Privacy & Data Handling Policy — Turbine Capital

1. Who we are

When you engage with us you trust us with your data. This policy intends to outline how we handle your company information as well as your personal data in line with General Data Protection Regulation (EU 2016/679) and your rights towards us and how you can use them. “Turbine Capital" (referring to TCAP Management AB as the main Data Controller but also including TCAP Fund 1 AB and all companies in the group) is a venture capital firm based in Sweden engaging in investments in unlisted companies with primarily domestic operations.

TCAP Management AB, 559488-0295, Östermalmsgatan 26A, 114 26 Stockholm

2. What Personal Data We Collect

We receive and collect personal data from you or third parties when you engage with us. Personal data that is given to us and processed:

  1. Contact form: Email & name

  2. When you send us a job application: Name, email, contact details, records to evaluate your suitability for the position and future career opportunities, your CV and personal letter, as well as other relevant documents

  3. If you contact us or engage in further discussions: We may collect additional personal data other than as informed above in order to ensure compliance with the relevant processes. 

We do not collect sensitive personal data (such as health or political information).

3. Personal data that we receive from third-party sources

We process personal data that are gathered from third-party sources. The following categories of personal data may be collected:

  1. When you sign up for an event through a third party service provider: Name & email

We do not use tracking cookies, tracking pixels, or other browser-based tracking technologies on www.turbinecapital.vc. If you are a partner of Turbine Capital engaging with us through other platforms such as Turbine Capital vector we use tracking cookies.

4. Why We Collect Personal Data

Your personal data will be deleted by us when processing is no longer necessary in line with stated above, except if otherwise required by law. We do not use personal data for automated decision-making.

Where processing is based on legitimate interest we evaluate that this processing does not override your rights and freedoms. Our legitimate interests include evaluating potential investments, maintaining business relationships, and communicating relevant updates.

5. Data Sharing

When engaging with us, we store personal data with third-party service providers. These third parties are limited by law and/or contract to use the personal data for purposes beyond that of which they are shared for. All hosting services use EU servers and we take care to ensure that all data handling remains fully compliant with EU data protection regulations. We do not intentionally transfer personal data outside the EU/EEA. If a transfer becomes necessary — for example when communicating with recipients outside the EU/EEA — we ensure appropriate safeguards.

The subcontractors we use include:

  1. Resource partners: External support in bookkeeping, legal or other expertise

  2. Cloud service provider: Providing hosting of personal data

  3. Event or marketing platforms: External platforms to facilitate event hosting or newsletters.

For the purpose of facilitating an investment or business opportunity we may share your personal data based upon legitimate interest with:

  1. Investors, companies, foundations

Personal data can be disclosed to the relevant authorities when required by applicable law. If Turbine Capital becomes subject to a transaction we may disclose personal data to a prospective buyer.  

6. Data Subject Rights

Under the General Data Protection Regulation (GDPR), individuals have the right to:

  • Access their personal data

  • Request correction or deletion

  • Object to processing

  • Withdraw consent (where applicable)

To exercise these rights, please contact us at: contact@turbinecapital.vc

You also have the right to send a complaint to the IMY (Integritetskyddsmyndigheten).

7. Data Security

We use adequate technical and organizational safeguards to ensure the security of your personal data. External service providers fulfill rigorous requirements in line with EU regulations.

8. Marketing & Opt-Out

If we send marketing communications, recipients will be offered a clear opt-out mechanism.

9. Sharing of non-personal data

Apart from processing personal information we also gather information about your company and business. Information about companies that contact us is shared with our investors (Limited Partners) through Turbine Capital Vector. The users (Limited Partners) are subject to confidentiality through a user agreement. 

Further we may use aggregated data for reporting and sharing in public settings.

10. Policy Updates

This policy may be updated from time to time. Updates will be reflected on our website or communicated via email when appropriate.

The policy was updated: 2025-12-10