PRIVACY POLICY AND PERSONAL DATA PROCESSING
Educational programs, courses, events and training initiatives organized by Cube Ventures.
2026
Bogotá D.C. - Colombia
CUBE VENTURES I LLC - CUBE VENTURES S.A.S
AMENDMENTS TO THIS POLICY
Cube Ventures reserves the right to modify or update this Policy from time to time to reflect legal, regulatory, operational or commercial changes.
Any updated version of this Policy will be published on the Cube Ventures website, on the page corresponding to the applicable Program, or through any other communication channel reasonably used by Cube Ventures to inform Participants.
In the event of material changes affecting the Processing of Personal Data, Cube Ventures shall reasonably notify Participants before such changes take effect, where required by applicable law.
IMPORTANT NOTICE
Cube Ventures I LLC and Cube Ventures SAS ("Cube Ventures") is a venture capital firm that invests in early-stage technology companies and provides acceleration services through structured programs, advisory support and executive training initiatives directed at founders, investors and family offices operating in global venture capital ecosystems. In addition to its investment activities, Cube Ventures develops and delivers educational and community-building programs designed to facilitate knowledge exchange, capital formation and strategic collaboration among participants in the venture capital and private equity industries.
Cube Ventures may develop, organize, administer or execute educational programs, courses, workshops, bootcamps, certifications, seminars, academic events, executive training initiatives and other educational activities (each, a "Program"), independently or in collaboration with universities, academic institutions, companies, sponsors, strategic partners or other organizations.
When a Program is developed jointly with a third party, such third party shall participate exclusively under the terms defined for the respective Program and shall not be considered a joint controller of the Processing of Personal Data unless expressly stated otherwise in the applicable documentation.
This Privacy Policy and Personal Data Processing (the "Policy") establishes the Terms and Conditions governing the collection, use, storage, transfer, retention and deletion of Personal Data in connection with the application, enrollment, registration, participation, administration, promotion, execution and subsequent activities associated with any Program organized or administered by Cube Ventures. The processing of personal data under this Policy shall be carried out in accordance with the following provisions:
1. IDENTITY OF THE DATA CONTROLLER
Cube Ventures I LLC and Cube Ventures SAS shall act as the controller of the Processing of Personal Data collected in connection with any Program organized, administered or executed by Cube Ventures.
When a Program is developed or executed jointly with universities, academic institutions, sponsors, strategic partners or other third parties, such third parties shall participate solely under the terms defined for the respective Program and shall not be considered joint controllers of the Processing of Personal Data unless expressly stated otherwise in the applicable documentation.
For the avoidance of doubt, any Personal Data collected or processed independently by such third parties in accordance with their own policies, internal procedures or operational requirements shall be subject exclusively to the privacy policies and compliance obligations applicable to such third parties. Cube Ventures shall not be responsible for Personal Data Processing activities carried out independently by third parties outside the scope of this Policy.
2. DEFINITIONS
For the purposes of this Policy, the following terms shall have the meanings set out below:
a. "Academic Partner" means any university, academic institution, sponsor, company, . organization, lecturer, provider or third party that participates in the promotion, organization, financing, administration or execution of a Program.
b. "International Transfer" means any transmission, storage or disclosure of personal . data across national borders, including the use of cloud platforms or external service providers located outside the participant's country of residence.
c. "Networking Directory" means any internal listing of participants prepared for the . purpose of facilitating professional engagement, networking or collaboration within the context of the Program.
d. "Participant" means any person who applies for, enrolls in, attends, participates in or interacts with a Program in any capacity.
e. "Personal Data" means any information relating to an identified or identifiable natural person enrolled or participating in the Program.
f. "Policy" means this Privacy Policy and Personal Data Processing.
g. "Processing" means any operation or set of operations performed on Personal Data, whether by automated or non-automated means, including collection, recording, organization, storage, use, disclosure, transfer, restriction, retention or deletion.
h. "Program" means any course, training program, certification, bootcamp, seminar, workshop, conference, academic event, educational initiative or training activity organized, administered or executed by Cube Ventures, whether in person, virtual or hybrid.
