Privacy NOTICE

1. Introduction

Welcome to STS Capital Partners M&A Advisers Inc (“STS” or “we” or “us”) Privacy Notice (“Notice”).

STS respects your privacy and is committed to protecting your Personal Data. This Notice explains how we look after your Personal Data when you interact with us – including when you visit the Website, make enquiries with us, engage with us in connection to our M&A advisory services (“Our Services”), or receive marketing from STS. It also tells you about your privacy rights and how the law protects you.

Please ensure that you read this Notice in conjunction with the Website’s Terms of Use.

2. Definitions and Interpretations

“Data”: means, collectively, all information that we collect, receive, generate or otherwise process in connection with you, whether submitted by you (by means of the Website or by any other means), received from third parties or public sources, or provided to us by, or on behalf of, a client (including in connection with our Services, a transaction, or related due diligence). This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

“Data Protection Laws”: means any applicable law relating to the processing of Personal Data, and any national or international implementing laws, regulations and secondary legislation;

“Website”: means the website that you are currently using, www.stscapital.com and any sub-domains of this site unless expressly excluded by their own terms and conditions; and

“You” / ”Your”: means any third party that accesses the Website, makes use of our Services, or or otherwise interacts with STS, including STS employees and consultants..

3. Important Information and Who we are

Purpose of this Notice

This Notice aims to give you information on how STS collects and processes your Personal Data when you interact with us, or when we interact with you. It is important that you read this Notice together with any other policy or notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Data.

This Notice was last updated June 2026.

Children and Minors

STS does not knowingly collect or solicit Personal Data (as defined in clause 2) from children and minors. Our Services are directed exclusively at businesses and professional counterparties, and are not intended for children or minors.

Our Website is not intended for individuals under the age of 18. If you are under 18, please do not provide any Personal Data through our Website. In the event that we become aware that we have inadvertently collected Personal Data from an individual under the age of 18 without appropriate parental or guardian consent, where required, we will take reasonable steps to delete such information from our records.

Data Controller

For the purposes of applicable Data Protection Laws, STS is the Data Controller of your Personal Data.

STS acts as an independent Data Controller in respect of all Personal Data it handles in connection with our Services whether received directly from you, obtained from third parties or public sources, or received in connection with a client mandate (including Personal Data relating to individuals connected with a transaction, such as management team members, employees, shareholders, or other individuals whose data appears in transaction materials or a data room). Where such data relates to individuals who are not themselves STS’s direct client, STS remains the Data Controller, exercising independent professional judgment as to how that data is used in the context of the engagement.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Notice. If you have any questions about this Notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact Details

Our full details are:

Full name of legal entity: STS Capital Partners M&A Inc.

Name or title of DPO: Jessica Yeoh

Email address: jyeoh@stscapital.com

Third-party Links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share Data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Website, we encourage you to read the Policy / Notice of every website you visit.

4. The Data We Collect About You

“Personal Data”, or personal information, means any information about an individual from which that person can be identified. It does not include Data where the identity has been removed (anonymous Data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

Identity Data includes first name, last name, customer code or identifier, title, date of birth, and gender.
Contact Data includes billing business address, delivery address, email address, and telephone numbers.
Financial Data includes bank account details, billing information, and fee arrangements relevant to Our Services.
Transaction Data includes details about fees, payments, and other financial arrangements in connection with Our Services.
Profile Data includes the nature of your business, your role and areas of interest, your engagement history with us, preferences, and any feedback you provide.
Usage Data includes information about how you use the Website and interact with our communications.
KYC Data includes information about the source of funds and source of wealth, credit and background checks, reputation in the market, sanctions and anti-money-laundering screening, and other Data we require in order to verify your suitability as a client or counterparty and to comply with our legal and regulatory obligations when doing business with you.
Marketing and Communications Data includes your preferences for receiving marketing communications from our third parties and us, your communication preferences, and the content and records of your communications and correspondence with us (including emails, call notes, and meeting records).
Employment Data includes your job title, role, employer, remuneration and benefits, and your position or interest in a transaction, where we receive this in connection with Our Services.
Technical Data includes your internet protocol (IP) address, login data, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access the Website.
Shareholding Data includes details of your shareholding, ownership interest, board or director positions, and other interests in a company or transaction relevant to Our Services.

