Privacy Policy

The data controller for personal data processed in connection with this website and the Reelmine platform is Elbe Tech Invest ETI GmbH ("Reelmine", "we", "us"), a company incorporated in Germany. You can reach us at info@reelmine.ai for any privacy-related question and at dpo@reelmine.ai to contact our Data Protection Officer.

This policy applies to all visitors of reelmine.ai (including subdomains) and to producers, investors, advisors and other counterparties who interact with the Reelmine platform.

We process personal data in compliance with the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR"), the UK GDPR and Data Protection Act 2018, and — where applicable — the California Consumer Privacy Act ("CCPA") as amended by the CPRA.

The platform is offered exclusively to qualified, professional or accredited investors as defined under MiCA, FCA rules and SEC Regulation D 506(c). Eligibility verification involves processing personal data as described in this policy.

We collect only the data we need to operate the platform safely and lawfully.

Provided directly by you

• Identity and contact data (name, email, company, role, country, time zone).
• KYC / KYB and accreditation documents (government ID, proof of address, source-of-funds evidence, ownership structure).
• Communications you send through the contact form, the producer survey or by email.
• Project information (when uploaded by producers): scripts, budgets, contracts, slates.
• Payment, settlement and wallet information (where you participate in an offering).

Collected automatically

• Technical data: IP address, user agent, device type, language, referrer, pages viewed, timestamps, security events.
• Cookies and similar technologies (see "Cookies" below).

Received from third parties

• Identity verification providers, sanctions / PEP screening providers, financial institutions and on-chain analytics providers used for compliance checks.
• Public registries (commercial register, beneficial-owner registers, sanctions lists, court records).

Operate the platform

Provide accounts, dashboards, scoring engine output and on-chain settlement (Art. 6(1)(b) GDPR — performance of a contract).

KYC, AML / CTF and accreditation

Verify identity, assess sanctions / PEP exposure, confirm investor eligibility (Art. 6(1)(c) GDPR — legal obligation; Art. 6(1)(f) — legitimate interest in fraud prevention).

Customer communications

Reply to messages, send transactional notifications and operational updates (Art. 6(1)(b); Art. 6(1)(f)).

Marketing

Send platform updates and pipeline alerts where you have explicitly opted in (Art. 6(1)(a) GDPR — consent). You can withdraw consent at any time.

Security and abuse prevention

Detect and respond to attacks, misuse and policy violations (Art. 6(1)(f)).

Legal claims

Establish, exercise or defend legal claims and respond to lawful requests (Art. 6(1)(c); Art. 6(1)(f)).

Aggregate analytics

Improve the product and report platform-level metrics. Aggregate analytics use mathematical noise so that no individual project or person can be re-identified (Art. 6(1)(f)).

When a producer uploads a script, contract or other production document, the file is processed by Reelmine's proprietary AI engine. We have made specific commitments around how that data is handled:

• No third-party AI providers. Models run on infrastructure we control. We do not call external AI APIs and do not transmit your scripts outside the platform.
• No training on your data. Your project material is not used to train, fine-tune or evaluate any general-purpose model and is never used to inform other producers' projects.
• Per-project isolation. Project data is encrypted with project-level keys and isolated by access control. External collaborators only see what you explicitly share.

Read more in our Security overview.

We do not sell personal data. We share data with categories of recipients strictly necessary to deliver the platform:

• Service providers acting as processors: hosting (EU-based), email delivery, transactional logging, customer support tooling, identity verification, sanctions screening, and accounting software. Each processor is bound by a data processing agreement.
• Counterparties in a transaction: where you participate in an offering, we share what is necessary with the relevant SPV, custodian, paying agent, escrow agent, distributor or co-investor.
• Regulators and authorities: when required by law or by a competent authority (financial regulators, courts, tax authorities, anti-money-laundering authorities).
• Professional advisors: auditors, lawyers and tax advisors under professional confidentiality.
• In connection with a corporate transaction: if Reelmine is involved in a merger, acquisition or asset transfer, your data may be transferred subject to equivalent protection.

Reelmine is operated from the European Union and personal data is primarily stored in the EEA. Where we transfer data outside the EEA / UK (for example to a US-based service provider), we rely on:

• An adequacy decision of the European Commission, where applicable; or
• Standard Contractual Clauses (Decision (EU) 2021/914) supplemented by a transfer impact assessment and additional technical measures (encryption in transit and at rest, key separation, access logging).

You may request a copy of the relevant safeguards by emailing us.

We retain personal data only as long as necessary for the purposes for which it was collected:

• Account and contractual data: for the duration of the relationship and up to ten (10) years after termination, in line with German commercial and tax law (HGB §257, AO §147).
• KYC / AML records: at least five (5) years after the end of the business relationship, in line with the German GwG and FCA / SEC requirements.
• Marketing consent records: until consent is withdrawn, plus a short audit window thereafter.
• Server logs: typically 90 days, longer when investigating a security incident.

After the applicable period we erase or irreversibly anonymise the data.

Subject to the conditions in applicable law, you have the right to:

• Access your personal data and obtain a copy.
• Correct inaccurate or incomplete data.
• Request erasure ("right to be forgotten") where no overriding legal basis applies.
• Restrict or object to certain processing.
• Receive your data in a portable, machine-readable format.
• Withdraw any consent you previously gave, without affecting prior processing.
• Lodge a complaint with a supervisory authority (in Germany, the Hamburgische Beauftragte für Datenschutz und Informationsfreiheit).

California residents additionally have the right to know, delete, correct and limit the use of sensitive personal information, as well as the right not to be discriminated against for exercising those rights.

To exercise any right, write to dpo@reelmine.ai. We will respond within 30 days (extendable by 60 days for complex requests).

We use a minimal set of strictly necessary cookies to keep the website working and to remember your preferences. Where required, optional cookies (such as analytics) are loaded only after you give consent through the cookie banner. You can change your choice at any time from the cookie settings link in the footer.

We protect personal data with banking-grade controls: AES-256 encryption at rest, TLS 1.3 in transit, role-based access control, secure enclaves for sensitive processing, audited smart contracts and continuous monitoring. See our Security overview for the full list of pillars.

Reelmine is not directed at children. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with data, contact us and we will delete it.

We may update this policy to reflect changes to the platform or to the law. We will indicate the revision date at the top of the policy and, for material changes, notify users through the platform or by email.

Elbe Tech Invest ETI GmbH
Hamburg, Germany
General: info@reelmine.ai
Data protection: dpo@reelmine.ai