Privacy Policy

PP Last Revised: July 13, 2026 This Privacy Policy (the “Privacy Policy”) is a legally binding agreement between Gil Solomon & Co. and any Affiliates thereof as may be from time to time (the “Company”, “we” or “us”) and the users of our mobile application (the “Application”) or visitors of our website, available at: https://equitas.gilsolomon.com (the “Website”) (each, a “User” or “You”). This Privacy Policy shall govern the access, download and use of the Website, the Application and any and all websites and applications that the Company operates or that link to this Policy, including but not limited to any and all pages within the Website or the Application, as well as any equivalent mirror, replacement, substitute or backup website or application, and pages that are associated with, or link to, each of the Website or the Application (collectively, the “Platform”) and any services, interactions, products or mobile applications which may be provided therein (collectively, the “Services”). The Company respects your right to privacy as detailed in this Privacy Policy. Please read and review carefully this Privacy Policy as it explains how we collect, process and use data we collect from You in connection with the Platform and the Services. We encourage You to read this Privacy Policy prior to accessing or using the Platform or the Services. Any capitalized terms not defined hereunder shall have the meaning ascribed to them under the terms of use of the Platform available at https://equitas.gilsolomon.com/legal/terms-of-use (the “Terms”). This Privacy Policy is incorporated by reference into the Terms as an integral part thereof. If You choose to access, use, register to the Platform or the Services or provide data to us or through the Platform or the Services You acknowledge that any use of the Platform or the Services is subject to, and is done in accordance with, this Privacy Policy. You may not use the Platform or the Services or submit any data through it if You do not agree to any of the terms hereunder. This Privacy Policy shall not be construed in any manner to derogate from the Terms or any other agreement made by and between the Company and You. ● You are not required by law to provide us with any Personal Data. Sharing Personal Data with us on the Platform is entirely voluntary. ● The Platform and the Services are intended for users over the minimum age for providing consent to processing of the Personal Data in the relevant jurisdiction. Children or minors under such age are not permitted to register to the Platform or use the Services. If you are under such age you should cease using the Platform or the Services immediately. ● We do not sell, trade, or rent the Personal Data of Users to third parties. We only share the Personal Data with third parties in connection with the provision of the Platform or the Services to our Users, or other limited circumstances specified in this Privacy Policy. ● You may be entitled under applicable law to request to review, amend, erase or restrict the processing of your Personal Data. Please note that in case you request to erase or restrict the processing of your Personal Data, your use of the Platform or the Services may be restricted or disabled. ● If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Policy, please send us an email to: gil@gilsolomon.com.

1. DEFINITIONS

“Affiliate” shall mean with respect to any Person, any other Person that, directly or indirectly, Controls, is Controlled by, or is under common Control with, such Person. “Authority” shall mean any instrumentality, subdivision, court, administrative agency, commission, official or other authority, province, prefect, municipality, locality or other government or political subdivision thereof, or any quasi-governmental or private body exercising any regulatory, taxing, importing or other governmental or quasi-governmental authority. “CCPA” shall have the meaning set forth in Section ‎9. “Claim” shall mean any action, claim, dispute, lawsuit, demand, inquiry, hearing, investigation, notice of a violation or noncompliance, litigation, proceeding, arbitration, appeal, or other dispute, whether civil, criminal, administrative or otherwise. “Control” shall mean (including, with its correlative meanings, “controlled by” and “under common control with”) the possession, directly or indirectly, of the power to direct or cause the direction of management or policies of a Person, whether through the ownership of securities or partnership or other ownership interests, by contract or otherwise. “GDPR” shall have the meaning set forth in Section ‎8. “Identifiers” shall have the meaning set forth in Section ‎9. “Non Personal Data” shall mean non-identifiable information which may be made available or gathered through use of the Platform or the Services by the Users. “Person” shall mean any individual or corporate entity including, but not limited to, any firm, partnership, joint venture, trust, corporation, limited liability entity as well as any unincorporated organization, estate, or any other entity (including any Authority). “Personal Data” shall mean any information that alone or in combination with other information can be used to specifically identify an individual, including but not limited to first and last name, phone number, email address, IP address, billing information, information about an individual’s personality, location, personal status, intimate affairs, health, financial information, vocational qualifications, opinions or beliefs. “Personally Identifiable Information” shall mean any representation of information that permits the identity of an individual to whom the information applies to be reasonably inferred by either direct or indirect means, i.e., any information whether such information is maintained in either paper, electronic or other media, that: directly identifies an individual (e.g., name, address, social security number or other identifying number or code, telephone number, email address, etc.) or by a specific individual may be identified in conjunction with other data elements, i.e., indirect identification. These data elements may include a combination of gender, race, birth date, geographic indicator, and other descriptors. Additionally, information permitting the physical or online contacting of a specific individual shall be deemed personally identifiable information. “Social Network” shall have the meaning set forth in Section ‎2. “UK GDPR” shall have the meaning set forth in Section ‎8.

