Privacy Notice

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Last updated: May 2026

Statement

When using the term “personal data” or “personal information” in this Privacy Notice, we are referring to information that relates to you and allows us to identify you, either directly or in combination with other information we may hold.

Information Collected

Athena Ventures Limited (referred to as “Athena”, “we”, “us” or “our”) collects various personal information as part of our client onboarding process and, during our business relationship, to enable us to provide services to you. The personal data we collect is required to comply with Gibraltar and international regulations.

We do not knowingly collect information from children under 16 years of age. We will only process personal data for the specific purposes of providing our advisory and professional services, and for any other purposes specifically permitted by the Data Protection Act and the General Data Protection Regulations. All data is processed fairly and lawfully and in accordance with the rights of the data subject.

Cookies & Website

We use cookies on our website at www.athena.gi. For full details of the cookies we use and how to manage your preferences, please refer to our Cookie Policy.

How We Use Your Data

The legal bases for processing your personal information are to:

1. Comply with our legal and regulatory obligations;
2. Perform a contract with you, or take steps at your request prior to entering into a contract;
3. Pursue our legitimate interests in operating and developing our business; and
4. Where applicable, process data based on your explicit consent.

Categories of Personal Data

• Information and documentation relating to identity, location, family background, employment history and financial details;
• Information received from your advisors or agents where you have given us permission to receive it;
• Information that may be obtained from sources available in the public domain.

Location & Storage of Your Personal Data

1. Electronic data is stored in secure, cloud-based systems provided by reputable third-party technology providers. These providers maintain industry-standard security certifications and infrastructure.
2. Paper files are stored in secure filing cabinets at our office premises in Gibraltar.
3. Where personal data is held by third-party providers, whether within or outside of the EEA, we take steps to ensure that a similar degree of protection is afforded to it, including entering into appropriate data processing agreements.

We will notify you and the relevant supervisory authority if any data security procedure is breached and/or if we suspect that your personal data has been compromised or accessed by an unauthorised individual.

Retention of Data

We do not keep personal data longer than is necessary for the purpose or purposes for which it was collected. The longest we will normally hold any personal data is 6 years from the date on which our client relationship ends.

Third Parties & Disclosure

We will not disclose, rent, sell or otherwise transfer your personal information without your consent, except as otherwise set out in this Privacy Notice. Certain personal information may be shared with associated companies or third parties solely for the purposes of providing the appropriate services to you.

Your Rights

Your principal rights under data protection laws include:

1. The right to access your personal data;
2. The right to rectification of inaccurate personal data;
3. The right to erasure of your personal data in certain circumstances;
4. The right to restrict processing of your personal data;
5. The right to object to processing of your personal data;
6. The right to data portability;
7. The right to complain to a supervisory authority; and
8. The right to withdraw consent where processing is based on consent.

Withdrawing Consent

If you wish to withdraw your consent to the processing of your personal data, you may do so in writing. Please note that such a withdrawal may affect the way in which we are able to deal with you and/or to provide services to you. We are legally and contractually obliged to retain certain information in accordance with applicable legislation, and withdrawal of consent does not affect the lawfulness of any processing carried out prior to the withdrawal.

Contact Us

Information requests will be free of charge. All requests will be processed and responded to within 28 days.

Legal entity	Athena Ventures Limited
Data Privacy Manager	David Frier, Director
Email	data@athena.gi
Telephone	(+350) 200 42250
Address	30/1 Cornwall’s Lane, P.O. Box 1451, Gibraltar GX11 1AA

Complaints

You have the right to lodge a complaint with the Gibraltar Regulatory Authority: www.gra.gi/data-protection

Appendix 1 — Personal Information

Types of personal data we may collect about you include:

• Full name and any previous names
• Residential and correspondence address
• Contact details (telephone number and email address)
• Date of birth • Gender • Nationality and country of residence
• Marital or relationship status
• Tax Identification Number
• National Insurance or Social Security Number
• Occupation and employment background
• Passport and/or national identity card details
• Bank account details • Source of wealth and source of funds
• Information relating to companies or other entities you are connected with
• Correspondence and communications with us

Sensitive Personal Data

Sensitive personal data is held only where this is directly relevant to the provision of our services, and subject to the express consent of the data subject (such consent may be withdrawn at any time).