Privacy Notice

Effective Date: September 07, 2026

Anneal Equity Partners Limited (“AEP”) takes the protection of your personal data seriously.

During the course of our relationship or interactions with you, we may collect your personal data. Personal data is information that either alone or in combination with other information can directly or indirectly identify you. Please refer to the relevant heading of this privacy notice ("Notice") below which correlates with your relationship with AEP to learn more about how we use your personal data.

Personal data: business contacts

If you have interacted with AEP, whether through email, meeting someone from AEP, or otherwise, we may keep limited amounts of your personal data.

(a) What personal data do we collect and use?

general information such as your name and contact details including phone number and email address; and
professional details such as your job title, employer organisation and information about your job role.

We do not collect any of your special category data; this is any information relating to your health or medical records, criminal records or convictions, sexual orientation, racial or ethnic origin, political or philosophical opinions or affiliations, religious or philosophical beliefs or affiliations or trade union membership or genetic or biometric data.

(b) How do we obtain your personal data?

We obtain your personal data directly from you or from your representatives or staff;
publicly available sources such as internet search engines; and
invoices, contracts, policies, correspondence and business cards.

We will always consider your interests and undertake a balancing exercise to ensure that our business interest does not cause you harm or override your own interest.

We will process your personal data for the following purposes and in reliance of the listed lawful bases:

Purpose for processing your personal data

Lawful basis

To provide business updates.

Legitimate interests (to run and promote our business).

To maintain a list of contacts.

Legitimate interests (to run and promote our business).

For marketing purposes.

Legitimate interests (to ask you along to our upcoming events or presentations).

For the purpose of corresponding with you.

Legitimate interests (to organise meetings between you and AEP’s representatives).

Personal data: actual or potential management teams

If you are involved in a transaction that AEP and/or the funds that it advises enters into, or a potential transaction that AEP is contemplating, we may keep certain limited amounts of your personal data.

(a) What personal data do we collect and use?

Information relating to your financial status and dealings, your CV, details of your previous employment history and professional activities, your nationality (including copies of identity documents, such as a passport), references provided by third parties, and results of other due diligence we may have conducted.

(b) How do we obtain your personal data?

We obtain your personal data in a number of different ways:

directly from you or during any form of correspondence such as face to face, written (including email) and phone correspondence;
from your representatives, staff or advisors; and/or
in certain limited circumstances from other third parties, for example, a recruiter.

We only process personal data for the purposes described in this Notice. Data Protection Laws require companies to have a "lawful basis" to collect and use personal data.

For AEP this will be that:

it is necessary for compliance with a legal obligation; or
it is necessary for legitimate business interests pursued by us or a third party and your interests and fundamental rights do not override those interests. We will always consider your interests and undertake a balancing exercise to ensure that our business interest does not cause you harm or override your own interest.

Where the information we process is special category data or criminal conviction data, we must have an additional lawful basis and we rely on the following legal bases when doing so:

There is a substantial public interest in the prevention and detection of unlawful acts such as where we suspect fraud.
It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty – such as carrying out fraud, credit and anti-money laundering checks
We need to use it to establish, exercise or defend legal rights, such as when we are facing legal proceedings or want to bring legal proceedings ourselves.

We will process your personal data for the following purposes and in reliance of the listed lawful bases:

Purpose for processing your personal data

Lawful basis

To evaluate potential transactions.

Legitimate interests (to effectively manage our business, in particular, to review potential transactions).

To keep records of assets and investments.

Legitimate interests (to effectively manage our business, in particular, to provide our investment services).

To assess your suitability for involvement in a transaction, including by verifying your identity to comply with money laundering and related regulation and in order to conduct satisfactory ‘Know Your Client’ checks.

Legitimate interests (to effectively manage our business, in particular, to provide our investment services).
To meet our legal and regulatory obligations.
Legitimate interests (for protecting you, us and third parties against fraud, and to complete identify verification checks).
When processed for the purposes of KYC and anti money laundering – the recognised legitimate interests of detecting, investigating or preventing crime prevention.
Legitimate interests (in connection with any prospective acquisition and ownership of portfolio companies by us).
Where your special category data is processed, it is:
- in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty.
- necessary to establish, exercise or defend legal rights.
- in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud).

To meet with our regulatory/legal obligations, including assessing and managing risk.

