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GPX Platform - Privacy Policy

Controller: GreenPeak Capital Partners FZCO ("GreenPeak", "we", "us", "our")

Platform: GPX, accessible at 101globalcapital.com and associated subdomains and APIs (the "Platform")

Last updated: 11 June 2026

Effective date: 11 June 2026

This Privacy Policy explains how GreenPeak Capital Partners FZCO collects, uses, discloses, and protects personal data in connection with the Platform. It should be read together with our Terms of Service. By using the Platform you acknowledge the practices described here. If you do not agree, you should not use the Platform.

GreenPeak Capital Partners FZCO is a free zone company established in the International Free Zone Authority (IFZA), Dubai, United Arab Emirates, and acts as the controller of the personal data described below, except where we act as a processor on a Customer's behalf.

1. Scope

This Policy applies to personal data we process about: (a) visitors to the Platform; (b) registered users and the authorised users of our customers ("Users"); and (c) the business and professional individuals whose information is included in the Platform's intelligence database (the "Database"), such as contacts at investors, lenders, sponsors, and other organisations ("Profiled Individuals"). It does not apply to third-party websites or services we link to.

2. The personal data we process

We process the following categories of personal data:

Account and contact data - name, business email address, employer, job title, and the credentials or identifiers associated with your sign-in method, including data received from identity providers when you sign in with LinkedIn or Microsoft (such as your name, email address, and profile identifier).

Usage, device, and log data - information generated when you use the Platform, including IP address, device and browser information, pages and features accessed, queries run, reveals and exports performed, API and credit usage, timestamps, and diagnostic logs. This data is used for operation, security, abuse prevention, and analytics.

Customer Content - documents, briefs, teasers, and other materials you submit for analysis. Where these contain personal data, we process them on your behalf to provide the Platform.

Payment data - billing information necessary to administer subscriptions. Card and payment-instrument details are collected and processed directly by our payment processor; we do not store full card numbers.

Database (professional contact) data - business and professional information about Profiled Individuals, including name, job title, employer, professional/work email address, professional social-media identifiers (such as a LinkedIn URL), business location, role seniority, and publicly observable professional activity and relationships. This information relates to individuals in their professional or business capacity.

We do not intentionally collect special categories of data (such as health, religion, or political opinions) and ask that you do not submit them through Customer Content.

3. Sources of personal data

We obtain personal data: (a) directly from you when you register, sign in, communicate with us, or submit Customer Content; (b) automatically through your use of the Platform; (c) from identity and payment providers you choose to use; and (d) for the Database, from a variety of third-party and public and licensed sources, including public professional profiles, company websites, industry publications, transaction records, and data providers, which are then compiled, verified, enriched, and synthesised by us.

4. How and why we use personal data, and our legal bases

We process personal data for the following purposes and on the following legal bases (where the EU or UK General Data Protection Regulation applies; the corresponding bases under the UAE Personal Data Protection Law apply where it governs):

  • To provide and operate the Platform, administer accounts, authenticate Users, and deliver Output - necessary for the performance of our contract with you.
  • To administer subscriptions and process payments - performance of contract and compliance with legal obligations.
  • To secure the Platform, prevent abuse, enforce usage and credit limits, and maintain audit and reveal logs - our legitimate interests in protecting the Platform and its data, and compliance with legal obligations.
  • To operate, maintain, and improve the Database and provide capital-markets intelligence, including processing professional contact data about Profiled Individuals - our legitimate interests (and those of our customers) in providing and using business-to-business market intelligence, balanced against the interests and rights of the individuals concerned, who are processed only in their professional capacity and whose data is business-related.
  • To communicate with you about the Platform, service messages, and support - performance of contract and legitimate interests.
  • To comply with law, respond to lawful requests, and establish, exercise, or defend legal claims - compliance with legal obligations and legitimate interests.
  • Where we rely on consent (for example certain non-essential cookies or optional communications), you may withdraw it at any time.

