Borrower Privacy Notice

Introduction

“Precede Capital Partners” means Precede Capital Partners Limited. The “Lending Entities” means PCP LendCo 1 Designated Activity Company (Ireland) and QR TSO 1 LendCo Limited (Jersey), and any other lending entity we tell you about in your loan documents. “We”, “us” and “our” means Precede Capital Partners and each of the Lending Entities.

We are committed to respecting your privacy. For the purposes of data protection law, Precede Capital Partners and each of the Lending Entities are controllers in respect of your personal data. Precede Capital Partners and the Lending Entities are each responsible for ensuring that they use your personal data in compliance with applicable data protection law, including the EU General Data Protection Regulation 2016/679 (“GDPR”), the Data Protection (Jersey) Law 2018 in the case of any Lending Entities incorporated in Jersey and the Irish Data Protection Acts 1988 to 2018 in the case of any Lending Entities incorporated in Ireland, and the GDPR in such form as incorporated into the laws of the United Kingdom (“UK”) and the UK Data Protection Act 2018 in the case of Precede Capital Partners.

This privacy notice (“Privacy Notice”) applies to you if you are an applicant, a borrower or any member of the borrower’s group (including directors and individual UBO’s) (the “Group”). The Privacy Notice sets out how we handle your personal data, that we create, you provide to us or that we obtain about you from other sources. You must not share any personal data with us unless you have the explicit authority of the relevant individuals and have shared this Privacy Notice with them beforehand.

Please take the time to read and understand this Privacy Notice. We may update this Privacy Notice from time to time.

Personal data we collect about you

We will collect and process the following personal data about you:

a. Information that you provide directly to us or one of our subsidiaries or affiliates

This includes information about you that you provide to us by filling in forms or by communicating with us, whether face-to-face, by phone, email or otherwise. Our application form which you submit in order to apply for a loan asks you for information to allow us to perform relevant Know-Your-Customer (“KYC”) checks to comply with applicable anti-money laundering and counter-terrorist financing laws and regulations and to assess your suitability for a loan.

The personal data we collect about you may include:

• personal details (such as, your name, address, date of birth, gender, nationality, citizenship, marital status, residential address, tax residency and tax related information), identity documents (such as, passport, driving license or other photo identification), contact details (including email, telephone, correspondence address) nationality and citizenship, contact and financial information (such as, bank account details), about you as an applicant or borrower as well as about directors, partners, members, shareholders, beneficial owners and guarantors in the Group;
• biometric data (such as facial recognition, used by our identity verification provider to match you to your identity document);
• personal data in any of the above forms about other named applicants or members of the Group;
• employment details (including job title and name of employer or details of any self-employment);
• information provided to us during the course of a loan (such as, identity documents, including passport, driving license or other photo identification), contact details (including email, telephone, correspondence address) and financial information about directors, partners, members, shareholders, beneficial owners and guarantors in the Group (including credit card commitments, loan commitments and income details);
• information about the devices you use to access our content and services (for example, your IP address, operating device, unique device identification number, ISP, location and other technical details). For information on how we handle your personal data when you visit our website, see our website privacy policy at https://www.precedecapital.com/privacy-policy/; and
• transcripts and notes of meetings and calls made using note-taking tools (see “Technology and AI tools” under “How we use your personal data and our lawful bases” below), data held on our customer relationship management systems and records of your activity on any information technology system maintained and provided by us or by any of our subsidiaries or affiliates.

If you are sharing personal data on behalf of another person, you must always have the authority to provide the personal data to us and have shared this Privacy Notice with them beforehand.

b. Information we obtain from other sources

We may also obtain information about you from third parties including credit reference agencies, fraud prevention agencies, the Home Office, HM Revenue & Customs, Companies House, government departments or regulatory authorities, accountants or agents, insolvency practitioners, debt advisers, AML specialist providers and screening tools, tracing agents, commercial databases, public records and other publicly available information sources.

The types of information we collect from third parties include KYC details and any money laundering, terrorist financing, financial sanctions or suspected fraud details, immigration status, validation of information supplied under the HMRC Verification Scheme, and we use the information we receive from these third parties to assess your application and suitability for a loan, undertake KYC checks, prevent fraud, money-laundering and terrorist financing, ensure compliance with financial sanctions obligations and to maintain and improve the accuracy of the records we hold about you.

In general, we will use the personal data we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal data.

How we use your personal data and our lawful bases

Precede Capital Partners and the Lending Entities may store and use your personal data for the purposes below. The table sets out the lawful basis for each.

In relation to our financial crime checks:

• If you give us false or inaccurate information and/or we suspect or identify fraud or money laundering or terrorist financing risks, we will record this and may allow law enforcement agencies to access and use your personal data to detect, investigate and prevent crime. We may also access and use information recorded by credit or fraud prevention agencies in other countries. This information may contain your personal data.
• If we, or a fraud prevention agency, determine that you pose a fraud, money laundering or terrorist financing risk, we may refuse to provide the services or financing you have requested and/or we may stop providing existing services to you.
• If we determine that it is necessary for the purposes of compliance with applicable financial sanctions obligations, we may refuse to provide the services or financing you have requested and/or we may stop providing existing services to you.

Special category and criminal offence data. Our identity, anti-money laundering, sanctions and fraud checks may reveal criminal offence data, such as sanctions, fraud or money laundering findings or unspent convictions, and our identity checks use biometric data (facial recognition) to verify your identity. We, and our identity verification provider, process this data only where data protection law permits it.

