Sense Street Limited (“Sense Street”, “we”, “us”, “our”) is committed to respecting your privacy, and ensuring secure handling of information. This privacy policy (“Privacy Policy”) outlines how we collect, use, share, and protect Personal Data (as defined below) we gather about you, including through our websites, applications, interactions and other services involving you (collectively, our “Services”). It also tells you about your rights and choices with respect to your Personal Data, and how you can contact us if you have any queries or concerns. By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes.

1. Scope of this Privacy Policy

This Privacy Policy applies to:

a) Personal Data we process for our clients (e.g., investment banks and other financial institutions) during the course of our business relationship;

b) Data generated, assessed, or processed through the usage of our Services, including as part of testing and maintenance.

We are a data processor in relation to (a). Where we process Personal Data for our clients, we act as a data processor and in accordance with their instructions and applicable laws. Any questions about our processing of Personal Data in this capacity should be raised directly with the relevant client.

We are a data controller in relation to (b). To develop, provide and maintain our Services, and to communicate with prospective and existing clients, we act as a data controller. We describe how we use this Personal Data below.

2. Information We Collect

In this Privacy Policy, “Personal Data” means any information relating to an identified or identifiable natural person. We may collect and process Personal Data about you in the ways outlined below. Where applicable, we

indicate whether and why you must provide us with your Personal Data, as well as the consequences of failing to do so. If you do not provide Personal Data when requested, you may not be able to benefit from our Services if that information is necessary to provide you with them or if we are legally required to collect it.

The types of Personal Data we may process include:

Information provided by you

• When you contact us. If you contact us directly, such as to sign up to one of our webinars, download content that we offer, or to raise any queries, we may collect Personal Data, such as your name, email address, phone number, job title and company name, together with the contents of your message.

• When attending events, meetings and conferences. If you interact with us at an event, meeting or conference, we may collect Personal Data that you choose to provide to us. This may include contact details such as your name, email address, phone number, job title and company name.● When you apply for a job at Sense Street. We may publish details of current vacancies on our website, and allow you to apply for these directly. If you apply to us, we will collect any information you provide in support of your application, and we will use this to assess your suitability for employment.

Information collected when you use our Services

• Location information. When you use our Services, we receive your location information. For example we infer your location information by using your IP address.

• Device information. We receive information about the device and software you use to access our Services, including IP address, device type, device identifiers, web browser type and version, and operating system version.

• Usage information. We automatically receive information about your interactions with our Services, like the pages or other content you view, referrer information (the website you visited before coming to our Services), the dates and times of your usage of our Services, and how you use them. This includes information from our server logs and error reports.

• Cookies and other tracking technologies. We and our third-party partners collect information about your activities on our website using cookies or other tracking technologies. Our third-party partners, such as analytics and advertising partners, may also use these technologies.

Information collected from other sources

• Other sources. We receive information from our trusted partners to protect against threats to our Services.

3. How We Use Information

We process the Personal Data listed above for the following purposes:

• Providing the Services. We use Personal Data about you to operate, maintain and provide our

  Services. We may also process limited Personal Data to design, develop, test, and maintain our Services including our custom software solutions.

• Hosting webinars and events. If you sign up to one of our webinars or events, we may process Personal Data such as your name, email address and company name for the purposes of registration and logistics.

• Engaging and communicating with you. We may use your details to contact you about our Services, and to provide you with technical support or respond to any other queries you raise.

• Security. We process your Personal Data to ensure security, compliance, and operational efficiency, to find and prevent fraud and abuse, and respond to trust and safety issues that may arise.

• Legal. We process your Personal Data to comply with legal and regulatory requirements, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

• For other purposes for which we provide specific notice at the time the information is collected.

4. Data Sharing

We may share information with third parties who assist in providing our Services, including in the following situations:

• Authorized service providers. We may share data with trusted third-party vendors that we have entered into contractual arrangements with (e.g., cloud service providers), and who assist us in providing the Services.