1. Non Personal Data. We collect Non Personal Data regarding users with respect to their use of the Platform or the Services, such as the scope, frequency, latency, pages accessed, what and when a user views or interacts with in connection to the content and materials displayed through our Platform or the Services, and other technical information regarding the device used to access the Platform or the Services, such as model, operating system, etc.

Please note that unlike Personal Data, Non Personal Data is not identifiable to a specific individual and therefore, while processing Non Personal Data, the Company is not aware of your identity as a result of such Non Personal Data.

1. Personal Data. In order to operate the Platform and provide the Services We collect the following Personal Data:

3.1. The Platform. When you interact with the Platform or the Services, we may collect additional information, such as, session duration, page impressions, advertisements viewed or clicked on, internet protocol (IP) address or the frequency and the extent of your use. 3.2. Social Network Services and Logins. You may enable or log in to the Platform or Services via various online third party services, such as social media providers like Facebook, LinkedIn, Google, Instagram or Twitter (each, a “Social Network”). To take advantage of these features and capabilities, we may ask you to authenticate, register for, or log into such Social Networks on the websites of their respective providers. As part of this integration, you expressly permit us to access certain information from your profile on such Social Networks, as such, Social Networks will provide us with access to certain information you have provided to them, and we will use, store, and disclose such information in accordance with this Privacy Policy. Please note that the way such third party services (including Social Networks) use, store, and disclose your information is governed solely by the policies of those third party services, and we have no liability or responsibility for the privacy practices or other actions of any third party website or service that may be enabled within the Platform or the Services. You may be able to control the amount of information that is accessible to us by adjusting your account privacy settings on such Social Networks. 3.3. Account Information. When You register for an Account, and when personnel of the Company (including employees, freelancers and interns) are provisioned with access to the Platform, we collect the name and email address of the applicable individual, together with related authentication data. Other than as set forth in this Privacy Policy, we do not collect additional Personal Data regarding such individuals through the Platform. 3.4. Documents and Document-Derived Data. As further described in Section 11 below, Documents uploaded to the Platform, and the Cap Table Data and other data extracted or derived therefrom, may contain Personal Data relating to shareholders, directors, officers, option holders, employees and other individuals, such as names, contact details, shareholdings, securities, vesting terms and other equity-related information.

1. Special Categories of Personal Data. Other than as expressly disclosed in this Privacy Policy, we do not knowingly collect or process any Personal Data included in Special Categories of Personal Data (as defined in the GDPR). In the event you become aware that such data has been posted to the Platform or collected by us, please inform us immediately.
2. We may also acquire information from other trusted sources to update or supplement the data that You voluntarily provide to us or that we collect automatically. Whenever required under applicable law, we will obtain consent prior to collection of Personal Data, and always offer the choice to opt-out.
3. TRACKING TECHNOLOGIES

