LEGAL NOTICE
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1- Identification data
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In compliance with the duty of information established in Law 34/2002, of July 11, 2002, on Information Society Services and Electronic Commerce (hereinafter, "LSSI"), the following information is provided below: the owner of www.acurio.vc (hereinafter, the "Website") is ACURIO VENTURES PARTNERS, SGEIC, S.A. with Tax Number A-95948238, company domiciled in Calle Buenos Aires 12, 48001 Bilbao, Spain. entity registered Registered in the Mercantile Register of Bizkaia under Volume 5837, Sheet 32, Page BI-72986 and Registered in the Administrative Registry of the CNMV under number 143, (hereinafter “ACURIO”).
Contact details: E-mail: dpo@acurio.vc

2- User's responsibility

Any person accessing this website assumes the condition of USER, undertaking not to use the WEBSITE or the information contained therein to carry out activities contrary to law, morality or public order and, in general, to use it in accordance with the conditions established by the entity.The User is responsible for the opinions, contents and, in general, for all the activities that they carry out, not being able to hold the entity responsible for any damages that may arise from such activities beyond his/her control and of which they are effectively unaware.

3- Responsibility of Acurio Ventures

The entity shall not be responsible for any possible errors in accessing the WEBSITE or its contents, but will do its best to ensure that they do not occur. The entity reserves the right, without prior notice, to temporarily suspend access to the WEBSITE in the event that it is necessary to carry out maintenance, repair or improvement work.

4- Intellectual and industrial property

All contents of the WEBSITE (including, but not limited to, databases, images, drawings, graphics, text files, audio, video and software) are the property of the entity and are protected by national and international intellectual and industrial property laws, and all rights are reserved. The domain name, trademarks, labels, distinctive signs or logos that appear on the WEBSITE are the property of the entity. The texts, graphic drawings, videos or audio supports that may be found in this WEBSITE, now or in the future, are property of the entity, so it is not allowed to use them:  
- Reproduction, distribution or modification, unless authorized by the entity or it is legally permitted. 
- Any violation of the rights of the entity or of the legitimate owners of the same. 
- Use for any type of commercial or advertising purposes other than those strictly permitted. 
- Any attempt to obtain the contents of the WEBSITE by any means other than those provided to USERS, and those normally used on the WEBSITE.

5- Disclaimer of warranties and liability

The entity is not responsible, in any case, for damages of any nature that may be caused by USERS, including but not limited to: errors or omissions in the content, lack of availability of the portal or the transmission of viruses or malicious or harmful programs in the content, despite having taken all the necessary technological measures to prevent it. 

6- Modifications

The entity reserves the right to make unannounced changes it deems appropriate in its WEBSITE, and may change, delete, or add content and services provided through it, as well as how they are presented or located on its WEBSITE.

7- Links

The establishment of any hyperlink from a web page to any of the pages of the entity's WEBSITE shall be subject to the following conditions:
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- The total or partial reproduction of any of the services of the entity's WEBSITE is not allowed.
- No "deep links" will be established with the pages of the entity's WEBSITE, nor will a search engine or environment be created in relation to them.
- The web page on which the hyperlink is established shall not contain any trademark, trade name, commercial name, establishment sign, denomination, logo, slogan or other distinctive signs belonging to the entity.
- In no case shall the entity be responsible for the contents, information, statements, opinions or services provided to the general public of the web page in which the hyperlink to this WEBSITE is established.
- Any hyperlink shall be made to the home page of the WEBSITE.The hyperlinks on the WEBSITE have been previously agreed with the owners of the linked websites. The entity is not responsible for the misuse or activities contrary to law, morality or public order carried out by the users of these linked web pages.

8- Validity of the terms of use

The entity may modify at any time the conditions determined here, being duly published as they appear here. The validity of the aforementioned conditions will depend on their exposure and will be in force until they are modified by others duly published. 

9- Applicable law and jurisdiction

The relationship between the entity and the USER shall be governed by the Spanish legislation in force and any dispute shall be submitted to the Courts and Tribunals ofof the city of Bilbao (Spain), unless other jurisdiction is deemed competent in accordance with applicable legislation.In the event that any of the terms of this document be declared null, they will be removed or replaced. Should this occur, the validity of the rest of the terms included in this document will not be affected.

