This version of our Privacy Policy was in force from 11 September 2026 until 13 October 2026. The current version is at https://quantumlightcapital.com/privacy-policy.

Controller: Quantum Light Management Ltd (company no. 13878761).

Version 1.0 — 11 September 2026.

1. IMPORTANT INFORMATION AND WHO WE ARE

This privacy policy sets out how Quantum Light uses and protects your personal data when you visit quantumlightcapital.com or use the Quantum Light Founder Portal. It is provided in a layered format so you can click through to the specific areas set out below. If you are an investor in one of our funds, our Investor Privacy Notice at https://quantumlightcapital.com/investor-privacy-notice applies to your investment; this policy applies to your use of our website and the Portal.

• Important information and who we are.
• The types of personal data we collect about you.
• How your personal data is collected.
• How we use your personal data.
• Disclosures of your personal data.
• International transfers.
• Data security.
• Data retention.
• Your legal rights.
• Contact details.
• Complaints.
• Changes to the privacy policy and your duty to inform us of changes.
• Third-party links.

This privacy policy gives you information about how Quantum Light collects and uses your personal data through your use of this website and the Founder Portal, including any data you provide when you register for the Portal, sign in to it, search it, read or rate material on it, or contact us.

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

Controller

Quantum Light Management Ltd, a company incorporated in England and Wales with company number 13878761 whose registered office is at 5th Floor, North Side 7/10 Chandos Street, Cavendish Square, London W1G 9DQ, is the controller and responsible for your personal data ("Quantum Light", "we", "us" or "our" in this privacy policy). We are registered with the Information Commissioner's Office under registration reference ZB332737.

You can contact our data protection officer, Kate Chan, at dpo@quantumlightcapital.com, about anything in this policy, including to exercise your rights (paragraph 9). Our contact details are in paragraph 10.

Our representative in the European Union

Because we offer the Founder Portal to individuals in the European Union and record how they use it, we have appointed a representative in the Union under Article 27 of the EU GDPR. Data Protection Representative Limited (trading as DataRep) has been appointed as our Data Protection Representative for the purposes of The General Data Protection Regulation (GDPR) in the EU/EEA and the Federal Act on Data Protection (FADP) in Switzerland. DataRep is registered in the Republic of Ireland with registered number 616588 and their registered address is 77 Camden Street Lower, Dublin, D02 XE80, Ireland. If you are in the EEA you may contact our representative on any matter relating to our processing of your personal data.

2. THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU

"Personal data" means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• "Identity Data": includes your first name, last name, the company you are associated with, and your Founder Portal username.
• "Contact Data": includes your work email address and, if you choose to receive sign-in codes by SMS, your mobile telephone number.
• "Credential Data": includes your password (which we store only as a salted hash), your passkey public key if you use one, and the one-time codes used to verify a sign-in.
• "Profile Data": includes your Founder Portal account profile, namely your username, the interface preferences you set, and your marketing and communication preferences.
• "Reading Data": includes which playbooks and other materials you open in the Founder Portal, when you open them, how long each page is open, whether you mark an item helpful, and the terms you type into the Portal search box.
• "Technical Data": includes your internet protocol (IP) address, your sign-in times, browser type and version, time zone setting, operating system and platform, and the entries recorded in our web server access log.
• "Preference Data": includes the interface choices you make in the Founder Portal, such as dark mode or a collapsed sidebar, and whether you have asked to stay signed in.
• "Usage Data": includes information about how you interact with our public website, collected through Google Analytics as described in paragraph 3 and in our Cookie Policy.
• "Marketing and Communications Data": includes your preferences in receiving communications from us, where you have asked to receive them. We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

We do not collect any special category data about you, and we do not knowingly collect any data about children. The Founder Portal is available only to adults acting in a business capacity.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you, including through:

Direct interactions

You may give us your Identity Data, Contact Data and Credential Data by filling in forms or by corresponding with us by post, telephone, email or otherwise. This includes the personal data you provide when you:

register for, or are given access to, the Founder Portal; sign in to, search, read or rate material in the Founder Portal; download or request one of our playbooks; ask us to send you updates; apply for a role with us; or give us feedback or contact us.

Automated technologies or interactions

As you interact with our public website, we collect Technical and Usage Data about your equipment and browsing, using cookies and similar technologies and our server logs. On the public website this is done through Google Analytics 4 (measurement ID G-H0MWQX733J) and Google Tag Manager (container GTM-5FHKTPCX), which we deploy only where you have consented. Inside the Founder Portal we use no third-party analytics or advertising technology and nothing is stored on your device to measure your reading.