i. "Program Platforms" means any digital system, registration tool, communication platform, learning management system (LMS), videoconferencing tool, customer relationship management system (CRM), networking portal or any other technology used before, during or after a Program for its promotion, administration, execution, certification or follow-up.
j. "Recorded Content" means any photographic, audio or video material captured during the Program sessions or related activities.
k. "Sensitive Personal Data" means any personal information voluntarily disclosed by the Participant relating to health conditions, accessibility needs, dietary restrictions or other information requiring greater confidentiality.
l. "Terms and Conditions" means the contractual terms governing the enrollment, participation and other aspects applicable to each Program.
m. "Third-Party Service Providers" means external providers contracted by Cube Ventures to provide technological, administrative, logistical, payment processing, insurance or security services related to the execution of the Program.
3. CATEGORIES OF PERSONAL DATA COLLECTED
In connection with the Program, Cube Ventures may collect and process personal data, including, without limitation, first names, last names, national identification numbers, professional or occupational information, email addresses, physical addresses, mobile phone numbers, corporate or employment affiliation information, passports or travel-related data when necessary for Program logistics, dietary or accessibility requirements voluntarily disclosed by the participant, billing and payment information, digital identifiers associated with the use of the Program Platforms, audiovisual recordings generated during Program activities, attendance and participation records, emergency contact data and academic preferences, history of participation in Programs, information relating to certifications issued, satisfaction survey results and any other information voluntarily provided by the Participant in connection with a Program.
4. SOURCES OF PERSONAL DATA
Cube Ventures may obtain Personal Data directly from the Participant through application forms, registration documents, digital enrollment platforms or communications submitted in connection with participation in the Program.
Personal data may also be obtained indirectly from third parties acting on behalf of or in coordination with the Participant, including employers, sponsoring institutions, logistics coordinators or technology platforms used for the academic, administrative or logistical management of the Program, universities, academic partners, sponsors, event organizers, corporate entities or third parties authorized by the Participant.
5. PURPOSES OF PROCESSING
Cube Ventures will process personal data for purposes related to participant onboarding, eligibility verification, payment administration, academic coordination, access control to physical facilities, digital platforms or virtual environments associated with the Program, compliance with internal security protocols, facilitation of professional networking activities among participants, issuance of completion certificates, alumni engagement initiatives, dispute resolution processes and compliance with applicable legal or regulatory obligations, as described in this Policy and the Program's Terms and Conditions.
Personal data may also be processed by automated means, including the use of learning management systems (LMS), videoconferencing tools, customer relationship management systems (CRM), registration platforms and attendance-tracking technologies used for the administration and execution of the Program. Cube Ventures does not use Personal Data for automated decision-making that affects participant eligibility.
In addition, personal data may be processed after the completion of the Program in order to provide participants with information about academic, educational or professional opportunities related to the sectors of entrepreneurship, innovation, investment, technology, business, leadership, executive education or other related thematic areas, including invitations to future programs, networking events or initiatives developed by Cube Ventures or its strategic partners, sponsors or affiliated organizations, which may act as independent controllers of the Processing of Personal Data in accordance with their own privacy policies, contractual terms or applicable internal provisions.
Such post-Program communications shall be limited to professional or academic opportunities reasonably related to venture capital, private equity, entrepreneurship, innovation, investment or executive education.
Additionally, Personal Data may be used for purposes of development, promotion, marketing, evaluation, continuous improvement, statistical analysis and administration of current or future Programs organized by Cube Ventures.
6. LEGAL BASIS FOR PROCESSING
The Processing of Personal Data under this Policy shall be carried out in accordance with the privacy and personal data protection laws and regulatory frameworks that are applicable depending on the nature of the Program, the location of the Participants and the Processing activities carried out by Cube Ventures. It shall be based on one or more of the following legal grounds, including the need for Processing for the performance of a contractual relationship with the Participant, the legitimate commercial interests of Cube Ventures in the administration and execution of the Program, the consent of the Participant where required under applicable law, and compliance with the legal or regulatory obligations to which Cube Ventures may be subject.