We also collect, use and share Aggregated Data such as statistical or demographic Data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as this Data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or to understand engagement with Our Services. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined Data as Personal Data which will be used in accordance with this Notice.

We do not seek to collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric Data). However, in connection with Our Services, we may incidentally receive such Personal Data. Where we receive Special Categories of Personal Data, or information about criminal convictions and offences, we will only process it where permitted under applicable Data Protection Laws, and we will apply appropriate safeguards when we do so.

5. How is Your Personal Data Collected?

We use different methods to collect Data from and about you including through:

Direct interactions

You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes Personal Data you provide when you:

engage or seek to engage STS in relation to Our Services;
meet with us either at our offices, your premises, or in other locations, and express an interest in Our Services;
subscribe to our updates, insights or publications;
request marketing to be sent to you;
complete a survey; or
give us some feedback.

Third Parties or Publicly Available Sources

We may receive Personal Data about you from various third parties and public sources as set out below:

Contact, Financial and Transaction Data from providers of technical, payment and professional services.
Identity and Contact Data from Data brokers or aggregators including business directories.
KYC Data from credit agencies such as processors, paid databases, and other third party providers of analogous services.
Identity and Contact Data from publicly available sources such as, for example, Companies House and the Electoral Register based inside the EU.
Identity, Contact and Employment Data from third parties where we provide Our Services as a sell-side adviser, including from your employer (our client), other parties relevant to the transaction (for example, prospective purchasers and their advisers) and regulators or authorities. We make this Personal Data available to prospective purchasers and their advisers through a data room and the due diligence process, relying on our legitimate interests in delivering Our Services and on the party that provided it having done so lawfully.

6. How We Use Your Personal Data

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

Where we need to perform or manage the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

7. Your Consent

We process your Personal Data on the lawful bases set out in this Notice, principally the performance of a contract, our legitimate interests, and compliance with our legal and regulatory obligations. We do not generally rely on your consent to process your Personal Data. Where specific consent is required under applicable Data Protection Laws, for example, for certain direct marketing, we will ask for it separately and clearly at the relevant time, and you may withdraw that consent at any time by contacting us. If we change this Notice, we will post the updated version on the Website.

8. Purposes for Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your Data.

Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.

Purpose/Activity	Type of Data	Lawful Basis for Processing Including Basis of Legitimate Interest
To onboard you as a new client, counterparty or service provider in connection with Our Services	(a) Identity (b) Contact (c) KYC	(a) Performance of a contract with you (c) Our legitimate interests, to ensure our business is properly protected when transacting. In some cases this is also to fulfill a legal requirement.
To identify and evaluate you as a prospective client, counterparty or service provider in connection with Our Services	(a) Identity (b) Contact (c) Profile	Where you have made an enquiry, in anticipation of entering into a contract with you. Where you have not, our legitimate interests is in growing our client base and identifying counterparties and service providers in connection with Our Services.
To manage our relationship with you in connection with Our Services, which will include: (a) Notifying you about changes to our terms or Notice (b) Requesting your feedback on Our Services	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to understand how clients use and engage with Our Services)
To provide Our Services to you and to enable you to engage with us in connection with Our Services	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to understand how clients engage with Our Services, to improve and develop them and to grow our business)
To administer and protect our business	(a) Identity (b) Contact (c) KYC	(a) Necessary for our legitimate interests (c) Either for our legitimate interests, or necessary to comply with a legal obligation
To deliver relevant marketing materials to you, invite you to events, and measure or understand the effectiveness of our communications regarding Our Services	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	Necessary for our legitimate interests (to understand how clients engage with Our Services, to develop them, to grow our business and to inform our marketing strategy)
To make suggestions and recommendations to you about Our Services that may be of interest to you	(a) Identity (b) Contact (c) Usage (d) Profile	Necessary for our legitimate interests (to develop Our Services and grow our business)
To compile our accounts, and tax returns.	Transaction	To comply with our legal obligations
To archive and back up our IT systems, and in order to protect our business assets	All Data	(a) Necessary to comply with our legal obligations (b) Necessary for our legitimate interests in protecting our business assets
To provide Our Services as a sell-side adviser, including conducting due diligence and making Personal Data available to prospective purchasers and their advisers through a CIM or data room	(a) Identity (b) Contact (c) Employment (d) Shareholding (e) KYC	(a) Performance of a contract with our client (b) Necessary for our legitimate interests (to deliver Our Services and progress the transaction) (c) Necessary to comply with a legal or regulatory obligation

