Last updated: March 2026

This Website, activumsg.com (including any other media form, media channel, mobile website, or mobile application related or connected thereto) (the “Website”) and our accompanying investor web portal, located at https://app.junipersquare.com/i/activumsg (the “Portal”), is operated by Activum SG Capital Management Limited. We take your privacy seriously and urge you to read this Website Privacy Policy (“Privacy Policy”) carefully as it contains important information about:

• Who we are;
• How and why we collect, store, share and otherwise use your “Personal Data”, defined as “any information which is related to an identified or identifiable natural person.”
• The rights you have in respect of your Personal Data; and
• How to contact us and supervisory authorities in the event you have a complaint.

Who we are

Activum SG Capital Management Limited (“Activum”, “we”, “our” or “us”) collects, uses and is responsible for certain Personal Data about you that we collect, or you provide us with, through your use of this Website and/or Portal. We do so in accordance with our obligations as a “controller” of that Personal Data under applicable data protection laws in Jersey, the United Kingdom and the European Union.

What Personal Data we collect

When you visit our Website or access our Portal, we may collect and use your Personal Data. The Personal Data we process includes:

• Identifiers, User Registration Data and Account Information: name, email address, phone number, location, online social accounts, username, password, account identification;
• Marketing preferences: if you choose to receive our marketing communication, we will ask for, and store, your preferences; and
• Internet or Other Similar Network Activity: we use tracking technologies to collect certain online identifiers and other technical information from your computer or mobile device when you use the Website and/or Portal, such as your Internet Protocol address, your web browser type and version, the name and version of your operating system, the pages you view on the Website and/or Portal, the pages you view immediately before and after you access the Website and/or Portal, and the search terms you enter on the Website and/or Portal. Please see “Cookies and Similar Technologies” below for more information.

How we use your Personal Data

We collect and process the Personal Data described above for the following reasons:

• to provide you with our Website and Portal services;
• to respond to any queries, questions or comments you may send to, or ask of, us via the Website, Portal, or by email, telephone or in writing;
• to gain a better understanding of how our Website and Portal are used. This understanding informs any improvements we undertake and ensures that the Website, Portal and their content continue to best serve the needs of our visitors.

We rely on the following lawful grounds to process your Personal Data:

• your consent, for example when we want to send you marketing communications;
• the performance of a contract we are party to with you or when taking steps to enter into a contract with you, for example when you contact us about our services; and
• our legitimate interests or those of a third party, namely when we process your Personal Data to improve and secure our Website, Portal, and the information provided to us, and, in certain circumstances, to provide you with marketing communications.

Legitimate Interests/Consent: Please note, to the extent we rely on our legitimate interests as a lawful ground for processing of your Personal Data, we have considered the balance between our own interests (among other things, the lawful and efficient operation of our Website and Portal, and quality and enhancement of our services, products and relationships with you) and your interests and we believe that (a) you would reasonably expect us to carry out the kind of processing outlined in this Privacy Policy and (b) such processing will not cause you any harm and/or will not seriously impact your rights and freedoms with regard to data privacy.

Depending on where you reside, consent may be the only lawful basis for our processing of your Personal Data. Where our legal basis to process your Personal Data is based upon your consent, you have the right to withdraw consent for such processing at any time by contacting us.
Cookies and Similar Technologies As stated above, we may collect Personal Data of you in the form of online identifiers. We do this through the use of cookies and other similar technologies. A cookie is a small text file which is placed onto your computer or electronic device when you access our Website and/or Portal. Similar technologies include web beacons, action tags, local shared objects (“flash cookies”) and single-pixel gifs. Such technologies can be used to track users’ actions and activities and to store information about them.

For more information on the cookies and other tracking technologies we use, please refer to our Cookies Policy.

Who your Personal Data may be shared with

We may share your Personal Data for the following reasons:

• we may share your Personal Data with law enforcement agencies, officials, regulatory agencies or other bodies which we are legally required to share the information in connection with any investigation to help prevent unlawful activity, or to protect and/or defend our rights or property or those of any third party;
• we may share your Personal Data with certain service providers or group companies to analyze the Website, Portal and/or our services so we can improve and provide the best Website, Portal, and services to you and others; and/or
• we may share your Personal Data if we undergo a merger, acquisition or other form or reorganization and pursuant to such, a third party will become the controller of your Personal Data.

We will not generally share your Personal Data with any other third parties.

