Last updated: 04 April 2025

Twelled, co. A C-Corp registered at 131 Continental Drive Suite 305, Newark, DE 19713, United States. EIN Number 35-2876446.

For the purposes of applicable data protection laws, Twelled is the data controller for personal data collected in relation to our Site and for your login, account, and transaction data on the Twelled Platform. The relevant entity you communicate with, including for employment purposes, is the data controller in relation to those communications.

This privacy policy (the “Privacy Policy”) sets out the basis on which we will process any personal data or usage information we collect from you, or that you provide to us, in connection with your use of our Site, twelled.com (our “Site”) and in connection with a transaction solutions technology platform and service (together, the “Platform”). The purpose of the Platform is to provide a digital infrastructure to enable transactions of and relating to shares, employee stock ownership plan contracts (“ESOPs”) and other convertible notes and securities (“Assets”) in private companies, including but not limited to the submission of Assets for sale and the placing of bids for Assets (the “Transactions”).

Please read this Privacy Policy carefully so that you understand your rights in relation to your personal data, and how we will collect, use, and process your personal data. This Privacy Policy supersedes any previous privacy-related notice or equivalent document which you may have been provided with by us from time to time. If you do not agree with this Privacy Policy in general or any part of it, you should not access the Site, use our Platform, or otherwise provide your information to us.

Our Site and Platform are not intended for children, and we do not knowingly collect data relating to children. Children must not use the Platform, except where their parent or guardian has provided consent, if this option is available in your location.

Information we collect

Information you give to us

You may provide some or all of the following personal data to us by: (i) meeting or interacting with us; (ii) contacting us by telephone, fax, email or other forms of electronic communication; or (iii) completing registration or other forms:

• Personal data relating to identification (e.g. full name, date of birth, residence address, email address, mobile number, passport, national identity card, visa details, photo, tax number).
• Employment details (e.g. employer name, employment address, employment details).
• Account data (e.g. your account ID, login details, details of transactions carried out, investment objectives, and means).
• Communications (e.g. details of your communications with us, such as for customer service purposes).
• Other personal data (e.g. sources of wealth, banking relationships).
• Special categories of personal data relating to biometric data (facial recognition processing during onboarding).

Information we collect automatically

When you visit our Site and use our Platform, we automatically collect the information sent to us by your computer, mobile phone, or other device. This information includes: (i) your IP address; (ii) device information including, but not limited to, name and type of operating system; (iii) mobile network information; (iv) standard web information such as your browser type and the pages you access on our Site; (v) transaction and account activity information (but not payment card or account details), including device information, transaction details, and IP address; (vi) security information including a list of certain installed software, device and internet connection information, and available space on the device. In addition, we may use third-party platforms such as Google Analytics that collect, monitor, and analyze information about demographics and navigational behavior.

Information we collect from third parties

We may process some or all of the following personal data as a result of such data being: (i) provided to us by your company, an authorized intermediary, agent, advisor, or custodian of your assets; (ii) provided to us by one of our group companies, or (iii) collected from publicly available sources.

• Personal data relating to identification (e.g. full name, date of birth, residence address, email address, mobile number, passport, national identity card, visa details, photo, tax number).
• Employment details (e.g. employer name, employment address, employment details).
• Account data (e.g. your account ID, login details, details of transactions carried out, investment objectives, and means).
• Communications (e.g. details of your communications with us, such as for customer service purposes).
• Other personal data (e.g. sources of wealth, banking relationships).
• Special categories of personal data relating to biometric data (facial recognition processing during onboarding), or criminal data (e.g., as a result of sanctions, politically exposed persons, and other legal and regulatory warnings databases).

What do we do with your personal data?

Processing means any operation or set of operations performed on personal data, whether or not by automated means, such as collecting, recording, storing, adjusting, organizing, using, disclosing, transferring, or deleting it.

We process your personal data in order to perform our contract with you, such as providing you with our Platform, other content, and Site functionality.