5. Profiled Individuals and professional contact data

A core function of the Platform is the compilation of professional, business-to-business intelligence. Where we process personal data about Profiled Individuals, we do so on the basis of legitimate interests in providing market intelligence to professional users, we limit the data to business and professional information, and we apply data-minimisation and accuracy measures. Profiled Individuals have the rights described in Section 10, including the right to object to processing and to request access, correction, or erasure of their information. Requests can be made using the contact details in Section 14 and will be handled in accordance with applicable law.

Users who obtain contact data through the Platform are independent controllers of that data for their own use and are responsible for complying with applicable data-protection, privacy, and electronic-marketing laws, including providing any required notices and honouring objections, when they contact Profiled Individuals.

6. Cookies and similar technologies

We use cookies and similar technologies that are necessary for the Platform to function (such as authentication and security), and, where applicable and with consent where required, technologies for analytics and performance measurement. You can control non-essential cookies through your browser settings or any cookie controls we provide. Disabling necessary cookies may affect the functioning of the Platform.

7. How we share personal data

We do not sell personal data. We share personal data only as follows:

  • Service providers / processors that help us operate the Platform under contract and on our instructions, including our cloud and database infrastructure provider (Supabase), our payment processor (Stripe), our transactional email provider, and our data-enrichment provider (Apollo), among others. These providers are permitted to process personal data only to provide their services to us.
  • Professional users of the Platform, who access Output (including Database contact data) under the licence and restrictions in our Terms of Service.
  • Legal and compliance recipients, where required to comply with law, regulation, legal process, or a lawful governmental request, or to protect our rights, security, or property.
  • Corporate transactions - in connection with a merger, acquisition, financing, reorganisation, or sale of assets, subject to appropriate confidentiality.

8. International transfers

We and our service providers operate in multiple jurisdictions, including the United Arab Emirates, the European Union, the United Kingdom, and the United States. Where personal data is transferred across borders, we take steps to ensure an appropriate level of protection in accordance with applicable law, including using recognised transfer mechanisms such as standard contractual clauses or equivalent safeguards where required.

9. Data retention

We retain personal data for as long as necessary to provide the Platform, to operate and maintain the Database, to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Account and usage data are retained for the duration of your relationship with us and for a reasonable period thereafter. Database information is retained for as long as it remains relevant to the Platform's purpose, subject to accuracy and objection handling. When personal data is no longer required, we delete or anonymise it.

10. Your rights

Subject to applicable law (including the UAE Personal Data Protection Law and, where applicable, the EU and UK General Data Protection Regulation), you may have the right to: access the personal data we hold about you; request correction of inaccurate data; request erasure; restrict or object to certain processing (including processing based on legitimate interests, and direct marketing); request portability of data you provided to us; and withdraw consent where processing is based on consent. Where the GDPR applies, you also have the right to lodge a complaint with a supervisory authority. We may need to verify your identity before responding, and certain rights are subject to legal exceptions. We will respond within the timeframes required by applicable law.

11. Security

We implement technical and organisational measures designed to protect personal data, including access controls, authentication, encryption in transit, role-based and key-based access to sensitive functions, usage metering, audit logging of sensitive data access, and monitoring for anomalous activity. No system is completely secure, and we cannot guarantee absolute security.

12. Children

The Platform is intended for professional and institutional use and is not directed to, or intended for, individuals under 18 years of age. We do not knowingly collect personal data from children.

13. Changes to this Policy

We may update this Policy from time to time. Material changes will be indicated by updating the "Last updated" date and, where appropriate, by other reasonable means. Your continued use of the Platform after changes take effect constitutes acknowledgement of the updated Policy.

14. Contact and how to exercise your rights

For privacy questions, or to exercise any of your rights, including a request by a Profiled Individual to access, correct, object to, or remove their information, contact GreenPeak Capital Partners FZCO using the contact details published on 101globalcapital.com. We will handle your request in accordance with applicable data-protection law.

This Privacy Policy is provided for general information about our data practices and does not constitute legal advice.