How long will your Personal Data be kept

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal requirements. To determine the appropriate retention period for information, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Keeping your Personal Data safe

We have appropriate security measures in place to prevent Personal Data from being accidentally lost or used or accessed in an unauthorized way. We limit access to your Personal Data to those who have a genuine need to know it. Those processing your Personal Data will do so only in an authorized manner and are subject to a duty of confidentiality.

We will also use appropriate technological and organization measures to keep your Personal Data secure. We implement and maintain physical, electronic, and procedural safeguards and security measures that are reasonably designed to protect your Personal Data from unauthorized access, modification, or disclosure.

We also have procedures in place to deal with any suspected incident. We will notify you and any applicable regulator of a suspected data breach and/or security breach where we are legally required to do so.

While we will use all reasonable efforts to secure your Personal Data, in using the Website and/or Portal you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any Personal Data that is transferred from you or to you via the internet. If you have any particular concerns about your Personal Data, please contact us using the details below.

Transfers of Your Personal Data

Your Personal Data may be processed in countries outside your jurisdiction. This means that your information may be transferred to countries where you may have fewer legal rights in respect of your Personal Data than you do under local law. In such cases, we take appropriate steps (as required by applicable law) to ensure that your privacy rights are adequately protected.

Your rights and your Personal Data

Subject to any applicable exemptions under applicable data protection laws, you have the following rights with respect to your Personal Data:

• Right to Access: The right to request a copy of your Personal Data which we hold about you.
• Right to Correct: The right to request that we correct any Personal Data we have collected about you if it is found to be inaccurate or out of date.
• Right to Delete/Be Forgotten: The right to request your Personal Data is erased where it is no longer necessary for us to retain such Personal Data, subject to certain legal exceptions.
• Right to Withdraw Consent: If we rely on your consent to process your Personal Data, the right to withdraw your consent to the processing at any time.
• Right to Data Portability: The right to request that we provide you with your Personal Data in a structured, commonly used, and machine-readable format and where possible, to transmit that Personal Data directly to another data controller.
• Right to Restrict Processing: The right, where there is a dispute in relation to the accuracy or processing of your Personal Data, to request a restriction is placed on further processing.
• Right to Object: The right to object to the processing of Personal Data for direct marketing/profiling or where we are processing your Personal Data for our legitimate interests.
• Right to Contact Supervisory Authority: The right to lodge a complaint with a relevant supervisory authority. In Jersey, this is the Jersey Data Protection Authority. In the UK, the relevant authority is the Information Commissioner’s Office or ICO and in the European Union it will be your national data protection authority.

If you would like to exercise any of these rights, please:

• Email or write to us using the contact details provided;
• Provide us with proof of your identity (a copy of your driving licence or passport). We retain the right to request additional information in this regard if we are unable to confirm your identity; and
• Let us know the information to which your request relates.

From time to time, we may also have other methods to unsubscribe (opt-out) from any direct marketing, including for example, unsubscribe buttons or web links. If such are offered, please note that there may be a period after selecting to unsubscribe in which marketing may still be received while your request is being processed.

Third party websites

Our Website and/or Portal may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share Personal Data about you. We do not control these third-party websites, plug-ins and/or applications and are not responsible for their privacy statements, and we encourage you to read the privacy policy of any such third-party website or application you visit or use.

Children’s Personal Data

Our Website, Portal and services are not intended for children, and we do not knowingly collect Personal Data relating to anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us and we will take appropriate steps to remove such information from our servers.

Do Not Track Signals

Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. We follow the DNT signals we receive from your browsers.

Changes to the Privacy Policy

This Privacy Policy was last updated on the date stated above.

We may change this Privacy Policy from time to time. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised privacy policy by your continued use of the Website and/or Portal after the date such revised privacy policy is posted.

Contact us

If you have any questions about this policy, or wish to exercise any of your rights, please write or email us using the contact information on the Website. You may also contact the Jersey Data Protection Authority (via (https://jerseyoic.org/) or, if you live in the United Kingdom or the European Union, the supervisory authority where you live to raise any privacy concerns or exercise your rights.

Last Updated: March 2026

The California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”) imposes certain obligations on Activum (collectively, “Activum”, “we”, “our” or “us”) as a “business” and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “Personal Information”, as defined under the CCPA.

