Privacy Notice

This Privacy Notice explains how Aionos Kethera Valaris Avantgarde Financial Systems, Inc., a Delaware corporation ("Avantgarde," "we," "us" or "our"), collects, uses, discloses and protects personal data when you visit avantgardefs.com (the "Site") or contact us through it.

For the purposes of the EU General Data Protection Regulation (Regulation (EU) 2016/679) ("EU GDPR") and the UK GDPR together with the UK Data Protection Act 2018 (together, "GDPR"), Avantgarde is the controller of personal data collected through the Site.

Controller contact: Aionos Kethera Valaris Avantgarde Financial Systems, Inc., 244 Fifth Avenue, Suite 269V, New York, NY 10001, United States. Email: [privacy@avantgardefs.com — to be established; until then vp@avantgardefs.com].

EU/UK representative (GDPR Article 27): [To be designated if required. Contact counsel.]

We have not appointed a Data Protection Officer because we are not currently required to do so. Privacy questions may be sent to the contact above.

The Site is intended for institutional investors, family offices, deal sponsors, corporate counterparties and government or defense organizations acting in a professional capacity. It is not directed at consumers or at individuals acting for personal, family or household purposes, and it is not directed at children under 16 (or under 13 in the United States). We do not knowingly collect personal data from children. If you believe a child has provided personal data to us, please contact us and we will delete it.

3.1 Information you provide. When you submit an inquiry through the Site, we collect the information you enter, which may include:

• Investor access requests: name, firm, title, business email, telephone number (optional), investor type, indicative ticket range, areas of interest, your self-attestation of accredited investor / qualified purchaser / qualified institutional buyer status, and your consent selections.
• Opportunity submissions (deal sponsors): name, organization, business contact details, opportunity type, sector, jurisdiction, size range, timeline, and the summary you provide.
• Briefing requests (government / defense): name, agency or organization, role, business email, topic, preferred format, proposed dates and notes.
• Correspondence: any information you include when you email us.

Please do not submit sensitive personal data (for example, health information, government identifiers or financial account numbers), material non-public information, classified information, controlled technical data (including ITAR- or EAR-controlled data), or information you are not authorized to share. See the Terms of Use, "Submissions."

3.2 Information collected automatically. When you use the Site, our hosting and infrastructure providers automatically process technical data needed to deliver and secure the Site, such as IP address, browser and device type, operating system, referring URL, pages requested, and the date and time of access (server and security logs).

3.3 Information stored on your device. The Site uses your browser's local storage (not advertising cookies) to remember:

• your light/dark display preference;
• the audience perspective you select (investor, sponsor or government); and
• an in-progress draft of the multi-step opportunity submission form, so you do not lose your work.

This information stays on your device, is not sent to us until you choose to submit a form, and you can clear it at any time through your browser settings. We do not currently use advertising, cross-site tracking or third-party analytics cookies. If we introduce analytics or other non-essential technologies, we will update this Notice and, where required by law (including the EU ePrivacy Directive and UK PECR), ask for your consent first.

3.4 Information from other sources. We may receive business contact information about you from introducers, counterparties, publicly available sources or professional databases in connection with a prospective relationship.

Where we rely on legitimate interests, we have weighed those interests against your rights. You may ask us for details of that balancing test. We do not use personal data for automated decision-making that produces legal or similarly significant effects, and we do not sell personal data or use it for cross-context behavioral advertising.

We share personal data only as described below:

• Service providers (processors) who host, store, secure and operate the Site and our systems on our instructions, including our website hosting and development platform, our cloud database provider, content delivery and security providers, and email and productivity providers. They are bound by written contracts that require confidentiality and appropriate security.
• Professional advisers, such as legal counsel, auditors, compliance consultants and KYC/AML verification providers, under duties of confidentiality.
• Affiliates and joint-venture partners, only where needed to respond to your inquiry and subject to confidentiality obligations.
• Regulators, law enforcement, courts and government authorities, where required by law or to protect our rights, our users or others.
• A successor or acquirer, in connection with a merger, financing, acquisition, reorganization or sale of assets, subject to confidentiality.

