Sagee Capital Ltd, a company incorporated and registered in the Republic of Cyprus, with registration number HE 482055 and registered office address at 1 Arch. Kyprianou & Ayiou Andreou Corner, Loucaides Building, 6th floor, 3036 (“Sagee Capital”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how Sagee Capital collects, uses, discloses, and protects personal data when you visit sageecapital.com (the “Website”), contact us, or otherwise interact with us in the context of our activities as a family office and venture creation ecosystem. This Privacy Policy is provided in accordance with applicable data protection laws, including, where applicable, the EU General Data Protection Regulation (“EU GDPR”) and the UK General Data Protection Regulation (“UK GDPR”), together “GDPR”.
1. Contact UsController For the purposes of data protection laws, Sagee Capital is the “controller” of your personal data processed via the Website. Contact details Name: Sagee Capital Ltd Postal address: 1 Arch. Kyprianou & Ayiou Andreou Corner, Loucaides Building, 6th floor, 3036 Limassol, Cyprus Email: info@sageecapital.com
If you have any questions about this Privacy Policy or how your personal data is handled, contact us using the details above. If a data protection officer (DPO) or EU/UK representative is appointed in the future, their contact details will be added here.
2. ScopeThis Privacy Policy applies to: Visitors to the Website (including those viewing information about our family office, Sagee Manor, and ventures such as Cullinan 1905). Individuals who contact us via Website forms, email, telephone, or social media in relation to potential investments, partnerships, employment, or other enquiries. Individuals whose details are provided to us by third parties (e.g. professional advisers, introducers, or portfolio companies) in the context of our family office activities. This Privacy Policy does not govern the processing of personal data: In the context of formal client, investor, or transaction engagements (e.g. KYC/AML, legal documentation), which may be subject to additional or separate privacy notices; or By portfolio companies, co‑investors, or other third parties, each of which will act as an independent controller with its own privacy documentation.
3. Personal Data3.1 Data you provide directly: When you interact with us via the Website or otherwise, you may provide: Identification and contact data – name, title, organisation, role, email address, telephone number, business website, social media handles, postal address, country of residence.
Professional and investment‑related information – company name, business area, nature of your query (e.g. capital introduction, venture collaboration, family office services), information contained in pitch decks or investment proposals. Communications – records of correspondence with us (including emails, contact form submissions, meeting notes, call logs). Event‑related data – if we invite you to or you register for events (e.g. presentations or site visits relating to Sagee Manor or Cullinan 1905), we may collect your preferences, attendance status and related logistics information. Marketing preferences – your choices regarding receiving updates about Sagee Capital, our projects, or thought leadership. If you submit information about third parties (e.g. colleagues, principals, beneficial owners), you confirm that you have authority to do so and that the individuals have been informed of this Privacy Policy.
3.2 Data we collect automatically When you visit the Website, we may automatically collect: Technical data – IP address, browser type and version, device identifiers, operating system, time zone setting, and other technology on the devices you use to access the Website. Usage data – pages visited, time and date of visit, time spent on each page, clickstream data, interaction with page elements, referring URLs. Cookie data – information from cookies and similar technologies (pixels, tags, SDKs, local storage) used for: Necessary functions (e.g. security, load balancing, session management); Analytics and performance; Preference and personalisation; (Where implemented) marketing and retargeting. More detail on cookies is provided in Section 6 and, where available, our separate Cookie Policy.
3.3 Data from third parties and public sources: Where permitted by law, we may receive personal data from: Professional advisers and intermediaries – lawyers, accountants, corporate finance advisers, introducers, and other intermediaries who share your details for potential collaboration, investment, or transaction opportunities. Portfolio companies and co‑investors – in the context of transaction diligence, board participation, or portfolio support. Public and official sources – corporate registries, sanctions and PEP lists, press reports, professional social networks, company websites and regulatory filings, to verify information and conduct compliance checks. Service providers – analytics providers, advertising networks, and search information providers, where such data is collected and shared in compliance with cookie consent and applicable law.