6.1. When you use the Platform or the Services, we may use tracking technologies known as cookies or web beacons and/or similar technologies. Cookies are small text files stored in a user’s browser, and web beacons are electronic images that allow to count visitors who have accessed a particular page and to access certain cookies. Cookies are normally used by websites that use third party traffic monitoring and tracking services. 6.2. The Platform or the Services may use cookies and web beacons for various purposes, such as to facilitate the use of the Services, to collect statistical information or customize the Platform or the Services. If you wish to block the cookies or web beacons available on the Platform or the Services, you will have to modify settings in your browser and follow the necessary instructions to disable receipt of cookies or web beacons. However, bear in mind that disabling cookies or web beacons may complicate or even prevent certain features of the Platform or the Services and your online experience may be limited. 6.3. We may permit third parties to use cookies or web beacons or other tracking technologies in order to collect information about your online usage activities across our Platform or the Services, this data may include the Personal Data, therefore, we recommend that you review such third party providers’ cookie policies carefully. 6.4. For further information about our use of tracking technologies in connection with the Platform or the Services please review our Cookie Policy which is available at: https://equitas.gilsolomon.com/legal/privacy-policy.

1. SHARING DATA WITH THIRD PARTIES

7.1. Please note that we do not share any Personal Data collected from you with third parties or any of our partners except in the following circumstances and solely to the extent needed: 7.1.1. To provide our users with the Platform or the Services in accordance with the terms and conditions of this Privacy Policy and the Terms; 7.1.2. We may share IP addresses collected by us, for the purpose of detecting any fraud, illegality, security risks or other technical issues as related to the Platform or the Services or as required for the operation and improvement of the Platform or the Services; 7.1.3. If the Company is required or reasonably thinks that it is required by law or law enforcement agencies to share or disclose your information; 7.1.4. In any case of conflict, dispute, or legal proceeding of any kind between users and the Company or between you and other users with respect to, or in relation to the Platform or the Services; 7.1.5. In case you have breached our Privacy Policy or the Terms, or you have violated your rights to use the Platform or the Services, or acted in a manner which we reasonably believe to be violating any applicable laws, rules, or regulations; 7.1.6. As required to prevent damage or breach to the rights or interests (including any legal rights) of third parties, including with respect to safety issues of the Company, our users or any applicable third party; 7.1.7. If the Company organizes the structure or business of the Platform or the Services within a different framework, or through another legal structure or entity, or in case of sale or merger of the Company; and 7.1.8. In certain cases, we may disclose Personal Data to our trusted partners and service providers so that they can perform certain services on our behalf, such as fraud detection, server and data storage provision, artificial intelligence and large language model processing as described in Section 11 below or for security purposes.