The provision of personal data by the Participant is voluntary; however, Participation in the Program is conditioned upon the provision of certain personal data necessary for the administration and execution of the Program in accordance with the Program's Terms and Conditions. Failure to provide such required personal data may prevent Cube Ventures from providing access to physical or virtual facilities, allowing participation in Program activities, issuing completion certificates or facilitating Program-related communications.
7. PROCESSING OF SENSITIVE PERSONAL DATA
Cube Ventures may process Sensitive Personal Data voluntarily disclosed by the Participant strictly to the extent necessary to accommodate reasonable logistical, health, accessibility or dietary requirements related to the Participant's attendance at the Program. Such data shall be processed solely for the purposes for which it was provided and in accordance with appropriate confidentiality safeguards.
8. INTERNATIONAL DATA TRANSFERS
Personal data collected in connection with the Program may be transferred, stored or accessed from jurisdictions other than the Participant's country of residence when such transfer is necessary for the administration, execution or logistical coordination of the Program, including the use of Program Platforms or the involvement of Third-Party Service Providers. Any such international transfer shall be carried out in accordance with applicable data protection laws and appropriate safeguards.
Participants acknowledge that enrollment and participation in any Program may involve the Processing and storage of Personal Data in multiple jurisdictions, given that Participants, academic partners, sponsors, service providers, lecturers or other third parties involved in the execution of the Program may be located in different countries. Likewise, certain administrative, academic, operational or logistical activities may be carried out from different jurisdictions through the use of cloud-based platforms, technological systems, digital tools or external service providers that support the organization, administration or execution of the Program.
When required by applicable foreign data protection laws, Cube Ventures may implement appropriate safeguards or contractual mechanisms designed to ensure that personal data transferred between jurisdictions has a level of protection consistent with applicable legal requirements.
9. DISCLOSURE TO EXTERNAL SERVICE PROVIDERS
Cube Ventures may disclose personal data to external service providers contracted to support the technological, administrative, logistical, payment processing, insurance or security execution of the Program, provided that such service providers are contractually obligated to process personal data solely for the purposes specified by Cube Ventures and in accordance with applicable confidentiality and data protection obligations.
Cube Ventures shall not be responsible for any interruption, error, delay or unauthorized access to Personal Data arising exclusively from the operation, performance or security vulnerabilities of third-party platforms or systems used in connection with the administration or delivery of the Program, except to the extent required by applicable law.
10. INTERACTION WITH ACADEMIC AND STRATEGIC PARTNERS
Cube Ventures may share limited Personal Data with universities, academic institutions, sponsors, strategic partners, providers or third parties involved in the organization or execution of a Program when this is necessary for academic, administrative, logistical and operational purposes related to such Program.
Unless expressly stated otherwise, such third parties shall act as independent controllers or processors as applicable in accordance with their own legal and contractual obligations.
11. RECORDING AND USE OF IMAGE AND LIKENESS
Participants acknowledge that photographs, audio recordings or video recordings may be captured during the Program sessions or related activities for educational, operational, institutional or internal promotional purposes by Cube Ventures, its sponsors or affiliated organizations. Any Personal Data derived from such Recorded Content shall be processed in accordance with this Policy and as provided in the Program's Terms and Conditions.
To the extent that any Recorded Content is used for external promotional purposes, institutional marketing or public communication (including websites, social media, press releases or sponsor-related materials), such use shall be subject to the authorization framework established in the Program's Terms and Conditions. Cube Ventures shall not sell or independently use a Participant's image for commercial purposes unrelated to the promotion, documentation or dissemination of Programs or institutional activities related to Cube Ventures.
Participants acknowledge that certain activities carried out in group learning, networking or professional interaction environments may be visible to other participants or attendees of the Program and that, in such contexts, absolute confidentiality of interactions cannot be guaranteed by Cube Ventures. Participants who do not wish to appear in such recorded content may submit a written request to Cube Ventures at legal@cube.ventures before or during the Program.
12. NETWORKING DIRECTORY AND PROFESSIONAL DISCLOSURE
Cube Ventures may compile and distribute an internal Networking Directory containing limited personal data provided by participants for the purpose of facilitating professional engagement and collaboration among Program attendees, including networking activities carried out during or after the Program.
