investors may resort to one of the following Consumer Arbitration Centers:

a) Centro de Arbitragem de Conflitos de Consumo da Região de Coimbra (CACRC);

b) Centro de Arbitragem de Conflitos de Consumo de Lisboa (CACCL);

c) Centro de Arbitragem de Conflitos de Consumo do Ave, Tâmega e Sousa (TRIAVE);

d) Centro de Informação de Consumo e Arbitragem do Porto (CICAP);

e) Centro de Informação, Mediação e Arbitragem de Consumo (Tribunal Arbitral de Consumo) (CIAB);

f) Centro de Informação, Mediação e Arbitragem do Algarve (CIMAAL); and

g) Centro Nacional de Informação e Arbitragem de Conflitos de Consumo (CNIACC).

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