Last updated: December 03, 2025

This Policy establishes the rules for processing personal data and regulates the use of the website https://leveluphub.io (hereinafter — the “Website”, “We”, the “Fund”, the “Company”) and the Telegram bot @Leveluphub_bot (hereinafter — the “Bot”).

Visiting the Website and/or interacting with the Bot constitutes acceptance of this Policy and confirms your voluntary consent to the processing of the personal data you provide.

1. General Provisions
1.1. Submission and evaluation of applications from entrepreneurs, startups, and project teams interested in receiving expert assessment and potential investment are carried out through the Website and the Bot, which serve as the respective tools for interaction.

1.2. This Policy applies to any information that the user transmits via the Website or the Bot, including project-related data, personal data, and any other materials provided.

1.3. Personal data is processed in accordance with applicable legislation and the principles of good faith. We take necessary measures to ensure confidentiality and security of the information and use the provided data strictly within the scope of the Fund’s activities.

2. Categories of Data Processed
Within the operation of the Website and the Bot, we collect and process the following categories of data provided by users:
2.1. We may collect the following types of personal information:

• Last name, first name, patronymic
• Contact information (including email, phone number, and/or the user’s Telegram identifier)
• Information about professional field, area of activity, or any other relevant characteristics
• Any other data voluntarily provided by the user

2.2. Project-related information, including:

• Project name and description
• Materials, documents, and any other data submitted by the user voluntarily
• Additional information provided by the user upon our request or submitted by their own initiative

3. Purposes of Processing Personal Data
3.1. The processing of personal data and project-related information is carried out solely for the following legitimate and justified purposes:

1. Conducting analysis, initial and expert evaluation of the submitted project
2. Establishing and maintaining communication with the user to clarify submitted information
3. Making a decision regarding the possibility of investment or further collaboration on the project
4. Improving and optimizing internal procedures related to the review and evaluation of project applications
5. Creating statistical data and conducting analytics based on aggregate submitted applications

4. Conditions for Disclosure of Project Information
4.1. The user confirms that they voluntarily provide information about their project for analysis and evaluation.

4.2. The user understands and agrees that even with all reasonable confidentiality measures in place, it is impossible to completely exclude the possibility that a similar idea or project may be independently created by third parties.

4.3. The Fund bears no responsibility if third parties create or launch a product or project similar to the one submitted by the user, provided that the Fund:

• has not disclosed the project information to third parties
• has not used the data in its own initiatives except for analytical purposes
• has ensured appropriate protective measures

5. Legal Grounds
5.1. Data processing is based on:
the user’s voluntary consent expressed when submitting information through the Website or the Bot
the legitimate interests of the Fund related to project evaluation and investment decision-making

6. Conditions for Using the Website and the Bot
6.1. The user guarantees that the data they provide is accurate, up-to-date, and submitted voluntarily.
6.2. The user confirms that they possess all rights to the materials and information they submit.
6.3. The Fund uses the submitted data solely for project evaluation and internal analysis.
6.4. The Website and the Bot serve as tools for communication and project submission. The Fund is not responsible for technical issues related to Telegram or Website hosting.

7. Data Transfer and Storage
7.1. We do not transfer personal data or project materials to third parties, except in the following cases:

• Your explicit separate consent
• Requirements of authorized government authorities
• Transfer within the group of companies (if applicable) purely for project evaluation purposes

7.2. The data retention period is no more than 3 years from the date of the last interaction, unless the user requests deletion earlier.
7.3. Data is stored on secure servers and in closed systems with restricted access.

8. User Rights
8.1. The user has the right to:

• Request information about what personal data is being processed
• Request corrections or amendments
• Request deletion of the data
• Restrict data processing
• Withdraw consent for data processing by sending a request to the Fund’s contact email

Upon withdrawal of consent, further project evaluation and interaction become impossible.

9. Use of the Telegram Bot @Leveluphub_bot
9.1. All information submitted via the Bot is processed under the terms of this Policy.
9.2. By submitting data through the Bot, the user consents to transferring the information to a third-party service — Telegram (Telegram’s terms apply separately).
9.3. The Fund is not responsible for failures in Telegram’s operation.

10. Updates to This Policy
10.1. We reserve the right to amend this Policy. The updated version is published on the Website with the effective date indicated.
10.2. Continued use of the Website and the Bot constitutes acceptance of the amendments.