Ardea Privacy Notice

‍Last Updated: October 26, 2023

This Privacy Notice explains how Ardea Partners (including Ardea Services LLC, Ardea Partners LP,Ardea Partners International LLP, Ardea Capital Partners Management LP and Ardea Capital Partners GP LLC) (together “Ardea”, “we”, “us” or “our”) collects, uses, discloses, and otherwise processes personal information (as defined below) in connection with www.ardeapartners.com (the “Site”) and other websites Ardeaowns and/or operates that link to this Privacy Notice or through other methods (e.g, e-mail, telephone, etc.), and the related content, platform, services, products, applications and other functionality offered on or through our services, including our investment banking services (collectively, the “Services”).

Ardea is the controller of the personal information we hold about you in connection with your use of the Services. This means that we determine and are responsible for how your personal information is used.

I. What is Personal Information?

When we use the term “personal information” in this Privacy Notice, we mean any data or information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person or household.
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II. Our Collection & Use of Personal Information

We collect personal information in a variety of ways. For example, you may provide us your personal information when you subscribe to our mailing lists or other Ardea communications, submit an application for an internship or employment at Ardea or use some other feature of our Services.

We may link or combine your activities and information collected from you on our Site with information we receive from third parties, as well as information we collect automatically through tracking technologies (defined below). This allows us to provide you with a personalized experience regardless of how you interact with us.

Personal Information Collected from You
‍We may collect the following categories personal information submitted to us by individuals through the Services:

• Business Contact Information, including first and last name, business email address, business postal address, employer, job title, your area of responsibility, company name, phone number, your country or region and communication preferences. We use this information to fulfill your request or transaction and to communicate with you in accordance with your preferences.
• Inquiry and Communications Information, including information provided in custom messages sent through the forms, in chat messages, to one of our email addresses, or via phone. This also includes contact information provided on our Services. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.

Personal Information Automatically Collected
As is true of many digital properties, we and any of our third-party providers may automatically collect certain information about you, your preferences, or your device when visiting or interacting with our Services, such as the list below and in the sub-sections here:

• Log data, including internet protocol (IP) address, operating system, device type and version, browser type and version, browser ID, the URL entered, the referring page/campaign, date/time of visit, other user agent string data, the time spent on our Services, and/or any errors that may occur during the visit to our Services). Log data may overlap with the other categories of data below.
• Analytics data, Including the electronic path you take to our Services, through our Services and when exiting our Services, UTM source, as well as your usage and activity on our Services, such as the time zone, activity information (first and last active date and time), usage history (flows created, campaigns scheduled, emails opened, total log-ins) as well as the pages, links, objects, products and benefits you view, click or otherwise interact with. We may also analyze the interaction between you and your customer using our Services.
• Location data (such as general geographic location that we or any of our third-party providers may derive from your IP address).

We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect this personal information. We may also use this information to distinguish you from other users of our Services. This helps us monitor and analyze how you use and interact with our Services. It also helps us and our third party partners to determine products and services that may be of interest to you. For more information about these practices and your choices regarding cookies, please see the Control Over Your Information section of this Privacy Notice.

‍Personal Information from Third Parties
‍We may also obtain personal information from third parties; which we may combine with personal information we collect either automatically or directly from an you and/or others. We may receive the same categories of personal information as described above from the following third parties:

• Ardea Entities: Ardea entities may receive personal information such as the information described in the sections above headed Personal Information Collected from You and Personal Information Automatically Collected from other companies and brands owned or controlled by Ardea. and other companies owned by or under common ownership with Ardea.
• Your Employer / Company: If you interact with our Services through your employer or company, we may receive your information from your employer or company, including another representative of your employer or company. We use this information to operate, maintain, and provide to you the features and functionality of the Services.
• Service Providers: Our service providers collect personal information on our behalf and often share some or all of this information with us. The information may include business contact information, information about your communications and related activities, and information about the use of our Services. We may use this information to administer and facilitate our Services.
• Business Partners: We may receive your information from our business partners. We may use this information to administer and facilitate our Services.
• Other Sources: We may also collect personal information about individuals that we do not otherwise have from, for example, publicly available sources, third-party data providers, or through transactions such as mergers and acquisitions, private placements, underwriting or investing. We use this information to operate, maintain, and provide you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you, and otherwise provide our Services.

Through the provision of our Services, we may also process deidentified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer or household. Ardea commits to maintain and use the information in deidentified form and will not attempt to reidentify the information, except in instances where necessary for determining whether the deidentification process used by Ardea satisfies the requirements under applicable law.

