Note: This is a courtesy translation. The Spanish version of this Privacy Policy is the legally binding one. In case of discrepancy between versions, the Spanish text shall prevail.

Privacy Policy

Last updated: 17 September 2026

At Álamos Innovación, we process personal information responsibly, transparently and only for the purposes for which it is necessary.

This Privacy Policy explains what personal data we may process when you use the Álamos Innovación website, contact us, submit a startup for assessment, use AngelGrade or its portal, or maintain a professional relationship or a relationship linked to a potential investment with us.

1. Data Controller

Data Controller: ALAMOS INNOVACION SL
Trade name: Álamos Innovación
Privacy contact email: contacto@alamosinnovacion.com

The company’s remaining identification and registration details can be found in the Legal Notice on this website.

AngelGrade is an investment opportunity analysis and management tool operated by ALAMOS INNOVACION SL. It is not a separate data controller.

2. What Data We May Process

The data we process depends on your relationship with Álamos Innovación and on the features you use.

2.1. Contact through the website

When you contact us through a form, email or another contact channel, we may process:

• first and last name;
• email address;
• company and job title;
• telephone number, if you provide it;
• information included in your enquiry or message.

2.2. Startup submissions and AngelGrade Radar

When you use the “Submit your startup” feature or an opportunity is registered in AngelGrade Radar, we may process:

• first and last name, email address and job title of the contact person;
• startup name, website, headquarters and general company information;
• information about the sector, business model, product and customer type;
• information about the founding team;
• traction, customers, sales, revenue or other relevant metrics;
• information relating to funding rounds, funding raised, valuation and financing needs;
• objectives associated with the funding round;
• information on the areas where the team considers Álamos Innovación may be able to add value;
• pitch deck and other documents voluntarily provided;
• technical information necessary for the security, traceability and operation of the form.

Some of this information may relate to the company itself and may not, by itself, constitute personal data. However, documents submitted may contain personal data relating to founders, employees, investors or other individuals.

2.3. Full evaluation of investment opportunities

When an opportunity moves into a more detailed assessment process through AngelGrade, we may additionally process:

• expanded information about founders and team members;
• relevant professional experience;
• corporate structure and, where necessary, information relating to shareholdings;
• financial, commercial and operational information;
• corporate, financial, technical and commercial documentation;
• information on customers, contracts, intellectual or industrial property and other assets;
• responses to due diligence processes;
• communications exchanged during the assessment;
• notes, analyses, scores and conclusions generated during the process.

We may also supplement the information provided with professional or business information obtained from legitimate public sources, such as corporate websites, professional profiles, public registers, publications, business databases and other lawfully accessible sources.

2.4. Entrepreneur Portal and AngelGrade users

When an account or portal access is created, we may process:

• first and last name;
• email address;
• role and company;
• credentials and information associated with the account;
• access permissions;
• information and documentation submitted during the process;
• activity necessary to maintain the security and traceability of the system.

2.5. Technical, security and browsing data

We may process:

• IP address;
• access date and time;
• device or browser type;
• technical logs;
• security events;
• information necessary to prevent abuse, fraud, spam or unauthorised access.

The use of cookies and similar technologies is also governed by our Cookie Policy.

3. Why We Use Your Data and Our Legal Basis

3.1. Responding to enquiries and information requests

We use your data to respond to messages, answer questions and manage requests made through the website or by email.

Legal basis: consent arising from the request made by the data subject and, where the enquiry concerns a potential contractual or professional relationship, steps taken at the request of the data subject prior to entering into a contract.

3.2. Managing professional services

Where a professional relationship exists, we use the data necessary to manage the provision of services, communications, invoicing and related obligations.

Legal basis: performance of a contract, steps taken prior to entering into a contract and compliance with legal obligations.

3.3. Receiving and analysing startup proposals

We use the information submitted through “Submit your startup”, AngelGrade Radar or other channels to:

• register the opportunity;
• assess its initial fit;
• understand the project and funding round;
• assess its potential interest;
• organise and compare opportunities;
• contact the entrepreneurial team;
• request additional information;
• decide whether to proceed to a more detailed evaluation.

Legal basis: Álamos Innovación’s legitimate interest in receiving, organising and assessing investment opportunities voluntarily submitted to us and, where appropriate, steps taken at the request of the data subject prior to entering into a contract.