4. How and when we use your personal dataUnder GDPR, we must have a valid legal basis to process your personal data. Depending on the circumstances, we most commonly rely on one or more of the following bases: consent, performance of a contract or steps prior to entering into a contract, compliance with legal obligations, and legitimate interests.
4.1 Website operation and security Purpose: Operating, administering, and securing the Website (including detecting and preventing fraud, abuse, and cyber‑attacks). Data: Technical and usage data, log files, limited identification data where necessary for investigation. Legal basis: Our legitimate interest in providing a secure, reliable Website and protecting our business (Article 6(1)(f) GDPR). 4.2 Responding to enquiries and relationship management Purpose: Responding to contact form submissions, emails, calls and social media messages; maintaining contact records; scheduling meetings; evaluating potential business or investment opportunities; managing ongoing relationships. Data: Identification/contact data, communications, professional and investment‑related information. Legal bases: Taking steps at your request prior to entering into a contract (Article 6(1)(b)), where applicable, and/or Our legitimate interest in developing and managing relationships with counterparties, investors, and partners and in maintaining communication (Article 6(1)(f)), subject to balancing against individual rights. 4.3 Investment, transaction, and due diligence activities Purpose: Evaluating and executing investment and transaction opportunities, including basic diligence on management teams, beneficial owners, and key stakeholders; assessing strategic fit and risk; managing ongoing asset and portfolio governance. Data: Identification/contact data, professional information, information from public and third‑party sources, any information contained in materials you provide. Legal bases: Our legitimate interest in conducting prudent investment and business management; Compliance with legal and regulatory obligations (e.g. anti‑money laundering, sanctions screening, record‑keeping) where relevant (Article 6(1)(c)). Where formal KYC/AML is undertaken, additional privacy information may be provided.
4.4 Marketing, updates, and thought leadership Purpose: Sending carefully selected communications about Sagee Capital, our projects (e.g. venture creation initiatives, assets such as Sagee Manor or ventures such as Cullinan 1905), events, and insights that may be of interest to you. Data: Identification/contact data, professional information, marketing preferences, interaction history. Legal bases: Consent, where required (e.g. certain electronic direct marketing to individuals); and/or Our legitimate interest in promoting and growing our business with professional contacts in a proportionate manner (Article 6(1)(f)). You can opt out of marketing at any time (see Section 9).
4.5 Analytics and improvement Purpose: Understanding how visitors use the Website; improving user experience, content relevance, design and navigation; assessing the impact of our communications.
Data: Technical, usage and cookie data (primarily aggregated or pseudonymised). Legal basis: Non‑essential cookies and similar technologies are processed based on your consent (Article 6(1)(a)). Where we analyse aggregated or anonymised statistical information to improve our Website, we rely on our legitimate interests (Article 6(1)(f) GDPR) in operating and enhancing a high-quality Website. 4.6 Legal and regulatory obligations; risk management Purpose: Where necessary to comply with applicable laws and regulations; respond to regulatory or law enforcement requests; establish, exercise, or defend legal claims; ensure corporate governance, conduct audits, and manage legal and operational risks.
Data: Any relevant category of data, limited to what is necessary. Legal basis: Compliance with legal obligations (Article 6(1)(c)) and our legitimate interest in protecting our rights and interests (Article 6(1)(f)). 4.7 Corporate transactions and restructuring (edge case) Purpose: In the context of strategic transactions, such as a sale, acquisition, merger, restructuring, or asset transfer involving Sagee Capital or any of its projects, where personal data may be transferred as part of the transaction. Data: Contact and business relationship data and other relevant data, limited to what is necessary and subject to appropriate safeguards. Legal basis: Our legitimate interest in enabling and completing corporate transactions (Article 6(1)(f)). Purpose: Sending carefully selected communications about Sagee Capital, our projects (e.g. venture creation initiatives, assets such as Sagee Manor or ventures such as Cullinan 1905), events, and insights that may be of interest to you. Data: Identification/contact data, professional information, marketing preferences, interaction history. Legal bases: Consent, where required (e.g. certain electronic direct marketing to individuals); and/or Our legitimate interest in promoting and growing our business with professional contacts in a proportionate manner (Article 6(1)(f)). You can opt out of marketing at any time (see Section 9).
