Website Privacy Policy

1. INTRODUCTION

1.1 Important Information and Who We Are

Welcome to dealOS's Privacy and Data Protection Policy ("Privacy Policy").

dealOS is a deal execution and advisory platform operated by ReachX Limited ("we", "us", or "our"). We are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation ("UK GDPR"), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. It will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

• Customers and registered users of dealOS
• Founders, companies and deal counterparties using the platform
• Advisors and Members
• Institutional investors accessing dealOS
• Suppliers and business contacts
• Employees and staff members

and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us in connection with the dealOS platform at dealos.info.

1.2 Who is Your Data Controller and Data Protection Officer

ReachX Limited is your Data Controller and responsible for your Personal Data.

We have appointed a Data Protection Officer ("DPO") who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights surrounding your Personal Data, please contact the DPO using the details set out below:

Full name: Rafael S. Lajeunesse
Email address: info@reachx.co
Postal address: Unit 2.02 High Weald House, Glovers End, East Sussex, Bexhill, TN39 5ES, United Kingdom
Website: dealos.info

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.3 Processing Data on Behalf of a Controller and Processors' Responsibility to You

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as "Processors"). The Data Controller and our Processors have the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the UK GDPR;
• Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
• Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
• Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
• Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
• Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the UK GDPR and allow for and contribute to audits, including inspections;
• Maintain a record of all categories of processing activities carried out on behalf of a Controller;
• Cooperate, on request, with the supervisory authority in the performance of its tasks;
• Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller;
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach;
• Designate a data protection officer where required by the UK GDPR, publish their details and communicate them to the supervisory authority; and
• Support the data protection officer in performing their tasks by providing resources necessary to carry out those tasks and access to Personal Data and processing operations.

2. LEGAL BASIS FOR DATA COLLECTION

2.1 Types of Data / Privacy Policy Scope

"Personal Data" means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

• Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
• Contact Data: This is data relating to your phone number, addresses, email addresses.
• Deal and Transaction Data: Information relating to deals, mandates, NDAs, milestones, and deal activity on the dealOS platform.
• Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
• Billing Data: This is information relating to your payment details such as the name attached to your payment details and your billing address.
• Professional Experience: Data relating to Advisors' work experience, credentials, and sector expertise.

We also collect, use and share Aggregated Data such as deal statistics and activity data. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the UK GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

• "Consent": Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or opt in to a service.
• "Contractual Obligations": We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
• "Legal Compliance": We're required by law to collect and process certain types of data, such as in connection with fraudulent activity or other illegal actions.
• "Legitimate Interest": We might need to collect certain information from you to be able to meet our legitimate interests — this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests.

3. HOW WE USE YOUR PERSONAL DATA

3.1 Our Uses

We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data.

3.2 Marketing and Content Updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about products, services, or deal opportunities that may be of interest to you.

3.3 Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Protection Officer.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

4. YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

4.1 What Control Do I Have Over dealOS's Use Of My Personal Data?

You may delete your account at any time – this will remove your account page from our systems and our related software. We guarantee this will delete all stored data.

You can access information associated with your account by logging into your account on dealos.info.

Your account information will be protected by a password for your privacy and security. You need to prevent unauthorised access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.

4.2 How Does dealOS Protect Customers' Personal Data?

We are committed to keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures including:

• Secure protocol (HTTPS only) across all dealOS services at dealos.info;
• Encrypted databases (AWS KMS);
• All security policies are defined as deny-all, with access limited to defined administrators;
• Personal Data collected by us is only accessible by a limited number of employees who have special access rights and are bound by obligations of confidentiality.

If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, no transmission of data over the internet is guaranteed to be completely secure. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

4.3 Opting Out Of Marketing Promotions

You can ask us to stop sending you marketing messages at any time by clicking the unsubscribe link in any marketing email or by contacting us directly. Where you opt out of receiving marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

4.4 How to Request Your Data and the Process for Obtaining It

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data. We may also contact you to ask for further information in relation to your request to speed up our response.

5. YOUR DATA AND THIRD PARTIES

5.1 Will We Share Your Data With Third Parties?

We may share Personal Data with interested parties in the event that ReachX Limited anticipates a change in control or the acquisition of all or part of our business or assets, or with interested parties in connection with the licensing of our technology.

If ReachX Limited is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy.

We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.

6. GOOGLE API SERVICES AND LIMITED USE

dealOS integrates with Google Workspace APIs (specifically the Gmail API) so that you can send investor outreach emails directly from your connected Google account. To do this we request OAuth permission via the https://www.googleapis.com/auth/gmail.send scope. We never request scopes that allow reading, modifying, or deleting your Gmail messages, contacts, or any other Google data.

dealOS's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

In line with the Limited Use requirements, we confirm that:

• We only use Google user data to provide or improve user-facing features that are prominent in the dealOS interface. In practice this means sending outreach emails you have explicitly composed and approved in the dealOS draft-email flow.
• We do not transfer Google user data to third parties except as necessary to provide or improve those user-facing features, to comply with applicable law, or as part of a merger, acquisition, or sale of assets with notice to you.
• We do not use Google user data for serving advertisements, including retargeting, personalised, or interest-based advertising.
• We do not allow humans to read Google user data unless we have your affirmative consent to view specific messages, it is necessary for security purposes such as investigating abuse, it is required to comply with applicable law, or the data have been aggregated and anonymised for internal operational reporting.

OAuth tokens issued to dealOS by Google are stored in our database under access controls and are limited to the minimum scope needed to send an email on your behalf. You can disconnect your Google account from dealOS at any time, which immediately revokes our access and removes your stored tokens. To revoke access directly from your Google account, visit https://myaccount.google.com/permissions.

7. HOW LONG WILL WE RETAIN YOUR DATA FOR?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

8. AGE LIMIT FOR OUR USERS

You must not use dealOS unless you are aged 18 or older. If you are under 18 and you access dealOS by lying about your age, you must immediately stop using dealOS.

This website is not intended for children and we do not knowingly collect data relating to children.

9. INTERNATIONAL TRANSFER OF DATA

Your information may be stored and processed in countries or jurisdictions outside the UK where ReachX Limited has facilities. We are currently storing data in the EU. By using dealOS, you are permitting and consenting to the transfer of information, including Personal Data, outside of the UK in accordance with applicable data transfer mechanisms.

10. NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY

We keep our Privacy Policy under review and will place any updates on this webpage at dealos.info. This version is dated 20 May 2026. By using dealOS, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of dealOS will constitute your express acceptance of any modifications to this Privacy Policy.

11. INTERPRETATION

All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored.

Our staff are not authorised to contract on behalf of ReachX Limited, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a ReachX Limited address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any ReachX Limited rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the ReachX Limited legal department.

12. TERMS OF USE

Please also see our Terms of Use which set out the terms, disclaimers, and limitations of liability governing your use of dealOS at dealos.info.