EXWORTH

(the “Platform”)

PRIVACY NOTICE

This notice (the “Privacy Notice”) explains how we use the personal data that the Platform (“we” and “us”) collect orwhich is provided to the Platform.

This Privacy Notice is directed to individuals whose personal data we or our third party processors handle in the course of carrying on our commercial activities, including any shareholder, beneficial owner, officer, director or other representative of your Company (“you”).

The Platform is responsible for ensuring that we use your personal data in compliance with applicable data protection law. This Privacy Notice sets out the basis on which any personal data about you will be processed by us.

Personal data that we collect and process about you

• Information that you provide to the Platform: the nature of our relationship with you will determine the kind of personal data we might ask for, though such information may include (by way of a non-exhaustive list) basic personal data such as name, address, email address, phone number and tax identification number.
• Information that we collect or generate about you: files that we may produce as a record of our relationship and any personal data that you provide during communications with us.
• Information that we obtain from other sources: this includes information from publicly available sources, professional advisers, and information obtained from sanctions checking and background screening.

Purpose of processing and legal basis for processing

Your personal data may be processed by the Platform (or any of its affiliates, agents, delegates or subcontractors) for the following purposes which are necessary for performance of your contract with us:

• To manage and maintain our relationship with you;
• To enforce or defend the Platform's rights either directly through the Platform or through third parties to whom it delegates such responsibilities; and
• To comply with any applicable legal, tax or regulatory obligations of the Platform.

Your personal data may be processed by the Platform (or any of its affiliates, agents, delegates or subcontractors) for the following purposes in order to enable the Platform to comply with its legal or regulatory obligations:

• in order to carry out anti-money laundering checks and related actions including sharing your personal data with police, law enforcement, tax or regulatory authorities, or other government agencies where we have a legal obligation, including screening transactions, reporting suspicious activity and complying with production and court orders;
• to report tax related information to tax authorities, including the automatic exchange of tax information;
• to investigate and resolve complaints and manage contentious regulatory matters, investigations and litigation; and
• to monitor electronic communications for investigation and fraud prevention purposes, crime detection, prevention and investigation.

Please ensure that you provide a copy of this Privacy Notice to any third parties whose personal data you provide to the Platform. This Privacy Notice may be updated at any time and the Platform will notify you in writing of any changes.

Recipients of data and international transfer of data

The Platform may disclose your personal data as follows:

• to our affiliates and third party service providers engaged in connection with the oversight, safekeeping, administration or operation of the Platform, in order to process the data for the above mentioned purposes; and
• to competent authorities (including tax authorities), courts and bodies as required by applicable law or requested by such entities or to affiliates for internal investigations and reporting.

The disclosure of personal data to the third parties set out above may involve the transfer of data to jurisdictions outside your country of residence for processing. Where the Platform transfers your personal data to another country it is required to do so in a manner consistent with legal requirements. This may be done in any of the following ways:

• the country to which we send your personal data might be approved by the European Commission as offering an adequate level of protection for personal data;
• the recipient may have signed a contract based on “model contractual clauses” approved by the European Commission, obliging it to protect personal data; or
• in other circumstances the law may permit us to otherwise transfer your personal data outside the Cayman Islands.

Personal data quality

We rely on the accuracy of the information provided by you and others. We take reasonable efforts to ensure that personal data collected by us or on our behalf is accurate, up to date, and complete, in accordance with applicable law. If any information about you changes or you have any concerns regarding the accuracy of information about you held by us, you should contact us at the address provided.

Security of personal data

The Platform has physical, electronic and procedural safeguards in place to protect personal data from loss, misuse, unauthorised access, disclosure, alteration and destruction, however no data security measures can guarantee complete security all of the time.

Retention period

The Platform will retain your personal information for as long as is necessary to provide our services to you, to fulfil the purposes described in this Privacy Notice and/or our business purposes, or as required by law, regulation or internal policy. We are obliged to retain certain information to ensure accuracy, to help maintain quality of service, and for legal, regulatory, fraud prevention, and legitimate business purposes. In general, the Platform (or our service providers) will hold personal data for as long as required for the Platform to perform the services or comply with applicable legal/regulatory obligations.

Data Subject Rights

You have various rights in relation to your personal data held by us, including the right to:

• be informed and to request access to your personal data;
• correct any mistakes on our records, erase or restrict records where they are no longer required;
• object to use of personal data where that processing is based on the Platform's legitimate business interests or for direct marketing; and
• request not to be subject to automated decision making if the decision produces legal or other significant effects on you.

Your rights in relation to your personal data outlined above are subject to a number of legal conditions and exemptions. We will respond to your request in writing as soon as practicable and in any event not more than within one month after of receipt of your request. In exceptional cases, we may extend this period by two months and we will tell you why. We may request proof of identification to verify your request.