PRIVACY & PERSONAL DATA PROCESSING POLICY
Executive Education – Venture Capital and Private Equity
Next-Gen Family Offices
2026
Babson College – Miami Campus
1200 Brickell Ave #300, Miami, Florida 33131, United States
CUBE VENTURES I LLC
AMENDMENTS TO THIS POLICY
Cube Ventures reserves the right to amend, modify, or update this Policy from time to time to reflect changes in legal, regulatory, operational, or business requirements.
Any updated version of this Policy shall be published on the official Program webpage or otherwise made available to Participants through reasonable communication channels. The version published shall indicate its effective date.
In the event of material changes affecting the Processing of Personal Data, Cube Ventures shall provide reasonable notice to Participants prior to such changes taking effect, where required by applicable law.
IMPORTANT NOTICE
Cube Ventures I LLC (“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 education initiatives aimed at founders, investors, and family offices operating across global venture 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.
The Executive Education – Venture Capital and Private Equity – Next-Gen Family Offices Program (the “Program”) has been jointly developed and implemented by Cube Ventures in academic collaboration with Babson College, a private business school specializing in entrepreneurship education and executive training. Babson College participates in the academic design and delivery of the Program exclusively in its capacity as an Academic Partner and venue host and shall not be deemed a contractual party or joint data controller for the purposes of this Policy or the Program’s Terms and Conditions.
This Privacy & Personal Data Processing Policy (the “Policy”) establishes the Terms and Conditions governing the collection, use, storage, transfer, retention, and deletion of Personal Data in connection with the application, registration, participation, administration, and execution of the Program. The Processing of Personal Data under this Policy shall be conducted in accordance with the following provisions:
1. IDENTITY OF THE DATA CONTROLLER
Cube Ventures I LLC shall act as the sole data controller responsible for determining the purposes and means of Processing any Personal Data collected in connection with the application, registration, participation, administration, and execution of the Executive Education – Venture Capital and Private Equity – Next-Gen Family Offices Program (the “Program”).
Babson College participates in the academic design and delivery of the Program exclusively in its capacity as an Academic Partner and venue host and shall not be deemed a joint controller, co-controller, or contractual party under the Program’s Terms and Conditions or under this Policy, nor shall it assume any independent responsibility for the Processing of Personal Data conducted by Cube Ventures in connection with the Program.
For the avoidance of doubt, any Personal Data independently collected or processed by Babson College pursuant to its own institutional policies, security procedures, or campus access protocols shall be governed exclusively by Babson College’s applicable privacy policies and internal compliance framework. Cube Ventures shall not be responsible for any Processing activities carried out independently by Babson College outside the scope of this Policy.
2. DEFINITIONS
For the purposes of this Policy, the following terms shall have the meanings set forth below:
a. “Academic Partner” means Babson College, which participates in the academic design and delivery of the Program exclusively in such capacity and shall not be deemed a joint controller or contractual party under this Policy.
b. “International Transfer” means any transmission, storage, or disclosure of Personal Data across national borders, including through the use of cloud-based platforms or Third-Party 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 individual who applies for, enrolls in, or attends the Program in any capacity.
e. “Personal Data” means any information relating to an identified or identifiable natural person enrolled in or participating in the Program.
f. “Policy” means this Privacy & Personal Data Processing Policy.
g. “Processing” means any operation or set of operations performed upon Personal Data, whether by automated or non-automated means, including collection, recording, organization, storage, use, disclosure, transfer, restriction, retention, or deletion.
h. “Program” means the Executive Education – Venture Capital and Private Equity – Next-Gen Family Offices Program to be held from April 20 to April 24, 2026.
i. “Program Platforms” means any digital systems, registration tools, communication platforms, learning management systems, videoconferencing tools, customer relationship management systems, or attendance tracking technologies used for the administration or delivery of the Program.
j. “Recorded Content” means any photographic, audio, or video material captured during Program sessions or related activities.
k. “Sensitive Personal Data” means any Personal Data voluntarily disclosed by the Participant relating to health conditions, accessibility needs, dietary restrictions, or other information requiring enhanced confidentiality.
