© 2026 Växa Partners

Welcome to the website of Vaxa Partners LLC (“Site”) and its affiliates (collectively, “Växa Partners,” “we,” “our,” or “us”). Please review our disclaimers, notices, and Terms of Use. Should you have any questions, please reach out to us at: Inquiries@Vaxa.Partners.

TERMS OF USE

By accessing or using this Site, you agree to comply with and be bound by these Terms of Use (“Terms“), which form a binding agreement between you and Växa Partners (“Agreement“). These Terms govern your access to and use of the Site and all content made available through it, including but not limited to text, graphics, images, designs, audio and video materials, downloadable files, user interfaces, data, tools, and services (collectively, the “Content”).

Please read these Terms carefully.

This Agreement was last updated July 2025.

PARAMETERS TO ACCESS

Before using this Site, please review these Terms of Use, including any linked policies and procedures, which are incorporated by reference and form part of these Terms. If you do not agree to these Terms, you are not authorized to use the Site. Your sole and exclusive remedy for dissatisfaction with the Site, its Content, or these Terms is to discontinue use.

Your access to and use of the Site is conditioned upon your compliance with these Terms and all applicable rules, policies, and procedures governing any portion of the Site. Any breach of these Terms or related provisions will result in the immediate and automatic termination of your access rights to the Site and its Contents – without notice – and may subject you to full liability for any resulting claims or damages, regardless of the identity of the claimant or injured party.

Växa Partners reserves the right to modify, update, or discontinue any aspect of the Site, including these Terms of Use, at any time and without prior notice. We encourage you to review the most current version of the Terms each time you access the Site, as your continued use constitutes acceptance of any changes. Each time you access the Site, you confirm your full acceptance of and agreement to comply with these Terms.

Your right to access and use the Site is limited and may be revoked by Växa Partners at any time, for any reason, and without prior notice.

SUBMISSIONS

As indicated on our Site, we welcome your questions and feedback regarding Växa Partners and our services. Please note, however, that any comments, suggestions, ideas, materials, or other information you submit through the Site (collectively, “User Information”) will not be treated as confidential or proprietary, unless expressly stated otherwise in our Privacy Notice.

By submitting User Information, you hereby grant to Växa Partners an unrestricted, worldwide, irrevocable, non-exclusive, perpetual, fully paid, royalty-free, transferable license to access, view, display, reproduce, adapt, publish, translate, store, host, cache, maintain, modify, distribute, and otherwise use and exploit such User Information in any manner, provided such use is consistent with our Privacy Notice. You also grant Växa Partners the right to sublicense these rights through multiple tiers and to enforce such rights, including the right to bring actions for infringement.

LIMITATIONS TO USE

Any content expressly made available for download from this Site is provided solely for your personal, non-commercial use. You may not reproduce, republish, transmit, distribute, display, modify, create derivative works from, sell, or otherwise exploit any portion of the content, in whole or in part, without prior written consent from Växa Partners.

You may not:

  • copy or print material from the Site for commercial purposes without our prior written consent;
  • make more than minimal copies of Site materials or copy substantial portions of the Site, even for non-commercial use, without our prior written consent;
  • alter, obscure, or remove any copyright, trademark, or other proprietary notices from Site content;
  • link to, frame, or mirror this Site or any portion thereof without express written approval;
  • interfere with or attempt to interfere with the proper functioning of the Site, its infrastructure, or any activities conducted on the Site;
  • use the Site to gain unauthorized access to any system, data, password, or network connected to the Site;
  • use any automated means—including, without limitation, bots, crawlers, spiders, or scrapers—to access, monitor, or copy any part of the Site without our express written permission;
  • take any action that imposes or may impose, in our sole discretion, an unreasonable or disproportionately large load on our servers or network infrastructure;
  • bypass, circumvent, or attempt to bypass or circumvent any measures we may use to restrict access to the Site; or
  • publish, upload, or link to any malicious content, including malware, spyware, or other harmful code.

The Site and all content included on the Site—such as graphics, logos, articles, and other materials—is the property of Växa Partners or its licensors and is protected by copyrights, trademarks, and other intellectual property rights. Växa Partners reserves all of its intellectual property rights in the Site and its content. This Agreement does not grant you any right or license with respect to any such intellectual property.

You agree not to sell, license, copy, reproduce, modify, republish, transmit, edit, adapt, create derivative works from, distribute, or otherwise make unauthorized use of any such intellectual property from the Site without the express written permission of Växa Partners. You further agree not to reverse-engineer, decompile, disassemble, or otherwise attempt to extract or discover the source code of the Site or any part thereof, except and only to the extent that such activity is expressly permitted by applicable law notwithstanding this limitation.

From time to time, the Site may display content, services, products, or hyperlinks provided by third-parties. The inclusion of such third-party materials does not constitute an endorsement, representation, or warranty – express or implied – by Växa Partners. We do not control, and are not responsible for, the accuracy, reliability, legality, or quality of any third-party information, services, or websites. Your access to or use of such third-party materials is entirely at your own risk and subject to the terms and policies of those third-parties.