Legitimate interests (to comply with law enforcement agencies' requests and assist with the prevention/detection of criminal activity).
To meet our legal and regulatory obligations.

To administer any transaction that we are involved with.

Legitimate interests (to provide our investment services).
It is necessary to perform the contract we have with you.

To safeguard our own legal rights and interests.

We have a legitimate business interest (to safeguard our legal rights and interests).

To receive advice from our professional advisors, including accountants, lawyers and other consultants.

Legitimate interests (to effectively manage our business, in particular, to provide our investment services.
It is necessary to perform the contract we have with you.

To provide business updates.

Legitimate interests (to run and promote our business).

For the purpose of corresponding with you.

Legitimate interests (to correspond with individuals as necessary to manage our business).

Personal data: suppliers and professional advisors

We will store limited amounts of personal data relating to suppliers to AEP, or one of AEP’s professional advisors.

(a) What personal data do we collect and use?

general information such as your name and contact details including phone number and email address;
professional details such as your job title, employer organisation, qualifications and information about your job role;
financial information such as your bank details, payment card details, and billing address;
other information (including publicly available information) obtained as part of our due diligence checks;
information captured during any correspondence with you; and/or
recordings and/or transcriptions of calls, meetings or presentations.

(b) How do we obtain your personal data?

We obtain your personal data in a number of different ways:

directly from you; such as via your website or during any form of correspondence or meeting such as face to face, written (including email) and phone correspondence or meetings;
from your representatives, staff or advisors;
publicly available sources such as internet search engines;
invoices, contracts, policies, correspondence and business cards; and
third party suppliers such as meeting recording and transcription tools providers.

We only process personal data for the purposes described in this Notice. Data Protection Laws require companies to have a "lawful basis" to collect and use personal data.

For AEP this will be either that:

It is necessary for complying with a legal obligation;
it is necessary for legitimate business interests pursued by us or a third party and your interests and fundamental rights do not override those interests. We will always consider your interests and undertake a balancing exercise to ensure that our business interest does not cause you harm or override your own interest;
in limited circumstances, where we have your consent

We will process your personal data for the following purposes and in reliance of the listed lawful bases:

Purpose for processing your personal data

Lawful basis

To manage and preserve records of services or advice we have received and authorising further services.

Legitimate interests (to effectively manage our business).

For the purpose of corresponding with you.

Legitimate interests (to correspond with individuals as necessary to manage our business).

For the purpose of administration, onboarding of a supplier (including due diligence checks) and supplier management; this will include billing and financing

Legitimate interests (to perform the agreement we have with you).
Legitimate business interests (to administer, invoice and procure your services).

To meet with our regulatory/legal obligations, including assessing and managing risk.

Legitimate interests (to comply with law enforcement agencies' requests and assist with the prevention/detection of criminal activity).
To meet our legal and regulatory obligations.

For general business management, record keeping and operation purposes such as business planning and audits

Legitimate interests (to effectively manage our business and suppliers).
Consent (with respect to meeting recording and transcription (please find more details about recording and transcription below)).

For the purpose of complying with applicable legal, taxation, accounting, regulatory and/or reporting obligations as well as any government or law enforcement requests.

Legitimate interests (to comply with law enforcement agencies' requests and assist with the prevention/detection of criminal activity.
To meet our legal and regulatory obligations.

Personal data: Individual investors

When you become a client of AEP or an investor and during the course of our dealings with you, we will collect personal data about you. This includes what you tell us about yourself and what we learn about you by having you as an investor.

(a) What personal data do we collect and use?

General information such as your first and last name, date of birth, marital status;
Contact information including telephone number, business and/or personal address(es), and email address;
Information regarding your job including your employer/company, job title, salary, employment history etc.;
Financial information, including the amount you are looking to invest, any monthly payments you may wish to make, your investment selection(s), your investment history, your net-worth, income, your investment history and your bank account information for any distributions or other payments to be made;
Proof of identification, including copies of your passport, driver's license or other identifying documents and information such as utilities bills, tax bills, national identification numbers etc.;
Personal data and contact information provided in correspondence with us, whether by email, letter, telephonically, or online (this will be information volunteered by you, it could include the reasons why you have decided to invest, or where your investment money has come from, by way of example);
IP address, login and browsing history on the limited partner extranet, or any other data room or portal we may use, operate or provide ("Data Rooms");
Transaction history with AEP and its affiliates (including account balance, commitment, other account data, and participation in other investments);
Information relating to your use of any other AEP services you currently have, have applied for or have previously held;
Information included in limited partnership agreements, investment advisory contracts, investment management agreements or subscription agreements, as applicable;
recordings and/or transcriptions of calls, meetings or presentations; and/or
Other information regarding your preferences where relevant to the services that we provide you.

