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Privacy Policy, Cookies & Legal Notice

Updated: June 25, 2026

This Personal Data Processing Policy (the “Policy”) explains how Univerum (“Univerum”, “we”, “us” or “our”) collects, uses, stores, shares and protects personal data gathered from users (“you”, “your”) through our website at univerum.com (the “Website”) and through any related communications. We are committed to protecting your privacy and to handling your personal data lawfully, fairly and transparently, in compliance with Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”), and applicable Finnish data protection law, including the Finnish Data Protection Act (Tietosuojalaki 1050/2018).

1. Data controller

Univerum is the data controller responsible for the personal data you provide through the Website. The controller determines the purposes and means of processing your personal data. If you have any questions, concerns or requests regarding this Policy or how your data is processed, you can contact us at:

  • Entity: Univerum (investment club)
  • Email: mail@univerum.com
  • Location: Helsinki, Finland

2. Personal data we collect

We collect different categories of personal data depending on how you interact with us. This may include, but is not limited to:

  • Identification and contact data that you submit voluntarily through our contact form, such as your name, email address, company or project name, and the contents of your message.
  • Technical data collected automatically when you visit the Website, such as your IP address, browser type and version, device information, operating system, referring URLs, and server log files.
  • Usage data about how you interact with the Website, such as pages visited, time spent, and navigation paths, where analytics are enabled.

We do not intentionally collect special categories of personal data (such as data revealing health, religion, or political opinions). Please do not include such information in messages you send us.

3. Purposes of processing

We process your personal data for the following purposes:

  • To respond to your inquiries, evaluate potential investment opportunities, and communicate with you about your venture.
  • To provide, operate, maintain and improve the Website and its functionality.
  • To analyse aggregated user behaviour in order to improve user experience and optimise our content (only where you have consented to non-essential cookies).
  • To ensure the security and integrity of our systems and to prevent fraud or abuse.
  • To comply with legal and regulatory obligations.

Under Article 6(1) GDPR, we rely on the following legal bases:

  • Consent (Art. 6(1)(a)) — for example, when you submit the contact form, accept non-essential cookies, or subscribe to communications. You may withdraw consent at any time.
  • Contractual necessity (Art. 6(1)(b)) — where processing is necessary to take steps at your request prior to entering into, or to perform, a contract or partnership.
  • Legitimate interests (Art. 6(1)(f)) — for purposes such as securing our Website, preventing abuse, and conducting limited analytics, provided your rights and freedoms do not override those interests.
  • Legal obligation (Art. 6(1)(c)) — where processing is required to comply with applicable law.

5. Data retention

We retain your personal data only for as long as necessary to fulfil the purposes set out in this Policy, or as required by applicable law. Inquiry and contact data is generally retained for up to 24 months after our last meaningful contact, unless a longer period is required for legal, accounting or legitimate business reasons, or unless you ask us to delete it sooner. Once data is no longer needed, it is securely deleted or anonymised.

6. Data sharing and disclosure

We do not sell or rent your personal data. We may share your data with trusted recipients strictly for the purposes described in this Policy:

  • Service providers (processors) who assist us with website hosting, email delivery (SMTP), and analytics, acting on our instructions under a data processing agreement.
  • Professional advisers and co-investors, where relevant to evaluating a partnership and where an appropriate confidentiality basis exists.
  • Legal authorities, where disclosure is required by law or necessary to protect our rights, safety, or property.
  • Business transfers, in the event of a merger, acquisition, reorganisation, or sale of assets, subject to appropriate confidentiality safeguards.

7. International transfers

Where your personal data is transferred outside the European Economic Area (EEA), we ensure that appropriate safeguards are in place to protect it, such as transfers to countries benefiting from a European Commission adequacy decision, or the use of Standard Contractual Clauses approved by the European Commission, together with any supplementary measures required.

8. Your rights under the GDPR

Subject to applicable conditions and exemptions, you have the right to:

  • Access — obtain confirmation of, and a copy of, the personal data we hold about you.
  • Rectification — have inaccurate or incomplete data corrected.
  • Erasure — request deletion of your personal data (“right to be forgotten”).
  • Restriction — request that we limit processing in certain circumstances.
  • Objection — object to processing based on legitimate interests or for direct marketing purposes.
  • Data portability — receive your data in a structured, commonly used, machine-readable format and have it transmitted to another controller.
  • Withdraw consent — at any time, without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact us at mail@univerum.com. We will respond within one month, as required by the GDPR. You also have the right to lodge a complaint with a supervisory authority. In Finland, this is the Office of the Data Protection Ombudsman (Tietosuojavaltuutetun toimisto, tietosuoja.fi). You may also contact the supervisory authority in your country of residence or place of work.

9. Cookies and tracking technologies

The Website uses cookies and similar technologies to function correctly and, where you consent, to understand how the Website is used. We distinguish between:

  • Strictly necessary cookies, required for the Website to operate (for example, security and basic functionality). These do not require consent.
  • Analytics and performance cookies, used to measure and improve Website performance. These are only set with your prior consent.

You can manage or disable cookies through your browser settings and, where applicable, through our cookie consent controls. Please note that disabling certain cookies may affect the functionality of the Website. This Website does not currently serve third-party advertising cookies.

10. Data security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, disclosure or destruction. These include encrypted transmission (TLS/HTTPS), access controls, and secure handling of contact submissions. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

11. Children’s privacy

The Website is intended for a professional, adult audience and is not directed at children under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without appropriate consent, we will take reasonable steps to delete it.

12. Changes to this Policy

We may update this Policy from time to time to reflect changes in our practices, technologies, or legal requirements. Any changes will be posted on this page with a revised “Last updated” date. We encourage you to review this Policy periodically.

13. Contact us

If you have any questions, concerns or requests regarding this Policy or how we handle your personal data, please contact us at:

The content of this Website is provided for general information purposes only and does not constitute investment advice, a financial promotion, an offer, or a solicitation to buy or sell any security or financial instrument in any jurisdiction. Nothing on this Website should be relied upon as the basis for any investment decision. All trademarks, logos and content are the property of Univerum or their respective owners and may not be reproduced without prior written permission. This Policy is governed by and construed in accordance with the laws of Finland and the European Union.

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