Privacy Policy | Zealium Capital S.A.S.

1. Data Controller Identification

Company Name: ZEALIUM CAPITAL S.A.S.
Tax ID (NIT): 901.138.193-5
Principal Domicile: Bogotá D.C., Republic of Colombia.
Address for Formal Notices: Calle 91 # 16-16, Buzón #1, Bogotá D.C., Colombia.
Designated Contact for Data Subject Rights & Formal Notices: notificaciones@zealiumcapital.com
Investment Opportunity Submissions Channel: opportunities@zealiumcapital.com

2. Legal Framework

This Personal Data Processing and Privacy Policy is adopted pursuant to Colombian Statutory Law 1581 of 2012, Regulatory Decree 1074 of 2015 (Chapter 25), and any applicable amending or supplementing regulations.

3. Information Collected via the Web Form

Through the investment opportunity submission form, this website collects directly and voluntarily the following information:

Identification and Contact Information: Full name, corporate or business email address, represented company or project, and country of origin.
Opportunity Fundamentals: Executive overview of the opportunity, business model or revenue sources, and available evidence of commercial traction or validation.
Proposed Structure and Terms: Concrete proposal for Zealium Capital S.A.S., capital required, target horizon and anticipated return or exit path, and projected use of funds.
Documentation and Links: Link to the investment deck, business plan, or cloud repository; and, optionally, links to the submitter's LinkedIn profile and corporate website.

4. Specific Purposes of Processing

Personal data collected will be processed exclusively for the following legitimate and explicit purposes:

Receiving, logging, classifying, and organizing submitted business opportunities.
Verifying the submitter’s basic identity and confirming provided contact details.
Conducting a preliminary evaluation of the project, asset, or business proposal against Zealium Capital S.A.S.’s investment criteria and thesis.
Communicating directly with the submitter regarding the review status, questions, or interest in the proposal.
Requesting clarifications or additional non-confidential materials when an opportunity warrants deeper assessment.
Performing reasonable background, legitimacy, and risk management checks (compliance with SAGRILAFT / anti-corruption and binding sanctions lists) where advancing discussions warrant such verification under applicable law and best practices.
Retaining technical audit logs of the submission and the data processing consent granted by the data subject.
Complying with statutory, tax, or regulatory obligations, or responding to formal orders issued by competent judicial or administrative authorities.

Strict Limitation: Collected data will not be used for mass unsolicited marketing, commercial advertising, sale or rental of databases, third-party profiling, or transferred to third parties for independent commercial purposes.

5. Rights of Data Subjects

In accordance with Article 8 of Colombian Law 1581 of 2012, data subjects are entitled to:

Know, update, and rectify their personal data with Zealium Capital S.A.S. as Data Controller.
Request proof of the consent granted for the processing of their data.
Be informed by Zealium Capital S.A.S., upon request, regarding the use made of their data.
Submit inquiries and complaints regarding the processing of their information.
Request the deletion of their personal data and/or revoke their consent when processing fails to observe constitutional and legal principles, provided there is no conflicting statutory or contractual obligation.
File complaints with the Colombian Superintendence of Industry and Commerce (SIC) for violations of data protection law, after exhausting direct consultation or complaint procedures with Zealium Capital S.A.S.
Access their processed personal data free of charge.

6. Procedure for Inquiries and Complaints

The designated team or individual at Zealium Capital S.A.S. will address inquiries and complaints via official email at: notificaciones@zealiumcapital.com.

Submission Requirements: Requests must include the full name and identification of the data subject, a clear and detailed description of the inquiry or claim, a valid email address for notifications, and relevant supporting documentation.

Inquiries: Handled within a maximum of ten (10) business days from the date of receipt. When resolution is not possible within this period, the applicant will be informed prior to deadline, stating the reasons for delay and indicating the expected response date, which shall not exceed five (5) business days following the initial term.

Complaints: Handled within a maximum of fifteen (15) business days from the next business day following receipt. If incomplete, the submitter will be requested within five (5) business days to rectify omissions; after two (2) months without response, the complaint is deemed abandoned. If resolving the complaint within the initial 15-day window is not possible, the reasons will be communicated along with a final resolution date not exceeding eight (8) business days following the initial deadline.

7. Children’s Data and Sensitive Information

The submission form and channels of Zealium Capital S.A.S. are strictly intended for legal adults representing business entities or investment opportunities. Submitters are expressly instructed not to provide personal data concerning children or adolescents, nor sensitive personal data (such as health, biometric, political, or ethnic origin data). If inadvertently received, Zealium Capital S.A.S. will strictly restrict its handling and proceed with immediate deletion in accordance with applicable regulations.

8. Confidentiality and Information Security

Zealium Capital S.A.S. implements reasonable technical, organizational, and administrative safeguards to protect data against unauthorized alteration, loss, consultation, use, or fraudulent access.

Notwithstanding the above, unilateral submission via the website form does not constitute or substitute a mutual Non-Disclosure Agreement (NDA). Do not submit proprietary trade secrets or highly sensitive strategic data without a prior formal bilateral agreement.

9. Retention and Deletion

General rule for unselected opportunities: Data and materials related to proposals that are not pursued or where active conversations do not continue will be retained for a prudent period of twelve (12) months from the date of submission, after which they will be securely purged or anonymized.

Exceptions: Information may be retained for longer periods where: active negotiations or discussions are ongoing, a legal or regulatory requirement mandates custody, or data is required for the defense of potential claims or legal proceedings.

Deletion applies to active systems under Zealium Capital S.A.S.’s reasonable control, subject to customary technical backup rotation cycles. Minimal evidence of consent and compliance will be retained for the period legally required to demonstrate adherence.

10. Technical Service Providers and International Data Transfers

For site hosting and communications, Zealium Capital S.A.S. engages technical service providers for web hosting, server infrastructure, and secure enterprise email. These providers operate as data processors and may be located in Colombia or internationally (e.g., the United States or the European Union), subject to appropriate contractual and legal safeguards under Colombian data protection rules for international data transmissions and transfers.

11. Tracking Technologies and Cookies

This institutional website does not deploy third-party advertising cookies, remarketing pixels, or invasive user tracking technologies. Because non-essential cookies are not utilized, no cookie consent banner is presented.

12. Effective Date and Amendments

This Policy is effective as of its official publication and may be amended periodically to reflect statutory updates or guidance issued by the Superintendence of Industry and Commerce.
Last updated: October 2026.