Privacy Policy

AlphaTerra Capital Alternative Investment Fund Management Single Member S.A. (“AlphaTerra Capital,” “we,” “us,” “our,” or “the Firm”) is committed to protecting the privacy and security of the personal data you provide to us during your visit to our website and/or the use of our services. By visiting our website and/or contacting us, you accept and acknowledge that we collect and process your personal data in the manner prescribed in this Privacy Policy.

Our Privacy Policy complies with national legislation L.4624/2019 (the “Greek Legislation”), as well as the EU General Data Protection Regulation (the “EU Legislation”) ((EU) 2016/679).

This Policy explains how we collect, use and process your personal data in connection with your use of our website.

Last Updated: December 9, 2025

1. Who We Are (Data Controller)

Data Controller: AlphaTerra Capital Alternative Investment Fund Management Single Member S.A., Zalokosta 5, 10671 Athens, Greece.

Please feel free to contact our Data Controller representative for any inquiries pertaining to our Privacy Policy by email: info@alphaterra-capital.com or telephone: +30 210 3644 506.

2. Categories of Personal Data Processed

When you use one or more of our services, including visiting our website, requesting information or material about us and/or the Fund(s) we manage, and/or applying for employment with the Firm, you may provide personal information to us, and we may collect such personal information from you. Such personal information may include, inter alia:

Personal identification information, such as your name, email address, telephone number, nationality, marital status, age, VAT and social security number, professional qualifications, etc.
Financial information, including your income, amount of taxes paid, credit history, etc.
Information in the context of our AML and CTF policy, including your ties and/or connections with Politically Exposed Persons, sanctioned parties, etc.
Device information, such as IP address, browser settings, etc.

3. Purpose of Use and Processing of Your Personal Data

The personal information you provide to us is necessary in the context of entering into a contractual arrangement with us and/or complying with any applicable regulatory requirements we may have.

We shall not share your personal information with any third parties outside the Firm without prejudice to the designated third parties specified below. Please note that these third parties are bound by the same limitations as we are.

4. Whom We May Share Your Data With (Recipients)

As indicated above, we may share your personal information with designated third parties in the context of providing our services and/or managing our website and/or complying with the applicable regulatory requirements, as follows:

Service Providers, Sub-contractors, Legal Counsels, Administrators, Auditors, etc.: Your personal information may be shared with our service providers, sub-contractors and other professionals, such as the Fund’s administrators, prime brokers, auditors, lawyers, etc., in the context of performing our contractual obligations towards you and/or complying with our regulatory requirements.
Tax, Law Enforcement and Regulatory Authorities: We may share your personal information with any regulatory and/or law enforcement/judicial authorities if we are required to do so pursuant to the applicable legislative framework.
Divestment: In case we sell our business, your personal information may be shared with the potential buyer(s).

5. Transferring Data (Third Countries)

As a Greek AIFM, your data is primarily processed within the European Union (EU) and/or the European Economic Area (EEA). However, primarily because we manage a non-EU/EEA AIF, your personal data may in some situations be transferred to third countries outside the EU/EEA and processed by a supplier and/or sub-contractor, such as:

for example, by the Fund’s corporate service providers in their jurisdiction or by a cloud service provider. All such transfers shall comply with the applicable data protection regulations, including the use of appropriate safeguards in line with those laws.
For the avoidance of doubt, please note that in case of transfers of your personal data to a third country for the purposes of processing, the Firm shall use as safeguards the European Commission–approved Standard Contractual Clauses.

6. Data Retention

We only retain your personal data for as long as is required for us to comply with all applicable legal obligations, being the longest of the following periods:

as long as it is necessary for the purposes of performing our contractual obligations towards you;
the length of time it is reasonable to ensure our compliance with the professional and/or regulatory requirements to which we are subject;
any retention period as required by any applicable legislation;
the end of the period in which any litigation, discovery process and/or other investigations might arise in relation to our contractual relationship.

Please note that we periodically review our records to ensure that the retained information is accurate, up to date and still required.

7. Your Data Protection Rights as Data Subject

As a Data Subject, you have the following rights concerning your personal data:

The Right to Be Informed: You have the right to be informed if the processing of your personal data takes place (e.g., for what purposes, to which recipients it is disclosed, etc.).
The Right of Access: You have the right to request in writing a copy of the personal data we hold about you, and we shall respond within a reasonable period in compliance with the applicable Greek Legislation.
The Right to Rectification: You have the right to request the correction of any inaccurate or incomplete data about yourself.
The Right to Be Forgotten: You have the right to request the deletion of your personal data in cases where the data is no longer necessary for the purpose for which it was collected, subject to our legal and regulatory obligations.
The Right to Restriction of Processing: You have the right to request that we limit the way we use your data.
The Right to Data Portability: You have the right, where applicable, to request data portability in certain circumstances.
The Right to Object: You have the right to object to the processing of your personal data in certain circumstances.
The Right to Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us using the Data Controller email provided in Section 1.

Right to Lodge a Complaint

If you believe that your data protection rights have been violated, you have the right to lodge a complaint with the Hellenic Data Protection Authority (HDPA):

Hellenic Data Protection Authority
Address: Kifisias 1-3, Athens 115 23, Greece
Website: www.dpa.gr
Contact: email: contact@dpa.gr, telephone: +30 210 6475600

8. Cookies Policy

This website uses small text files called “cookies” to enhance your experience. We use the following types of cookies:

Essential Cookies: Required for the basic functionality of the website (e.g., managing security, remembering your cookie preference). These are strictly necessary for the website to function and do not require your consent.
Analytics Cookies: Used to analyze how visitors use our website and to monitor website performance. We only use these with your explicit consent.

You can manage your cookie preferences or withdraw your consent at any time through the website’s Cookie Consent Manager or by adjusting your browser settings.

9. How We Protect Your Personal Data

We ensure that we have controls and mechanisms in place that protect your personal data from any unauthorized access. Only our employees and authorized sub-contractors and professionals may have access to your personal data, and in any case they are always bound by confidentiality.

Please note that although we follow the industry standard pertaining to data protection safeguards, we cannot guarantee that your personal data can never be accessed by an unauthorized person. We can therefore not be held responsible for any intrusion or other unauthorized disclosure if the personal data has been submitted to us via the internet or other public network.

10. Changes to This Policy

We may update this Privacy Policy from time to time, without notice, to reflect changes in our practices or legal obligations. If our Privacy Policy changes, we will place an updated version on our website to ensure that you are always aware of our current Policy and your data protection rights.

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