Your privacy, in a few words.

Last updated: 5 September 2026

TWEFDA Limited is committed to handling personal information fairly, transparently and securely. This Privacy Policy explains how personal data is collected and used through the TWEFDA website, including enquiries, controlled investor access, the WaveAmp investment process and other interactions with TWEFDA.

1. Who we are

The website is operated by TWEFDA Limited, a company incorporated in Scotland under company number SC585091.

Website: https://www.twefda.com
Privacy and data-protection enquiries: twefda@twefda.com

Unless we tell you otherwise in relation to a particular activity, TWEFDA Limited is the controller of personal data collected through this website.

Some investor enquiries submitted through this website relate specifically to WaveAmp, TWEFDA’s focused commercialisation route for Weight-Changing Energy. TWEFDA may administer those enquiries and the associated controlled-access investor environment. Where WaveAmp separately determines the purposes and means of processing personal information, additional privacy information will be provided where required.

2. Personal information we may collect

Depending on how you interact with us, we may collect information including your name, professional email address, organisation, role or position, country, investor or organisation type, the reason for contacting us, investment or commercial interests, correspondence with us and information that you voluntarily provide.

Where you receive access to a controlled investor or technical area, we may also record your access level, invitation creation and expiry dates, confidentiality or NDA status where applicable, room access events, document access or download events and related security information.

For security and audit purposes, our controlled investor-access system may create a one-way keyed hash derived from an IP address. The Investor Data Room activity log is designed not to retain the raw IP address itself.

3. Why we use personal information

We may use personal information to respond to enquiries; assess investor, commercial, research or collaboration requests; manage access to confidential information; conduct investor and commercial discussions; administer the WaveAmp Investment Panel and TWEFDA Investor Data Room; issue, manage, expire or revoke personal access permissions; maintain security and audit records; manage confidentiality and due-diligence processes; protect TWEFDA’s and WaveAmp’s intellectual property and confidential information; establish, exercise or defend legal rights; comply with legal, regulatory, accounting or corporate obligations; and operate, protect and improve this website.

Submitting an investor-access request does not automatically grant access to confidential or restricted material. Requests may be reviewed by TWEFDA and/or authorised representatives before access is granted.

4. Our lawful bases for processing

Depending on the circumstances, we process personal information on one or more of the following lawful bases:

• Legitimate interests — including responding to professional enquiries, assessing potential investors or commercial relationships, administering controlled due diligence, protecting confidential information and intellectual property, maintaining appropriate security and audit records, and managing TWEFDA’s and WaveAmp’s legitimate business activities.
• Steps before entering into a contract or performance of a contract — where processing is necessary in connection with an agreement, proposed investment, confidentiality arrangement, licence or other commercial relationship requested by you.
• Legal obligation — where we need to process information to comply with applicable legal, regulatory, tax, accounting or corporate requirements.
• Consent — where consent is specifically requested, for example for certain non-essential cookies or other activities for which consent is the appropriate lawful basis.

Where we rely on legitimate interests, we consider whether those interests are necessary and balanced against your rights and reasonable expectations.

5. WaveAmp investor access and controlled due diligence

If you request access to WaveAmp investor materials, we may ask for sufficient professional information to identify you, understand the context of your request and determine the appropriate level of disclosure.

Investor access is personal. It may be time-limited, restricted to particular document categories, made subject to confidentiality requirements, refused, withdrawn or revoked where appropriate.

The investment-access system may record when an authorised recipient enters the Investment Panel and when controlled documents are accessed or downloaded. These records are maintained for legitimate security, confidentiality, due-diligence and audit purposes.

Access to one level of information does not automatically authorise access to more sensitive material. Restricted Technical information may require additional approval even where confidentiality or NDA requirements have already been satisfied.

6. Confidentiality and NDA records

Where an investor, partner or other recipient enters into or acknowledges a confidentiality agreement or NDA, we may retain information necessary to evidence the agreement, its version, relevant dates, the parties involved and the access subsequently granted.

Acceptance of general website terms or a request for investor access is not treated as acceptance of an NDA unless the NDA is separately and clearly presented for acceptance or otherwise executed between the relevant parties.

7. Marketing communications

Submitting a contact form, investor-access request or confidential-document request does not automatically subscribe you to marketing communications.