l. “Terms and Conditions” means the contractual terms governing the Participant’s enrollment and participation in the Program.
m. “Third-Party Service Providers” means external vendors engaged by Cube Ventures to provide technological, administrative, logistical, payment processing, insurance, or security-related services in connection with 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, names, surnames, national identification numbers, profession or occupational information, email addresses, physical addresses, mobile phone numbers, corporate affiliation or employment-related information, passport or travel-related information where required for Program logistics, dietary or accessibility requirements voluntarily disclosed by the Participant, billing and payment information, digital identifiers associated with the use of Program Platforms, audiovisual recordings generated during Program activities, attendance and participation logs, emergency contact details, and professional networking preferences provided for the purpose of facilitating engagement among Participants within the context of the 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, travel coordinators, or technological platforms used for the academic, administrative, or logistical management of the Program.
5. PURPOSES OF PROCESSING
Personal Data shall be processed by Cube Ventures for purposes related to Participant onboarding, eligibility verification, payment administration, academic coordination, venue access control, compliance with internal security protocols, facilitation of professional networking activities among Participants, issuance of certificates of completion, alumni engagement initiatives, dispute resolution processes, and compliance with applicable legal or regulatory obligations, as further described in this Policy and in the Program’s Terms and Conditions.
Personal Data may also be processed through automated means, including the use of learning management systems (LMS), videoconferencing tools, customer relationship management (CRM) systems, registration platforms, and attendance tracking technologies utilized for the administration and delivery of the Program. Cube Ventures does not use Personal Data for automated decision-making affecting Participant eligibility.
Additionally, Personal Data may be processed following completion of the Program for the purpose of providing Participants with information regarding academic, educational, or professional opportunities related to the venture capital and private equity ecosystem, including invitations to future programs, networking events, or initiatives developed by Cube Ventures or its strategic partners, sponsors, or affiliated organizations, who may act as independent data controllers where applicable under separate internal arrangements. Such post-Program communications shall be limited to professional or academic opportunities reasonably related to venture capital, private equity, or executive education.
6. LEGAL BASIS FOR PROCESSING
The Processing of Personal Data under this Policy shall be conducted in accordance with applicable United States privacy frameworks and shall be based on one or more of the following legal grounds, including the necessity of Processing for the performance of a contractual relationship with the Participant, Cube Ventures’ legitimate business interests in administering and executing the Program, the Participant’s consent where required under applicable law, and compliance with 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 conditional upon the provision of certain Personal Data necessary for the purposes of administering and executing the Program in accordance with the Program’s Terms and Conditions. Failure to provide such required Personal Data may prevent Cube Ventures from facilitating venue access, enabling participation in Program activities, issuing certificates of completion, or providing academic communications related to the Program.
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 in connection with 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 to, stored in, or accessed from jurisdictions other than the Participant’s country of residence where such transfer is necessary for the administration, execution, or logistical coordination of the Program, including the use of Program Platforms or engagement of Third-Party Service Providers. Any such International Transfer shall be conducted in accordance with applicable data protection laws and appropriate safeguards.
Participants acknowledge that enrollment in the Program may involve the Processing and storage of Personal Data across multiple jurisdictions, given that Participants may reside in different countries and that, although the Program will be conducted in Florida, United States, certain administrative, academic, and logistical coordination activities may be carried out from other jurisdictions through the use of cloud-based platforms or subcontracted service providers supporting the execution of the Program.
Where required by applicable foreign data protection laws, Cube Ventures may implement appropriate safeguards or contractual mechanisms designed to ensure that Personal Data transferred across jurisdictions is afforded a level of protection consistent with applicable legal requirements.
9. DISCLOSURE TO THIRD-PARTY SERVICE PROVIDERS
Cube Ventures may disclose Personal Data to Third-Party Service Providers engaged to support the technological, administrative, logistical, payment processing, insurance, or security-related execution of the Program, provided that such service providers are contractually bound 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 held responsible for any interruptions, errors, delays, 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. ACADEMIC PARTNER INTERACTION
Cube Ventures may share limited Personal Data with Babson College strictly to the extent necessary to facilitate academic coordination, venue access, or logistical arrangements related to the delivery of the Program. Any such disclosure shall be limited to information required for the execution of the Program and shall not be construed as creating any joint controllership or independent responsibility on the part of Babson College with respect to the Processing of Personal Data under this Policy.
