Privacy Policy

2. Scope and Processing Roles

2.1 White-Label Clients

Where Pynn provides services to White-Label Clients, Pynn generally acts as a data processor under Article 28 GDPR, processing personal data on behalf of the White-Label Client, who acts as data controller. White-Label Clients are responsible for providing adequate privacy information to their end users and for ensuring lawful data processing instructions are given to Pynn.

2.2 Direct Users

For startups, investors, and other individuals who interact directly with Pynn-powered services, Pynn may act as a data controller for certain processing activities including platform analytics, service improvement, AI model development, and ecosystem intelligence.

2.3 Platform Data Storage and Use

3. Personal Data Processed

Pynn may process the following categories of personal data:

• Identification data: name, email address, company name, job title
• Professional contact details
• Startup and company information submitted via application forms
• Investment profile and interest data for investor users
• Technical data: IP address, browser type, device information, session data
• Platform usage and interaction data
• AI assessment inputs and outputs

No special categories of personal data as defined under Article 9 GDPR are processed unless expressly agreed in writing with the relevant White-Label Client.

4. Purposes of Processing

• Responding to enquiries and contact requests
• Managing contractual and pre-contractual relationships with White-Label Clients
• Providing, maintaining, and improving the Pynn platform and services
• Generating AI-powered startup assessments on behalf of White-Label Clients
• Operating the AngelHive global deal flow marketplace
• Training and improving Pynn's AI assessment models using aggregated and anonymised data
• Analysing platform performance, usage trends, and ecosystem data in aggregated and anonymised form
• Complying with legal and regulatory obligations

5. Legal Basis for Processing

• Performance of a contract (Article 6(1)(b)): for processing necessary to provide the subscribed services
• Legitimate interests (Article 6(1)(f)): for platform improvement, security, AI model development, and anonymised analytics
• Legal obligation (Article 6(1)(c)): where required by applicable law
• Consent (Article 6(1)(a)): where explicitly obtained for specific processing activities

6. Data Retention

Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected. For White-Label Client subscriber data, this means for the duration of the active subscription and thereafter as required by applicable Spanish and EU law.

Platform data — including startup profiles, investor profiles, and assessment data submitted through the Pynn platform — is retained by Pynn following termination of a White-Label Client subscription, as set out in Clause 7.3 of the Terms and Conditions. Individual data subjects retain their rights under this Privacy Policy regardless of the subscription status of the White-Label Client through which they were onboarded.

7. Data Recipients

Personal data may be shared with:

• Technology and hosting providers acting as data processors under Article 28 GDPR data processing agreements
• Payment processors (Stripe Inc.) for subscription billing purposes
• Public authorities where required by applicable law
• Other participants within the AngelHive marketplace, solely in respect of startup profile data that has been made visible by the originating White-Label Client's configuration settings

No personal data is sold to third parties. International data transfers outside the EEA are only carried out where appropriate safeguards are in place, including Standard Contractual Clauses or applicable adequacy decisions.

8. White-Label Processor Role

In white-label scenarios, Pynn acts as a data processor on behalf of the White-Label Client as data controller, processing personal data of the Client's end users in accordance with Article 28 GDPR. White-Label Clients retain full responsibility for informing their end users about data processing activities and for ensuring appropriate legal bases are in place for the processing of their end users' personal data.

10. Security Measures

Pynn implements appropriate technical and organisational measures to ensure the confidentiality, integrity, and availability of personal data in accordance with Article 32 GDPR, including encrypted data transmission, access controls, regular security reviews, and incident response procedures.

11. Cookies

The Pynn website and platform may use cookies and similar tracking technologies for functional, analytical, and performance purposes. Detailed cookie information is provided in the Pynn Cookie Policy available at pynn.ai.

12. Changes to This Policy

Pynn reserves the right to update this Privacy Policy to reflect legal, regulatory, or operational changes. The latest version is always available at pynn.ai. Material changes will be communicated to active White-Label Client subscribers via email at least 30 days prior to taking effect.

13. Contact

For questions regarding this Privacy Policy or the exercise of data subject rights: info@maxventures.eu