NOTICE OF COPYRIGHT INFRINGEMENT

In accordance with the Digital Millennium Copyright Act of 1998 (DMCA), Växa Partners respects the intellectual property rights of others and provides a process for copyright owners to report alleged infringements occurring on this Site.

If you believe in good faith that any content, information, or materials available on the Site infringe your copyright, you may submit a written notice containing the following information:

  • a physical or electronic signature of the person authorized to act on behalf of the owner of the copyright that is allegedly infringed;
  • identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works are covered by a single notification, a representative list of such works;
  • identification of the material that is claimed to be infringing or the subject of infringing activity, and information reasonably sufficient to permit us to locate the material on the Site;
  • contact information for the complaining party, including name, mailing address, telephone number, and email address;
  • a statement that the complaining party has a good faith belief that the use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law; and
  • a statement that the information in the notification is accurate, and under penalty of perjury, that the complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

Please submit your notice to Växa Partners at: ​Inquiries@Vaxa.Partners.

THIRD-PARTY CONTENT

Some of the content available on the Site may be provided by users, publishers, and other third-parties and is not under the control of Växa Partners. You acknowledge and agree that such content is the sole responsibility of the third-party that originated it, and Växa Partners assumes no responsibility for the accuracy, completeness, legality, or reliability of any third-party content or information.

While Växa Partners reserves the right, but not the obligation, to review, monitor, or remove any content or information made available on the Site, we do not undertake to do so and make no representations regarding our review practices. Access to and use of third-party content made available through the Site is entirely at your own risk.

This Agreement does not govern your use of any website, service, or content other than the Site. You are responsible for reviewing and complying with the applicable terms and policies of any third-party websites or services linked to or referenced on the Site. Växa Partners does not endorse, sponsor, or affiliate with any third-party content, and the inclusion of any link or reference does not imply any such relationship.

To the maximum extent permitted by applicable law, Växa Partners disclaims all liability for any content submitted, posted, linked to, shared, or otherwise made available by third-parties via the Site, including, without limitation, any errors, omissions, intellectual property infringement, or any loss or damage of any kind incurred as a result of the use of such content.

NO OFFER OR ADVICE

You acknowledge that the content of this Site is provided for general, informational purposes only and does not constitute an offer to sell or a solicitation of an offer to buy any securities, financial instruments, or other assets. Nothing on this Site should be construed as a promise to undertake or solicit business, or as a recommendation to engage in any investment strategy or transaction. Offers can only be made where lawful under, and in compliance with, applicable law.

We make no representations or warranties – express or implied – regarding the accuracy, completeness, reliability, or timeliness of any information provided through the Site. You are solely responsible for evaluating the risks and merits associated with the use of the Site and any content or services made available through it.

The Site is not intended to provide, and should not be relied upon for, investment, legal, accounting, tax, or other professional advice. Any decisions you make based on information contained on the Site are your sole responsibility. You should consult your own professional advisors with respect to your individual circumstances and needs.

Any transactions or case studies referenced on the Site are included for illustrative purposes only and may not be representative of all transactions or of overall performance.

FORWARD-LOOKING STATEMENTS AND PAST PERFORMANCE

The contents of this Site may include forward-looking statements, as well as statements of opinion or intention. These can be identified by the use of forward-looking terminology such as “may,” “can,” “will,” “would,” “should,” “seek,” “expect,” “anticipate,” “forecast,” “project,” “estimate,” “potential,” “intend,” “continue,” “target,” “plan,” “believe,” or similar expressions, including the negatives thereof.

Such statements – including those relating to current or future market conditions, trends, or expectations – are not historical facts. They are based on beliefs, assumptions, current expectations, estimates, and projections about the financial industry, the economy, Växa Partners, or its analysis. These statements are inherently uncertain and are not guarantees of future performance. Actual results may differ materially from those expressed or implied in any forward-looking statements due to a variety of known and unknown risks, uncertainties, and other factors.

You should not place reliance on any forward-looking statements. Important factors that could cause actual results to differ materially include, but are not limited to:

  • changes in market or economic conditions;
  • our ability to raise new funds or products;
  • investment performance;
  • regulatory or tax changes;
  • reliance on key personnel;
  • use of leverage; and
  • litigation or operational risks.

Växa Partners undertakes no obligation to update, amend, or clarify any forward-looking statements, whether as a result of new information, future events, or otherwise.

Any past performance information presented on the Site is provided for illustrative purposes only and is not indicative of future results. No representation is being made that any investment will or is likely to achieve profits or losses similar to those achieved in the past, or that significant losses will be avoided.

Any views expressed on this Site are subject to change without notice.