This California Privacy Notice (“California Privacy Notice”) supplements our Privacy Policy and applies to those visitors or users of our Website and/or Portal and others who are residents of California, as required under the CCPA. This California Privacy Notice expands upon the key information about how we collect and use Personal Information that we provided in our California Privacy Notice at Collection. Terms used in this California Privacy Notice have the meaning ascribed to them in the CCPA.

For additional information, including details regarding your privacy rights, please see our Privacy Policy and/or our California Privacy Notice at Collection.

Notice of Collection and Use of Personal Information. Depending on how you interact with us, we may collect or use information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“Personal Information”). The chart below describes the Personal Information we collect, our business or commercial purposes for collecting, using and disclosing it.
In the last twelve (12) months, we have collected the following categories of Personal Information from the sources identified below for the business and commercial purposes indicated, and disclosed such categories of Personal Information with the specified categories of third parties:

Retention of Personal Information. We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal requirements. To determine the appropriate retention period for 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 whether we can achieve those purposes through other means, and the applicable legal requirements.

Our Disclosure of Personal Data. We do not sell your Personal Information for monetary consideration or as that term is traditionally defined. However, certain of our marketing or advertising activities or analytics tools used could be considered a “sale” or “sharing” of Personal Information under the CCPA. You have the right to opt out of these types of disclosures of your Personal Information. We do not knowingly sell or share the Personal Information of California Residents under 18 years old.

In the preceding twelve (12) months, we have sold or shared the following categories of Personal Information (as described in more detail above) to the following categories of third parties:

In addition, we may disclose and in the preceding 12 months, may have disclosed all of the categories of Personal Information identified above in the section, “Information We Collect,” to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law. We may disclose Personal Information to all of the third parties listed above to comply with our legal obligations or for the business or commercial purposes identified above in “Purposes for Collecting and Using Personal Data.”

Use and Disclosure of Sensitive Personal Data. The CCPA requires that we provide you with a right to limit our use or disclosure of such Sensitive Personal Information in certain circumstances. Currently, we are not collecting information that would be considered “Sensitive Personal Information” under the CCPA.

Rights of California Consumers. Under the CCPA, you have certain rights with respect to your Personal Information, including the:

a) Right to Notice. You have the right to be notified which categories of Personal Information are being collected and the purposes for which the Personal Information is being used, as outlined in our California Privacy Notice at Collection and this California Privacy Notice.

b) Right to Know and Access Personal Information. You have the right to request that we disclose certain information about our collection and use of your Personal Information over the past twelve (12) months. We may ask that you provide certain information to identify yourself so that we may compare it with our records in order to verify your request. You may request the following:

• The categories of Personal Information we have collected about you.
• The categories of sources for the Personal Information we have collected about you.
• The specific pieces of Personal Information we have collected about you.
• Our business or commercial purpose for collecting and/or selling your Personal Information.
• The categories of third parties to whom we have sold or shared your Personal Information, if any, and the categories of Personal Information that we have shared with each third-party recipient.

c) Right to Opt-Out of the Sale or Sharing of Personal Information. You have the right to opt-out of the sale of your Personal Information and/or the sharing of your Personal Information with third parties for the purposes of cross-context behavioral advertising or profiling by submitting a request to us. Please note, we do not sell Personal Information, including the Personal Information of any individuals under the age of 16.

d) Right to Limit Use of Sensitive Personal Information. You have the right to request that we limit our use of any Sensitive Personal Information, as defined under the CCPA, to those uses which are necessary to provide our services and/or products or for other business purposes as identified in the CCPA. Please note that we do not currently collect Sensitive Personal Information.

e) Right to Delete. You have the right to request that we delete any Personal Information that we collect and retain from and/or about you, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) the relevant Personal Information from our records, unless an exception under the law applies.

f) Right to Correct. You have the right to request that we correct any inaccurate Personal Information we maintain about you, taking into account the nature of the Personal Information and the purposes for which we are processing such Personal Information. We will use commercially reasonable efforts to correct such inaccurate Personal Information.

g) Right to No Discrimination. You will not receive any discriminatory treatment from us for the exercise of your privacy rights conferred by the CCPA.

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information like Personal Information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations. We also reserve the right to retain, and not to delete, certain Personal Information after receipt of a “Request to Delete” from you where permitted by the CCPA or another law or regulation.