PRIVACY POLICY

1- Website manager
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This website is the responsibility of ACURIO VENTURES PARTNERS, SGEIC, S.A,with Tax Number: A-95948238, company domiciled in Calle Gran via don Diego Lopez de Haro 1 1, 48001 Bilbao, Spain, Registered in the Mercantile Register of Bizkaia under Volume 5837, Sheet 32, Page BI-72986 and Registered in the Administrative Registry of the CNMV under number 143, (hereinafter, ACURIO).

2- Motivation

The entity respects the privacy rights of its Users and recognizes the importance of protecting the personal data that the entity collects about its Users. The purpose of this document is to inform the Users of the website about the processing of personal data carried out on this website.

3- Personal data processed by the access to the website
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3.1. Which data are processed
By simply accessing the website, the entity collects the IP address and other data relating to the connection and its origin. The IP address is a code that identifies the User's Internet connection at a specific time. Only the User's Internet access provider can identify the subscriber who was assigned an IP address at a particular time. By the very nature of the server that supports the website, the User's IP address is automatically recorded along with the date and time of access.

3.2. What is this data used for?
This data is used only to manage the normal use of the website and to perform statistical analysis on the use of the website.

3.3. Data recipients
The entity does not provide this information to any third party, unless required to do so by applicable law (e.g., an official request in the context of a police investigation).

3.4. Lawful processing
The legal basis that legitimizes the processing of the IP address is the technological necessity to enable the provision of the website.
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3.5. Time limit for data processing
IP addresses will be retained for a period of 1 month. 

4- User´s rights and how to exercise them
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Data protection regulations guarantee Users the following rights:
- Access: Allows the User to know what information is held, from where it has been obtained, to whom it has been provided and with what uses it has been treated.
- Rectification: Allows the User to rectify any erroneous or outdated data. 
- Suppression: Allows the User to stop the processing of his/her data.
- Opposition: Allows the User to stop the use of his/her data for a specific purpose.
- Limitation: Allows the user to restrict the processing of their data, but so that they are retained for a subsequent purpose.
- Portability: Allows the User to obtain a copy of his/her data in electronic format and, under certain circumstances, to request that they be communicated to another service provider. It is only applicable for computerized processing carried out with the consent of the User or for the fulfillment of a contract.- Revocation of consent: Allows the User to withdraw the consent that, where appropriate, has been given for the processing of their data.These rights require the possibility of identifying the User requesting them and linking his identity with the data processed by the entity.However, the entity cannot establish this link with any of the data processed by the mere access to the website, unless the User could provide certain documentation that allows its identification (for example, a certificate from its Internet access provider indicating the IP address that the User had assigned on a specific date and time).Users are informed that they can exercise the aforementioned rights to ACURIO, as well as revoke their consent for the processing they have given, by post to the above-mentioned address or by e-mail to dpo@acurio.vc specifying the right they are requesting, as well as providing information to identify them.If Users wish to receive further information on this matter or consider that their right to the data protection has been violated, they can contact the Spanish Data Protection Agency (www.aedp.es). 

5- Other processings of personal data
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5.1. Cookies and similar tecnologies
The entity uses cookies and other similar mechanisms for storing and retrieving data on terminal equipment (hereinafter, cookies).Cookies are files that are downloaded to the User's browser and can be read later by the entity. In this way, cookies allow various functionalities, such as, for example, recognizing a User who has previously accessed the website and being able to analyze the use of the web service in order to improve it. However, it is not possible to find out the identity of the User from the cookies used by the entity, unless the User provides additional information through other means and these could be linked to the cookies downloaded.For more information, please consult the Cookies Policy].

5.2. Contact email
ACURIO will process the data provided through the contact requests, with the aim of attending to the request for contact. Legal basis: The legal basis that legitimates the processing is the consent of the user expressed at the moment of sending his request of contact.Retention period: The data will be processed for the time necessary to resolve the user's request for contact. Subsequently, they will be blocked and kept for 3 years to deal with any liabilities arising from the processing.You can withdraw the consent given, as well as exercise your data protection rights at any time, as indicated in the rights section "USER’S RIGHTS AND HOW TO EXERCISE THEM" of this Privacy Policy.

6 - Minors
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Minors under 16 must not send any personal information without consent from a parent or guardian. ACURIO assumes no liability for information sent by under 16 minors without due authorization.

7- Commercial comunications

ACURIO informs the user that the commercial communications requested by the user or if the user has not objected to receiving them by ticking the corresponding boxes on the forms, will be sent using the tool Mailchimp, managed by the company The Rocket Science Group LLC whose servers are located in the United States, a country whose legislation offer a level of data protection equivalent to that of Europe; with adequate guarantees of data protection are provided by signing the Standard Contractual Clauses approved by Decision 2021/914/EU of the European Commission.In each communication, the user will be able to oppose to receive this type of information through the specific mechanisms to process the cancellation, as well as to request in its case its right of revocation of consent, opposition or suppression. 