1. EU RELATED PROVISIONS

8.1. The Lawful Basis Under Which the Company Processes Personal Data. This section applies to You if You are a resident of the European Union (the “EU”) or the United Kingdom (the “UK”). As part of our Privacy Policy we would like to explain to You the lawful basis under which we process Personal Data, all subject to the EU General Data Protection Regulation (the “GDPR”) or the United Kingdom’s Data Protection Act 2018 and any other data protection laws substantially amending, replacing or superseding the GDPR following the exit by the United Kingdom from the European Union (the “UK GDPR”), as well as other applicable data privacy regulations, as follows: 8.1.1. Where a User uses the Platform, we process Personal Data of such User in order to perform our contract with such User (as embodied in the Terms) or to provide the Services to such User; 8.1.2. We process Personal Data, as described below, under the lawful basis which relies on our legitimate interests. Such interests include, among other things, processing Personal Data of our users: (i) as required for the provision of the Services in accordance with Recital 47 of the GDPR; (ii) as necessary for the purposes of preventing fraud or exploiting or abuse of the Platform or the Services; (iii) as required to be shared among our Affiliates for the purpose of the provision of the Services; or (iv) as required for the prevention of unauthorized access to electronic communications networks and malicious code distribution or stopping ’denial of service’ attacks and damage to computer and electronic communication systems. 8.1.3. Some types of Personal Data, such as third-party cookies we use are based on consent provided to us by the Users as set forth in our Cookie Policy under https://equitas.gilsolomon.com/legal/privacy-policy; 8.1.4. Where the User provides an explicit consent, as necessary for the performance of direct marketing and communication purposes; and 8.1.5. Some of Personal Data may be processed by our trusted third party partners, as described below, under the lawful basis which relies on our legitimate interests, except where such interests are overridden by the fundamental rights of individuals which require protection of Personal Data. 8.2. Will the Company transfer my Personal Data Internationally? We may store or process your Personal Data in the EU or in other countries. If You are a resident of the European Economic Area (the “EEA”) or the UK we will take appropriate measures to ensure that your information receives an adequate level of data protection upon its transfer outside of the EEA or the UK, as applicable. If You are a resident of a jurisdiction where transfer of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your Personal Data. 8.3. Right of erasure and restriction. You may be entitled to request the erasure or the restriction of your Personal Data, and we will comply with such requests, to the extent required under applicable law. 8.4. Reviewing and amending your Personal Data. You may send us a request in connection with reviewing your Personal Data to: gil@gilsolomon.com. In the event any Personal Data is incorrect or outdated, You may update and correct such data by providing us with appropriate notification or correcting the data directly on the Platform, where possible. 8.5. Retention of Data. We retain Personal Data only for as long as necessary to fulfill the purposes for which it was collected, in accordance with the following criteria: 8.5.1. Account-related data (where applicable) is retained for the duration of the User’s account and for a limited period thereafter, as necessary to comply with legal obligations, resolve disputes, and enforce our agreements. 8.5.2. Contact and inquiry data (including information provided through contact forms or communications with us) is retained until the inquiry has been fully handled and no further communication is reasonably expected. 8.5.3. Marketing-related data is retained until the User withdraws consent or unsubscribes from receiving marketing communications. 8.5.4. Usage, analytics, and technical data (including IP addresses and cookie-related data) is retained only for as long as necessary for statistical analysis, system operation, and improvement of the Platform and the Services, and may thereafter be deleted or anonymized. 8.5.5. Security and log data is retained for as long as necessary to detect, prevent, and investigate fraud, security incidents, or misuse of the Platform. 8.5.6. Notwithstanding the above, we may retain Personal Data for a longer period where required to comply with applicable laws, regulations, or legal obligations, or where necessary for the establishment, exercise, or defense of Claims. 8.6. Portability of Personal Data. To the extent relevant to You and to the Platform or the Services, You may be entitled to request the portability of your Personal Data, and we will comply with such requests, to the extent required under applicable law. 8.7. Objection to processing of Personal Data and Profiling. You have the right to object, to or to request restriction, of the processing of your Personal Data and You have the right to object to profiling. 8.8. Withdrawal of Consent. You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. 8.9. Cross-Border Data Transfers. You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality. 8.10. Complaints. You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place of work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that You please attempt to resolve any issues with us before You contact your local supervisory authority and/or relevant institution by contacting us at: gil@gilsolomon.com. 8.11. Cookies Consent Withdrawal. If You wish not to continue to receive cookies from us, with the exception of technical cookies, You may notify us by following the instructions for opting out of such cookies on our Cookie Policy or sending us an email to: gil@gilsolomon.com. If You are accessing our Website from the EEA or the UK, the use of Cookies, including third party and persistent cookies, shall be made in accordance with the laws applicable to You. In case You have any questions about how we use cookies which are not answered in this statement, You may contact us by sending us an email to: gil@gilsolomon.com.