11. RECORDING AND USE OF IMAGE AND LIKENESS
Participants acknowledge that photographs, audio recordings, or video recordings may be captured during 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 further provided in the Program’s Terms and Conditions.
To the extent that any Recorded Content is used for external promotional, institutional marketing, or public communication purposes (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 commercially exploit a Participant’s image in isolation from Program-related communications.
Participants should not expect privacy in group learning or networking environments, including but not limited to group sessions, networking activities, or common areas within the Program venue. Participants who do not wish to appear in such Recorded Content may submit a written request to Cube Ventures at legal@cube.ventures prior to 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 attendees of the Program, including networking activities conducted 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 Program-related activities, who may act as independent data controllers where applicable under separate internal arrangements. Participants who do not wish to have their information included in the Networking Directory may submit a written request to Cube Ventures at legal@cube.ventures prior to 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. Personal Data included in the Networking Directory shall not be sold, licensed, or disclosed for unrelated commercial marketing purposes. Any sponsor or strategic partner receiving limited access to such information shall be expected to use it solely in connection with Program-related engagement activities.
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, issuance of certifications, alumni engagement activities, compliance with applicable legal or regulatory obligations, or the resolution of disputes arising in connection with participation in the Program, after which such Personal Data shall be securely deleted or anonymized in accordance with internal policies and applicable law.
Personal Data may also be retained and transferred in the event of a merger, acquisition, corporate reorganization, sale of assets, or similar business transaction involving Cube Ventures, where such retention or transfer is necessary to ensure continuity in the administration of Program-related obligations or alumni engagement activities.
Retention may extend beyond completion of the Program where reasonably necessary for certification verification, alumni engagement, or compliance with applicable legal obligations.
14. INFORMATION SECURITY MEASURES
Cube Ventures shall implement reasonable technical and organizational measures designed to protect Personal Data against unauthorized access, loss, misuse, alteration, or disclosure during the course of Processing, taking into account the nature of the Personal Data processed and the operational context of the Program.
Cube Ventures shall limit the collection and Processing of Personal Data to that which is reasonably necessary for the purposes described in this Policy, in accordance with principles of data minimization and proportionality.
Such measures may include, where appropriate, access control restrictions, encryption of sensitive data in transit or at rest, contractual data protection commitments with Third-Party Service Providers, and internal policies designed to limit unauthorized disclosure.
15. PARTICIPANT RIGHTS
Participants may, to the extent permitted under applicable law, request access to, correction of, or deletion of their Personal Data, as well as the restriction of Processing or 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 verification of identity prior to responding to such requests and shall respond within a reasonable timeframe consistent 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 in conjunction with this Policy.
17. COMPLIANCE WITH APPLICABLE PRIVACY LAWS
Cube Ventures shall process Personal Data in accordance with applicable federal and state privacy laws in the United States, including the Florida Information Protection Act (FIPA), to the extent applicable. This Policy shall be governed by and construed in accordance with the laws of the State of Florida, without regard to its conflict of laws principles.
18. DATA BREACH NOTIFICATION
In the event of a security incident involving unauthorized access to or disclosure of Personal Data, Cube Ventures shall take reasonable steps to notify affected Participants as required under applicable law.
19. CHILDREN’S DATA DISCLAIMER
The Program is not directed to individuals under the age of eighteen (18), and Cube Ventures does not knowingly collect or process Personal Data from minors in connection with the Program.
20. AMENDMENTS TO THIS POLICY
Cube Ventures reserves the right to amend or update this Policy at any time to reflect changes in legal, regulatory, or operational requirements. Any such amendments shall become effective upon reasonable notice to Participants.
21. CONTACT INFORMATION
Any questions, requests, or concerns regarding 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.