ACCESSIBILITY STATEMENT

Växa Partners is committed to providing individuals with disabilities equal access to its programs, services, and digital content, including through an accessible website experience. We strive to meet or exceed applicable accessibility standards and continuously work to improve the usability of our Site for all users.

If you have questions, comments, or encounter any difficulty accessing information on this Site, please contact us at: Inquiries@Vaxa.Partners.

INTERNET PHISHING & FRAUD STATEMENT

Please be aware that malicious actors may attempt to misuse the name, brand, and reputation of Växa Partners by publishing fraudulent websites or engaging in phishing schemes designed to obtain personal or confidential information. Växa Partners does not authorize such misuse and actively investigates these matters to protect its legal rights and reputation.

When communicating with Växa Partners through digital platforms, please exercise caution and observe the following guidelines before disclosing any personal information:

  • Verify the authenticity of the website to ensure it is an official Växa Partners domain.
  • Communicate only with individuals affiliated with an authorized office of Växa Partners. A list of authorized office locations is available on our “Contact Us” page.
  • Authorized representatives of Växa Partners will only use official email addresses ending in “@Vaxa.Partners.” Do not engage with individuals claiming to represent Växa Partners if they are using non-authorized email domains.
  • Never share your password or login credentials with anyone, including anyone claiming to be from Växa Partners. Except for secure investor portals requiring login credentials, Växa Partners will never request your password or login information.

If you have any questions or concerns regarding the authenticity of communications or websites purporting to represent Växa Partners, please contact us at: Inquiries@Vaxa.Partners.

PRIVACY NOTICE AND COOKIES POLICY

Your privacy is important to us. To understand how we collect, use, and protect your information when you access or use this Site, please review our Privacy Notice and Cookies Policy, which are available below.

By continuing to use the Site, you acknowledge and agree to the collection, use, disclosure, and other handling of your information in accordance with the Privacy Notice and Cookies Policy. We encourage you to review these policies carefully.

GOVERNING LAW

You agree that your use of this Site, the Notices herein, and these Terms of Use – and any disputes arising out of or relating to any of them – shall be governed in all respects by the laws of the State of New York, without regard to its conflict of law principles.

Any dispute, claim, or controversy arising out of or relating to your use of the Site or these Terms (including the breach, termination, enforcement, interpretation, or validity thereof) shall be resolved exclusively and finally by binding arbitration administered by the American Arbitration Association (“AAA”) in accordance with its Commercial Arbitration Rules then in effect. The arbitration shall be conducted before a single arbitrator in New York County, New York, and the proceedings shall be conducted in English.

You and Växa Partners agree that the arbitration shall be conducted on an individual basis only, and not in a class, consolidated, or representative action. The arbitrator shall have the authority to grant any relief that would be available in a court of law or equity, subject to the limitations of these Terms.

Judgment on the arbitration award may be entered in any court having jurisdiction. You acknowledge and agree that by agreeing to arbitration, you are waiving the right to a trial by jury or to participate in a class action.

TERMINATION

This Agreement is effective unless and until terminated by either you or Växa Partners. You may terminate this Agreement at any time by ceasing all use of the Site. Växa Partners may terminate or suspend your access to the Site, in whole or in part, at any time and for any reason, in its sole discretion, without notice or liability.

Upon termination, all rights granted to you under this Agreement will immediately cease, and you must promptly discontinue all use of the Site and any content obtained from it.

The following provisions on this Site concerning No Offer or Advice; Forward-Looking Statements and Past Performance; ownership of Site and materials; Submissions; third-party content; disclaimers; limitations of liability; indemnity; Governing Law; and Enforceability shall survive any termination or expiration of this Agreement.

ENFORCEABILITY

If any provision of this Agreement is found to be unlawful, void, or for any reason unenforceable, then that provision shall be deemed severable from this Agreement and shall not affect the validity and enforceability of any remaining provisions.

This Agreement, together with the Privacy Notice and any other legal notices published by Växa Partners on the Site, constitutes the entire agreement between you and Växa Partners concerning your use of the Site and supersedes any prior or contemporaneous communications, whether oral or written.

No waiver of any term or condition set forth in this Agreement shall be deemed a further or continuing waiver of such term or condition or any other term or condition, and any failure of Växa Partners to assert a right or provision under this Agreement shall not constitute a waiver of such right or provision.

DISCLAIMERS & LIMITATION OF LIABILITY

DISCLAIMERS

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE SITE, INCLUDING ALL CONTENT, FEATURES, FUNCTIONALITY, INFORMATION, AND SERVICES MADE AVAILABLE THROUGH OR ACCESSED FROM THE SITE, IS PROVIDED ON AN “AS IS,” “AS AVAILABLE,” AND “WITH ALL FAULTS” BASIS, WITHOUT WARRANTIES OF ANY KIND – EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE – INCLUDING, WITHOUT LIMITATION, ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, OR ACCURACY.

