Privacy Policy

1. Data Controller

ETIIC Sàrl ("ETIIC", "we", "us"), as the sponsoring entity of the Y7 Capital initiative, is the data controller responsible for your personal data processed through this website. Upon establishment of Y7 Capital Management S.à r.l. in Luxembourg (anticipated 2026), data controller responsibilities will transfer accordingly.

2. Data We Collect

We collect and process the following categories of personal data:

• Contact Information: Name, email address, phone number when you contact us
• Technical Data: IP address, browser type, device information, pages visited
• Usage Data: How you interact with our website, collected via cookies
• Professional Information: Company name, role, investment interests (if provided)

3. Legal Basis for Processing

We process your personal data under the following legal bases per GDPR Article 6:

• Consent (Art. 6(1)(a)): For analytics and marketing cookies
• Legitimate Interest (Art. 6(1)(f)): For website security, fraud prevention, and business development
• Contractual Necessity (Art. 6(1)(b)): For communications regarding potential investments
• Legal Obligation (Art. 6(1)(c)): For regulatory compliance and record-keeping

4. Cookies

We use cookies categorized as follows:

• Essential Cookies: Required for website functionality (always active)
• Analytics Cookies: Google Analytics for understanding site usage (opt-in)
• Marketing Cookies: LinkedIn Insight for campaign measurement (opt-in)

You can manage cookie preferences at any time via the cookie settings icon in the bottom-left corner.

5. Data Sharing

We may share your data with:

• Service providers (hosting, analytics) under data processing agreements
• Professional advisors (legal, accounting) under confidentiality obligations
• Regulatory authorities when required by law

We do not sell your personal data to third parties.

6. International Transfers

Some of our service providers are based outside the EEA. For transfers to the United States, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission to ensure adequate protection.

7. Data Retention

• Contact inquiries: 3 years from last contact
• Analytics data: 26 months
• Regulatory records: 10 years (as required by CSSF)

8. Your Rights

Under GDPR, you have the right to:

• Access your personal data
• Rectify inaccurate data
• Erase your data ("right to be forgotten")
• Restrict processing
• Data portability
• Object to processing
• Withdraw consent at any time

To exercise these rights, contact: privacy@etiic.com

9. Supervisory Authority

For EU residents, you may also contact the supervisory authority in your country of residence.

10. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be communicated via our website. Continued use of the site after changes constitutes acceptance.