Compliance

Prevention of Money Laundering and Terrorism Financing

VENT undertakes to comply with the provisions of Law 10/2010, of April 28, 2010, on the prevention of money laundering and terrorist financing (the "Law 10/2010"), which transposes into Spanish law Directive 2005/60/EC, of the European Parliament and of the Council, of October 26, 2010, on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing (the "Third Directive"), as well as with the provisions of Royal Decree 304/2014 of May 5, which approves the Regulation of Law 10/2010, as well as Royal Decree-Law 7/2021 of April 27, on the transposition of European Union directives in matters of competence, prevention of money laundering, credit institutions, telecommunications, tax measures, prevention and repair of environmental damage, posting of workers in the provision of transnational services and consumer protection and with any other rule and/or regulation implemented or created in accordance with such rules, or that implement, develop, modify, replace, recreate or consolidate them, as well as any other laws applicable to the prevention of money laundering and the financing of terrorism that may exist in any applicable jurisdiction, to the extent that such rules may be applicable to it.

Consequently, VENT declares that neither itself as a company nor, to the best of its knowledge, any of its shareholders (or their legal representatives, employees or agents) has participated in any activity or acted in any way that could be understood as constituting a violation or non-compliance with the applicable regulations in relation to the prevention of money laundering and the financing of terrorism. Furthermore, VENT declares that it will implement and maintain a system of identification of its investors and/or users, requiring from them a document proving their identity (indicative but not limited to: national identity card, passport, residence card, proof of residency and phone, described as it follows:

KYC verification is mandatory for all VentUp IDO launches. Users are required to upload:

• National ID (Passport/Driving License)

• Proof of Residency

• Verify phone number or pass AML

Together with our strategic partner Synaps, we provide a complete KYC verification flow on a platform level. Unlike existing IDO platforms, VentUp only requires the process to be completed once.

KYC Process Preview

Protection of Personal Data

Both in relation to personal data processing activities involving the ICO and in relation to processing in the context of its operations VENT will comply with the General Data Protection Regulation (EU) 2016/679 of 27 April 2016 (hereinafter the "GDPR") as well as any other rules and/or regulations implemented or created pursuant to such regulation, or that implements, develops, modifies, replaces, recreates or consolidates it, as well as any other laws applicable to the processing of personal data that may exist in any applicable jurisdiction, including, where applicable, guides and codes of practice issued by supervisory authorities.

To ensure compliance with the GDPR and other applicable regulations, VENT has hired the services of the law firm ATH21, experts in privacy and data protection, among other areas.

Among other applicable obligations, VENT will comply with the principles of privacy by default and privacy by design. VENT has established procedures to ensure compliance with the right to information in the collection of data through the use of the corresponding informative clause at the time it collects personal data from its investors or users. In addition, it undertakes to sign with all those third parties who access personal data under its responsibility the corresponding data processing contract.