8- Security Measures

ACURIO has taken personal data protection safety measures required by current legislation in accordance with the type of information processed and has implemented other media and additional technical measures within their reach to avoid the unauthorized alteration, loss, processing of or access to the data received.ACURIO hereby guarantees that it has adopted the appropriate security measures to ensure the security of the information and the confidentiality of the data that you send us.

9- More Information

If you have any questions about the information collected in our Privacy Policy, please send an email to: dpo@acurio.vc
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ESG CRITERIA INTEGRATION POLICY

1. Purpose of the Policy

This document describes the policy for the integration of environmental, social and corporate governance criteria, known as ESG criteria (hereinafter, «ESG Criteria«)  ACURIO VENTURES PARTNERS, SGEIC, S.A.  (hereinafter «the Company«), which the Company will take into consideration in the development of its activities as a manager of venture capital entities (entidades de capital riesgo).

This policy is developed in compliance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on the disclosure of information relating to sustainability in the financial services sector.

2. ESG Criteria

When referring to the ESG Criteria, reference is made to the following factors:
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- The environmental factor (E): how companies’ activities affect the environment. It focuses on the environmental impact of companies, as well as on the efforts made by companies to reduce the levels of pollution or carbon emissions. It would cover, for example, issues such as waste management, water management and the use of other natural resources.
- The social factor (S): takes into account the community impact of the activities carried out by companies, for example in terms of diversity, administration, human rights or healthcare. It also includes for example the links established by companies with the community (corporate citizenship and philanthropic initiatives).
- The governance factor (G): studies the impact of the shareholders themselves and on  entity management, and takes into account issues such as the structure of boards of directors, management compensation and shareholders’ rights, as well as transparency in the relationship between shareholders and the management.
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3. Policy for the Integration of the ESG Criteria
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‍3.1 The Company’s Positioning on the Integration of the ESG Criteria
‍The Company is aware of the importance of the ESG Criteria for the achievement of the Sustainable Development Goals «SDGs» (2015-2030).

Notwithstanding the foregoing, for the time being, the Company has decided not to integrate the ESG Criteria in the investment decision-making processes, as it does not yet have a sufficient level of development and detail to assess the impact of such criteria. Furthermore, based on its current positioning, the Company acknowledges that it does not take into account the adverse impact of investment decisions on the ESG Criteria.

‍3.2 Company’s Commitment to the ESG Criteria
‍The Company is working on the conceptualization of a general framework related to the ESG Criteria, which applies to issues such as:

- investment and divestment decisions;non-financial reporting to be implemented in current and future portfolio companies;
- non-financial reporting to be provided to investors in the vehicles managed by the Company;
- andthe day-to-day running of the Company. 

During 2021, the Company will evaluate various external ESG providers with a view to ultimately selecting one of them to lead and assist in the implementation of an all-encompassing ESG policy and practices. In addition, the Company is already considering a collaboration with a company invested by vehicles managed by the Company. Such company has developed a specific software for the management, monitoring and reporting of all ESG activity, which will allow the Company to better implement and monitor the integration of ESG Criteria in all its activities. The Company expressly states that, beyond the legal obligations imposed, it is fully committed to the adoption of ESG practices.

4. Remuneration Policy and Policies for the Integration of Sustainability Risks
The Company’s remuneration policy is not affected by not considering the ESG Criteria when making investment decisions.

5. Publication of ESG Policy and Documentation
The Company, in compliance with Art. 3 of Regulation (EU) 2019/2088, publishes this policy on its website, with the commitment to gradually incorporate any progress that the Company implements as a result of future regulatory changes, as well as of future developments in line with the aforementioned section 3.

6. Applied Regulations
- Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on the disclosure of sustainability-related information in the financial services sector.
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- Law 11/2018, of 28 December, amending the Code of Commerce (Código de Comercio), the consolidated text of the Capital Companies Act (Ley de Sociedades de Capital) approved by RDL 1/2010, of 2 July, and Law 22/2015, of 20 July, on Auditing of Accounts, regarding non-financial information and diversity.
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- Directive 2007/36/EC of the European Parliament and of the Council, of 11 July 2007, on the exercise of certain rights of shareholders of listed companies.
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- Sustainable Development Goals (SDGs).