Privacy policy

Effective Date: 20 April 2026

This Privacy Policy explains how AdQuantum Ltd («AdQuantum«, the «Fund«, «we«, «us«, or «our«) collects, uses, stores, and protects personal information submitted through the investment program application form on our website https://adquantum.fund/ (the «Site«). Please read this policy carefully before submitting an application.

Information We Collect
Information You Provide Directly

When you complete and submit an application through the Site, we may collect the following information:

Name — the full name of the contact person submitting the application (required)
Email address — a valid email address for communication purposes (required)
Social media handles — links or usernames for relevant social media profiles (optional)
P&L data or Pitch Deck — financial performance data or a pitch deck, submitted either as an uploaded file or as a link to an external document (required)
App link or URL — a link to the application, product, or platform being submitted for consideration (required)
Team size — the number of people currently on your team (required)
Free-text message — any additional information or context you choose to share in the open text field (optional)

Information Collected Automatically

When you visit the Site, certain data is collected automatically through standard web technologies, including:

IP address
Browser type and version
Device type and operating system
Pages visited and time spent on the Site
Log files and technical error reports
Cookies and similar tracking technologies (see Section 10 for details)

How We Use Your Information

We process the personal data we collect for the following purposes:

To receive, review, and evaluate your application for the AdQuantum × Union Apps Investment Fund program
To communicate with you about the status of your application and any follow-up steps
To maintain records of business correspondence and internal documentation
To store and manage application data in our internal systems, including for archival and analytical purposes
To monitor and improve the performance and user experience of the Site
To meet applicable legal and regulatory obligations
To protect the rights and interests of AdQuantum and to respond to legal claims if they arise

Legal Basis for Processing

Where data protection law requires us to identify a lawful basis for processing, we rely on the following:

Consent — you provide consent when you voluntarily submit your application through the Site
Legitimate interests — we have a legitimate interest in evaluating applications, managing our investment activities, and improving our services
Legal obligation — we may process data where required to comply with applicable laws or regulatory requirements

Data Sharing

We may disclose your personal information to the following categories of recipients:

AdQuantum and Union Apps group companies — your data may be shared within the AdQuantum and Union Apps group of companies for the purposes described in this policy, including investment assessment and portfolio management
Service providers — third-party vendors that support our operations, such as hosting providers, analytics platforms, CRM systems, and communication tools
Professional advisers — lawyers, auditors, accountants, or other advisers engaged in connection with our business activities
Regulatory or governmental authorities — where we are required to disclose information under applicable law

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

International Data Transfers

Your personal data may be transferred to and processed in countries outside your country of residence, including countries that may not provide the same level of data protection as your home jurisdiction. Where such transfers occur, we implement appropriate safeguards — such as Standard Contractual Clauses approved by relevant authorities, or reliance on adequacy decisions — to ensure your data remains protected in accordance with applicable law.

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including:

Evaluating your investment application
Maintaining associated business records
Fulfilling legal, regulatory, or internal compliance obligations

As a general rule, application data is retained for no longer than five (5) years from the date of collection, unless a longer retention period is required by law or the data is held in a secure, non-active format solely for internal reference purposes.

Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, loss, or misuse. These measures include:

Secure server infrastructure with restricted database access
Encryption of data in transit and at rest where appropriate
Role-based access controls limiting who can view your data
Regular review and testing of our security practices

While we take reasonable steps to protect your information, no system or transmission over the internet can be guaranteed to be entirely secure. We encourage you to exercise care when sharing sensitive information online.

Your Rights (GDPR/UK GDPR)

If you are located in the European Economic Area, the United Kingdom, or another jurisdiction covered by equivalent data protection legislation, you have the following rights in relation to your personal data:

Right of access — to request a copy of the personal data we hold about you
Right to rectification — to request that inaccurate or incomplete data be corrected
Right to erasure — to request deletion of your personal data, subject to certain legal exceptions
Right to restriction — to ask us to limit how we process your data in certain circumstances
Right to object — to object to processing based on legitimate interests
Right to data portability — to request your data in a structured, machine-readable format where technically feasible

To exercise any of these rights, please contact us using the details in Section 12. We may ask you to verify your identity before processing your request. We will respond within the timeframe required by applicable law.

Your Rights (CCPA/CPRA — California Residents)

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), grants you the following rights:

Right to know — to request information about the categories and specific pieces of personal information we have collected about you, the sources of that information, the purposes for collecting it, and the categories of third parties with whom it is shared
Right to delete — to request that we delete your personal information, subject to applicable exceptions
Right to correct — to request correction of inaccurate personal information we hold about you
Right to opt out of sale or sharing — to direct us not to sell or share your personal information; for the avoidance of doubt, we do not sell personal information
Right to limit use of sensitive personal information — to restrict the use or disclosure of sensitive personal information beyond what is necessary for the stated purposes

We will not discriminate against you for exercising your privacy rights.

Cookies and Tracking Technologies

We use cookies and similar technologies on the Site to:

Ensure the Site operates correctly and securely
Understand how visitors interact with and navigate the Site
Improve Site performance and overall user experience
Remember certain preferences or settings during your visit
Measure the reach or effectiveness of content and marketing activity where applicable

By continuing to use the Site without changing your cookie settings, you indicate your acceptance of cookies as described in this policy.

Third-Party Links

The Site may contain links to external websites or resources operated by third parties. This Privacy Policy applies only to information collected through our Site. We are not responsible for the privacy practices or content of third-party sites and encourage you to review their respective privacy policies.

Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, or applicable law. Any revised version will be posted on this page with an updated «Effective Date«. Where changes are material, we may notify you directly via email or through a prominent notice on the Site.

Contact Us

If you have any questions about this Privacy Policy, wish to exercise your privacy rights, or would like to request more information about how we handle your personal data, please contact us at:

AdQuantum Ltd

Address: Spyrou Kyprianou 61, 1st floor, SK House, 4003 Mesa Geitonia, Limassol, Cyprus

Email: info@adquantum.com

We will endeavour to respond to all legitimate inquiries within a reasonable timeframe and, where required by law, within the statutory deadline.