VÄXA PARTNERS MAKES NO REPRESENTATIONS OR WARRANTIES THAT THE SITE OR ANY PART THEREOF WILL BE UNINTERRUPTED, ERROR-FREE, OR SECURE; THAT DEFECTS WILL BE CORRECTED; OR THAT THE SITE OR THE SERVERS THAT MAKE IT AVAILABLE ARE FREE OF VIRUSES, MALICIOUS CODE, OR OTHER HARMFUL COMPONENTS. NO INFORMATION OR MATERIALS OBTAINED BY YOU THROUGH THE SITE SHALL CREATE ANY WARRANTY NOT EXPRESSLY STATED IN THESE TERMS.

YOU EXPRESSLY AGREE THAT YOUR USE OF THE SITE, INCLUDING ANY RELIANCE ON ANY CONTENT, DATA, OR MATERIALS ACCESSED THROUGH THE SITE, IS AT YOUR SOLE RISK. VÄXA PARTNERS DISCLAIMS ANY AND ALL LIABILITY FOR THE ACTS, OMISSIONS, AND CONDUCT OF ANY THIRD-PARTIES IN CONNECTION WITH OR RELATED TO YOUR USE OF THE SITE.

IN CERTAIN JURISDICTIONS, THE LAW MAY NOT PERMIT THE DISCLAIMER OF CERTAIN WARRANTIES. IN SUCH CASES, THE ABOVE DISCLAIMERS SHALL APPLY TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW.

INTERNATIONAL USE

Due to the global nature of the Internet, this Site may be accessed by users in countries outside the United States. Växa Partners makes no representation or warranty that the content, materials, or services available on or through the Site are appropriate or available for use in any particular jurisdiction.

Access to the Site from territories where its content or use is illegal or otherwise restricted is prohibited. If you choose to access the Site from outside the United States, you do so on your own initiative and are solely responsible for compliance with all applicable local laws, regulations, and restrictions.

By using the Site, you acknowledge and agree that you are solely responsible for ensuring that your use complies with all laws and regulations applicable in your jurisdiction.

LIMITATION OF LIABILITY

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, VÄXA PARTNERS AND ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, LICENSORS, AND SERVICE PROVIDERS SHALL NOT BE LIABLE FOR ANY DAMAGES OR INJURY OF ANY KIND ARISING OUT OF OR IN CONNECTION WITH YOUR ACCESS TO, USE OF, OR INABILITY TO USE THE SITE, OR FROM ANY INFORMATION, CONTENT, MATERIALS, PRODUCTS, OR SERVICES INCLUDED ON OR OTHERWISE MADE AVAILABLE TO YOU THROUGH THE SITE.

THIS INCLUDES, WITHOUT LIMITATION, ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO DAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, DATA, OR OTHER INTANGIBLE LOSSES, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

WITHOUT LIMITING THE FOREGOING, VÄXA PARTNERS SHALL NOT BE LIABLE FOR ANY DAMAGES OR INJURY RESULTING FROM:

  • FAILURE OF PERFORMANCE, ERROR, OMISSION, INTERRUPTION, OR DELAY IN OPERATION OR TRANSMISSION;
  • COMPUTER VIRUS, MALWARE, OR OTHER HARMFUL COMPONENTS;
  • LINE OR SYSTEM FAILURE;
  • UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS OR DATA;
  • ANY OTHER TECHNICAL OR SECURITY MALFUNCTION.

YOUR SOLE AND EXCLUSIVE REMEDY FOR DISSATISFACTION WITH THE SITE OR ANY CONTENT IS TO STOP USING THE SITE.

INDEMNIFICATION

To the maximum extent permitted by applicable law, you agree to indemnify, defend, and hold harmless Växa Partners, along with its officers, directors, employees, agents, affiliates, subsidiaries, parent companies, licensors, trustees, and managing members (collectively, the “Indemnitees”), from and against any and all third-party claims, demands, complaints, charges, liabilities, losses, damages, costs, and expenses (including, without limitation, reasonable attorneys’ fees and legal costs) arising out of or relating to:

  • your access to or use of the Site;
  • your violation of these Terms of Use or any applicable law or regulation; or
  • your infringement or misappropriation of any intellectual property or other rights of any third-party.

This indemnity obligation does not apply to the extent that any such claim, damage, or liability is caused by the gross negligence of any Indemnitee.

SECURITIES DISCLAIMER

This website and the materials contained herein are provided for informational purposes only and do not constitute an offer to sell, or a solicitation of an offer to buy, any securities or financial instruments issued by Växa Partners or any of its affiliates in any jurisdiction. Nothing on this Site should be construed as a recommendation, offer, or invitation to engage in any investment activity, nor as a representation regarding the suitability or advisability of any investment or transaction.

This website and its contents may not be relied upon in connection with the purchase or sale of any security and do not constitute professional, financial, legal, or investment advice. Any offering of securities may only be made by a properly authorized, licensed, and regulated entity (“Offeror“) through the delivery of a confidential offering memorandum and related subscription materials, and only in jurisdictions where such offerings are lawful and to investors who meet applicable legal and regulatory requirements.