Opt-Out of Sale or Sharing. As noted above, you have the right to opt-out of certain advertising and marketing activities including online tracking and email marketing that could be considered a sale or sharing of your Personal Information. You can exercise your right to opt-out of the sale or sharing of Personal Information by clicking the “Your Privacy Choices” link on the footer of our Websites or through an opt-out preference signal, such as a “Global Privacy Control”. If you choose to exercise this right through an opt-out preference signal and we detect such a signal, it will be honored. If you submit a request to opt-out, including through an opt-out preference signal, after you have agreed to our sale or sharing of Personal Information, we will opt you out of any further sale or sharing of Personal Information.

Shine the Light. We only share Personal Information (as defined) with third parties for direct marketing purposes if you either specifically opt-in, or are offered the opportunity to opt-out and elect not to opt-out of such sharing at the time you provide Personal Information or when you choose to participate in a feature on the Websites or the Portal. If you do not opt-in or if you opt-out at that time, we will not share your Personal Information with that identified third party for direct marketing purposes.

How to Submit a Request. You or your authorized agent may submit Request to Know, Request to Correct or a Request to Delete (“Consumer Rights Request”), as described above, by contacting us:

• via phone: +44 (0) 1534 825200
• Email: [email protected]

Verifying Requests: We are only required to respond to verifiable Consumer Rights Requests made by you or your legally authorized agent. When you submit a Consumer Rights Request, we may ask that you provide clarifying or identifying information to verify your request, which may include depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only.

Authorized Agents: You are permitted to designate an authorized agent to submit a Consumer Rights Request on your behalf and have that authorized agent submit the request through the aforementioned methods. In order to be able to act, authorized agents have to submit proof that they are authorized to act on your behalf or have a power of attorney. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.

Changes to this California Privacy Policy. We may update this California Privacy Policy from time to time and to reflect changes in our Personal Information practices. We encourage you to review the most current California Privacy Policy provided to you.
Contact for More Information. If you have any questions or concerns about this California Privacy Policy, please contact us at:

• Post: Summit Fund Services Jersey Limited, Ordnance House, 31 Pier Road, St Helier, Jersey, JE4 8PZ, Channel Islands
• Email: at [email protected]

Last Updated: March 2026

This California Privacy Notice at Collection (“Notice at Collection”) supplements the ActivumSG (collectively, “ActivumSG”, “we”, “our” or “us”) Privacy Policy and applies to those visitors or users of our Websites and/or Portal and others who are residents of California, as required under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”). This Notice at Collection provides key information about how we collect and use personal information. Terms used in this Notice at Collection have the meaning ascribed to them in the CCPA.

For additional information, including details regarding your privacy rights, please see our Privacy Policy and/or our California Privacy Notice above.

Categories of Personal Information We Collect

Depending on how you interact with us, we may collect or use information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“Personal Information”). The below chart describes the Personal Information we collect, our purposes for collecting and using it, whether it is sold or shared.

Please note, we do not “sell” (as that term is defined under the CCPA) your Personal Information; however, we may share certain information with our service providers, advertising and marketing companies, our business parties, and other third-party vendors as directed by you. You have the right to opt-out of the sale or sharing of Personal Information for certain purposes. For more information or to exercise your rights please see the below section, Your Right to Opt-Out of Sale or Sharing.

Retention of Personal Information

We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal requirements. To determine the appropriate retention period for 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 whether we can achieve those purposes through other means, and the applicable legal requirements.

Your Right to Opt-Out of Sale or Sharing

We do not sell your Personal Information for monetary consideration or as that term is traditionally defined. However, we do engage in certain activities related to marketing, advertising and data analytics that could be a “sale” of Personal Information under the CCPA. You have the right to opt-out of the sharing of your Personal Information for cross-context behavioral advertising purposes. You can exercise your right to opt-out of the sale or sharing of Personal Information clicking the “Your Privacy Choices” link on the footer of our Website or through an opt-out preference signal, such as a “Global Privacy Control”. If you choose to exercise this right through an opt-out preference signal and we detect such a signal, it will be honored. If you submit a request to opt-out, including through an opt-out preference signal, after you have agreed to our sale or sharing of Personal Information, we will opt you out of any further sale or sharing of Personal Information.

For Additional Information

For additional information, including details regarding your privacy rights, please see our Privacy Policy and/or our California Privacy Notice. If you have any questions about this Notice at Collection, please contact us:

• Post: Summit Fund Services Jersey Limited, Ordnance House, 31 Pier Road, St Helier, Jersey, JE4 8PZ, Channel Islands.
• Email: [email protected]