Privacy Policy

1. Introduction

Energio ("we", "us", "our") is committed to protecting your personal data and to being transparent about how we collect and use it. This Privacy Policy explains our data practices in connection with your use of the Energio platform at https://www.energio.transyralogistics.com/public (the "Platform") and any related services.

This policy applies to all users of the Platform, including investors, advisors, and visitors. Where Energio acts as a data controller — determining the purposes and means of processing your personal data — we are responsible for ensuring that processing is carried out lawfully and in accordance with applicable data protection law.

2. Personal Data We Collect

We collect personal data in the following categories:

3. How We Use Your Personal Data

We process your personal data for the following purposes and on the following legal bases:

• Account registration and management — to create and manage your investor account (contract performance).
• Identity and AML verification (onboarding/KYC) — to comply with our legal obligations under anti-money laundering and financial crime prevention legislation (legal obligation).
• Investment facilitation — to process investment commitments, execute subscription agreements, and manage SPV participation (contract performance).
• Distribution and reporting — to process income distributions, deliver quarterly reports, and provide annual financial statements (contract performance).
• Regulatory compliance — to meet obligations under applicable securities, financial, and data protection regulations (legal obligation).
• Platform improvement and security — to monitor platform usage, detect fraudulent activity, and improve our services (legitimate interests).
• Marketing communications — to inform you of new opportunities and platform updates where you have opted in (consent), or where we have a legitimate business interest and you have not opted out.

4. Sharing Your Data

We do not sell your personal data. We share your data only in the following circumstances:

• Identity verification and compliance providers — regulated third-party identity verification and AML screening services, bound by data processing agreements.
• Legal and SPV administration — lawyers, corporate administrators, and trustees involved in structuring and managing the SPVs you participate in.
• Payment processors and banking partners — to process investment funding and distribution payments.
• Auditors and regulators — where required by law, regulatory audit, or court order.
• Technology service providers — cloud hosting, analytics, and security providers operating under strict data processing agreements with access limited to what is necessary for their service.

5. Data Retention

We retain personal data for as long as necessary to fulfil the purposes for which it was collected and to comply with our legal obligations. Specifically:

• Onboarding/KYC and AML records are retained for a minimum of 5 years from the end of the business relationship, or longer where required by applicable law.
• Investment transaction records are retained for the duration of the investment plus at least 7 years thereafter for legal and regulatory purposes.
• Account data is retained until account closure and for a reasonable period thereafter.
• Communication records are retained for up to 3 years from the date of correspondence.

6. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include encryption in transit and at rest, access controls, and regular security assessments. However, no internet transmission or electronic storage is entirely secure. If you have reason to believe that your data has been compromised, please contact us immediately at energio@transyralogistics.com.

7. Your Rights

Depending on your jurisdiction, you may have the following rights in relation to your personal data:

• Right of access — to request a copy of the personal data we hold about you.
• Right to rectification — to request correction of inaccurate or incomplete data.
• Right to erasure — to request deletion of your data, subject to our legal retention obligations.
• Right to restrict processing — to request that we limit processing of your data in certain circumstances.
• Right to data portability — to receive your data in a structured, machine-readable format.
• Right to object — to object to processing based on legitimate interests, including direct marketing.
• Right to withdraw consent — where processing is based on consent, to withdraw it at any time without affecting prior processing.

To exercise any of these rights, contact us at energio@transyralogistics.com. We will respond within 30 days. You also have the right to lodge a complaint with your local data protection supervisory authority.

8. Cookies

We use cookies and similar tracking technologies to support platform functionality, maintain secure sessions, and analyse usage patterns. Essential cookies are required for the Platform to function and cannot be disabled. Analytics and functional cookies require your consent where applicable law demands it. For full details, please see our Cookie Policy.

9. International Data Transfers

Energio operates internationally. As such, your personal data may be processed in countries outside your home jurisdiction. Where we transfer data to countries that do not provide an equivalent level of data protection, we ensure appropriate safeguards are in place — such as standard contractual clauses approved by the relevant supervisory authority — to protect your data in accordance with applicable law.

10. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Effective date" at the top of this page and notify registered users by email where appropriate. Your continued use of the Platform after any changes constitutes your acceptance of the updated policy.

11. Contact Us

For privacy-related questions, data requests, or concerns, please contact our data privacy team: