Effective Date: 13 November 2023

1. Purpose and Scope

TULA Companies GmbH (“TULA”, “we”, “us”, “our”) is dedicated to protecting the confidentiality of information shared with us by our clients. This confidentiality policy (the “Policy”) outlines how we handle, use, and disclose such confidential information in the course of our business activities.

2. Definition of Confidential Information

“Confidential Information” refers to any non-public information provided by our clients that is designated as confidential or, given the nature of the information or the circumstances surrounding its disclosure, should reasonably be considered as confidential. This includes, but is not limited to, business plans, financial data, technological innovations, and marketing strategies.

3. Handling of Confidential Information

We are committed to maintaining the confidentiality of all Confidential Information, ensuring it is not disclosed to third parties, except as outlined in this Policy. The use of Confidential Information will be strictly limited to the purpose of evaluating potential business relationships or investment/financing opportunities.

4. Permitted Disclosure

We may disclose Confidential Information to financing partners when it is necessary for the evaluation of a potential business relationship or investment/financing opportunity. All financing partners will be made aware of this Policy and the confidential nature of the Confidential Information.

5. Forced Disclosure

Should TULA be legally compelled to disclose Confidential Information, we will endeavor to notify the concerned party promptly and cooperate to the extent possible in protecting against or minimizing such disclosure.

6. Data Retention

Upon termination of the business relationship and at the request of the disclosing party, TULA will return or securely destroy all copies of Confidential Information, except as required for compliance with legal obligations or internal record-keeping.

7. No Warranty

TULA does not guarantee the accuracy or completeness of any Confidential Information.

8. Policy Acknowledgement

By sharing Confidential Information with us or receiving Confidential Information from us without prompt dissent, clients, financing partners and all others who are made aware of this Policy acknowledge and consent to the terms of this Policy. Reference to this Policy in agreements with clients or financing partners without any prompt dissent thereto will constitute acknowledgment and acceptance of the terms of this Policy.

9. Amendments

This Policy may be amended from time to time at the discretion of TULA. For changes to become effective retroactively, they have to be communicated to the relevant parties.