(b) How do we obtain your personal data?

We obtain your personal data in a number of different ways:

when you complete investor questionnaires, applications and other related documentation;
directly from you or during any form of correspondence or meeting such as face to face, written (including email) and phone correspondence or meetings;
from your representatives, staff or advisors;
when you access our Data Rooms; and/or
third party suppliers such as meeting recording and transcription tools providers.

We only process personal data for the purposes described in this Notice. Data Protection Laws require companies to have a "lawful basis" to collect and use personal data. For AEP this will be:

it is necessary for legitimate business interests pursued by us or a third party and your interests and fundamental rights do not override those interests. In each case we will always consider your interests and undertake a balancing exercise to ensure that our business interest does not cause you harm or override your own interest;
it is necessary for us to enter into or perform a contract with you;
where we need to so we can comply with our legal and regulatory obligations; and
in limited circumstances, where you have given your consent.

Where the information we process is special category data, we must have an additional lawful basis and we rely on the following legal bases when doing so:

There is a substantial public interest in the prevention and detection of unlawful acts such as where we suspect fraud.
It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty – such as carrying out fraud, credit and anti-money laundering checks
We need to use it to establish, exercise or defend legal rights, such as when we are facing legal proceedings or want to bring legal proceedings ourselves.

We will process your personal data for the following purposes and in reliance of the listed lawful bases:

Purpose for processing your personal data

Lawful basis

To process your requests of, and applications to, us.

It is necessary to enter into a contract with you.
Legitimate interests (to process all requests and applications).
Legitimate interests (in connection with any prospective acquisition and ownership of portfolio companies by us).

To verify your identity and undertake KYC checks for the purpose of preventing fraud or other financial crimes, complying with statutory, regulatory and internal compliance requirements for example, in relation to anti-money laundering requirements.

To meet our legal and regulatory obligations.
Legitimate interests (for protecting you, us and third parties against fraud, money, laundering and crime and to complete identify verification checks).
When processed for the purposes of KYC and anti money laundering – the recognised legitimate interests of detecting, investigating or preventing crime prevention.
Legitimate interests (in connection with any prospective acquisition and ownership of portfolio companies by us).
Where your special category data is processed, it is:
- in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty.
- necessary to establish, exercise or defend legal rights.
- in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud).

For the purpose of evaluating an investment or prospective portfolio company investment.

It is necessary to perform the contract we have with you.
Legitimate interests (to provide our investment services).
Legitimate interests (in connection with any prospective acquisition and ownership of portfolio companies by us).

For the purpose of evaluating whether to accept investments from prospective investors, including processing investor questionnaires and subscription documents.

Legitimate interests (to provide our investment services).
It is necessary to perform the contract we have with you.

For the purpose of performing our obligations under limited partnership agreements, investment advisory contracts, investment management agreements or subscription agreements.

It is necessary to perform the contract we have with you.
Legitimate interests (to provide our investment services).

For the purpose of sending you newsletters or other marketing or promotional materials and information on our products and service offerings.

We have your consent (where required).
Legitimate interests (to send you information about our products or services which we think you may be interested in and to improve our products and services and to develop our business).

For the purpose of corresponding with you.

Legitimate interests (to correspond with individuals as necessary to manage our business).

To send invoices or reminder notices, granting access to Data Rooms.

Legitimate interests (to effectively manage our business).

For the purpose of administering investments pursuant under limited partnership agreements, investment advisory contracts, investment management agreements or subscription agreements and providing you or your employer with any agreed upon services.

Legitimate interests (to provide our investment services).
It is necessary to perform the contract we have with you.

For the purpose of complying with applicable legal, taxation, accounting, regulatory and/or reporting obligations as well as any government or law enforcement requests.

Legitimate interests (to comply with law enforcement agencies' requests and assist with the prevention/detection of criminal activity).
To meet our legal and regulatory obligations.

