Data Policy.

Defy Ventures (“Defy Ventures”, “we”, “us”) is a portfolio of independent ventures. This website is operated by XCUBE.CO W.L.L. (“xcube.co”), a company incorporated in the Kingdom of Bahrain under commercial registration no. 181289-1, with its registered office at 3rd floor, Arcapita Building, Bahrain Bay, BH 346, Bahrain. xcube.co is responsible for the personal data collected through this website.

This Data Policy explains what personal data we collect through this website, why we collect it, and the choices you have. We handle personal data in line with the Kingdom of Bahrain’s Law No. (30) of 2018 with Respect to Personal Data Protection.

This policy applies to this website and its contact form. Each company in our portfolio is a separate entity with its own data policy for its own services.

01What we collect

We only collect what you give us through the contact form on this website. This includes:

• your name, professional email address, organisation and role;
• your LinkedIn profile;
• whether you are an investor, a technology partner, a financial institution, a startup or another type of organisation;
• your message;
• your consent to this Data Policy, with the date and time you gave it.

If you email us directly, we receive the details in your email.

Our hosting provider also processes standard technical data, such as your IP address and browser type, to deliver and secure the website. We do not use this data to identify you.

02Why we collect it

To reply to your enquiry about investing, partnering with us or joining our corporate accelerator programme.

To understand which organisations are interested in Defy Ventures. Your LinkedIn profile helps us confirm your professional context.

If your message concerns one of our portfolio companies, to pass it to that company so that it can reply to you. We tell you before we do so.

To keep a record of your consent, and to comply with the law.

We will not sell your personal data, and we will not share it with third parties for their own marketing.

03Consent

We collect and use your personal data on the basis of the consent you give by ticking the box on our contact form. The box is never pre-ticked, and you cannot submit the form without it. Your consent covers only the purposes described in this policy.

Withdrawing your consent. You can withdraw your consent at any time by emailing our Data Protection Officer, Julia Chin, at julia@jfourthsolutions.com. Once your withdrawal is processed, we will stop using your data for the purposes you consented to.

Withdrawing consent does not affect processing that took place before it, or processing the law permits or requires without consent.

04Service providers

We use trusted service providers to host the website, receive the form and host our email. They process data on our behalf, only for the purposes in this policy and under written contracts. We remain responsible for your personal data.

Provider	Purpose
Web3Forms	Receives the contact form and forwards it to our inbox
Infomaniak	Email hosting, where your message is stored
Vercel	Website hosting and delivery

05Transfers outside Bahrain

Some of our service providers are located outside the Kingdom of Bahrain. We transfer your data only to countries that the Personal Data Protection Authority recognises as offering sufficient protection, or with your consent, which you give when you submit the form.

06How long we keep it

We keep your enquiry for as long as we need it to follow up on your interest.

Where we go on to work together, we keep your data for as long as needed for legal, tax, accounting and contractual purposes.

We keep consent records for as long as we hold the related data.

We do not keep personal data in a form that identifies you for longer than the purpose requires. If you withdraw consent or ask us to delete your data, we will do so unless the law requires us to keep it.

07Your rights

You can ask us to:

• confirm whether we hold personal data about you, and tell you what it is, where it came from, why we use it and who receives it;
• correct, block or erase personal data that is inaccurate, incomplete or no longer needed;
• stop any direct communication with you;
• review a decision about you that was made only by automated means. We make no such decisions.

Email our Data Protection Officer, Julia Chin, at julia@jfourthsolutions.com. We may ask you to confirm your identity. Requests are free of charge. We answer requests for access within 15 working days, and requests to correct, erase or stop direct communication within 10 working days.

Accuracy. We rely on the information you give us. If your details change, please let us know so that they stay current, complete and accurate.

If you are not satisfied with how we have handled your personal data, please contact us first. You may also lodge a written complaint with the Personal Data Protection Authority of the Kingdom of Bahrain at pdp.gov.bh.

08Security

This website is served only over encrypted HTTPS connections. Access to form submissions is limited to the people who need it, protected by sign-in controls, and bound by confidentiality. No method of transmission or storage over the internet is completely secure, so we cannot guarantee absolute security, but we review our measures regularly.

If a breach affects your personal data, we will notify the Personal Data Protection Authority as Bahraini law requires, and we will inform you where it affects your rights.

09Cookies and trackers

This website does not use analytics or advertising cookies or trackers. We do not build profiles of visitors.

10Minors

This website is intended for professionals and institutions. We do not knowingly collect personal data from minors. If we learn that we have, we will delete it.

11Changes to this policy

We may update this Data Policy from time to time, for example in response to changes in the law or in how we run the site. The “Last updated” date at the top shows when it last changed. If we ever want to use your data for a new purpose, we will ask for your consent first.

12Contact us

For any question about this policy or your personal data, email our Data Protection Officer, Julia Chin, at julia@jfourthsolutions.com. For general enquiries, email info@defy.financial.