Legal — tsishuk.com

Contents

• Privacy Policy
• Terms of Use
• Disclaimers
• Cookie Notice
• Your Rights & Contact

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Privacy Policy

Controller: Alex Tsishuk (“I”, “me”, “my”).

Contact: info@tsishuk.com

Location: Warsaw, Poland. A mailing address for formal correspondence is available on request.

What this covers

This Policy explains how I handle personal data of: (i) website visitors, (ii) prospective investors, (iii) prospective sellers and brokers/intermediaries, and (iv) newsletter subscribers.

This Policy does not relate to client money services; the Site does not solicit investments, accept deposits, or provide portfolio management. Materials are information-only and aimed at a professional audience.

Data I collect

- Enquiry data (forms): name, email, company (optional), country/region, message.

- Investor vetting: self-attestation of Professional/Qualified Investor status; indicative ticket size (non-binding).

- Seller screening: high-level metrics (e.g., revenue/EBITDA ranges). No documents at the indicative stage.

- Technical data: IP address, device/browser info; cookies (see Cookie Notice).

- Marketing preferences: newsletter opt-in/opt-out and subscription type.

Sources

Directly from you (forms/emails) and automatically via cookies/analytics (with your consent where required).

Purposes & legal bases

- Respond to your enquiry / deliver requested content — consent (Art. 6(1)(a)) or legitimate interests (Art. 6(1)(f)).

- Send newsletters and investor updates — consent (Art. 6(1)(a)); you may unsubscribe at any time.

- Business relationship management with sellers, investors, brokers — legitimate interests (Art. 6(1)(f)).

- Pre-contractual steps / contracting — Art. 6(1)(b).

- Compliance (e.g., basic sanctions/KYC checks when applicable) — Art. 6(1)(c)/(f).

- Security, fraud prevention, service analytics — Art. 6(1)(f).

Providing your data (necessity)

Providing contact details is voluntary, but necessary to respond to your enquiry and/or deliver the requested content. If you do not provide the required fields, I will be unable to respond or send the newsletter.

Recipients

I share data on a need-to-know basis with: (i) service providers (HubSpot, cloud/email hosting, analytics, security), (ii) professional advisers (legal/financial/technical) under confidentiality, (iii) co-investors or lenders for deal evaluation where lawful and under NDA, and (iv) authorities where legally required.

International transfers

Where data is transferred outside the EEA/UK, I use appropriate safeguards (e.g., EU Standard Contractual Clauses) and, where necessary, transfer risk assessments. Details are available on request.

Retention

Enquiry records: 24 months after last interaction.

Marketing subscriptions: until you unsubscribe.

Contractual/compliance records: for applicable statutory periods.

Backups/archives are held under restricted access.

Your rights

You have the right to access, rectify, erase, restrict, object (including to direct marketing) and data portability. Where processing is based on consent, you may withdraw it at any time without affecting prior processing. You may lodge a complaint with your local DPA and/or the Polish DPA (UODO).

How to exercise rights

Email info@tsishuk.com. I may need to verify your identity. I respond within one month (extendable where permitted).

Children

The services are not directed to children. I do not knowingly process children's data.

Security

I apply technical and organisational measures including access control, encryption in transit, MFA for admin access, least-privilege permissions and periodic reviews.

Automated decisions

I do not use automated decision-making, including profiling, that produces legal or similarly significant effects concerning you.

Cookie legal basis

I use consent for analytics/marketing cookies (ePrivacy + GDPR Art. 6(1)(a)) and legitimate interests/necessity for strictly necessary cookies.

Changes to this Policy

I may update this Policy from time to time. Material changes will be highlighted on this page prior to taking effect.

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Terms of Use

By using this website (the “Site”), you agree to these Terms.

Use of the Site

Use the Site lawfully and in accordance with these Terms. Do not attempt unauthorised access, introduce malware, or interfere with the Site.

Intellectual Property

Content on the Site is protected by IP laws. You receive a limited, revocable, non-exclusive licence to access and use the Site for personal or internal business purposes. You may not copy, modify, distribute, or create derivative works without prior written consent.

No advice; no offer

Site content is for information only and is not investment, legal or tax advice, nor an offer or solicitation.

User submissions

If you submit information via forms, you confirm you have the right to do so and grant me a licence to use it to respond to your enquiry and for purposes described in the Privacy Policy.

Third-party services

The Site may integrate third-party services (e.g., HubSpot, analytics, scheduling, security). I am not responsible for them.

Availability & changes

I may update or discontinue the Site or any part of it without notice.

Disclaimers & liability

The Site is provided “as is” without warranties. To the maximum extent permitted by law, I exclude liability for indirect or consequential loss and cap my aggregate liability at €100 (or the minimum mandatory amount).

Indemnity

You agree to indemnify me for losses arising from your misuse of the Site or breach of these Terms.

Governing law; jurisdiction

These Terms are governed by the laws of Poland. The courts of Warsaw, Poland have non-exclusive jurisdiction.

Changes

I may revise these Terms. Continued use of the Site signifies acceptance of the updated Terms.

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Disclaimers

Information-only; no client money. The Site and emails are for informational purposes only; I do not solicit or accept investments, manage client assets, or provide portfolio management.

No investment advice; no offer. Website/email content is general information only and does not constitute investment advice, an offer to sell or a solicitation to buy any securities or interests. Any potential transaction requires definitive documentation and eligibility checks.

Professional/Qualified investors. Certain materials may be available only to Professional/Qualified Investors (MiFID II or local equivalent). Self-attestations may be collected for routing/eligibility.

Performance & forward-looking statements. Any figures are illustrative; past performance is not indicative of future results. Forward-looking statements involve risks; actual outcomes may differ.

Confidentiality. Non-public information is shared only under a Mutual NDA. Do not submit confidential information until an NDA is in place.

Third-party links. I am not responsible for third-party websites’ content, security or privacy practices.

Capital at risk. Investments in private companies involve risk of loss of capital and illiquidity.

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Cookie Notice

I use strictly necessary cookies to operate the Site and (with your consent) analytics/marketing cookies to improve content and measure campaigns. Manage preferences in the cookie banner. Providers may include: HubSpot, Google Analytics/Ads, LinkedIn, reCAPTCHA. For details (cookie names, purposes, lifetimes) contact info@tsishuk.com or use the banner’s More info.

Your Rights & Contact

To exercise your rights (access, rectification, erasure, restriction, objection including to direct marketing, and data portability) or withdraw consent at any time, email info@tsishuk.com. You may also lodge a complaint with your local DPA or the Polish DPA (UODO).

Controller: Alex Tsishuk, Warsaw, Poland. A mailing address for formal correspondence is available on request.