‍Additional Uses of Personal Information
‍We may use personal information we collect to:

• Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations or to deliver the Services you have requested;
• Manage our organization and its day-to-day operations;
• Verify your identity and entitlement to products or Services;
• Register you for and provide you access to events and webcasts;
• Communicate with individuals, including via email, text message, Teams, WhatsApp and/or telephone calls;
• Administer, improve and personalize our Services, including by recognizing an individual and remembering the individual’s information when the individual returns to our Services;
• Conduct research and analytics on our customer and/or user base and/or our Services;
• Improve and customize our Services to address the needs and interests of our user base and/or other individuals we interact with;
• Test, enhance, update and monitor the Services and/or to diagnose and/or fix technology problems;
• Help maintain the safety, security and integrity of our Site and Services;
• To enforce our contractual rights, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
• Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
• Comply with contractual and legal obligations or requirements, such as know-your-customer and anti-money laundering requirements or respond to any legal process, subpoena or court order;
• To comply with our regulatory obligations, including responding to the requests of any regulator;
• To fulfill any other purpose for which you provide personal information;
• For any other lawful purpose; and
• For any other purpose that you consent to.

Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.
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III. Our Disclosure of Personal Information

We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:

• Entities within the Ardea group of companies: We may share personal information with other companies owned or controlled by Ardea, and other companies owned by or under common ownership as Ardea, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
• Your Employer / Company: If you interact with our Services through your employer or company, we may disclose your information to your employer or company, including another representative of your employer or company.
• Consultants and/or Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as investment advisers and software providers. For example, we may disclose personal information to Inter Invest S.A. for certain Services that are regulated in the European Union;
• Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets or equity. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
• Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors, regulators and law enforcement:
  
  - in connection with the establishment, exercise, or defense of legal claims;
  - to comply with laws or to respond to requests or legal process;
  - to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
  - to detect, suppress, or prevent fraud;
  - to protect the health and safety of us and others; or
  - as otherwise required by applicable law.
  
• With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with the individual’s consent or direction. For example, with an individual’s consent or direction, we may post the individual’s testimonial on our Site or in Service-related publications.

IV. Control Over Your Information

You may control your information in the following ways:

• Device and Browser Settings. You may control the Services’ access to your device and browser information through your “Settings” app on the applicable device or browser.
• Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., transactional communications, changes/updates to features of the Services, technical and security notices).
• Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, please contact us. We may not be able to modify or delete your information in all circumstances.
• Cookies: For information about our and our third-party partners’ use of cookies and related technologies to collect information automatically, and any choices you may have in relation to cookies, please see the Information We Collect Automatically section above.

V. Data Retention

We generally store the personal information we collect about you for no longer than necessary to fulfil the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.

Once retention of the personal information is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal information or, if this is not possible (for example, because personal information has been stored in backup archives), then we will securely store the personal information until deletion or deidentification is possible.
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VI. Children's Personal Information

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, the individual should not use our Services or otherwise provide us with any personal information either directly or by other means. Subject to our regulatory obligations, including responding to the requests of any regulator, i a child under the age of 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information (unless otherwise required by our regulatory obligations).
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VII. Links to Third-party Websites or Services

Our Services may include links to third-party websites, plug-ins,applications and services. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites, plug-ins, applications and services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

VIII. Updates to This Privacy Notice

We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. All changes shall be effective from the date of publication unless otherwise provided.
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IX. Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to compliance@ardeapartners.com.
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X. Region-specific Disclosures

We may choose or be required by law to provide different or additional information relating to the processing of personal information (as defined below) about residents of certain countries, regions or states. Please refer below for additional information that may be applicable to you:

A. United States

• 1. California
  If you are a California Resident, please see our California Privacy Notice for additional California-specific privacy information.
  
• 2. Nevada
  If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. We do not currently sell covered information.

B. European Economic Area, United Kingdom or Switzerland

If you are located in European Economic Area (Member States of the European Union together with Iceland, Norway, and Liechtenstein), United Kingdom, or Switzerland, please see the Additional European Economic Area, United Kingdom, and Switzerland Privacy Disclosures section for additional European-specific privacy disclosures.

California Privacy Notice

Scope of Notice

This California Privacy Notice (the “CA Notice”) supplements the information contained in our Privacy Notice above and applies solely to individual residents of the State of California (“ “you”).

