Privacy Policy

This privacy policy aims to give you information on how WakeUp Capital collects and processes your personal data through your use of our website, including any data you may provide through this website.

This website is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

This Privacy Policy applies solely to information collected through our website and relates to visitors’ use of the website and the information they provide to, or that is collected by, WakeUp Capital through such online interactions. It does not apply to information collected offline or through any other channels or means of communication.

WAKEUP CAPITAL MANAGEMENT DESIGNATED ACTIVITY COMPANY (company registration number: 672146) with registered office at 2 Chester Gardens, Chester Road, Dublin 6, D06 E045, Ireland is the controller and is responsible for your personal data.

If you have any questions about this privacy policy, please contact us using the details set out below.

Contact details

Our full details are:

• Full name of legal entity: WAKEUP CAPITAL MANAGEMENT DESIGNATED ACTIVITY COMPANY
• Email address: info@wakeupcapital.com
• Postal address: 2 Chester Gardens, Chester Road, Dublin 6, D06 E045

You have the right to make a complaint at any time to the Data Protection Commission (DPC), the Irish regulator for data protection issues.

We keep our privacy policy under regular review.

This version was last updated on 20 October 2026. It may change and if it does, these changes will be posted on this page and, where appropriate, notified by email. The new policy may be displayed on-screen, and you may be required to read and accept the changes to continue your use of the website.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

We may collect, use, store and transfer different kinds of personal data about you as follows:

1. Contact Data
2. Usage Data
3. Communications Data
4. Technical Data

We explain these categories of data at DESCRIPTION OF CATEGORIES OF PERSONAL DATA below.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing the website. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We will collect personal data about you as follows:

• Information you give us: this is information (including Contact, Usage and Communications Data) you consent to giving us about you by filling in forms on the website, or by corresponding with us (for example, by email). It includes information provided when you contact us and any correspondence between you and us.
• Technical data: this is information provided by you when you visit our website. It includes your internet protocol (IP) address, browser type, internet service provider, date and time stamp of your visit to our website, any exit pages and the number of clicks you made on the website.

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where you have consented before your personal data is used;
• For marketing communications, where you have consented to receive such communications;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
• Where we need to comply with a legal or regulatory obligation.

We will only send you direct marketing communications by email if we have your consent. You have the right to withdraw that consent at any time by contacting us at info@wakeupcapital.com.

Please note we do not use automated decision making (including profiling).

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose	Type of data	Lawful basis for processing
To manage our relationship with you	Contact Communications Usage	Your consent Necessary for our legitimate interests (to keep records updated and analyse how you use our website)
To contact you directly in relation to any query you have raised about our website	Contact Communications	Your consent Necessary for our legitimate interests (for running our business)
To improve quality, stability and security of our website	Usage Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to ensure that our website is presented in the most effective manner for you)

We may share your personal data with the third parties set out below and for the purposes set out in the table at PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA above:

• Service providers such as Google and Affinity;
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

Many of our External Third Parties and service providers are based in Ireland but sometimes we will need to store and process your personal data outside of Ireland and the European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EEA.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Ireland.

All information you provide to us is stored on Google Cloud. Once we have received your information, we will use strict and appropriate procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see YOUR LEGAL RIGHTS below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Under certain circumstances you have the following rights under data protection laws in relation to your personal data:

• Right to request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • if you want us to establish the data’s accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

You can exercise any of these rights at any time by contacting us at info@wakeupcapital.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

In the event that you wish to make a complaint about how your personal data is being processed by us, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority who can be contacted as follows. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance:

Contact	Data Protection Commission
Telephone	+353 57 8684800 / +353 761 104 800
Email	info@dataprotection.ie
Post	Data Protection Commission 21 Fitzwilliam Square Dublin 2, D02 RD29 Ireland

LAWFUL BASIS

• Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us at info@wakeupcapital.com.
• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at info@wakeupcapital.com.
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

EXTERNAL THIRD PARTIES

Professional advisers including lawyers, bankers, auditors and insurers based in Ireland (or elsewhere) who provide consultancy, banking, legal, insurance and accounting services.

The Irish Revenue, regulators and other authorities based in Ireland (or elsewhere) who require reporting of processing activities in certain circumstances.

Google and Affinity based in third countries who provide hosting services.

• Contact Data: includes email address and phone number.
• Usage Data: includes details of your use of our website including but not limited to how you interact with our website, the resources that you access on the website, whether this is required by us to improve the Platform and/or user experience, fix usability issues, dimension our infrastructure or otherwise.
• Communications Data: includes your communication/correspondence with us (via emails or otherwise).
• Technical Data: includes information provided by you when you visit our website including but not limited to your internet protocol (IP) address, browser type, internet service provider, date and time stamp of your visit to our website, any exit pages and the number of clicks you made on the website.