Effective Date: November 3, 2025

1. Introduction
   
   This Privacy Policy explains how R+ Capital (“we”, “us”, or “our”) collects, uses, and protects personal data when individuals (“you”, “members”, or “users”) apply for or participate in our private investor network (the “Platform”).
   We are committed to protecting your privacy and processing your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and applicable Polish data protection laws.
   By using the Platform or submitting your data to us, you agree to this Privacy Policy.

   
   

2. Data Controller
   
   The data controller is Mateusz Bodio operating the R+ Capital investor membership network.

   
   

3. What Data We Collect
   
   We collect only the information necessary to manage membership and operate the Platform effectively. This may include:
   Identification data: full name, email address, and contact details.

   Investor status: self-certification confirming you are a professional client under MiFID II.

   Technical data: browser type, device information, and IP address (for website analytics and security).

   Communication data: correspondence and preferences for receiving updates.
   We do not collect or process identification documents, financial statements, or personal data for KYC (Know Your Customer) or AML (Anti-Money Laundering) purposes. Those processes, if required, are performed directly by regulated third-party investment platforms.

4. How We Use Your Data

We use your personal data to:
Evaluate and process membership applications;

Communicate with you about membership, updates, or opportunities;

Maintain records of membership status and professional investor declarations;

Manage access to private areas of the Platform;

Improve the user experience and website security;

Comply with applicable legal obligations (e.g., recordkeeping).
We will not use your personal data for automated decision-making or profiling.

5. Data Sharing

We may share limited personal data with trusted third parties, but only where necessary and in accordance with GDPR:
Service providers: IT, hosting, and communication tools that support our Platform.

Regulatory or legal authorities: only when required by law.
We do not sell, rent, or trade personal data to any other parties.

6. Legal Basis for Processing

We process personal data on the following legal bases:

Purpose
Legal Basis
Processing membership applications
Performance of a contract (Art. 6(1)(b) GDPR)
Maintaining membership records and communications
Legitimate interest (Art. 6(1)(f))
Providing updates and information
Consent (Art. 6(1)(a))
Legal recordkeeping or compliance
Legal obligation (Art. 6(1)(c))

7. Data Retention
   
   We retain personal data only for as long as necessary to fulfill the purposes described in this Policy:
   While you remain a member of the Platform; and

Up to five (5) years after membership ends, unless longer retention is required by law.
Data used for email communications will be deleted immediately upon your withdrawal of consent.

8. Your Rights

As a data subject under GDPR, you have the right to:
Access – request a copy of your personal data we hold.

Rectify – correct inaccurate or incomplete data.

Erase – request deletion of your personal data (“right to be forgotten”).

Restrict processing – limit how we use your data.

Object – oppose processing based on legitimate interests.

Withdraw consent – opt out of optional communications at any time.

Data portability – request transfer of your data to another controller.

To exercise these rights, contact us at hello@rplus.vc.

We may need to verify your identity before processing your request.


9. Data Security

We use appropriate technical and organizational measures to protect your personal data from loss, misuse, unauthorized access, alteration, or destruction. Despite these efforts, no online transmission or storage method is completely secure, and we cannot guarantee absolute security.

10. International Transfers

Your data may be transferred to and processed by service providers or partners located outside the European Economic Area (EEA). Where this occurs, we use Standard Contractual Clauses (SCCs) or other safeguards approved under GDPR to ensure your data remains protected.

11. Cookies

Our website uses cookies and similar technologies to ensure proper functionality and to collect limited technical data about usage (e.g., pages visited, browser type, and session duration).
These cookies are strictly necessary to operate the website and to maintain secure member access.
We do not use cookies for advertising or behavioral tracking.
You can configure your browser to block or delete cookies at any time. For more information, see the “Help” section of your browser.

12. Updates to This Policy

We may update this Privacy Policy periodically. The latest version will always be available on our website with the updated “Effective Date.” If material changes occur, we will notify members by email or platform notice.

13. Contact

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us:
hello@rplus.vc