1. Introduction

This Privacy Policy explains how personal data is collected, used and protected when you visit thinkfirstcapital.com (the “Website”) or contact us through it.

We process personal data in accordance with the Law on Personal Data Protection of the Republic of North Macedonia (Official Gazette No. 42/2020, as amended). Where our processing falls within the territorial scope of Regulation (EU) 2016/679 (the General Data Protection Regulation, “GDPR”), we process personal data in accordance with that Regulation as well.

2. Who controls your data

The controller of your personal data is:

Think First Capital Group ul. Vostanicka 2, 1000 Skopje, North Macedonia Registered in the Central Register of the Republic of North Macedonia.

Email: contact@tfcapital.mk

3. What personal data we collect

Data you provide directly. Where you use a contact form, request materials, or write to us: first name and surname, email address, telephone number, company or organisation name, position, country, and the content of your message.

Investor eligibility data. Where your enquiry concerns an investment opportunity, we may additionally process information relating to your client classification, your knowledge and investment experience, and identity and source-of-funds documentation required under applicable know-your-customer and anti-money-laundering rules.

Technical and usage data. Collected automatically when you visit the Website: IP address, browser type and version, operating system, device type, referring page, pages viewed, date and time of visit, and approximate location derived from IP address.

Cookie data. Information stored on or read from your device through cookies and similar technologies. Details are set out in our Cookie Policy, and consent is managed through the consent banner.

Correspondence records. Records of communications between you and us.

4. Why we process it, and on what basis
Purpose Legal basis
Responding to enquiries submitted through the contact form or by email Our legitimate interest in responding to enquiries addressed to us. Where the enquiry concerns a prospective agreement, the basis is steps taken at your request prior to entering into a contract
Assessing investor eligibility and professional-client classification Compliance with a legal obligation, and our legitimate interest in ensuring communications reach only eligible recipients
Know-your-customer and anti-money-laundering checks Compliance with a legal obligation
Operating, securing and maintaining the Website, including detecting and preventing abuse Our legitimate interest in the security and correct functioning of the Website
Analytics and measurement of Website traffic Your consent, given through the cookie consent banner
Marketing communications Your consent
Establishing, exercising or defending legal claims Our legitimate interest in protecting our rights

Providing personal data is voluntary. However, without the data marked as required in a contact form we will not be able to respond to your enquiry, and without eligibility and identity data we will not be able to progress any investment discussion.

5. Who we share it with

Personal data may be disclosed to:

providers of IT, hosting, email and website maintenance services;
providers of analytics and marketing tools, where you have consented to their use;
legal, tax, accounting and audit advisers;
entities involved in the Think First Capital I platform and, where relevant to your enquiry, NOVARIS CAPITAL Alternatywna Spółka Inwestycyjna S.A. w organizacji, with its registered office in Warsaw, Poland;
competent public authorities, where disclosure is required by law.

External providers process personal data on our behalf under written data processing agreements, and may not use it for their own purposes.

We do not sell personal data.

6. Transfers outside North Macedonia

The Think First Capital I platform operates across borders, and personal data may be transferred to recipients outside the Republic of North Macedonia — in particular to Poland in connection with the platform’s alternative investment company structure, and to service providers established in the European Union and other jurisdictions.

Such transfers are made only where the recipient country ensures an adequate level of protection, or where appropriate safeguards are in place, including standard contractual clauses, together with any authorisation required under the Law on Personal Data Protection. You may request further information about the safeguards applied by writing to us at the address in section 2.

7. How long we keep it

Enquiries and correspondence — for the period necessary to handle the matter, and thereafter for the limitation period applicable to related claims, generally five years.
Investor eligibility, know-your-customer and anti-money-laundering records — ten years from the end of the relationship, as required by applicable anti-money-laundering legislation.
Data processed on the basis of consent — until consent is withdrawn.
Server logs — twelve months.
Cookies — for the periods stated in the Cookie Policy.

Where a legal obligation or an ongoing claim requires a longer period, data is retained for that period and no longer.

8. Your rights

You have the right to:

request access to your personal data and a copy of it;
request correction of inaccurate or incomplete data;
request erasure of your data;
request restriction of processing;
receive your data in a portable format, where processing is based on consent or contract and carried out by automated means;
object to processing based on our legitimate interest, on grounds relating to your particular situation;
object at any time to processing for direct marketing purposes;
withdraw consent at any time where processing is based on consent. Withdrawal does not affect the lawfulness of processing carried out before it.

To exercise any of these rights, write to contact@tfcapital.mk. We will respond within the period required by applicable law.

You also have the right to lodge a complaint with the Agency for Personal Data Protection of the Republic of North Macedonia (Агенција за заштита на личните податоци), Skopje — www.azlp.mk. Where the GDPR applies to the processing concerned, you may instead lodge a complaint with the supervisory authority of your Member State of residence, place of work, or the place of the alleged infringement.

9. Automated decision-making

Personal data collected through the Website is not used for automated decision-making that produces legal effects concerning you or similarly significantly affects you.

10. Security

We apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction or alteration. These include encrypted transmission (SSL/TLS), access controls limiting data to personnel who need it, and contractual confidentiality obligations on personnel and service providers.

11. Changes to this Policy

We may update this Privacy Policy to reflect changes in our processing activities or in applicable law. The current version, with the date of the last update, is always published on this page.

12. Contact

Questions about this Privacy Policy or about how we process your personal data should be sent to contact@tfcapital.mk, or to the postal address in section 2.