When you submit an application, we process your personal data on the lawful basis of legitimate interests (investment evaluation) and, where consent is required, with your explicit consent.

Your rights under GDPR include:

• Right to access your personal data
• Right to rectification of inaccurate data
• Right to erasure (“right to be forgotten”)
• Right to restrict processing
• Right to data portability
• Right to object to processing

We retain application data for 2 years unless you request earlier deletion. Portfolio company data is retained in accordance with legal and regulatory requirements.

In compliance with EU Anti-Money Laundering directives (including the 6th AML Directive and AML Regulation), we conduct customer due diligence on all investment counterparties.

KYC procedures are required at term sheet stage and include:

• Identity verification of beneficial owners and key executives
• Beneficial ownership structure documentation
• Source of funds verification where applicable
• Ongoing transaction monitoring

To minimize friction during the initial application phase, KYC requirements are only requested once we move toward issuing a term sheet.

Vanguard Venture Capital operates as an Alternative Investment Fund Manager (AIFM) subject to the Alternative Investment Fund Managers Directive (AIFMD) and relevant national implementing regulations.

We maintain appropriate capital reserves, implement robust risk management procedures, and provide regular reporting to investors and regulators as required.

Fund domicile and jurisdiction: Our funds are domiciled in Luxembourg and subject to CSSF supervision. Marketing of fund interests complies with national private placement regimes and, where applicable, AIFMD passporting provisions.

Submission of an application does not constitute a commitment to invest by Vanguard Venture Capital or a commitment to accept investment by the applicant company.

This website and application process are for informational purposes only and do not constitute an offer to sell or solicitation to purchase securities or fund interests. Any such offer will be made only through formal documentation.

Investment in venture capital and private equity involves substantial risk. Past performance is not indicative of future results.