To the extent that any content on this website may be interpreted as a general solicitation or general advertising under Rule 506(c) of the U.S. Securities Act of 1933, as amended, please note that Växa Partners does not offer or sell securities.

Any offering of securities referenced on this website, if applicable, is made solely by an unaffiliated or affiliated Offeror through the delivery of a confidential offering memorandum and related subscription materials. Such offerings are conducted independently by the Offeror and only in compliance with applicable securities laws and regulations.

Prior to the sale of any security, the Offeror is required to take reasonable steps to verify that each prospective investor is an “accredited investor.” Such verification steps may include, but are not limited to:

  • Reviewing IRS forms (e.g., W-2, 1099, 1040) that report the purchaser’s income, along with a written representation that the purchaser expects to meet the income threshold in the current year;
  • Receiving written confirmation from a registered broker-dealer, SEC-registered investment adviser, licensed attorney, or certified public accountant that such professional has taken reasonable steps to verify the purchaser’s accredited investor status.

Before providing any information regarding a private investment opportunity, the Offeror must determine that each prospective investor satisfies the relevant eligibility criteria. Satisfaction of such criteria does not guarantee that an offer will be made or that additional information will be provided. Any such offering is made solely at the discretion of the managing member of the Offeror.

No interests in any Offeror, Växa Partners, or any of their affiliates have been registered under the U.S. Securities Act of 1933, as amended, or under the securities laws of any U.S. state or foreign jurisdiction.

If you are interested in determining whether you meet the eligibility criteria to receive information about a private investment vehicle offered by an unaffiliated or affiliated Offeror, please contact us directly so that we may direct you to the appropriate resources. Any such determination will be made solely by the Offeror, in its discretion, and in accordance with applicable laws and regulations.

COOKIE NOTICE

At Växa Partners and its affiliates, we value your privacy. This Cookie Notice outlines how we use cookies and similar technologies on our Site in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR), UK GDPR, the e-Privacy Directive, and the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).

We use cookies, web beacons, pixel tags, and related technologies (collectively, “Cookies”) to operate our Site, manage communications, and gather information about your browsing behavior across time and websites.

TYPES OF COOKIES WE USE

  • Session Cookies: Temporary cookies that are deleted when you close your browser.
  • Persistent Cookies: Remain on your device for a set period or until manually deleted.
  • Strictly Necessary Cookies: Essential for the Site to function properly, such as enabling secure logins.
  • Analytical/Performance Cookies: Help us understand how visitors interact with the Site, so we can improve usability and performance.
  • Functionality Cookies: Remember your preferences (e.g., language or region) and recognize you on return visits.

We also collect technical data about your device and browser to enhance your experience. This includes browser type, operating system, internet service provider, referring and exit pages, pages visited, and interactions with content or ads. These insights help us personalize your experience and improve our services. We may use third-party analytics tools, such as Google Analytics, to measure and analyze Site usage and performance.

HOW TO MANAGE YOUR COOKIES PREFERENCES

Most browsers allow you to manage cookie settings, including receiving alerts when cookies are being used or disabling them entirely (excluding Flash Cookies). For more information, visit www.aboutcookies.org or your browser’s help section. To manage Flash Cookies, visit Adobe’s website.

Please note that disabling cookies may affect your ability to use certain features of the Site, such as saved preferences or login functionality. To opt out of Google Analytics tracking, you can install the Google Analytics Opt-out Browser Add-on, available here: https://tools.google.com/dlpage/gaoptout.

PRIVACY NOTICE

This Privacy Notice is issued by Växa Partners. For administrative purposes only, this Notice also applies to certain affiliated entities that may act as data controllers (see Annex A for a list of such entities). These entities operate on a shared technology platform, which supports an integrated approach to data handling.

This Notice outlines how we collect, use, store, process, disclose, and transfer personal data in the course of our business interactions with individuals (“Data Subjects”). These may include, but are not limited to:

  • Directors, officers, employees, and representatives of portfolio companies which Växa Partners evaluates;
  • Representatives of third-parties such as sellers, placement agents, finders, investment bankers, consultants, legal and financial advisers, and other service providers, whether or not formally engaged by Växa Partners;
  • Directors, officers, employees, and representatives of Växa Partners itself;
  • Individuals applying for or inquiring about employment opportunities with us;
  • Current or prospective investors and their authorized representatives;
  • Visitors to our websites and users of any digital services we offer.

We are committed to respecting the privacy of all Data Subjects. This Privacy Notice provides a general overview of how Växa Partners entities handle personal data. In some cases, we may issue additional privacy notices tailored to specific entities, categories of individuals (e.g., investors, employees), or jurisdictions, as required by applicable laws.