For the purpose of compiling market research and statistical analysis .

Legitimate interests (to understand how we can improve the products and services we offer).

For the purpose of investigating and responding to any complaints or feedback.

Legitimate interests (to respond complaints and feedback about our products and services).
To meet our legal and regulatory obligations.

For general business management, recording keeping and operational purposes such as business planning and audits and to arrange insurance.

Legitimate interests (to effectively manage our business).
To meet our legal and regulatory obligations.
Consent (with respect to meeting recording and transcription (please find more details about recording and transcription below)).

To protect our legal interests or in defence of a claim.

We have a legitimate business interest (to defend any legal claims).

Personal data: Event attendees

This section will apply to individuals when they attend events hosted by AEP.

(a) What personal data do we collect and use?

general information such as your name and contact details including phone number and email address; and
professional details such as your job title and information about your job role.

(b) How do we obtain your personal data?

We obtain your personal data directly from you.

We will always consider your interests and undertake a balancing exercise to ensure that our business interest does not cause you harm or override your own interest.

We will process your personal data for the following purposes and in reliance of the listed lawful bases:

Purpose for processing your personal data

Lawful basis

To liaise with you about prospective investment opportunities.

Legitimate interests (to provide our investment services).

For the purpose of corresponding with you.

Legitimate interests (to keep you updated about the event).

For marketing purposes.

Legitimate interests (to send you information about upcoming events that may be of interest to you).
Legitimate interests (to send you information about our products or services which we think you may be interested in and to improve our products and services and to develop our business).

Personal data: website users

This Notice also applies to how AEP controls, processes, handles and protects your personal data while browsing or using AEP’s website (aepartners.ai), including your rights under current laws and regulations. AEP uses this information to provide you with a better service, and, in particular, for the following reasons.

(a) What personal data do we collect and use?

i. general information such as your name and contact details including phone number and email address;

ii. professional details such as your job title and information about your job role;

iii. any information that you choose to provide to us in relation to the nature of your query;

iv. information obtained through our use of cookies such as unique user identifiers, IP address and login data; please see our Cookie Policy for more information; and

v. your marketing preferences, subject to any requirements regarding marketing consents under law.

(b) How do we obtain your personal data?

We obtain your personal data:

directly from any of AEP's websites that you use; and/or
via our website collected via cookies.

We only process personal data for the purposes described in this Notice. Data Protection Laws require companies to have a "lawful basis" to collect and use personal data. For AEP these will be that it is necessary for legitimate business interests pursued by us or a third party and your interests and fundamental rights do not override those interests.

We will always consider your interests and undertake a balancing exercise to ensure that our business interest does not cause you harm or override your own interest.

We will process your personal data for the following purposes and in reliance of the listed lawful bases:

Purpose for processing your personal data

Lawful basis

To provide answers to your questions asked via the website.

Legitimate interests (to respond to any enquiries you have raised via our website).

To improve the content of the website.

Legitimate interests (to provide a better user experience of the website as it relates to our business).

To understand visitor behaviour patterns to improve the website.

Legitimate interests (to set cookies to ensure that our websites are functional).
We have your consent.

To respond to your media queries about us.

Legitimate interests (to respond to your media queries raised about us).

AEP’s websites may contain hypertext links to external websites. AEP is not responsible for and accepts no liability in relation to these websites or their contents. You should read any applicable privacy policy on any such website.

Marketing Activities: Mailing lists

As part of our marketing activities, AEP collects and use personal data to provide updates on our activities and to issue invitations to events we host. We don’t rent or trade email lists with other organisations and businesses.

Recording of meetings, presentations or calls

In certain circumstances, we process personal data using recording and transcription tools to create records of meetings, presentations or calls, to support our work and aid our decision-making. These records may consist of voice and/or video recordings as well as speech to text transcripts including AI powered transcription. The personal data recorded may consist of names, contact details, and any information shared during these interactions.

We shall only undertake recording and transcription in certain scenarios, in accordance with our internal recording and transcription use policies, using approved AI tools (such as Copilot, Claude for Enterprise and ChatGPT for Enterprise) and recording tools (such as Microsoft Teams).