• As required by law. We may disclose data to comply with applicable laws, regulations, or legal processes such as to respond to lawful requests from public authorities, including to meet national security or law enforcement requirements, or where we need to enforce or apply our agreements or policies, or to protect the rights, privacy, safety, or property of Sense Street, our users, or others.

• Business transfers. We may disclose or otherwise transfer Personal Data to an acquirer, successor or assignee as part of the consideration, negotiation, or completion of any merger, acquisition, debt

  financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

• Consent. We may also disclose your Personal Data with your permission.

5. Our Legal Basis for Processing Personal Data

If you are located in the European Economic Area, Switzerland or the United Kingdom (“Europe”), we only process your Personal Data where we have a legal basis to do so. The legal bases we rely on include:

• Necessary for compliance with a legal obligation to which we are subject. We may process your Personal Data where we are required to do so to comply with our legal obligations, for example to comply with tax and accounting obligations or to comply with a court order.

• Necessary for a legitimate interest that we pursue. Where we or a third party have a legitimate interest in processing your Personal Data, we may do so provided that our interest is not overridden by your rights and interests. We may rely on this legal basis to, for example, keep business records, respond to unsolicited communications from you, assert our legal rights and obtain professional advice.

• Consent. We may also process your Personal Data on the basis of consent in some circumstances. For example, we may ask for your consent to sign up to direct marketing. You may withdraw your consent at any time by contacting us.

6. Data Security

We make reasonable efforts to protect your Personal Data by using physical and electronic safeguards designed to improve the security of the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information, to the extent permitted by applicable law.

7. Data Retention

We retain Personal Data for as long as necessary to fulfil the purpose outlined in this Privacy Policy, meet contractual obligations, or comply with legal requirements. For example, we may need to retain your Personal Data to comply with tax requirements, or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse or enforce the terms of any contract we have in place with you or your employer.When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the relevant statute of limitations. In some cases, the length of time we retain data depends on your settings. When we no longer need to use or retain your Personal Data, for example upon completion of a project or termination of a contract, Personal Data is securely deleted or anonymised so that it no longer identifies you.

8. Data Transfers

Sense Street is based in the United Kingdom. We may use third party service providers located outside the UK to process your Personal Data. Where we do so, we take measures to ensure that your Personal Data remains protected in accordance with this Privacy Policy and applicable data protection laws. In particular, for data transfers outside Europe, we will rely on

(i) an EU Commission, UK Secretary of State or Swiss government adequacy decision, (ii) contractual protections for the transfer of your Personal Data, including by entering into data transfer agreements with relevant parties, or (iii) another valid data transfer mechanism. If you are located in Europe, you may contact us as specified below for more information about the safeguards we use to transfer Personal Data outside of Europe.

9. Your Rights

Depending on where you live, you may have certain rights under applicable data privacy laws. For example, in Europe, to the extent applicable, you have the following legal rights:

• Access and portability. You may ask us to provide you with a copy of the Personal Data we maintain about you, including a machine-readable copy of the Personal Data that you have provided to us, and request information about its processing

• Correction and deletion. You may ask us to correct inaccuracies in your Personal Data, or to have the information anonymized or deleted, as appropriate.

• Restriction and objection. You may ask us to restrict the processing of your Personal Data, or object to such processing.

• Consent withdrawal. You may withdraw any consent you previously provided to us regarding the processing of your Personal Data, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.

• Complaint. You may lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where an incident took place. We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority, so please contact us in the first instance.

You may exercise these rights by contacting us using the contact information set out below. Please note that there are exceptions and limitations to each of these rights. Any requests relating to personal data we hold on behalf of our clients as a data processor, detailed above in Section 1 (Scope), should be addressed directly to the relevant client.

10. Updates to This Privacy Policy

Sense Street Limited may update this Privacy Policy periodically to reflect changes in our practices, legal obligations, or industry standards. Sense Street Limited may be contacted by email at privacy@sensestreet.com