5. Special categories of personal dataThe Website is not intended to collect special category data (e.g. health, political opinions, religious beliefs) or criminal offence data. Such information should not be submitted via general contact forms. 6. Cookies and similar technologies6.1 What are cookies? Cookies are small text files placed on your device by websites you visit. Similar technologies include pixels, tags, and local storage. They can be “session” cookies (deleted when you close your browser) or “persistent” cookies (stored for a defined period).
6.2 Types of cookies we use On the Website, we may use: Strictly necessary cookies Essential for the operation of the Website (e.g. page navigation, load balancing, security, consent management). These do not require your consent but are disclosed for transparency. Preference / functional cookies Remember choices (e.g. language, region, cookie preferences). Used to provide an enhanced user experience. Analytics / performance cookies Collect information on how visitors use the Website (e.g. page views, time on site, navigation paths) to help improve performance and content. For example, we may use privacy‑centric analytics tools or, if implemented, Google Analytics with IP‑anonymisation and appropriate configuration. Marketing and social media cookies (if implemented) Used to deliver or measure digital campaigns (e.g. for awareness of major projects like Cullinan 1905) or to enable social media sharing features. These may be set by third parties (e.g. LinkedIn, Meta, X) to build profiles of your interests.
6.3 Cookie consent and control Non‑essential cookies (preference, analytics, marketing) will only be set with your consent, obtained through our cookie banner or consent management platform, in line with GDPR and ePrivacy rules. You can: Accept or reject all non‑essential cookies; Manage preferences by cookie category; Withdraw or change your consent at any time using the cookie settings link (e.g. “Cookie Settings”) available on the Website. Your browser may also allow you to block or delete cookies. However, blocking certain cookies may affect the Website’s functionality. A more detailed description of the specific cookies used, their providers, purposes, and retention periods is available in our Cookie Policy [link], which forms part of this Privacy Policy.
8. International data transfersGiven the international nature of our activities and use of global service providers, your personal data may be transferred to and processed in countries outside the European Economic Area (“EEA”) and/or the UK , including locations that may have different data protection standards.
Where such transfers occur, Sagee Capital will ensure that (as applicable):The transfer is to a country deemed to provide an adequate level of protection by the European Commission and/or UK authorities; or
Appropriate safeguards are in place, such as standard contractual clauses (SCCs) approved by the European Commission or the UK Secretary of State, together with additional security and contractual protections where required; or
A specific derogation applies (for example, where the transfer is necessary for the performance of a contract or for the establishment, exercise, or defence of legal claims).
You may contact us for more information about international transfers and to obtain a copy of the relevant safeguards (subject to redactions for confidentiality).
7. Who we share your personal data withSagee Capital will not sell your personal data. We may share your data with: Service providers (processors) – trusted third parties who provide services to us such as Website hosting, IT support, security, analytics, CRM systems, email delivery, and professional communication tools. These providers are bound by contractual obligations to only process personal data on our instructions and to implement appropriate security measures.
Professional advisers – including lawyers, accountants, auditors, and consultants where necessary for the purposes described in this Privacy Policy.
Portfolio companies and co‑investors – in connection with a specific investment opportunity or transaction, where data sharing is necessary and appropriate confidentiality measures are in place.
Authorities and regulators – where required by law or reasonably necessary to protect our rights, respond to legal process, or cooperate with regulatory investigations.
Prospective buyers or business partners – in the context of mergers, acquisitions, or other corporate transactions (see Section 4.7), subject to confidentiality and data protection safeguards.Where third parties act as independent controllers (for example, a social media platform or a portfolio company), their own privacy notices will apply. Personal data will be retained only for as long as reasonably necessary to fulfil the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting requirements.
9. Data retentionPersonal data will be retained only for as long as reasonably necessary to fulfil the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting requirements. Indicative retention periods include: Website logs and basic technical data: typically a few months, unless required longer for security or investigation. General enquiries and relationship records: usually up to [3–7] years from last meaningful contact, depending on the context and applicable limitation periods. Marketing contact details: for as long as you remain engaged and have not withdrawn consent or opted out, subject to periodic review. Investment and transaction‑related records: as required under applicable financial, corporate, tax or regulatory requirements, which can be significantly longer (often up to 10 years or more from the end of the relevant relationship). Where data is no longer needed, it will be securely deleted or anonymised so it can no longer be associated with an identifiable individual.
