1. Introduction
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Welcome to Aligned Syndicate Ltd’s (“Aligned”) privacy notice.

Aligned respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or use our investment services or other services and tell you about your privacy rights and how the law protects you.

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2. Who we are
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Aligned Syndicate Ltd is an investment and advisory business focused on sourcing and facilitating investments into startups and related opportunities.

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When this privacy notice refers to “Aligned”, “we”, “us” or “our”, it is referring to Aligned Syndicate Ltd as the controller responsible for your personal data in connection with this website and our services.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please use the contact details set out in section 3 below.

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3. Purpose of this privacy notice

This privacy notice aims to give you information on how Aligned collects and processes your personal data through your use of this website and any use by you of our investment services, including any data you may provide through this website when you create an account with us, sign up to receive updates from the website or indicate an interest in any services offered through the website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing 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 privacy notice supplements the other notices and is not intended to override them.

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4. Contact details and complaints
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If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us here:

• Full name of legal entity: Aligned Syndicate Ltd
• Postal address: 41a Banks Road, Poole, Dorset BH13 7PW

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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5. Changes to This Privacy Notice and Your Duty to Inform Us of Changes

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This version was last updated January 2026.

It is important that the personal data we hold about you is accurate and current, so please keep us informed if your personal data changes during your relationship with us.

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6. Third-Party Links
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This 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 our website, we encourage you to read the privacy notice of every website you visit.

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7. The Data we collect about you
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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).

Depending on your interactions with us, we may collect, use, store and transfer different kinds of personal data about you, which we may group as follows:

• Identity Data such as first name, last name, title and similar identifiers.
• Contact Data such as email address, telephone numbers and postal address.
• Technical Data such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Usage Data such as information about how you use our website and services.
• Profile Data such as your interests, preferences, feedback and responses.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose, which is not considered personal data in law if it does not directly or indirectly reveal your identity.

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8. How we use your personal data
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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 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 third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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 below.

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9. Marketing
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We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

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Promotional offers from us

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 products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or invested capital into startups we have sourced or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time by contacting us using the details in section 4 or by using any unsubscribe link in the communications you receive.

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10. Cookies
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You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.

If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Where required by law, we will ask for your consent before placing non-essential cookies (for example, for analytics or advertising) on your device.

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11. Change of Purpose

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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 explain the legal basis which allows us to do so, unless we are required or permitted by law to process the data without such notice.

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12. Disclosures of Your Personal Data

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We may share your personal data with the parties set out below for the purposes described in this privacy notice:

• External 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 privacy notice.
• Service providers acting as processors based in the United Kingdom and other countries who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

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.

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13. International Transfers

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Some of our external third parties may be based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by using at least one of the following safeguards:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
• We may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

You can contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

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14. Data Security

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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 and they will only process your personal data on our instructions and 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.

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15. Data Retention

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We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In general, we keep most client and investor-related records for up to 7 years after the end of the relevant relationship or transaction to meet legal and regulatory obligations, after which they will be securely deleted or anonymised unless a longer retention period is required or permitted by law.

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16. Your Legal Rights

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Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• 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, 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 certain products or services to you, and we will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the details in section 4.

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17. No Fee Usually Required

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If you wish to exercise any of the rights set out above, please contact us. 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). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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18. What We May Need From You

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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.

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19. Time Limit to Respond

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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.

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20. Automated Decision-Making

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We do not currently make decisions based solely on automated processing, including profiling, that have legal or similarly significant effects on you in the context of this website or our core investment services.

If this changes in the future, we will update this privacy notice and provide you with information about the logic involved and the significance and envisaged consequences of such processing, as required by law.

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21. Definitions and Glossary

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Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

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Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

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Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

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22. External Third Parties (Detailed)

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• Service providers acting as processors based in the United Kingdom & other countries who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

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23. Contact Information

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Contact

Aligned Syndicate Ltd

41a Banks Road

Poole, Dorset

BH13 7PW

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hello@alignedsyndicate.com

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