By being a member of EstBAN, you shall agree to comply with the Code of Conduct.

Last updated: 22 January 2026

1. Introduction

By being a member of EstBAN, you shall agree to comply with the Code of Conduct. 

Members shall conduct themselves professionally, ethically, and responsibly in all EstBAN-related activities and shall comply with applicable laws and regulations, including data protection laws such as the General Data Protection Regulation (GDPR) and EstBAN’s Privacy Policy when accessing, receiving, or processing any personal data through EstBAN activities.

2. Business Angel Network

A Business Angels Network (BAN) is an organization that aims to bring together new or growing small and medium-sized companies (Investees) with private, informal investors (Business Angels). 

The main activity of a BAN is to match the capital-seeking entrepreneur with the informal investor, help lead investors to arrange syndicates, carry out training sessions for the Angels as well as educate the startup ecosystem players about angel investing. 

3. Business Angel

Individual, who invests their own money into unquoted companies, and contributes time, experience and expertise for the benefit of the Investee.

4. Investees/Entrepreneurs

Entrepreneurial company eligible or looking for investment.

5. Angel investment

Angel investing is a high-risk asset class. Returns are typically achieved across a diversified portfolio of multiple investments, and no return is guaranteed.

Members acknowledge that any investment decision is made at their own discretion and responsibility. There is a real risk of losing the entire invested amount, and each member must make their own informed and independent decision.

Angel and/or startup investments are usually suggested to be not more than 10% of your investment portfolio and your angel portfolio is recommended to consist of at least 10 different investments. 

6. Best Practice

At all times, EstBAN members shall conduct business in a fair, honest, and professional manner in dealings with investees, fellow investors, EstBAN partners, and other business angel networks.

Members shall not engage in, support, or associate with unlawful, unethical, or improper practices that could damage the reputation of EstBAN.

Members shall not knowingly participate in transactions where the source of funds appears unlawful or of questionable origin.

A legal contract must be entered into between an EstBAN member and any investee or investor with whom they invest. Members are encouraged to use standard investment documentation recommended by Startup Estonia or EstBAN.

Members shall not intentionally withhold material information about an investee or deal that could reasonably be expected to negatively affect other members of the EstBAN network.

EstBAN members who are not authorised or regulated to provide investment advice shall clearly inform both investors and investees that they do not provide advice on suitability and that each party must carry out their own independent due diligence.

7. Membership and fees

EstBAN membership is membership fee-based, annually with a one-time entrance fee.

The yearly membership invoice will be issued in the I quarter of the year. Changes in the membership fees have to be confirmed by the Annual General Meeting.

When applying for the membership, the applicant is committing to pay the membership fee according to the invoices issued in a timely manner.

To become a member, an applicant must:

• Complete the membership application on EstBAN’s website;
• Agree to this Code of Conduct;
• Provide at least two (2) recommendations from existing EstBAN members.

The new members are confirmed by the managing board of EstBAN.

In order to terminate EstBAN membership, the investor shall clear all debts to EstBAN and send a written wish to terminate the membership via email to the managing director of EstBAN.

EstBAN has the right to terminate the membership in case of not complying with the Code of Conduct.

8. Confidentiality, data protection and ethics

8.1 Confidentiality and lawful use of information

EstBAN members shall use all information received through EstBAN, including business, investment, and personal information, solely for legitimate EstBAN purposes, such as evaluating investment opportunities, participating in EstBAN activities, or facilitating network collaboration.

Information received through EstBAN must not be exploited, reused, or applied for unrelated purposes, including personal sales activities, unsolicited marketing, profiling, data enrichment, or training artificial intelligence or automated systems.

When an investee enters into a contract with EstBAN they must provide an executive summary and business plan in a format that can be circulated to the EstBAN members via e-mail. These details must not be shared with others than members of EstBAN network and/or the syndicate members.

8.2 Personal data and data protection obligations

For the purposes of this Code of Conduct, personal data means any information relating to an identified or identifiable natural person, including founders, startup employees, investors, event participants, speakers, mentors, partners, and EstBAN members.

Members acknowledge that personal data accessed or received through EstBAN activities is subject to applicable data protection laws, including the GDPR, and EstBAN’s Privacy Policy. These obligations apply to members individually, regardless of whether the data is accessed through EstBAN systems or shared informally.

8.3 Practical handling of personal data

In practice, EstBAN members must:

• Use personal data only for the purpose for which it was provided;
• Not copy, download, scrape, store, or upload personal data into personal databases, CRM systems, cloud storage, messaging platforms, or third-party tools unless expressly authorised and legally permitted;
• Not share personal data or deal materials outside the EstBAN network without prior written consent of the data subject and/or EstBAN, unless required by law;
• Limit access to personal data to what is reasonably necessary for evaluation or participation purposes.

8.4 Data security and retention

Members shall take reasonable measures to protect personal data against unauthorised access, disclosure, loss, or misuse, taking into account the sensitivity of the information.

Personal data shall not be retained longer than necessary for the relevant EstBAN purpose and must be securely deleted, anonymised, or irreversibly destroyed once it is no longer required.

8.5 Data incidents and cooperation

Any suspected or actual loss, unauthorised disclosure, access, or misuse of personal data related to EstBAN activities must be reported to EstBAN without undue delay.

Members shall cooperate fully with EstBAN in investigating, mitigating, and remedying any such incident, including providing relevant information required for legal or regulatory compliance.

8.6 Events, photography, and public sharing

EstBAN events may be photographed or recorded for documentation, communication, and promotional purposes in accordance with EstBAN’s Privacy Policy and applicable law.

Members shall respect all notices, instructions, and opt-out mechanisms communicated by EstBAN regarding photography or recording at events.

8.7 Ethical conduct

EstBAN members shall act professionally and ethically at all times.

The EstBAN network must not be used as a sales channel for unsolicited professional services or products.

Members shall consciously avoid any conduct that constitutes verbal, physical, or other forms of harassment, including sexual harassment.

Any suspected misuse of information or breach of this Code of Conduct may be reported to the EstBAN managing board.

9. Adoption and enforcement

This Code of Conduct is adopted by the managing board of EstBAN.

Breaches of this Code of Conduct may result in corrective measures, suspension, or termination of membership, depending on the severity and nature of the breach.

These rules are adopted by the EstBAN managing board, to which any information of misuse also can be directed.