DATA COLLECTED

At Växa Partners, “Personal Data” refers to any information that can reasonably be used to identify an individual. In the course of our business, we may collect a variety of Personal Data, including but not limited to:

TYPES OF COLLECTED PERSONAL DATA
  • Identifiers: Name, mailing address, tax identification number, passport number, IP address, email address, account credentials, Social Security number, driver’s license number, phone number, and similar identifiers.
  • Legally Protected Information: Data classified as sensitive or protected under applicable laws, such as nationality, date and place of birth, gender, marital status, number of dependents, photographs, and any history of criminal or unlawful conduct.
  • Financial and Commercial Information: Tax records, bank account and payment details, credit card numbers, transaction records, investment profiles, credit history, outstanding debts, and related financial data.
  • Online Activity Data: Information about your interactions with our website or digital services, including browsing and search history, and engagement with online content or advertisements.
  • Visual Data: Photographs or other visual identifiers.
  • Professional Information: Employment details, employer name, job title, and compensation-related information.
  • Educational Background: Academic qualifications and level of education.
HOW WE COLLECT DATA

We gather Personal Data through various means, including:

  • Direct Collection: Information you provide directly to us, such as through website forms, email communications, or other correspondence.
  • Indirect Collection: Information obtained from third-party sources, such as public records, service providers, or business partners who are authorized to share such data.
  • Automatic Data Collection: When you visit our Site, we may automatically collect certain information using data collection technologies such as cookies and similar tools (“Cookies”). These tools help us understand how visitors interact with our Sites by capturing usage metrics such as:
    • The number and frequency of visits,
    • Pages viewed and time spent on the Site,
    • Websites visited immediately before or after accessing our Site, and
    • The type of browser and device used.

For more details on how we use Cookies and how you can manage your preferences, please refer to our Cookie Notice.

If you are located outside the United States, please note that any Personal Data we collect may be transferred to, processed, and stored in the United States. The data protection laws in the U.S. may differ from those in your country of residence and may not offer the same level of protection. However, we implement appropriate safeguards, as required by applicable law, to ensure that your Personal Data remains protected during and after such transfers.

HOW WE USE PERSONAL DATA AND OUR LEGAL BASIS

We use Personal Data for a range of legitimate business and legal purposes. These include:

  • To Comply with Legal and Regulatory Obligations: We may process your Personal Data to meet obligations under applicable laws and regulations, such as know-your-client (KYC) and anti-money laundering (AML) due diligence, and regulatory reporting and compliance requirements.
  • To Fulfill or Prepare to Enter into a Contract: We may use your data when it is necessary to perform a contract with you or to take steps at your request before entering into one. This includes providing information about Växa Partners’ products or services, responding to inquiries and assisting with requests, assessing your eligibility for our offerings and determining applicable terms, and responding to KYC/AML requests from counterparties acting on your behalf.
  • For Other Legitimate Business Interests: We may also process your Personal Data for purposes such as communicating with you in the normal course of business, managing client relationships and internal operations, developing and improving our products, services, and digital platforms, conducting market research and user experience analysis, investigating and resolving disputes or security incidents, enforcing our Terms of Use and other agreements, monitoring compliance with internal policies and legal obligations, and evaluating job applications and verifying submitted information.

We will not use Personal Data for purposes that are inconsistent with this Privacy Notice without your explicit consent.

NO SALE OF PERSONAL DATA

We do not sell Personal Data and have not done so in the past.

SHARING PERSONAL DATA

Personal Data may be shared with affiliated entities and third-parties, but only as necessary and in accordance with applicable laws and internal policies.

  • Within Växa Partners and Affiliates: Personal Data may be shared among Växa Partners and its affiliated entities for the purposes outlined in this Privacy Notice. These entities operate on a shared infrastructure and are subject to internal controls that limit further disclosure to non-affiliated parties, unless permitted by law or explicitly stated in this Notice.
  • With Third-Parties: Personal Data may be disclosed to third-parties under the following circumstances:
    • Service Providers: Third-party vendors may be engaged to perform services on behalf of Växa Partners, such as IT support, website hosting, and investor services. These providers may access Personal Data solely to fulfill their contractual obligations and are generally required to maintain confidentiality and data security.
    • Corporate Transactions: In the context of a merger, acquisition, joint venture, financing, asset sale, or similar business transaction—including bankruptcy or insolvency proceedings—Personal Data may be disclosed or transferred as part of the transaction. Notice will be provided in the event of a material change in data ownership or control.
    • Legal and Regulatory Disclosures: Personal Data may be disclosed when required by applicable law, regulation, or legal process. This includes responses to subpoenas, court orders, regulatory inquiries, or other lawful requests from government and law enforcement and regulatory authorities.

PROTECTING PERSONAL DATA

Växa Partners takes the protection of Personal Data seriously. All Personal Data held by the firm is treated as confidential and managed in accordance with applicable internal policies and procedures. Reasonable technical and organizational measures are implemented to safeguard Personal Data against loss, unauthorized access, disclosure, or misuse.