Who we share your personal data with

When we share your personal data, we do so in accordance with applicable law and our internal security standards. We may disclose your personal data to:

our legal and other professional advisers, auditors, and independent consultants;
governmental and regulatory bodies such as tax authorities, financial regulators and non-financial regulators (depending on the circumstances of the sharing);
overseas tax authorities, to the extent that you are subject to tax in a different jurisdiction than the fund. This may include us sharing your personal data directly with the relevant tax authorities (instead of through the local authority);
other organizations and businesses who provide services to us under contract, such as maintaining or servicing customer accounts, providing marketing services to us (such as a placement agent), back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions;
buyers or successor managers of a fund and their professional representatives, as part of any restructuring or sale of our business or assets;
administrators or custodians;
identity verification agencies, anti-money laundering screening services; and/or
companies related to AEP by common ownership or control, including financial and nonfinancial companies for administration of their products and services, conducting marketing and credit checks.

Personal data: international transfers

Due to the international nature of AEP’s operations, any personal data that we hold may be transferred to, and stored at, a country outside of your country of residence. This could include countries outside of the UK and/or the EEA. To the extent we transfer personal data outside of the UK and/ or the EEA, we will ensure such transfers comply with applicable law. This may include entering into data transfer agreements with recipients.

How long do we keep your personal data?

We will only keep your personal data for as long as is necessary to fulfil the relevant purposes as set out in this privacy policy and more widely to comply with our legal and regulatory obligations. After this period, we will securely destroy your personal data in accordance with our data retention policy.

What are your rights?

If AEP holds your personal data you may be entitled to make certain requests of us in relation to the personal data that we hold about you. If you wish to make any such request you should submit it by email (info@aepartners.ai).

Please note that not all of your data subject rights will be absolute; this means that there may be some circumstances where we may not be able to comply with your request (such as where this would conflict with our obligation to comply with legal requirements). However, if we cannot comply with your request, we will tell you the reason, and we will always respond to any request you make.

There may also be circumstances where exercising some of these rights (such as the right to erasure, the right to restrict processing and the right to withdraw consent) will mean we can no longer provide you with our services. We will inform you of these consequences when you exercise your right.

Your rights under applicable data protection law are:

the right to access your personal data:
1. you are entitled to a copy of the personal data we hold about you and certain details of how we use it; and
2. we will usually provide you with your personal data in writing, unless you request otherwise, or where you have made the request using electronic means, in which case the information will, where possible, be provided to you by electronic means;
the right to rectification: we take reasonable steps to ensure that your personal data that we hold is accurate and complete, however, you can ask us to amend or update the personal data if you do not believe that this is so or if your details change;
the right to erasure: you have the right to ask us to erase your personal data in certain circumstances, for example where you withdraw your consent or where the personal data we obtained is no longer necessary for the original purpose; this right, will, however, need to be balanced against other factors, for example, we may have legal obligations which mean we cannot comply with your request;
the right to restrict processing: in certain circumstances, you are entitled to ask us to stop using your personal data, for example where you think that we no longer need to use your personal data or where you think that the personal data we hold about you may be inaccurate;
the right to data portability: you have the right, under certain circumstances, to ask that we transfer personal data that you have provided to us to another third party of your choice;
the right to object to marketing: you can ask us to stop sending you marketing messages at any time. You can exercise this right by either clicking on the "unsubscribe" link which is contained in any email that we send to you or you can contact us at info@aepartners.ai. Please note that exercise of this right does not extend to service related communications which, where necessary, we will continue to send;
the right to object to processing: where we process your personal data based on our legitimate business interests (indicated in this privacy policy), you can object to our processing. We will consider your objection and determine whether or not our legitimate business interests prejudice your privacy rights;
rights relating to automated decision-making: we do not currently carry out any solely automated decision making.
the right to lodge a complaint with us and the Information Commissioner's Office: if you have a query or complaint with respect to how we handle your personal data, you can contact us directly using the contact details set out below.
1. e-mail: info@aepartners.ai
2. address: The Directors, Anneal Equity Partners Limited, 15a Clerkenwell Close, London, EC1R 0AA

You always have the right to complain to the relevant data protection regulator. For UK residents this is the Information Commissioner's Office (https://ico.org.uk).

Although you can complain to the ICO without speaking to us first, they expect you to raise the issue with us first.

AEP's ICO registration details will be published here once registration is complete.