Privacy Policy – Investment Health Triage (Startup Term Sheet Analysis)

Last Updated: November 7, 2025

This Privacy Policy describes how Artur Woszczyk (hereinafter, “the Controller” or “we”) processes the personal data of users who use the **Investment Health Triage** (hereinafter, the “**Application**”), the tool for Term Sheet analysis.

This information is provided pursuant to **Arts. 13 and 14 of the EU Regulation 2016/679 (GDPR)**.

1. Data Controller

The Data Controller is solely responsible for managing all personal data collected through the Application:

Role (GDPR)	Contact Details
Data Controller (For the technical calculation and feedback service)	Artur Woszczyk Corso 22 marzo 32/a, Milano, Italy Privacy Email: artur.woszczyk@gmail.com

    Zero-Knowledge Principle: As long as you only use the calculator to get the estimate, the data entered (the 15 Term Sheet parameters) are processed exclusively in the server's temporary memory by the Controller and are deleted immediately upon closing the session (see Technical Report). Only if you use the "Contacts & Additional Feedback" form, your contact data are processed for the specific purpose of responding to your request.

2. Personal Data Collected

a) Data provided by the user (Feedback and Contact Form)

Type of Data	Examples	Mandatory?
Contact Data	Name, email address, (optional: phone number)	Yes (only if you use the "Contacts & Additional Feedback" form)
Analysis Data	The 15 Term Sheet parameters (e.g., Liq. Pref., Veto, Vesting).	No (processed only in RAM for calculation; not saved.)
Other personal data	Content of the request or feedback submitted.	Yes (only if you use the "Contacts & Additional Feedback" form)

b) Technical navigation data

IP Address (anonymized where possible)
System logs (access date/time, for security purposes)
Strictly necessary technical cookies: csrf_token_master_lite (HttpOnly, Secure), essential for preventing cyber attacks.

3. Purposes and Legal Basis of Processing

Purpose	Legal Basis (GDPR)	Data Categories
1. Provision of the Calculation Service To provide you with the immediate analysis (Score and Scenario).	Contract/Pre-contractual execution (Art. 6.1.b) Processing in RAM is necessary to respond to your service request.	Analysis Data (temporary)
2. Feedback and Contact Management To respond to generic requests submitted via the dedicated form.	Explicit Consent (Art. 6.1.a) You manifest this by ticking the specific box before submitting the Contact form.	Contact Data, Other Personal Data
3. Security and Maintenance To protect the site from attacks and abuses.	Legitimate Interest (Art. 6.1.f) To protect the Controller's technological infrastructure.	IP Address, Technical Logs

Your consent for purposes 1 and 2 is always freely given and can be revoked at any time (see Sec. 7).

4. Processing Methods and Security

Data is processed using automated IT tools, observing advanced technical and organizational security measures:

Encryption in transit: All communications take place over secure HTTPS protocol (TLS 1.3).
Zero-Knowledge Architecture: Sensitive Term Sheet data never leaves temporary memory.
Secure Hosting: Servers are located in the European Union and managed by Netsons S.r.l.

5. Data Communication and Transfer

To Technical Providers (Data Processors): We may use third-party providers for strictly necessary technical services (e.g., hosting, transactional email sending for the Contact Form), appointed as Data Processors.
**No Communication to Third Parties:** In this Beta phase, **no communication or transfer of your data** is made to external parties (e.g., law firms, financial consultants) for marketing or commercial purposes.
No Dissemination: Your data will never be publicly disseminated.

6. Retention Period

Data Type	Retention Period
Calculation data (without submitting a request)	Immediate deletion upon closing the browser session (Zero-Knowledge Principle).
Contact Form Data (Feedback)	Retained for the time necessary to handle the request and subsequently for a maximum of 12 months for legal protection or service improvement purposes.

7. Your Rights (Arts. 15-22 GDPR)

As a data subject, you have the right to request access, rectification, erasure of your personal data, or object to the processing. To exercise these rights, please write to: artur.woszczyk@gmail.com.
You also have the right to lodge a complaint with the Supervisory Authority for the protection of personal data (www.garanteprivacy.it).

8. Disclaimer Professional and Legal

Important: Nature of the Service

The Application provides a **purely indicative assessment** based on algorithms that apply benchmarks and standard practices of international Venture Capital (VC).

The result **DOES NOT constitute professional legal, tax, or financial advice.**
The use of the Application **DOES NOT establish any professional advisory relationship** with the Controller.
It is **essential** to consult industry experts before making decisions based on the results obtained.