3.4. Assessing a potential investment or collaboration

When an opportunity progresses, the data may be processed to:

• analyse the startup, team, market, business model, traction and funding round;
• perform valuations;
• identify risks and issues requiring clarification;
• conduct due diligence;
• prepare questions, analyses and investment reports;
• assess possible forms of investment, support or value contribution to the project;
• negotiate, where appropriate, the terms of a potential relationship.

Legal basis: Álamos Innovación’s legitimate interest in analysing and managing potential investments and controlling the associated risks and, where appropriate, steps taken prior to entering into a contract or performance of any agreements that may be reached.

3.5. Managing AngelGrade and the portal

Data is used to create and maintain accounts, manage permissions, enable information exchange between authorised persons, preserve process traceability and ensure system security.

Legal basis: performance or preparation of the relevant relationship and our legitimate interest in securely managing the evaluation process.

3.6. Sending operational communications

We may send emails necessary for the operation of the process, for example:

• confirmation that a startup submission has been received;
• requests for additional information;
• portal invitations;
• notices relating to an evaluation;
• communications connected with a professional or investment-related relationship.

These communications are not considered marketing communications where they are necessary to manage the relevant relationship or request.

3.7. Security and abuse prevention

We may use technical information to protect our systems, prevent fraud, spam, abusive use or unauthorised access and diagnose errors.

Legal basis: Álamos Innovación’s legitimate interest in ensuring the security of its services, systems and information.

3.8. Compliance with obligations and protection of legal rights

We may retain and use certain data where necessary to:

• comply with legal obligations;
• respond to requests from authorities;
• handle claims;
• establish, exercise or defend legal rights or claims.

Legal basis: compliance with legal obligations and legitimate interest in the defence of legal rights.

4. Use of Artificial Intelligence and Evaluation Support Tools

AngelGrade may use automated systems and artificial intelligence tools to help organise and analyse available information.

These tools may be used, among other purposes, to:

• extract data from documents;
• summarise information;
• identify missing information;
• cross-check data;
• prepare questions;
• carry out research;
• propose preliminary assessments;
• identify risks or inconsistencies;
• generate draft analyses and reports.

Scores, classifications, alerts or recommendations generated by AngelGrade are decision-support tools.

Álamos Innovación does not make investment decisions based solely on automated processing that produces legal effects or similarly significant effects on the data subject.

The decision to continue an evaluation, request further information, initiate due diligence, negotiate a potential transaction or make an investment is ultimately made by a person.

5. Where the Data Comes From

Most of the data is provided directly by the data subject or by the startup team.

During an evaluation, we may also obtain information from:

• other authorised team members;
• corporate documentation provided;
• websites and professional profiles;
• public registers;
• publications;
• business databases;
• media outlets;
• other lawfully accessible sources.

Where personal data is obtained from sources other than the data subject, it will only be processed where there is a lawful basis to do so and in accordance with the principles of necessity and proportionality.

6. Personal Data of Third Parties Included in Documents

If you submit a pitch deck or other documentation containing personal information about other individuals, such as co-founders, employees or advisers, you should ensure that the data included is adequate, relevant and limited to what is necessary to present or evaluate the project.

Anyone providing personal information about third parties must be authorised to do so and, where applicable, must have informed those individuals about the disclosure.

Special category or otherwise sensitive personal data that is not necessary for the assessment of the startup should not be included.

7. Who May Receive or Access the Data

We do not sell personal data or disclose it to third parties for their own commercial or advertising purposes.

Certain service providers acting as processors or sub-processors may have access to some data in order to provide our services and operate our technological infrastructure.

These may include:

• Vercel, for website hosting and infrastructure;
• Supabase, for databases, authentication and secure storage of information and documents;
• Brevo, for communications and transactional emails;
• Anthropic, when its artificial intelligence services are used as part of the analysis process;
• analytics and web service providers, such as Google, where those services are enabled in accordance with the relevant configuration and consent requirements;
• other technology providers strictly necessary to operate the services.

These providers may only process the data in accordance with the applicable contractual terms and corresponding instructions where they act as data processors.

Data may also be disclosed:

• to legal, tax, accounting or other professional advisers where necessary;
• to public authorities, courts or other authorities where required by law;
• to other recipients where there is a sufficient lawful basis.

Other investors or co-investors

Submitting a startup to Álamos Innovación does not in itself mean that the pitch deck or confidential information will be distributed to other investors.