10. Data protectionSagee Capital implements appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access.
These measures may include: Access controls and least‑privilege principles; Secure networks, encryption in transit and at rest where appropriate; Regular software updates and security patching; Use of reputable hosting and infrastructure providers; Internal policies, confidentiality undertakings, and limited access based on role; Incident response procedures, regularly reviewed.
While no system can be completely secure, these controls are designed to reduce the risk of data breaches to a level appropriate to the nature and sensitivity of the data and the risks involved.
12. Complaints to supervisory authoritiesYou have the right to lodge a complaint with your local data protection authority. For example: If you are in Cyprus, with the Office of the Commissioner for Personal Data Protection;
You may contact them at: Address: Kypranoros 15, Nicosia 1061 , Cyprus Telephone: +357 22818456 Email: commissioner@dataprotection.gov.cy Website: https://www.dataprotection.gov.cy
If you are in the UK, with the Information Commissioner’s Office (ICO); Or with the authority in the EU Member State of your habitual residence, place of work, or alleged infringement. 13. ChildrenThe Website is not directed at, nor intended for use by, children under the age of 18, and Sagee Capital does not knowingly collect personal data from children via the Website. If you believe that a child has provided personal data to us, please contact us so that appropriate steps can be taken to delete such data and, if necessary, restrict related processing. 14. Automated decision‑making and profilingSagee Capital does not use automated decision‑making (including profiling) via the Website that produces legal effects concerning you or similarly significantly affects you. If this changes – for example, if any online tools, loyalty or gamification features, or digital engagement platforms associated with our ventures are integrated into the Website such that automated decisions significantly affect individuals – additional information will be provided and the processing will be conducted in line with applicable legal requirements, including obtaining consent where required.
11. Your data protection rightsSubject to applicable law and certain conditions and exemptions, you may have the following rights in relation to your personal data: Right of access – to obtain confirmation whether Sagee Capital processes your personal data and, if so, to receive a copy of the personal data we hold about you. Right to rectification – to have inaccurate or incomplete personal data corrected. Right to erasure (“right to be forgotten”) – to request deletion of your personal data in certain circumstances (e.g. where it is no longer necessary, or consent is withdrawn and there is no other legal basis). We may retain data where we are legally required to do so or for the exercise, establishment or defence of legal claims. Right to restriction of processing – to request that processing is restricted in certain cases (e.g. while the accuracy of data is contested). Right to data portability – to receive personal data you provided to us in a structured, commonly used, machine‑readable format and to transmit it to another controller, where technically feasible and where processing is based on consent or contract and carried out by automated means. Right to object – To processing based on our legitimate interests, on grounds relating to your particular situation; and To direct marketing at any time (including profiling related to such marketing). Right to withdraw consent – where processing is based on consent, you may withdraw that consent at any time. This will not affect the lawfulness of processing prior to withdrawal. Right to lodge a complaint – with a competent supervisory authority if you believe your rights have been infringed.
To receive more information and/or exercise any of these rights, contact us using the details in Section 1. We may need to verify your identity before acting on your request and will respond within the timeframes required by applicable law.
15. Third-party websites and social mediaThe Website may contain links to third‑party websites, services, or social media platforms (e.g. LinkedIn, Instagram, specialist real estate or investment sites). Clicking on such links may allow third parties to collect or share data about you. These websites are not controlled by Sagee Capital, and this Privacy Policy does not cover their processing. You are encouraged to read the privacy policies of each site you visit.
16. Changes to this privacy policySagee Capital may update this Privacy Policy from time to time, for example to reflect changes in law, guidance, or our operations. When changes are made, the “Last updated” date at the top will be revised. In cases of material changes, reasonable efforts will be made to notify you, which may include a prominent notice on the Website. You are encouraged to review this Privacy Policy periodically to stay informed about how Sagee Capital protects your personal data