1. CALIFORNIA RESIDENTS RELATED PROVISIONS

This section of our Privacy Policy applies to You, if You are a California resident and the terms and conditions that apply to Personal Data in this Privacy Policy shall apply to your Personally Identifiable Information, mutatis mutandis, as such Personally Identifiable Information may be treated in accordance with the California Consumer Privacy Act (the “CCPA”). 9.1. Personally Identifiable Information Collected. The Company has collected the following categories of Personally Identifiable Information from consumers within the last twelve (12) months: 9.1.1. Identifiers and Personal Information categories listed in the California Customer Records statute. These include name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) addresses or email addresses (collectively, “Identifiers”) 9.1.2. Internet or other electronic network activity information, including, but not limited to log-in and log-out time, the duration of sessions, the content uploaded and downloaded, viewed webpages or specific content on webpages, activity measures as well as your access device and connection information such as browser type, version, and time zone setting and browser plug-in types and versions 9.1.3. Geolocation data. 9.1.4. Inferences drawn from any of the information identified above to create a profile about consumers. 9.2. Our Categories of Sources for Personally Identifiable Information. The Company obtains the categories of Personally Identifiable Information listed above from the following categories of sources: 9.2.1. The Users of our Platform. 9.2.2. Third party service providers assisting us in connection with security and obtaining fraud protection as well as performing ’know your customer’ and anti money laundering investigations if the Company is required to perform the same in accordance with applicable law. 9.3. What Does the Company Do with Personally Identifiable Information? 9.3.1. The Company further uses Personally Identifiable Information to enable the Platform and the Services, to study and analyze the functionality of the Platform and the Services, to provide support, to measure the Platform and the Services activity, to maintain the Platform and the Services, to make the Platform and the Services better, and to continue developing the Platform and the Services. 9.3.2. If You provide us your email address, the Company may use it to contact You when necessary, to provide information and notices about the Platform and the Services. The Company may include commercial and marketing information about our Platform and the Services. 9.3.3. If necessary, the Company will use Personally Identifiable Information for the following purposes: (i) to enforce our Terms, this Privacy Policy and other legal agreements; (ii) to comply with court orders and warrants, and assist law enforcement agencies; (iii) to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Platform and the Services; (iv) to prevent cyber security attacks and any other unlawful or unauthorized use of your personal information and the Platform and the Services; (v) to take any action in any legal dispute and proceeding; and (vi) for additional purposes which are compatible with the purposes listed under this policy and that the Company believes in good-faith to be within your reasonable expectation. 9.4. Our Use and Disclosure Practices. 9.4.1. The Company uses the Personally Identifiable Information that the Company collects or receives for the business purposes as described above under the section titled “What Does the Company Do with Personally Identifiable Information?” of this Privacy Policy. 9.4.2. The Company discloses Personally Identifiable Information to third parties for business purposes as described above under the section titled “Sharing Data with Third Parties” in this policy. 9.4.3. In the preceding twelve (12) months, the Company has disclosed the following categories of Personally Identifiable Information for business purposes: (i) Identifiers. (ii) Internet or other electronic network activity information. (iii) Inferences drawn from any of the information identified above. 9.5. Your Rights as a California Resident. You are entitled to the following specific rights under the California Consumer Privacy Act in relation to your Personally Identifiable Information: 9.5.1. Access to Specific Information and Data Portability Rights. You have the right to request that the Company will disclose certain information to You about our collection and use of your Personally Identifiable Information over the past 12 months. After verifying your request, the Company will disclose to You: (i) The categories of Personally Identifiable Information that the Company collected about You; (ii) The categories of sources for the Personally Identifiable Information that the Company collected about You; and (iii) Our business or commercial purpose for collecting or selling Personally Identifiable Information related to You. (iv) The categories of Personally Identifiable Information that the Company disclosed for a business purpose or sold, and the categories of third parties to whom the Company disclosed or sold that particular category of Personally Identifiable Information; (v) The specific pieces of Personally Identifiable Information that the Company has collected about You; (vi) If the Company sells or discloses Personally Identifiable Information related to You for a business purpose, the Company will provide You with two separate lists which will identify the Personally Identifiable Information categories that each category of recipient purchased or obtained. 9.5.2. Deletion Rights. You have the right to request that the Company delete Personally Identifiable Information related to You that the Company has collected from You. After verifying your request, the Company will delete the Personally Identifiable Information that You have requested to delete from our records, unless an exception applies (such as if the Company is required to maintain records in accordance with applicable law). 9.5.3. The Right to Opt-Out. You have the right to opt out of the sale of Personally Identifiable Information related to You. For a period of 12 months following the execution of your request to opt out, the Company will not ask your permission to sell Personally Identifiable Information related to You. (i) Exercising your Rights. (ii) To exercise the access, data portability, and deletion rights described above, please submit your request to us by sending us a detailed message to: gil@gilsolomon.com. (iii) To exercise your right to opt out of the sale of Personally Identifiable Information related to You, please submit your request to us by sending us a detailed message to: gil@gilsolomon.com. (iv) Only You or a person authorized to act on your behalf, may make a request related to Personally Identifiable Information. You may also make a request on behalf of your minor or child. (v) A request for access can be made by You only twice within a 12-months period. (vi) The Company cannot respond to your request or provide You with the requested Personally Identifiable Information if the Company cannot verify your identity or authority to make the request and confirm the Personally Identifiable Information that relates to You. The Company will only use the Personally Identifiable Information provided at your request to verify your identity or authority to make the request. (vii) The Company will do the Company’s best to respond to your request within 45 days. If the Company needs more time (up to additional 45 days), the Company will inform You of the reason and extension period in writing. The Company will deliver our written response by email. (viii) Any disclosures that the Company will provide will only cover the 12-months period preceding receipt of your request. (ix) Any response the Company will provide will also explain the reasons for our inability to comply with your request, if applicable. (x) The Company does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If the Company determines that the request warrants a fee, the Company will inform You of the reasons for such decision and provide You with a cost estimate before processing your request.