Access to Personal Data is restricted to authorized personnel and approved third-parties who require it for legitimate business purposes. Data is stored in secure environments designed to prevent unauthorized access or breaches.

DATA RETENTION

Personal Data is retained for as long as necessary to fulfill contractual, legal, and regulatory obligations. The specific retention period may vary depending on the jurisdiction or the relevant Växa Partners entity. In general, data is not kept longer than required for the purposes for which it was collected, as outlined in this Privacy Notice.

Retention practices are governed by Växa Partners’ internal records management policies. Questions regarding data retention can be directed to Inquiries@Vaxa.Partners.

WEBSITES

We operate one website from servers in the United States: www.Vaxa.Partners

BY USING OUR SITE AND PROVIDING INFORMATION TO US, YOU CONSENT TO THE TRANSFER AND PROCESSING OF YOUR PERSONAL DATA IN THE UNITED STATES.

Our Site may contain links to external websites operated by third-parties. These third-party sites are not controlled by Växa Partners, and we are not responsible for their content, privacy practices, or data protection policies. Users are encouraged to exercise caution when navigating away from our Site and to review the privacy policies of any third-party websites, particularly if those sites collect Personal Data.

ADDTIONAL INFORMATION FOR JOB APPLICANTS: APPLICANT PRIVACY NOTICE

This Applicant Privacy Notice applies to all individuals applying to become employees or associated personnel of Växa Partners. It outlines how we collect, use, and protect your personal data during the recruitment process. Questions, comments, requests, or complaints regarding this Privacy Notice and our use of your Personal Data should be directed to Inquiries@Vaxa.Partners​.

ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA (THE “EEA”) AND THE UNITED KINGDOM (THE “UK”)

This section applies to any individual located in the EEA or the UK whose personal data is processed by Växa Partners in connection with the use of our website or recruitment activities.

For the purposes of the General Data Protection Regulation (EU) 2016/679 and the UK Data Protection Act 2018 (together, the “GDPR”), the data controller responsible for your personal data is:

Växa Partners
540 Madison Avenue, Floor 34
New York, NY 10022
Email: Inquiries@Vaxa.Partners

As the data controller, Växa Partners determines the purposes and means of processing your personal data. We are committed to processing your information lawfully, fairly, and transparently, and in accordance with applicable data protection laws.

GDPR DATA PROTECTION PRINCIPLES

In respect of the collection, holding, storage, use, and processing of your Personal Data, Växa Partners adheres to the following principles, as required under the GDPR:

  • Lawfulness, Fairness, and Transparency: We process personal data lawfully, fairly, and in a transparent manner.
  • Purpose Limitation: We collect data only for specified, explicit, and legitimate purposes and do not process it in a manner that is incompatible with those purposes.
  • Data Minimization: We collect only the personal data that is adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
  • Accuracy: We take reasonable steps to ensure that personal data is accurate and, where necessary, kept up to date.
  • Storage Limitation: We retain personal data only for as long as necessary for the purposes for which it was collected, subject to applicable legal or regulatory requirements.
  • Integrity and Confidentiality: We use appropriate technical and organizational measures to ensure the security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.
TRANSFER OF PERSONAL DATA OUTSIDE OF THE UK/EEA

Where personal data is transferred outside the UK or EEA, Växa Partners ensures that such transfers comply with applicable data protection laws:

  • Transfers to third-countries or international organizations are made only where the European Commission or UK authorities have issued an adequacy decision, or where appropriate safeguards are in place.
  • These safeguards may include the use of Standard Contractual Clauses (SCCs) approved by the European Commission or the UK Information Commissioner’s Office, which impose contractual obligations on the recipient to protect personal data.
  • Where required, we also conduct transfer impact assessments to evaluate the legal environment of the recipient country and implement supplementary measures where necessary.

A copy of the applicable safeguards (such as SCCs) can be requested by contacting us at ​Inquiries@Vaxa.Partners.

GDPR DATA SUBJECT RIGHTS

Under the GDPR and the UK Data Protection Act 2018 (as amended by the Data Use and Access Act 2025), individuals located in the EEA or UK have the following rights in relation to their personal data, subject to certain legal limitations:

  • Right of Access: You have the right to request access to the personal data we hold about you and to receive information about how we process it.
  • Right to Rectification: You may request that we correct or complete any inaccurate or incomplete personal data.
  • Right to Erasure (“Right to be Forgotten”): You may request that we delete your personal data where there is no lawful reason for us to continue processing it, such as compliance with legal obligations or the performance of a contract.
  • Right to Restrict Processing: You may request that we suspend the processing of your personal data, for example, if you want us to establish its accuracy or the reason for processing it.
  • Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you may request that we transfer your personal data to you or to a third-party in a structured, commonly used, and machine-readable format.
  • Right to Object: You may object to our processing of your personal data where we are relying on a legitimate interest (or those of a third-party), and you feel it impacts your fundamental rights and freedoms.
  • Right to Withdraw Consent: Where you have provided consent for the processing of your personal data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, please contact us at Inquiries@Vaxa.Partners​. We may need to verify your identity before responding to your request.