Where it may be useful to share an opportunity with a co-investor or another independent third party for evaluation purposes, this will only be done where a lawful basis exists and, where appropriate, the entrepreneurial team will be informed in advance or its authorisation will be requested.

AngelGrade users acting as co-investors may only access projects that have been expressly shared with them and within the permissions assigned to them.

8. International Data Transfers

Some technology providers used by Álamos Innovación or their sub-processors may be located outside the European Economic Area or may process information outside it.

Where an international transfer of personal data takes place, mechanisms recognised under applicable data protection law will be used, such as:

• adequacy decisions adopted by the European Commission;
• Standard Contractual Clauses approved by the European Commission;
• or other legally recognised safeguards.

You may request further information about the applicable safeguards by contacting contacto@alamosinnovacion.com.

9. How Long We Keep the Data

Data will be retained for as long as necessary to fulfil the purpose for which it was collected.

As a general rule:

Enquiries that do not lead to a further relationship

Data may be retained for up to 12 months from the last interaction, unless it is necessary to retain it for longer for a legitimate or legal reason.

Startups submitted that do not progress

The information, Startup Snapshot and pitch deck may be retained for up to 24 months from the last interaction.

This period allows us to maintain a reasonable history of assessed opportunities, including the possibility of reassessing a company whose situation has evolved.

The data subject may request earlier deletion where legally applicable.

Startups that move to full evaluation

Data will be retained for the duration of the assessment, negotiation or any subsequent relationship and afterwards for the periods necessary to comply with legal obligations and address potential liabilities arising from the relationship.

Portal users

Data associated with portal access will be retained for as long as the user requires access to the project and afterwards for the period necessary depending on the status and retention of the relevant file or record.

Technical and security logs

These will be retained only for as long as strictly necessary to ensure security, investigate incidents and protect the systems, in accordance with the configuration and policies of the services used.

Once the applicable retention periods expire, the data will be deleted or restricted where legally required.

10. Your Rights

Where applicable, you may exercise the following rights:

• Access: obtain confirmation of whether we process personal data about you and access that data.
• Rectification: request correction of inaccurate data.
• Erasure: request deletion of your data where applicable.
• Restriction: request temporary restriction of processing in certain circumstances.
• Objection: object to certain processing based on legitimate interests.
• Data portability: receive certain data in a structured format and transmit it to another controller where applicable.
• Withdrawal of consent: where processing is based on consent, withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise these rights, you may contact:

contacto@alamosinnovacion.com

and indicate which right you wish to exercise, providing the information necessary for us to identify your request.

As a general rule, you do not need to send a copy of your national identity document or passport. If we have reasonable doubts about the identity of the person submitting the request, we may request additional information strictly necessary to verify identity.

You also have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos – AEPD) if you believe that the processing of your data does not comply with applicable data protection law: www.aepd.es.

11. Security and Confidentiality

Álamos Innovación implements technical and organisational measures designed to protect information against:

• unauthorised access;
• alteration;
• loss;
• destruction;
• improper disclosure.

Startup documents stored in AngelGrade are not public documents. Access is restricted to individuals who have the appropriate permissions.

However, no system connected to the Internet can guarantee absolute security.

12. Confidential Information and Trade Secrets

The fact that certain business documents do not constitute personal data does not mean that they are unprotected.

Álamos Innovación treats pitch decks, commercial information and documentation provided during an evaluation as confidential and uses them only for purposes connected with assessing the opportunity and managing any relationships that may arise from it.

At the initial stage, we recommend that you do not provide technical, commercial or strategic information whose disclosure is not necessary to understand and assess the opportunity.

13. Minors

The services provided by Álamos Innovación and AngelGrade are intended for professionals and company representatives.

They are not designed for minors to submit personal data directly.

14. Cookies and Similar Technologies

The website may use technical cookies that are necessary for its operation and, where applicable, other technologies subject to user consent.

Specific information about the cookies used, their providers and retention periods can be found in our Cookie Policy.

15. Changes to this Privacy Policy

This Privacy Policy may be updated when our services, the tools we use or applicable regulatory requirements change.

Where material changes are made, the date shown at the top of this page will be updated and, where necessary, affected individuals will be informed by additional means.

For any questions relating to privacy or data protection, please contact:

contacto@alamosinnovacion.com