1. PROTECTION OF PERSONAL DATA

10.1. The Company uses industry standard tools and security measures to prevent unauthorized access or disclosure of Personal Data of Users including unlawful destruction or accidental loss, as is acceptable in the industry. In the event you believe that your privacy rights or security is not treated in accordance with this Privacy Policy, or you have reasonable concerns with respect to the Company’s privacy and data protection practices, please contact us at: gil@gilsolomon.com. 10.2. Although the Company makes best efforts to protect Personal Data, please be aware that these security measures cannot fully eliminate security risks associated with Personal Data. Therefore, while the Company strives to use commercially acceptable means to protect Personal Data, the Company cannot guarantee its absolute security, and therefore, subject to applicable laws and regulations, the Company shall not be liable for any damage caused by unauthorized access to your Personal Data. 10.3. Please note that in the event of a security incident, in which the Company discovers that your Personal Data may be at risk, the Company will take reasonable efforts to notify You and the applicable authority (if required, subject to applicable laws and regulations).

1. DOCUMENTS, CAP TABLE DATA AND ARTIFICIAL INTELLIGENCE PROCESSING

11.1. As part of the Platform and the Services, Users and, where applicable, personnel of the Company acting on behalf of a client, may upload, import, submit or otherwise make available Documents (as such term is defined in the Terms), including without limitation agreements, side letters, board and shareholder resolutions, articles of association, share certificates, option plans and grant documentation. The Company may collect, receive, access, store, use, analyze and otherwise process such Documents, the data contained therein and the Cap Table Data (as such term is defined in the Terms) derived therefrom, for the purposes described in this Privacy Policy. 11.2. The Platform uses artificial intelligence technologies, including third-party large language models, to analyze Documents and to extract, generate and maintain Cap Table Data, which may include, without limitation, names and details of shareholders and other security holders, share classes, shareholdings, options, warrants and other securities, vesting terms, transfer history, valuations and related corporate and equity information, as well as analytics, reports and other materials derived therefrom. 11.3. The categories of data that we may process in connection with the Platform include: (i) account information of Users and of Company personnel, limited to names, email addresses and related authentication data; (ii) Documents and the information contained therein, which may include Personal Data of shareholders, directors, officers, option holders, employees and other individuals; (iii) Cap Table Data and other data extracted or derived from Documents; (iv) analytics, reports and other materials derived from Documents or Cap Table Data; and (v) usage, diagnostic, security, log, device and technical data. 11.4. We process such data for the purposes of: (i) providing, operating, maintaining, securing and supporting the Platform and the Services, including the generation and maintenance of Cap Table Data; (ii) enabling account creation, authentication, access control, administration, communications and customer support; (iii) testing, debugging, troubleshooting, quality assurance, security, fraud and abuse prevention, and compliance with and enforcement of the Terms; (iv) complying with applicable law, resolving disputes and protecting the rights, property and safety of the Company, Users and third parties; and (v) any other purpose disclosed to You in the Platform, the Terms or this Privacy Policy. 11.5. Uploads by Company Personnel. Personnel of the Company, including employees, freelancers and interns, may upload Documents or input data on behalf of a client only pursuant to, and in accordance with, the prior, explicit and documented authorization and instructions of such client, and solely for the purpose of providing the Services to such client. Such personnel are permitted to access Documents and Cap Table Data solely on a need-to-know basis for the foregoing purposes and are subject to confidentiality obligations. Documents uploaded by Company personnel on behalf of a client are processed in the same manner, and subject to the same protections, as Documents uploaded directly by the applicable client, and the applicable client remains responsible for the representations and warranties set forth in the Terms with respect to such Documents. 