We do not sell personal data, and we do not "share" it for cross-context behavioral advertising as those terms are defined under California law.

Avantgarde is based in the United States, and our service providers may process data in the United States and other countries. If you are in the European Economic Area, the United Kingdom or Switzerland, your personal data will be transferred to countries that may not provide the same level of data protection as your home country. Where required, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses (and the UK International Data Transfer Addendum), or recipients' certification under the EU-U.S. Data Privacy Framework and its UK and Swiss extensions where applicable. You may request a copy of the relevant safeguards by contacting us.

We keep personal data only as long as necessary for the purposes described above:

• Inquiries that do not lead to a relationship: generally up to 24 months after our last interaction, then deleted or anonymized.
• Records relating to investors, transactions and KYC/AML checks: for the periods required by applicable law and regulation (which may be five years or longer after the relationship ends).
• Security logs: generally up to 12 months.

We may keep data longer if needed to comply with law, resolve disputes or enforce agreements.

We use reasonable administrative, technical and physical safeguards designed to protect personal data, including encryption of data in transit (TLS/HTTPS), access controls that restrict inquiry records to authorized personnel, database row-level security, and spam and abuse protections. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Please do not send confidential deal documents through the Site; we will arrange a secure channel when appropriate.

Subject to conditions and exceptions in applicable law, you have the right to:

• access your personal data and receive a copy;
• rectify inaccurate or incomplete data;
• erase your data ("right to be forgotten");
• restrict processing;
• object to processing based on legitimate interests, and to object at any time to direct marketing;
• data portability; and
• withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing before withdrawal.

You also have the right to lodge a complaint with a supervisory authority, in particular in the EU member state where you live or work or where an alleged infringement occurred, or, in the UK, with the Information Commissioner's Office (ico.org.uk). We would appreciate the chance to address your concern first.

Depending on your state of residence, you may have rights under state privacy laws, which may include the California Consumer Privacy Act as amended by the CPRA, and comprehensive privacy laws in states such as Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Delaware, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky and Rhode Island. Many of these laws apply only to businesses that meet thresholds, or exempt business-to-business contact information. Where they apply, they may give you the right to:

• know or access the personal data we hold about you;
• correct it;
• delete it;
• obtain a portable copy;
• opt out of the sale of personal data, targeted advertising and certain profiling (we do not engage in these activities);
• limit the use of sensitive personal data (we do not seek to collect it); and
• not be discriminated against for exercising your rights.

You may also have the right to appeal our decision on a request by replying to our response.

California "Shine the Light": we do not disclose personal information to third parties for their own direct marketing purposes.

Global Privacy Control / Do Not Track: because we do not sell or share personal data or use targeting technologies, these signals do not change how the Site operates. Where required by law, we treat a Global Privacy Control signal as a valid opt-out request.

Nevada residents: we do not sell covered information as defined under Nevada law.

To make a request, email [privacy@avantgardefs.com / vp@avantgardefs.com] with the subject line "Privacy Request." We will verify your identity in proportion to the request and respond within the period required by applicable law (generally one month under GDPR and 45 days under most U.S. state laws, extendable where permitted). You may use an authorized agent where the law allows; we may ask for proof of authorization.

If you become an investor in a fund, vehicle or account sponsored or advised by Avantgarde or its affiliates, separate privacy notices may apply to that relationship, including notices required under the Gramm-Leach-Bliley Act and SEC Regulation S-P, or offering-document disclosures. Those notices govern that relationship.

The Site may link to third-party websites, such as partner websites. We are not responsible for their privacy practices. Please review their privacy notices.

We may update this Notice from time to time. We will post the updated version with a new "Last updated" date and, where required, notify you or seek your consent.

Aionos Kethera Valaris Avantgarde Financial Systems, Inc.

244 Fifth Avenue, Suite 269V, New York, NY 10001, United States

Email: [privacy@avantgardefs.com / vp@avantgardefs.com]