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Last updated: 4 April 2026

1. Introduction

This Investor Privacy Notice explains how The Lab Group Limited (“The Lab Group”, “we”, “our”, “us”) collects, uses, and protects personal information in connection with:

• investment opportunities introduced or managed by us;

• participation in Special Purpose Vehicles (“SPVs”); and

• investor onboarding, communications, and administration.

This notice supplements our general Privacy Policy.

2. Investment Structure (Important)

Investments are typically made into separate legal entities (SPVs) and not into The Lab Group itself.

The Lab Group may:

• originate, structure, or manage SPVs;

• act as sponsor, operator, or advisor to those SPVs;

• coordinate investor onboarding and communications.

Each SPV is a separate legal entity and may have its own governance, agreements, and obligations.

3. Our Role in Data Processing

Depending on the context, The Lab Group may act as:

3.1 Data Controller

Where we collect and use personal data for our own purposes, including:

• investor onboarding

• communications

• relationship management

• internal administration

3.2 Joint Controller

Where data is used jointly with an SPV for:

• investor records

• governance and reporting

• communications relating to investments

3.3 Data Processor

Where we process data strictly on behalf of an SPV.

3.4 SPV Role

The relevant SPV may act as a data controller in respect of investor data relating to that investment.

4. Information We Collect

4.1 Identity and Contact Information

• full name

• date of birth

• residential address

• email address

• phone number

4.2 Financial and Investment Information

• investment amounts and commitments

• bank account details (for capital calls and distributions)

• source of funds information

• investment preferences

4.3 Verification and Compliance Data

• identity verification documents (passport, ID)

• proof of address

• sanctions screening results

• politically exposed person (PEP) status

• anti-money laundering (AML) data

4.4 Corporate Information (if applicable)

• company name and registration details

• beneficial ownership information

• directors and authorised signatories

4.5 Communications

• correspondence with us

• investor updates and reports

• meeting notes and interactions

5. How We Use Your Information

We use personal data to:

• assess eligibility and suitability for investment opportunities

• facilitate subscriptions into SPVs

• maintain investor registers and records

• administer capital calls, distributions, and returns

• communicate performance updates and operational matters

• comply with legal and regulatory requirements

• prevent fraud and financial crime

• manage investor relationships

6. Legal Basis for Processing

We process personal data under:

6.1 Contractual Necessity

To enter into and perform agreements relating to SPVs and investments.

6.2 Legal Obligations

Including:

• anti-money laundering regulations

• tax and accounting requirements

• regulatory reporting obligations

6.3 Legitimate Interests

Including:

• managing investor relationships

• operating and growing our investment activities

• maintaining accurate records

• protecting our legal and commercial interests

6.4 Consent (where applicable)

For specific uses such as marketing communications.

7. Sharing of Information

We may share your personal information with:

7.1 SPVs

• entities into which you invest

• their directors, officers, and administrators

7.2 Professional Advisors

• legal advisors

• accountants and auditors

• tax advisors

7.3 Financial Institutions

• banks

• payment providers

• distribution agents

7.4 Compliance Providers

• identity verification services

• AML and sanctions screening providers

7.5 Regulators and Authorities

Where required by law or regulatory obligation.

7.6 Business Transfers

In the event of restructuring, sale, or transfer of assets.

8. International Transfers

Your personal data may be transferred outside the UK or EEA.

We ensure appropriate safeguards, including:

• standard contractual clauses

• equivalent legal protections

9. Data Retention

We retain investor data:

• for the duration of the investment relationship

• as required by applicable law (including AML obligations)

• for legal, accounting, and reporting purposes

Certain records may be retained for extended periods where required.

10. Security

We implement appropriate technical and organisational measures to protect personal data.

However, no system is completely secure.

11. Your Rights

You may have the right to:

• access your personal data

• correct inaccuracies

• request deletion (subject to legal obligations)

• restrict or object to processing

• request data portability

To exercise your rights, contact:

hello@thelabgroup.com

12. Mandatory Information

Certain personal information is required by law.

If you do not provide this information:

• we may be unable to onboard you as an investor

• we may be required to delay or refuse transactions

13. No Investment Advice

Nothing in this notice or any related communication constitutes:

• financial advice

• investment advice

• a recommendation to invest

You should seek independent professional advice before making investment decisions.

14. Changes to This Notice

We may update this notice from time to time.

Where appropriate, we will notify investors of material changes.

15. Contact Us

For any privacy-related questions:

hello@thelabgroup.com