AUTOMATED DECISION MAKING

We respect your legal rights under Article 22 of the GDPR and UK GDPR not to be subject to decisions based solely on automated processing of your personal data, including profiling, where such decisions produce legal effects or similarly significant consequences for you.

In the context of our business operations, Växa Partners does not rely on solely automated decision-making processes when establishing or managing a business relationship. However, we may process certain personal data automatically for limited purposes, including:

  • To comply with legal or regulatory obligations, such as those related to anti-money laundering (AML), counter-terrorism financing, and fraud prevention.
  • To tailor communications and marketing based on your preferences or interactions with our platforms (profiling).

Where such processing occurs, it is either:

  • Not solely automated (i.e., involves meaningful human review), or
  • Based on your explicit consent or necessary for the performance of a contract, in accordance with Article 22(2) of the GDPR.
COMPLAINTS TO LOCAL AUTHORITIES

If you are a resident of the EEA or the UK and believe that we have not complied with applicable data protection laws in our handling of your personal data, you have the right to lodge a complaint with your local data protection supervisory authority.

You can find contact details for EEA supervisory authorities via ​https://edpb.europa.eu/about-edpb/board/members_en​, and for the UK via ​https://ico.org.uk/make-a-complaint/​.

You will not be required to pay a fee to access your personal data or to exercise any of your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.

CALIFORNIA DATA SUBJECT RIGHTS

Under California law, including the California Consumer Privacy Act (CCPA) and the “Shine the Light” law (California Civil Code § 1798.83), California residents have the following rights:

SHINE THE LIGHT

California residents may request, once per calendar year and free of charge, information about the categories of personal information (if any) we disclosed to third-parties for their direct marketing purposes in the preceding year. To make such a request, please contact us at Inquiries@Vaxa.Partners.

CCPA RIGHTS (AS OF 2025)

If you are a California resident, you may have the right to:

  • Request Access to the personal information we have collected about you in the past twelve (12) months.
  • Request Deletion of your personal information, subject to certain exceptions (e.g., to comply with legal obligations, complete transactions, or defend legal claims).
  • Request Information about the categories of personal information collected, the sources of that information, the business or commercial purpose for collecting it, and the categories of third-parties with whom it is shared.

You may submit a request for access or deletion by emailing us at ​Inquiries@Vaxa.Partners​.

To protect your privacy and security, we will verify your identity before processing any request. This may include asking you to confirm specific information we already hold about you. We will not disclose or delete any personal information until your identity has been verified.

If you are requesting access, please note that we may be unable to provide certain pieces of personal information if doing so would create a substantial, articulable, and unreasonable risk to the security of your personal information, your account, or our systems.

If you are requesting deletion, we may ask you to confirm your request before proceeding.

AUTHORIZED AGENTS

You may designate an authorized agent to submit a request on your behalf by providing that agent with written permission. If an agent submits a request on your behalf, we may still require you to verify your identity directly with us before we can honor the request.

Authorized agents must submit proof of their authorization to act on your behalf. We will not process requests from agents until we have verified both the agent’s authority and your identity, as required under Section 7063 of the CCPA regulations.

NON-DISCRIMINATION

We will not discriminate against you for exercising any of your rights under the CCPA. This includes denying you goods or services, charging you different prices or rates, or providing a different level or quality of service, unless such differences are reasonably related to the value provided by your data.

ECONOMIC & MARKET INFORMATION NOTICE

Economic and market views and forecasts reflect the judgment of Växa Partners as of the date of publication and are subject to change without notice. Forecasts are inherently uncertain, based on assumptions, and may change materially as economic and market conditions evolve. Växa Partners undertakes no obligation to update or revise any forward-looking statements or forecasts, whether as a result of new information, future developments, or otherwise.

Certain information contained herein may have been obtained from third-party sources that have not been independently verified or updated through the date hereof. While such information is believed to be reliable for the purposes used, Växa Partners and its affiliates make no representation or warranty, express or implied, as to the accuracy, completeness, or fairness of such information.

References to specific portfolio companies or investments are provided for illustrative purposes only and do not constitute, and should not be construed as, a recommendation or endorsement of any particular company, investment, or security. The investments described herein were not made by a single investment fund or product and do not represent all investments made or recommended by any fund or strategy managed by Växa Partners.

This material is provided for informational purposes only and does not constitute an offer to sell, or a solicitation of an offer to buy, any security or investment product in any jurisdiction where such offer or solicitation would be unlawful. It is not intended to provide, and should not be relied upon for, investment, accounting, legal, or tax advice. This material does not take into account the specific investment objectives, financial situation, or needs of any particular investor.

540 Madison Avenue, 34th Floor, New York, NY 10022

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