9. Marketing

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.

Promotional Offers

We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which of Our Services, insightss and eventss may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or engaged us in connection with Our Services and, in each case, you have not opted out of receiving that marketing. If you are a business, we may also contact you about Our Services where we believe they may be of interest, unless you have told us not to.

Third-Party Marketing

We will get your express opt-in consent before we share your Personal Data with any company outside our group of companies for marketing purposes.

Opting Out

You can ask us or third parties to stop sending you marketing messages by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us in connection with Our Services or any other transaction or engagement between us.

10. Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

11. Cookies

The Website may place and access certain ‘cookies’ on your computer, information about which can be found at our cookie policy.

12. Disclosures of Your Personal Data

We may have to share your Personal Data with third parties for the purposes set out in the table in clause 8 above. These include:

third party providers of Data and other services to us, such as credit agencies, and third party archival, cloud and backup providers;
third party providers of professional services, such as accountants, bankers, insurers and lawyers;
regulatory authorities;
counterparties and other parties relevant to a transaction or to Our Services, and their advisers, including prospective purchasers and their advisers to whom we make Personal Data available through a data room or due diligence process;
third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Notice.

We may also disclose your Personal Data where necessary to establish, exercise or defend our legal rights, including obtaining legal advice or in connection with legal or regulatory proceedings.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

13. International Transfers

We ensure your Personal Data is protected by requiring all our group companies to follow the same rules when processing your Personal Data.

Whenever we transfer your Personal Data internationally, we ensure a similar degree of protection is afforded to it by relying on an appropriate transfer mechanism recognised under the applicable Data Protection Laws or an adequacy decision applicable to the transfer in question.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data.

14. Data Security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

15. Data Retention

How long will we use your Personal Data for?

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Laws or regulation may set a minimum period for which STS has to retain Personal Data.

In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

16. Requests

What we may need from you

Following any request made by you we may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

17. Your Legal Rights

You have the right to:

Be informed of how your Personal Data is being utilised by us, as set out in this Notice.

Request access to your Personal Data (commonly known as a “Data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate Data we hold about you corrected, though we may need to verify the accuracy of the new Data you provide to us.

Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the Data’s accuracy; (b) where our use of the Data is unlawful but you do not want us to erase it; (c) where you need us to hold the Data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your Data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide our Services to you. we will advise you if this is the case at the time you withdraw your consent.

Lodge a complaint with the relevant data protection authority if you consider that our processing of your Personal Data infringes your rights. We would, however, appreciate the opportunity to address your concerns before you do so, and ask that you contact us in the first instance.

No fee usually required

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights).

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

18. General

You may not transfer any of your rights under this Notice to any other person. We may transfer our rights under this Notice where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this Notice (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Notice will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This Notice will be governed by and interpreted according to the law of State of New York. All disputes arising under this Notice will be subject to the exclusive jurisdiction of the State of New York courts.

19. Changes to This Notice

STS reserves the right to change this Notice as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Notice on your first use of the Website following the alterations.

To exercise your legal rights or raise any data protection matter, please contact the DPO at jyeoh@stscapital.com. For all other matters, you may contact STS by email at marketing@stscapital.com.