11.6. Storage. Documents, Cap Table Data and related Personal Data are stored on servers of our hosting and infrastructure providers located in Europe. The Company may change its hosting providers or storage locations from time to time, subject to applicable law and this Privacy Policy. 11.7. Artificial Intelligence Providers. Documents and related data may be transmitted to, and processed by, third-party artificial intelligence and large language model providers engaged by the Company from time to time, currently Anthropic. The Company uses commercially available configurations and settings intended to prevent such providers from using Documents and related data to train their generally available models, where such configurations are made available by the applicable provider. However, the Company does not warrant or guarantee that any third-party provider will not use such data for training or other purposes, and such providers may process such data as necessary to provide their services, including for abuse monitoring, security, reliability, debugging, compliance and temporary retention, in each case subject to the applicable provider’s terms and data processing arrangements. 11.8. No Training by the Company. The Company does not use Documents or Cap Table Data to train artificial intelligence models of general application, and will not intentionally make your non-public Documents or Cap Table Data available to other Users, except where You instruct, authorize or enable the Company or the Platform to do so, or where required by applicable law. 11.9. Other Service Providers. The Company may use additional third-party service providers in connection with the Platform, including providers of hosting, cloud infrastructure, database, storage, authentication, analytics, monitoring, logging, security, customer support and email delivery services. Such providers may process data on our behalf where necessary for the purposes described in this Privacy Policy and subject to appropriate confidentiality and data protection obligations. 11.10. Third-Party Personal Data in Documents. Documents may contain Personal Data relating to individuals other than the uploading User, such as shareholders, directors, officers, option holders and employees. The Company processes such Personal Data as part of the Services and on the basis of the instructions and representations of the applicable client and uploading User. You and the applicable client are solely responsible for ensuring that all such Documents and data are provided lawfully, that all rights, consents, notices and lawful bases required under applicable law have been obtained or established, and that the individuals concerned have been informed of the processing described in this Privacy Policy. 11.11. Sensitive Data. The Platform and the Services are not intended for the upload or processing of Special Categories of Personal Data or other sensitive data, such as health or biometric information, other than data customarily included in corporate and equity documentation. You should not upload such data unless strictly necessary for the Services and unless You have all rights, consents and lawful bases required under applicable law. 11.12. Retention and Deletion. Documents, Cap Table Data and related Personal Data are retained for as long as the applicable Account is active or as necessary to provide the Services, and thereafter as reasonably necessary to comply with applicable law, resolve disputes, enforce the Terms, maintain security and backups, or protect the rights, property and safety of the Company, Users and third parties. You may request deletion of your Account, Documents or Cap Table Data by using the applicable Platform functionality, where available, or by contacting the Company at: gil@gilsolomon.com. The Company may retain and use aggregated, statistical or de-identified data that does not identify any individual.