If we introduce optional email marketing or newsletters, we will provide the appropriate information and choice at the point of subscription and you will be able to unsubscribe from such communications.

8. Who we may share information with

Personal information may be shared where necessary with authorised personnel working for or with TWEFDA; WaveAmp where relevant to a WaveAmp investment or commercial discussion; professional advisers such as legal, tax, patent, financial or corporate advisers; technology, website, hosting, email and security service providers acting on our behalf; and public authorities or regulators where disclosure is required by law.

We do not sell personal information to advertisers.

9. International transfers

Some of our service providers or professional advisers may process personal information outside the United Kingdom or the European Economic Area. Where applicable data-protection law requires safeguards for an international transfer, we will rely on an applicable adequacy decision or regulation, contractual safeguards or another lawful transfer mechanism.

You may contact us at twefda@twefda.com if you would like further information about safeguards relevant to your personal information.

10. How long we retain personal information

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected and for legitimate legal, security and record-keeping requirements.

General enquiries may normally be retained for up to 24 months after the last substantive interaction unless a continuing relationship or legal reason requires longer retention.

Investor-access applications, due-diligence correspondence and access records may normally be retained for up to 24 months after the last substantive investor interaction where no investment or continuing relationship results.

Where an investment, commercial relationship, NDA, licence or other agreement proceeds, relevant records may be retained for the duration of that relationship and afterwards for the period reasonably necessary to meet legal, regulatory, accounting or contractual requirements or to establish, exercise or defend legal claims.

Access tokens themselves are designed to expire and may also be revoked before their scheduled expiry.

11. Security

We use organisational and technical measures intended to protect personal information and confidential material against unauthorised access, alteration, disclosure or loss.

Controlled investor and technical documents may be stored separately from publicly accessible website files and delivered through personal, expiring or revocable access mechanisms.

No internet service can guarantee absolute security. We therefore review our controls as the website and investor-access infrastructure develop.

12. Cookies and similar technologies

The website may use cookies or similar technologies that are strictly necessary for security, administration, language or requested functionality.

The controlled Investor Data Room may use a strictly necessary session mechanism to maintain secure access after a valid personal invitation. It is not intended for advertising or behavioural profiling.

Where non-essential cookies or similar technologies are used, including analytics or advertising technologies where consent is required, they will be subject to the applicable consent requirements and cookie controls.

13. Embedded content and third-party services

Pages on this website may contain embedded videos, images, maps, documents, links or other content provided by third-party services. Interacting with third-party content may allow the relevant provider to receive information about your visit and may be subject to that provider’s own privacy and cookie practices.

14. Comments, submissions and uploaded material

Where comments, Knowledge Base contributions, document submissions or other user-submission features are enabled, we may collect the information submitted together with technical information reasonably necessary to operate, moderate and secure the service.

Please do not submit confidential personal information, special-category personal data or personal information relating to another person unless it is necessary and you are authorised to provide it.

15. Automated decision-making

We do not currently use solely automated decision-making that produces legal or similarly significant effects in deciding whether to grant investor or restricted-document access. Controlled-access requests are subject to human review where approval is required.

16. Your data-protection rights

Depending on the applicable law and circumstances, you may have rights to request access to your personal information, correct inaccurate information, request erasure, restrict processing, object to certain processing and receive certain information in a portable format.

Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Your right to object: where we rely on legitimate interests, you have the right to object to the processing of your personal information in circumstances provided by applicable data-protection law.

To exercise a privacy right, contact twefda@twefda.com. We may need to verify your identity before fulfilling a request.

17. Complaints

If you have concerns about our handling of personal information, please contact us first at twefda@twefda.com so that we can investigate.

You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO) where UK data-protection law applies.

Where the EU GDPR applies, you may also have the right to complain to the competent supervisory authority in the EU Member State of your habitual residence, place of work or the place of the alleged infringement.

18. Changes to this Privacy Policy

We may update this Privacy Policy when our website, investor-access arrangements, service providers or legal obligations change. The current version and its last-updated date will be published on this page.

19. Contact

For privacy, data-protection or personal-information enquiries:

TWEFDA Limited
Scotland · Company No. SC585091
Email: twefda@twefda.com
Website: https://www.twefda.com