Privacy Policy

Last updated: 6 October 2026

1. Introduction

This Privacy Policy explains how as ValBor Capital("ValBor", "we", "us" or "our"), collects, uses and protects personal data when you visit or interact with the ValBor website at [www.valborcapital.com] (the "Website").

We are committed to protecting your privacy and processing personal data in accordance with applicable data protection laws, including the EU General Data Protection Regulation (Regulation (EU) 2016/679 – "GDPR") and applicable national data protection legislation.

2. Data controller

The data controller responsible for the processing of personal data through this Website is:

ValBor Capital
Email: [privacy@valborcapital.com]

For any questions concerning the processing of your personal data, please contact us using the details above.

3. Personal data we may collect

Depending on how you interact with the Website, we may collect the following categories of personal data:

Information you provide to us

If you contact us, submit an enquiry, request information or otherwise communicate with us, we may collect:

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your name;
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professional contact details, such as your email address, telephone number and company;

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the content of your communication;
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any other information that you voluntarily provide to us.

Information collected automatically

When you visit the Website, certain technical information may be collected automatically, including:

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IP address;
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browser and device type;
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operating system;
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pages visited and interactions with the Website;

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date and time of access;
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referring website;
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technical information necessary to maintain website security and functionality.

Where required by applicable law, non-essential analytics or similar technologies will only be used after obtaining your consent.

4. Purposes of processing

We may process personal data for the following purposes:

to operate, maintain and secure the Website;

to respond to enquiries and communications;

to assess and manage potential business, investment, acquisition or partnership opportunities;

to communicate with prospective investors, shareholders, business owners, advisers, counterparties and other professional contacts;

to improve the functionality and performance of the Website;

to understand Website usage and traffic, where appropriate consent has been obtained;

to comply with applicable legal and regulatory obligations;

to establish, exercise or defend legal claims;

to protect our rights, property and the security of our systems.

We will not use personal data for purposes incompatible with those described above without providing appropriate information and, where required, obtaining your consent.

5. Legal bases for processing

Depending on the circumstances, we process personal data on one or more of the following legal bases under Article 6 GDPR:

Legitimate interests – where processing is necessary for our legitimate business interests, provided that those interests are not overridden by your rights and interests;

Performance of a contract or steps prior to entering into a contract – where processing is necessary to respond to or manage a contractual or pre-contractual relationship;

Legal obligation – where processing is necessary for compliance with a legal obligation;

Consent – where we have requested and obtained your consent, including where required for certain cookies or analytics technologies.

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

6. Disclosure of personal data

We may disclose personal data to trusted service providers and professional advisers where reasonably necessary for the purposes described in this Privacy Policy.

These may include:

website hosting and technology providers;

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IT and cybersecurity providers;
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analytics providers, where applicable;
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professional advisers, including legal, accounting, tax and financial advisers;

regulators, public authorities or other third parties where required by law;

transaction counterparties or their advisers where this is necessary in connection with a potential or actual investment, acquisition, financing, restructuring or other business transaction and is subject to appropriate confidentiality arrangements.

We do not sell your personal data.

7. International transfers

Some of our service providers may process personal data outside the European Economic Area ("EEA").

Where personal data is transferred outside the EEA, we will ensure that an appropriate legal mechanism is in place in accordance with Chapter V GDPR, such as:

an adequacy decision of the European Commission;

Standard Contractual Clauses approved by the European Commission; or

another legally recognised transfer mechanism.

8. Data retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including to satisfy legal, accounting, regulatory or reporting requirements and to establish, exercise or defend legal claims.

The retention period depends on the nature of the information and the purpose for which it is processed.

When personal data is no longer required, we will delete it or anonymise it where reasonably practicable.

9. Your rights

Subject to the conditions and limitations provided by applicable law, you may have the right to:

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request access to your personal data;
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request correction of inaccurate or incomplete personal data;

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request deletion of your personal data;
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request restriction of processing;
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object to certain processing;
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request portability of personal data where applicable;

withdraw consent where processing is based on consent.

You may exercise your rights by contacting us at:

[privacy@valborcapital.com]

We may need to verify your identity before responding to a request.

You also have the right to lodge a complaint with a competent data protection supervisory authority. In the Netherlands, this is the Autoriteit Persoonsgegevens.

10. Cookies and similar technologies

The Website uses cookies and similar technologies.

Some cookies are necessary for the Website to function correctly and do not require consent. Other cookies, such as certain analytics, performance or marketing cookies, may require your consent under applicable law.

Further information about the cookies used by the Website, their purposes and how you can manage your preferences is provided in our Cookie Policy.

11. Third-party websites

The Website may contain links to third-party websites, including professional networks, service providers or other external websites.

We are not responsible for the privacy practices or content of third-party websites. We recommend reviewing the privacy policies of those websites before providing them with personal data.

12. Security

We take reasonable technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.

However, no internet transmission or electronic storage system can be guaranteed to be completely secure.

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our activities, technology, legal requirements or the Website.

The latest version will always be published on this page, with the date of the most recent update indicated at the top.

14. Contact

For questions regarding this Privacy Policy or our processing of personal data, please contact:

ValBor Capital B.V
Netherlands
Email: [privacy@valborcapital.com]