Participants acknowledge that such information may be shared within the Program environment or with strategic partners or sponsors involved in the execution of activities related to the Program, who may act as independent data controllers where applicable under separate internal agreements. Participants who do not wish their information to be included in the Networking Directory may submit a written request to Cube Ventures at legal@cube.ventures before or during the Program.
The Networking Directory shall contain only limited professional identification information voluntarily provided by Participants, such as name, professional affiliation and contact details intended for networking purposes. The personal data included in the Networking Directory must not be sold, licensed or disclosed for unrelated commercial purposes. Any sponsor or strategic partner receiving limited access to such information is expected to use it solely in connection with engagement activities related to the Program.
13. DATA RETENTION PERIODS
Personal data shall be retained by Cube Ventures only for as long as necessary to fulfill the purposes for which it was collected, including the administration and execution of the Program, the issuance of certifications, alumni engagement activities, compliance with applicable legal or regulatory obligations, or the resolution of disputes arising from participation in the Program, after which such personal data shall be securely deleted or anonymized in accordance with internal policies and applicable legislation.
Personal data may also be retained and transferred in the event of a merger, acquisition, corporate reorganization, asset sale or similar commercial transaction involving Cube Ventures, when such retention or transfer is necessary to ensure continuity in the administration of obligations related to the Program or alumni engagement activities.
Retention may extend beyond the completion of the Program when reasonably necessary for the verification of certifications, alumni engagement or compliance with applicable legal obligations.
14. INFORMATION SECURITY MEASURES
Cube Ventures will implement reasonable technical and organizational measures designed to protect Personal Data against unauthorized access, loss, use, alteration or disclosure during Processing, taking into account the nature of the Personal Data processed and the operational context of the Program.
Cube Ventures will limit the collection and processing of personal data to what is reasonably necessary for the purposes described in this Policy, in accordance with the principles of data minimization and proportionality.
These measures may include, where appropriate, access control restrictions, encryption of sensitive data in transit or at rest, contractual data protection commitments with external service providers and internal policies designed to limit unauthorized disclosure.
15. PARTICIPANTS' RIGHTS
Participants may, to the extent permitted by applicable law, request access to, correction or deletion of their personal data, as well as the restriction of processing or the withdrawal of consent where such processing is based on consent, by submitting a written request to Cube Ventures at legal@cube.ventures. Cube Ventures may require reasonable identity verification before responding to such requests and shall respond within a reasonable period in accordance with applicable legal and contractual obligations.
16. CROSS-REFERENCE TO TERMS AND CONDITIONS
Certain aspects related to the use of Program Platforms, Recorded Content, participation requirements and official communications may be further regulated in the Program's Terms and Conditions. Participants are encouraged to review such Terms and Conditions together with this Policy.
17. COMPLIANCE WITH APPLICABLE PRIVACY LAWS
Cube Ventures will process Personal Data in accordance with the privacy and data protection laws, regulations and regulatory frameworks that are applicable depending on the nature of the Program, the location of the Participants, the Processing activities carried out and the jurisdictions involved in the provision of services related to the Program.
Nothing in this Policy shall limit the application of mandatory data protection rules that are binding under applicable legislation.
18. DATA BREACH NOTIFICATION
In the event of a security incident involving unauthorized access to or disclosure of personal data, Cube Ventures will take reasonable measures to notify affected participants as required by applicable law.
19. LEGAL NOTICE REGARDING CHILDREN'S DATA
Unless expressly stated otherwise in the documentation of a specific Program, the Programs organized by Cube Ventures are not directed at persons under eighteen (18) years of age, and Cube Ventures does not knowingly collect or process Personal Data of minors in connection with such Programs.
20. AMENDMENTS TO THIS POLICY
Cube Ventures reserves the right to modify or update this Policy at any time to reflect changes in legal, regulatory or operational requirements. Any such amendments shall take effect upon reasonable notice to Participants.
21. CONTACT INFORMATION
Any questions, requests or concerns related to the Processing of Personal Data under this Policy may be directed to:
a. Cube Ventures I LLC
b. Data Contact: Santiago Rojas Montoya
c. Email: legal@cube.ventures
d. Address: 1007 North Orange Street, 4th Floor, Suite 1382, Wilmington, Delaware 19801, EE. UU.