As set out above, we require your personal data to be able to enter into an agreement with you regarding your loan and to comply with our legal and regulatory obligations. Accordingly, if the personal data required is not provided, a prospective borrower may not be able to transact with us.

Disclosure of your information to third parties

We may share your personal data as follows:

• with our affiliates to be stored and processed in the ways and for the purposes set out above in this Privacy Notice.
• with credit reference and fraud prevention agencies. If false or inaccurate information is provided and/or fraud is suspected or identified, details will be passed to fraud prevention agencies;
• with a third-party loan servicer for the purposes of providing services to us and you, and in particular providing investment advisory and asset management services, facility agent services and security agent services. Any third-party servicer will be subject to confidentiality requirements and they will only use your personal data as described in this Privacy Notice;
• with third party service providers, such as IT service providers, providers of software, cloud and AI services (including AI-enabled document, meeting-notes and loan origination tools), identity verification and KYC providers, corporate service providers, data hosting providers, professional advisers, legal services providers for the purposes of providing services to us, including marketing services. Any third-party service provider will be subject to confidentiality obligations to safeguard your personal data when they have access to it. They act only on our instructions and may not use your personal data for their own purposes.
• we may disclose your personal data to our institutional funding lines and equity providers in accordance with our contractual obligations. Any such disclosure will be subject to confidentiality requirements and your personal data would only be used as described in this Privacy Notice;
• if we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes;
• if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer;
• to government bodies and agencies in the UK, Jersey, Ireland and overseas, as required;
• with payment systems if you require us to use them to process transactions; and
• there may also be circumstances where we are obliged by law to disclose personal data, including to law enforcement agencies and applicable regulators, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us.

Transfers of personal data outside the European Economic Area / United Kingdom / Jersey

Noting that the EU Commission has published an adequacy decision with respect to the UK, the personal data that we collect from you may be stored in the UK, Jersey, Canada and/or European Economic Area (“EEA”) as well as being transferred to a destination outside these jurisdictions, such as the United States. Jersey and Canada have both been recognised by the EU Commission and the UK Government as jurisdictions which provide adequate protection with regards to data protection laws in the UK and the EEA. However, the United States may not provide the same protections as the data protection laws in the UK and/or EEA. Where the country we transfer your personal data to outside the UK or the EEA is not already recognised by the UK Government or the European Commission as providing adequate protection, where required, we will implement appropriate safeguards (such as the European Commission approved standard contractual clauses, the UK Government approved international data transfer terms or, where the recipient is certified, the UK Extension to the EU–US Data Privacy Framework (or, for transfers from the EEA, the EU–US Data Privacy Framework)) to govern such transfers, pursuant to applicable data protection laws. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice. If you require further information, please contact us at privacy@precedecapital.com.

Our shareholders may also transfer personal data we share with them to the United States, under their own safeguards.

Retention of personal data

The retention policy period of Precede Capital Partners and the Lending Entities for personal data, is at least six years from the date of an occasional transaction (where there is no business relationship) or 12 years from the end of a business relationship. With respect to any Lending Entities incorporated in Ireland, the retention policy period is six years in most cases, subject to such shorter timelines as may be specified in applicable laws and regulations in respect of certain categories of records. Transcripts made by our meeting note-taking tools are deleted after no more than 4 months. Notes and summaries we keep are retained as part of our loan records.

Your rights

Individuals whose personal data is processed by us have certain legal rights in respect of their personal data where EU, Jersey and UK data protection laws apply. To exercise these rights and controls, please use the details provided in the “Contact Us” section below. These individual rights include:

• The right to request a copy of the personal data that we hold about you free of charge; however we may charge a ‘reasonable fee’ if we think that your request is excessive, vexatious, unfounded or repetitive, to help us cover the costs of locating the information you have requested, or if you ask for additional copies of your personal data. Alternatively, we could refuse to comply with your request in these circumstances.
• The right to require rectification (correction) of errors in personal data if it is inaccurate or needs to be updated.
• The right to have personal data erased in certain circumstances where you think that we should not be holding or processing your personal data any more. Please note that this may not always be possible due to legal obligations.
• The right to restrict the processing of your personal data (other than storing it) in certain situations including where: (i) you contest the accuracy of the personal data (until the accuracy is verified); (ii) the personal data is being processed unlawfully but you do not want the personal data erased; (iii) the personal data is no longer needed for the purposes for which it was collected, but you still require that personal data to help establish, exercise or defend legal claims; or (iv) you object to the processing where we process your personal data on the basis of our, or a third party’s legitimate interests pending verification of whether our, or a third party’s legitimate interests override your own rights.
• The right to receive personal data in a structured, commonly used and machine-readable format and (if certain conditions are satisfied), transmit that personal data to a third party, if we have the technical means.
• The right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
• Rights in relation to decisions based solely on automated processing that have legal or similarly significant effects on you, including the right to human review. We do not make such decisions.

In the limited circumstances where the individual may have provided their consent to the collection, processing and transfer of personal data for a specific purpose, the individual has the right to withdraw consent for that specific processing at any time. To withdraw consent, please use the details provided in the “Contact Us” section below.

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 facilitate our response.

Contact us

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data, the exercise of any of the rights listed above, or if you have any other questions about the processing of your personal data, please address questions, comments and requests to privacy@precedecapital.com.

Issues or concerns you may have regarding how we handle your personal data can also be brought to the attention of the Information Commissioner’s Office (UK), the Data Protection Commission (Ireland) or the Jersey Office of the Information Commissioner. However, if you have any concerns or questions, we request that you contact us in the first instance to respond and address any concerns. We will acknowledge any complaint within 30 days and tell you the outcome.

Last updated: 20 October 2026