This CA Notice describes how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, “CCPA”). It does not address our privacy practices relating to Ardea job applicants, employees and other personnel.

Unless otherwise expressly stated, all terms in this CA Notice have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.
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Collection and Use of Personal Information

We collect personal information from and about consumers for a variety of purposes. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information, and the purposes for which we use this information, please refer to the “Our Collection of Personal Information” and “Our Use of Personal Information” sections of our Privacy Notice. In the last 12 months, we have collected the following categories of personal information:

• Identifiers, such as your email address;
• California Customer Records (Cal. Civ. Code § 1798.80(e)), such as your phone number;
• Commercial Information, such as products and services purchased, obtained, or considered;
• Internet/Network Information, such as device information, logs and analytics data;
• Professional/Employment Information, such as job title and company;
• Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34C.F.R. Part 99).
• Other Personal Information, including information you provide in any communications between you and Ardea; and
• Inferences, such as information generated from your use of the Services reflecting predictions about your interests and preferences.

We collect this information from a variety of sources, including directly from you, from your employer or organization, from our customers and other users, from our business partners and affiliates, from your browser or device when you use our Services, or from third parties that you permit to share information with us. Please see the Our Collection of Personal Information section of the Privacy Notice for more information about the sources of personal information we collect.

In the last 12 months we have not collected “sensitive personal information” as that term is defined in the CCPA from users of our Services.
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Disclosure of Personal Information

As described in the Our Disclosure of Personal Information section of our Privacy Notice, we share personal information with third parties for business purposes.

The categories of third parties to whom we disclose your personal information for a business purpose may include (i) other brands and affiliates in our family of companies, (ii) our service providers, vendors and advisors, (iii) strategic partners and (iv) analytics providers.In the previous 12 months, we have not disclosed or sold all of the categories of personal information we collect, explained in the Collection and Use of Personal Information section of this CA Notice, to third parties for a business purpose.

Your California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the personal information that we have collected about you (subject to certain limitations at law):
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How to Exercise Your California Consumer Rights

Please submit a request by either:
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- Completing our CCPA Request Form
- Emailing us at Compliance@ardeapartners.com
- Calling +1-212-430-2300

Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally either require the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email address, phone number, employer address and the Service provided to you.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems or if we are required by a regulator to maintain, or prohibited from deleting, that information. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

Authorized Agents

In certain circumstances, you are permitted to use an authorized agent (as that term is defined by theCCPA) to submit requests on your behalf through the designated methods set forth in this CA Notice where we can verify the authorized agent’s authority to act on your behalf.

For requests to know, delete or correct personal information, we require the following for verification purposes:

• a power of attorney valid under the laws of California from you or your authorized agent; or
• sufficient evidence (as determined by us in our sole discretion) to show that you have:

• provided the authorized agent signed permission to act on your behalf; and
• verified your own identity directly with us pursuant to the instructions set forth in this CA Notice; or directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.

For requests to opt-out of personal information “sales” or “sharing”, we require a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.

Minors

We do not sell the personal information and do not have actual knowledge that we sell the personal information of minors under 16 years of age. Please contact us at compliance@ardeapartnerers.com to inform us if you, or your minor child, is under the age of 16.

We may not be able to modify or delete your information in all circumstances such as if we are required by a regulator to maintain, or prohibited from deleting, that information.
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Additional European Economic Area, United Kingdom, and Switzerland Disclosures

This section contains disclosures on how we collect, store, process, transfer, share or use personal information of residents of the European Economic Area (“EEA”), Switzerland and the United Kingdom(“UK”). These disclosures supplement the information contained in the Privacy Notice and apply to residents of the EEA, Switzerland or UK. Please ensure that you have read and understood these disclosures before using our Services. Unless otherwise expressly stated, all terms in this section have the same meaning as defined in the Privacy Notice or as otherwise defined in the General Data Protection Regulation (“GDPR” as applicable to the EEA or UK).

1. Who Is Responsible For Your Personal Information?

Ardea Partners LP / Ardea Partners International LLP / Ardea Services LLC (“we”, “our” or “us”in these disclosures) are the data controllers of the personal information we hold about you.This means that we determine and are responsible for how your personal information is used.

2. Personal Information We Collect About You And How We Use It

2.1 We collect personal information that you voluntarily submit directly to us when you use the Services. This can include information you provide to us when you correspond with us by phone, e-mail or otherwise, or use some other feature of our Services.