Third parties

We receive Technical and Usage Data from our analytics provider, Google LLC, which is based outside the UK.

Your company or our investment team

Where your name, email address or company is provided to us so that we can create your Founder Portal account, rather than by you, we obtain it from your company or from our own investment records.

4. HOW WE USE YOUR PERSONAL DATA

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of contract: We may use your personal data where it is necessary to perform our contract with you, namely the Founder Portal terms of service.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure experience of our website and the Founder Portal. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Direct marketing

You will receive marketing communications from us only if you have asked to receive them. We will not add you to a marketing list because you have a Founder Portal account.

Third-party marketing

We do not share your personal data with any third party for that third party's own marketing purposes.

Opting out of marketing

You can ask us to stop sending you marketing communications at any time by following the unsubscribe link in any communication we send you, from the Founder Portal settings page, or by emailing dpo@quantumlightcapital.com.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative purposes, for example sign-in codes, notices of changes to the Founder Portal terms of service or to this privacy policy, and messages checking that your contact details are correct.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Policy at https://quantumlightcapital.com/cookie-policy.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data where necessary with the parties set out below for the purposes set out in the table under "Purposes for which we will use your personal data" in paragraph 4 above.

• Our hosting and infrastructure provider, Amazon Web Services, which hosts the Founder Portal in the United Kingdom; the provider that delivers your one-time sign-in codes by email or SMS; Google LLC, in respect of analytics on our public website where you have consented; our documentation platform provider where playbook content is synchronised; and our auditors, insurers and professional advisers.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

The Founder Portal and its database are hosted in the United Kingdom. Two flows leave the UK, and both are described below.

• Analytics. Where you consent to analytics on our public website, Google Analytics sends your IP address and a randomly generated identifier to Google LLC in the United States.
• Sign-in codes. Where you receive a one-time sign-in code by email or SMS, it passes through a communications provider that may route it outside the United Kingdom. Whenever we transfer your personal data out of the UK to a country whose laws do not provide the same level of data protection as UK law, we ensure that a similar degree of protection is afforded to it by putting in place one of the safeguards described below.

Where personal data is transferred out of the UK we rely on the UK International Data Transfer Agreement, or the UK Addendum to the European Commission's standard contractual clauses, or (for transfers to the United States) the UK Extension to the EU-U.S. Data Privacy Framework where the recipient is certified. To obtain a copy of the safeguards we use, please contact us at dpo@quantumlightcapital.com.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

Passwords are stored only as salted hashes and are never accessible to us in readable form. Access to the Founder Portal database is limited to named individuals and is logged.

8. DATA RETENTION

How long will you use my personal data for? Founder Portal reading records are held in a form that identifies you for 90 days. After 90 days we keep only aggregated figures, which do not identify you. Your account details are held for as long as you have an account and for 12 months afterwards. Web server access logs are held for 30 days. Analytics data on our public website is retained by Google for the period set in our Google Analytics configuration, currently 14 months.

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, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised 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, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Object to our use of your Reading Data. Most of what we do with your Founder Portal reading records relies on our legitimate interests. You can object at any time, on grounds relating to your particular situation, by emailing dpo@quantumlightcapital.com or from the Portal settings page. Objecting is free, and it will not affect your access to the Portal or to any material on it.
• Object to our storing your interface preferences. Separately from the right above, you can object free of charge to our storing your interface preferences on your device, from the Portal settings page.
• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or that of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting out of marketing in paragraph 4 for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information in relation to which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in paragraph 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios: If you want us to establish the data's accuracy; Where our use of the data is unlawful but you do not want us to erase it; Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. If you wish to exercise any of the rights set out above, please contact us at dpo@quantumlightcapital.com.

No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to confirm your identity before we act on a request. For Founder Portal users we will normally do this by asking you to re-authenticate through your account rather than by asking for identity documents.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. CONTACT DETAILS

If you have any questions about this privacy policy or about the use of your personal data, or you want to exercise your rights, please contact us in the following ways:

• Email: dpo@quantumlightcapital.com
• Post: Data Protection, Quantum Light Management Ltd, 5th Floor, North Side 7/10 Chandos Street, Cavendish Square, London W1G 9DQ

11. COMPLAINTS

You have the right to make a complaint to the Information Commissioner's Office (ICO), the UK regulator for data protection (www.ico.org.uk). If you are in the EEA you may instead complain to the supervisory authority in your country, or to our EU representative. Before doing so, please make sure you have first made your complaint to us.

12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We will update this privacy policy when our processing changes, and will tell Founder Portal users by email if we make a material change. This version is dated 11 September 2026 (version 1.0).

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

13. THIRD-PARTY LINKS

This website 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 data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.