In order to be responsive to you, to provide effective Platform to you, and to maintain our business relationship, as a matter of our legitimate interests, we will use your personal data to:

• Verify your identity and assess whether we can accept you as a customer.
• Create and maintain your account and allow you to access and use our Platform.
• Maintain the safety and security of our users, the Site, our Platform, and business.
• Administer the Site and Platform, and for internal operations, to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis.
• Send you announcements in relation to security, privacy, or administrative-related communications (these communications are not marketing-oriented, and we do not rely on consent, so you may not opt out).
• Personalize our Site and Platform to ensure content is presented in the most effective manner for you and your device.
• Improve and develop our products (including but not limited to training our artificial intelligence systems on personal data by verifying information and details provided by you and/or collected from publicly available sources, recognizing the text present on documents shared by you, extracting such data, matching the extracted data against verified information on the Platform and ensuring that such information adheres to our business requirements, as well as more generally detecting fraud and misrepresentation).

We obtain your consent to process your personal data for the following reasons:

• If you opted into marketing, to communicate with you about our products, Platform, marketing, promotions, events, and other news and information we think will be of interest to you.
• To process your biometric data (using facial recognition processing) as this is necessary to effectively verify your identity for onboarding purposes.

In addition, we will use some or all of the above information to comply with any applicable legal obligations (such as in relation to onboarding users), to enforce any applicable terms and conditions and/or terms of service, and to protect or defend the Platform, our rights, the rights of our users, or others.

Cookies

Cookies are small text files, stored on your browser, that uniquely identify your browser or device.

We use cookies and other similar technologies (“Tracking Technologies”) which are essential to the functioning of our Site and Platform, to provide a service requested by you or to comply with the law (e.g. the security requirements of data protection law). We do not need to obtain your consent in order to use these Tracking Technologies and these Tracking Technologies cannot be turned off as we cannot provide the Site and Platform without them.

Most browsers allow you to change your settings so that you can:

• See what Tracking Technologies are used on your device and delete all non-essential Tracking Technologies on a collective basis.
• Block third-party Tracking Technologies.
• Block Tracking Technologies from particular sites.
• Block all Tracking Technologies from being set.
• Delete all Tracking Technologies when you close your browser (although deleting cookies means that any preference settings you have made on our Site and Platform may be lost).

For more information on how to manage your browser settings, please see below:

• Cookie settings in Internet Explorer
• Cookie settings in Edge
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari

With whom do we share your personal data and for which reasons?

We do not use or share your personal data with others except as described in this Privacy Policy. In certain circumstances, we will share your information with third parties with your consent, as necessary, or as otherwise required or permitted by law. Specifically, we share your personal data:

• With service providers for business purposes in our legitimate interests, or to perform a contract with you. Such third parties include: (i) IT service providers; (ii) marketing companies; and (iii) data analytics vendors (including artificial intelligence systems). These service providers assist us with many different functions and tasks, such as providing application or infrastructure support, managing customer communications, verifying authenticity of information in and documents provided to us, preparing reports and statistics, printing materials and designing products.
• When you request us to share certain information with third parties, with consent or to perform a contract with you. With your permission or upon your discretion, we will disclose your personal data to relevant third parties.
• With professional advisors, in our legitimate interests or as required by law. As necessary, we will share your personal data with professional advisors functioning as service providers such as auditors, law firms, or accounting firms.
• For legal and security reasons and to protect our Platform and business, in our legitimate interests or as required by law. We will share your personal data with regulators, law enforcement agencies, public authorities, or any other relevant organizations: (i) in response to a legal obligation; (ii) if we have determined that it is necessary to share your personal data to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries; (iii) to protect the interests of, and ensure the safety and security, of us, our users, a third party, or the public; (iv) to exercise or defend legal claims; and (v) to enforce our terms and conditions, other applicable terms of service, or other agreements.
• With our affiliates, in our legitimate interests. We may share your personal data with companies within our corporate family.
• In connection with an asset sale or purchase, a share sale, purchase or merger, bankruptcy, or other business transaction or re-organization, in our legitimate interests. We will share your personal data with a prospective buyer, seller, new owner, or other relevant third party as necessary while negotiating or in relation to a change of corporate control such as a restructuring, merger, or sale of our assets.

Where we store your information

The personal data that we collect from you may be transferred to, and stored at/processed in countries outside the United States. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy.

Our contact details

We welcome your questions, comments, and concerns about this Privacy Policy or your personal data.

To contact Twelled, please send us an email to compliance@twelled.com.

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Official Company Information:

Twelled, Co.

131 Continental Drive Suite 305

Newark, DE 19713

EIN

35-2876446

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