Privacy Policy

Introduction

Precede Capital Partners Limited and its affiliates, including PCP LendCo 1 Designated Activity Company and QR TSO 1 LendCo Limited (“Precede”, “we”, “us” or “our”), take the protection of your personal data seriously.

This Privacy Policy explains how we use your personal data when you visit our website (the “Website”) or deal with us or the business you work for, and your rights under data protection law: the EU General Data Protection Regulation (“GDPR”) and the Irish Data Protection Acts 1988 to 2018, the GDPR in such form as incorporated into the laws of the United Kingdom (“UK”) and the UK Data Protection Act 2018, and the Data Protection (Jersey) Law 2018 (the “Data Protection Laws”).

The controller of your personal data is Precede Capital Partners Limited or, where it holds your data, one of the other entities named above, unless we tell you otherwise.

We review this Privacy Policy regularly and will tell you about any changes.

Who this Privacy Policy covers

This Privacy Policy covers visitors to our Website and the people we deal with in our business: borrowers, guarantors and their directors, shareholders and beneficial owners; brokers and introducers; co-lenders, funders and investors; our service providers; and their representatives. Borrowers and investors also receive our Borrower Privacy Notice or Investor Privacy Notice, which give more detail. If you give us personal data about someone else, such as a guarantor, please give them a copy of this policy.

1. Information we collect

We collect personal data when you:

• contact us through our Website, including the “Get In Touch” page;
• browse our Website, through cookies and similar technologies (see section 4);
• provide services to us, or work for a business that does;
• ask about, or give us information about, our products or services;
• meet or speak with us, where we may use note-taking tools to make transcripts and notes (see section 3);
• attend our events or exchange details with us there; or
• apply for a role with us.

This may include your name and title; contact details; employment details (company and role); identity documents (such as passport, driving licence, work permit or visa); tax residency and tax information; CVs (qualifications and employment history); background check results (references, qualifications and, where the law permits, unspent criminal convictions); and transcripts and notes of meetings and calls.

We may also receive personal data about you from other sources: the business you work for or represent; brokers, introducers and co-lenders; our professional advisers and service providers (including identity verification providers); and public sources such as Companies House, HM Land Registry, planning portals, company websites, LinkedIn and the press.

2. Why we collect your personal data

The table below sets out why we use your personal data and the lawful basis for each use.

Special category and criminal offence data. We process special category data (such as equal opportunities information) and criminal offence data (such as criminal record checks) only where the law permits, for example to meet employment law obligations, monitor equality of opportunity or prevent unlawful acts.

3. How we use technology and AI tools

We use selected technology tools, including artificial intelligence (AI) tools, to draft and review documents; summarise and analyse information about loans, investments and other transactions; screen lending opportunities; and transcribe and take notes of meetings and calls.

If we use a note-taking tool on a meeting or call, we will tell you at the start, and you can ask us not to. Transcripts made by our note-taking tools are deleted after no more than 4 months. Notes and summaries we keep are retained as part of our loan or investment records.

Our providers act only on our instructions, under written contracts that require them to keep your data confidential and secure. They may not use it to train their AI models or for any purpose of their own. Some process data in the United States (see section 7). A list of our main providers is available on request. When we search the internet for publicly available information about you or a transaction, the search provider processes the search terms under its own terms.

Our staff make every lending, investment or other decision that affects you, and check AI output before relying on it. We do not make decisions about you based solely on automated processing that have legal or similarly significant effects.

4. Cookie Policy

Please refer to our Cookie Policy.

5. Marketing

We may tell you about our products, services and events by email, post, phone or SMS, with your consent where the law requires it. We will not sell your personal data. You can opt out at any time using the unsubscribe link in any message, or by emailing enquiries@precedecapital.com.

6. How we share your personal data

We share personal data with:

• service providers, such as providers of IT, hosting, cloud and website analytics services, software and AI services (including AI-enabled document, meeting-notes and origination tools), AML and background checks, loan administration, corporate services, recruitment, marketing, and facility and security agent services. They act only on our instructions and may not use your data for their own purposes;
• event co-hosts, limited to your name, title and employer, to run the event;
• courts, regulators and public authorities, where the law requires it or in response to a lawful request;
• buyers, investors and their advisers, in connection with a merger, restructuring, sale or assignment of our business or assets, including during due diligence;
• our shareholders and their advisers, for investor reporting, governance and oversight of our transactions;
• other Precede group entities, for the purposes in this policy; and
• co-lenders and investors, in connection with a loan.

7. Data transfers

We store personal data in the UK, Jersey, Canada and the European Economic Area (EEA), and may transfer it elsewhere, including to the United States, where some of our service providers store it. Our shareholders may also transfer data we share with them to the United States, under their own safeguards. The UK and EU recognise Jersey and Canada as providing adequate protection; the United States may not. For transfers to countries not recognised as adequate, we use approved safeguards, such as the EU standard contractual clauses or the UK international data transfer agreement, or, where the recipient is certified, the UK Extension to the EU–US Data Privacy Framework or the EU–US Data Privacy Framework. For details, email privacy@precedecapital.com.

8. Retaining your personal data

We keep personal data only as long as we need it for the purposes we collected it for, or as the law requires. In setting retention periods, we consider the amount, nature and sensitivity of the data, the risk of harm from misuse, and our legal obligations. We may anonymise data so it no longer identifies you. Transcripts made by our meeting note-taking tools are deleted sooner, as set out in section 3.

9. Protecting your personal data

We use technical and organisational measures to protect your personal data against loss, misuse and unauthorised access or disclosure. Our staff are trained to handle personal data in line with this policy, and misuse is a disciplinary matter.

10. What are your rights?

You have the right to:

• access your personal data and receive a copy (we may charge a reasonable fee for further copies);
• ask us to correct or delete it;
• object to, or ask us to restrict, our use of it;
• receive it in a portable format and, in some cases, have it sent to a third party;
• withdraw your consent at any time, where we rely on consent; and
• complain to a data protection authority.

To exercise your rights, contact us using the details in section 11. If you have a concern, please contact us first at privacy@precedecapital.com. We will acknowledge your complaint within 30 days and tell you the outcome. You can also complain to the Information Commissioner’s Office (UK), the Data Protection Commission (Ireland) or the Jersey Office of the Information Commissioner.

11. How to contact us

For questions about this policy or to exercise your rights, write to Precede Capital Partners Limited, 16 Berkeley Street, London W1J 8DZ, or email privacy@precedecapital.com.

We will post any changes to this policy on this page and update the date below.

Last updated: 19 October 2026