2.2 This information may include, for example, your contact details such as your name and email address. We will indicate to you if the provision of certain personal information is mandatory or optional. If you choose not to provide any personal information marked as mandatory, we may not be able to respond to your queries or provide other services to you.

2.3 The table below sets out in detail the categories of personal information we collect about you and how we use that information when you use the Services, as well as the legal basis which we rely on to process the personal information.

3. Information We Collect About You Automatically

3.1 We also automatically collect personal information indirectly about how you access and use the Services, where you access it from, and information about the device you use to access the Services. We use this information to provide to you certain features and functionality and to monitor and improve the Services.

3.2 We typically collect this information through a variety of tracking technologies, including cookies and similar tracking technologies. Cookies are pieces of code that we transfer to your device for record-keeping purposes. This helps us to provide certain functionalities of the Services, to monitor and improve the Services.

3.3 We use the following types of cookies:

• Strictly necessary cookies. These are cookies that are required for the operation ofour Services and without, our Website would not function.
• Analytical/performance cookies. They allow us to recognize and count the number of visitors, to see how visitors move around the Services when they are using it and to monitor the performance of certain features on the Services. This helps us to improve the way the Services works, for example, by ensuring that users are finding what they are looking for easily and to test the rollout of new features.

3.4 The table below sets out in detail the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information. For more information on cookies and other tracking technologies we use, please see below.

3.5 We may anonymize and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving the Website and our services or developing new services and features. We may also share such anonymized and aggregated information with others.

3.6 Other than cookies that are required to operate the Website, we will only place cookies on your device with your consent. You can also change your preferences in relation to the cookies you consent to receive at any time in our Privacy Preference Center by clicking the floating cookie icon on the website bottom left.

3.7 You also have the ability to opt out by disabling cookies in your browser or mobile settings. These settings will typically be found in the "options" or "preferences" menu of your browser. You should use the "Help" option in your browser for more details.

How Long We Keep Your Personal Information

3.8 To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal and regulatory requirements.

4. Recipients

4.1 As required in accordance with how we use your personal information, we may share yourpersonal information with the following:

5. Storing And Transferring Your Personal Information

5.1 Security. We implement reasonable technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our servers. We will never send you unsolicited emails or contact you by phone requesting your password, credit or debit card information or national identification numbers.

5.2 International Transfers of your personal information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in. For example, where we or our third-party service providers have operations. If you are in the EEA, Switzerland or the UK, your personal information may be processed outside of the EEA, Switzerland or the UK. These international transfers of your personal information will be made pursuant to appropriate safeguards, including:

• ensuring that the personal information is transferred to countries recognized by the European Commission or the UK Secretary of State (as applicable) as offering an equivalent level of protection; or
• ensuring that such transfer is to a third party who uses appropriate safeguards in respect of the processing in question, including but not limited to the UK or EU standard contractual clauses, which are recognized as offering adequate protection for the rights and freedoms of data subjects, as determined by the European Commission or the UK Secretary of State (as applicable).

5.3 We may transfer your personal information to, or store your personal information in, the United States of America, the United Kingdom or France.

5.4 We will take appropriate steps to ensure that your personal information is treated securely and in accordance with applicable law and this Privacy Notice regardless of where it is processed.

5.5 If you wish to enquire further about the safeguards we use, please contact us using the details set out at the end of our Privacy Notice.

6. Your Rights In Respect Of Your Personal Information

6.1 In accordance with applicable privacy laws and subject to our regulatory obligations, you have the following rights in respect of your personal information that we hold:

(a) Right of access. You have the right to obtain:

• confirmation of whether, and where, we are processing your personal information;
• information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
• information about the categories of recipients with whom we may share your personal information; and
• a copy of the personal information we hold about you.

(b) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.

(c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

(d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

(e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

6.2 You have a right to object to any processing based on our legitimate interests. There may, depending on the particular circumstances, be compelling reasons for continuing to process your personal information despite your objection, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

6.3 If you wish to exercise one of these rights, please contact us using the contact details in our Privacy Notice.

6.4 We will not charge you a fee for complying with your request to exercise one of these rights, other than where the request is manifestly unfounded or excessive (such as if you submit a number of repeated requests), in which case we may charge you a reasonable fee to cover our administrative costs.

6.5 You also have the right to lodge a complaint to your local data protection authority. If you arebased in the European Union, information about how to contact your local data protectionauthority is available here. If you are based in the UK, information about how to contact yourlocal data protection authority is available here.