GioiaWinvest OÜ Last updated: June 30, 2026

1. Who We Are

GioiaWinvest OÜ is a private limited company (osaühing) registered in Estonia. We are the data controller responsible for the personal data described in this policy.

Contact: [email protected]

2. What Data We Collect

When you complete the investor qualification form on this website, we collect:

First name and last name

Email address

Phone number

Country of residence

Whether you are a US person for securities law purposes

How you heard about Gioia Village

Your investing capacity (individual, company or fund, family office, or exploratory)

Your indicative investable capital range

If you proceed to sign a Non-Disclosure Agreement, we additionally record the date and details of that signature.

If you book an introductory call, we collect the date and time of that appointment.

3. Why We Process This Data

We process your personal data on the following legal bases under the General Data Protection Regulation (GDPR):

Legitimate interest. We use your qualification form responses to assess whether you are an appropriate fit for a private investment opportunity before sharing confidential investment materials, and to comply with our obligations under applicable securities law not to solicit investment from the general public.

Performance of a contract or pre-contractual steps. Once you sign the Non-Disclosure Agreement, we process your data to administer that agreement and to manage the investment process described on this website, at your request.

Legal obligation. Where applicable, we process certain data to meet anti-money laundering, know-your-customer, and securities law obligations in the jurisdictions in which we operate.

We do not use your data for marketing purposes unless you separately and explicitly opt in to receive marketing communications.

4. Who We Share Your Data With

Your data is shared only with:

Members of the GioiaWinvest team directly involved in investor relations

Our legal and financial advisors, where necessary to administer the Non-Disclosure Agreement or evaluate your qualification

Service providers who help us operate this website and our customer relationship system (for example, our website and CRM platform provider), acting under contractual data protection obligations

Regulators or authorities, where required by law

We do not sell your personal data to any third party.

5. International Transfers

GioiaWinvest OÜ is based in Estonia, within the European Union. If you are located outside the European Economic Area, your data will be transferred to the EU for processing. If we use service providers located outside the EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses, in accordance with GDPR requirements.

6. How Long We Keep Your Data

If you submit the qualification form but do not proceed further, we retain your data for 24 months from submission, after which it is deleted unless you re-engage.

If you sign the Non-Disclosure Agreement, we retain your data for the duration of that agreement plus any period required by applicable securities or contract law afterward.

If you become an investor, your data is retained for as long as required by applicable financial, tax, and corporate law in Estonia and any relevant jurisdiction.

7. Your Rights

Under the GDPR, you have the right to:

Access the personal data we hold about you

Request correction of inaccurate data

Request deletion of your data, subject to our legal retention obligations

Object to or restrict certain processing

Request a copy of your data in a portable format

Withdraw consent at any time, where processing is based on consent

To exercise any of these rights, contact us at [email protected]. You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or your local supervisory authority.

8. Security

We take reasonable technical and organizational measures to protect your personal data, including restricted access to investor records and password protection on confidential investment materials.

9. Changes to This Policy

We may update this policy from time to time. The date at the top of this page indicates when it was last revised.

10. Contact

For any questions about this policy or how your data is handled, contact:

GioiaWinvest OÜ [email protected]