1. CHANGES TO THE PRIVACY POLICY

12.1. Please be advised that the Company reserves the right to change this Privacy Policy from time to time and the Company will post the amended version of this Privacy Policy on the Platform and make reasonable efforts to notify You by email of material changes. The last revision will be reflected in the “Last Revised” date above. The amended terms will take effect immediately. Therefore, You should review the Privacy Policy periodically in order to remain informed of any changes. You agree to accept the posting of a revised Privacy Policy as actual notice to You. 12.2. Your continued use of the Platform or the Services after any changes to this Privacy Policy have been posted as of the “Last Revised” date above indicates your acceptance of those changes. If You do not agree to the revised Privacy Policy, please refrain from using the Platform or the Services and contact us by sending an email to: gil@gilsolomon.com.

1. PERSONS UNDER 18

13.1. Our Platform and the Services are intended for Users over the minimum age for providing consent to processing of the Personal Data in the relevant jurisdiction. Children or minors under such age are not permitted to register to the Platform or use the Services. If You are under such age, You should cease using the Platform or the Services immediately. 13.2. If a parent or guardian becomes aware that his/her child has provided us with Personal Data, he/she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 18 years old (or the applicable minimum age for providing consent to processing of the Personal Data in any jurisdiction we operate in). If we become aware that a person under 18 years old has provided us with Personal Data, we will delete such data from our databases. If You are aware that your child has provided us with Personal Data, please contact us at: gil@gilsolomon.com.

1. LINKS TO THIRD PARTY WEBSITES AND APPLICATIONS

14.1. Please note that the Platform or the Services may link to other websites or applications of third parties that provide useful information or services. Any information Users provide on the linked pages is provided directly to the applicable third party and is subject to such third party’s privacy policy. 14.2. We are not responsible for the content or privacy practices of websites which are linked via the Platform. Links from the Platform to third parties or other sites are provided for the convenience of the Users. You should learn about the privacy practices of each such website before providing them with Personal Data.

1. WILL I RECEIVE PROMOTIONAL MATERIALS FROM THE COMPANY?

The Company does not send users any commercial or promotion information via direct mailing such as emails or SMS messaging without obtaining the explicit prior consent of the Users. You may unsubscribe from receiving such communications at any time, by sending us a notification to: gil@gilsolomon.com or by following the instructions for unsubscribing included in such communications.

1. APPLICABLE LAWS

16.1. Please note that the provisions included in this Privacy Policy relating to matters regulated under the GDPR or the UK GDPR will apply only to the processing of Personal Data which is subject to the GDPR or the UK GDPR, respectively, in accordance with the applicability of the provisions contained therein. If the GDPR or the UK GDPR does not apply to the processing of your Personal Data, some of the provisions above may not apply to you. 16.2. Please note that the provisions included in this Privacy Policy relating to matters regulated under the CCPA will apply only to the processing of Personally Identifiable Information which is subject to the CCPA in accordance with the applicability of the provisions contained therein. If the CCPA does not apply to the processing of your Personal Data, some of the provisions above may not apply to you. 16.3. Please note that the provisions included in this Privacy Policy relating to matters regulated under the data protection or privacy laws of any other country including, without limitation, the Israeli Protection of Privacy Law 5741-1981 and any regulations enacted thereunder including the Privacy Protection Regulations (Transfer of Data to Databases Abroad), 5761-2001 and Privacy Protection Regulations (Data Security), 5777-2017, and any guidelines and/or instructions published by the Israeli Privacy Protection Authority will apply only to the processing of Personal Data which is subject to the aforementioned legislation, if the aforementioned legislation does not apply to the processing of your Personal Data, some of the provisions above may not apply to you as well.

1. QUESTIONS OR CONCERNS REGARDING PRIVACY

17.1. If You have any questions or concerns regarding privacy issues, please send us a detailed message to: gil@gilsolomon.com and we will make every effort to resolve your concerns without delay. 17.2. You are also entitled to file a complaint with the appropriate supervisory authority in connection with concerns You may have with regards to your privacy and Personal Data. We ask that You please attempt to resolve any issues with us before You contact your local supervisory authority and/or relevant institution by contacting us at: gil@gilsolomon.com.