LAUREL INSIGHTS PRIVACY NOTICE (EU/UK)

Last Updated: July 2026


At Laurel Insights LLC (“ Laurel Insights”) we provide qualitative research to our

clients (“ Services”). Your privacy is important to Laurel Insights and our affiliates

(together, ‘our’, ‘us’, ‘we’ or ‘company’). We are committed to protecting the privacy

of our website visitors, clients, research respondents and the subjects we research in

connection with the provision of our Services.

This privacy notice (“ Privacy Notice”) describes how we process your personal data

in connection with the provision of our Services, our

website: https://laurelinsights.com, and other data collection points where we refer to

this Privacy Notice.

For the purposes of applicable data protection laws in the United Kingdom (“ UK”)

and European Union (“ EU”), including Regulation (EU) 2016/679 (the “ EU GDPR”),

the UK equivalent of the EU GDPR (the “ UK GDPR”) and the Data Protection Act

2018, (together, “ EU and UK Data Protection Laws”) Laurel Insights will be a

controller in respect to the data processing covered by this Privacy Notice. If you

have any questions regarding our use of your personal data, or this Privacy Notice,

please contact Laurel Insights LLC 111 Town Square Place Suite 1201, PMB 1274

Jersey City, NJ 07310 or use the details in the Contact Us section of this Privacy

Notice.

Please take a moment to read and understand this Privacy Notice. You do not need

to take any action as a result of this Privacy Notice, but you do have certain rights as

described below in the section headed “ Your rights”.

THE TYPES OF PERSONAL DATA WE PROCESS

In providing our website and Services, we may collect and process different types of

personal data about you for different processing purposes. The types of personal

data we collect depends on who you are, how you use our website and Services,

and your relationship to us and may include the following:

Identity Data: first name; last name.

Contact Data: email addresses; telephone numbers.

Professional Data: employer, country/region, job title, education and/or professional

history.

Research Data: Your responses to any interviews, surveys or questionnaires you

have participated in, references, opinions or feedback provided by you or that we

collect from participants about you concerning you and your role at a specific

company.

Publicly Available Media Data: information about articles (or similar) that you may

have published or other publicly available social media related information such as

information published on your LinkedIn account or similar if you have one, or media

(including articles and podcasts) that are about you or you participated in.

Public Records Data: occasionally, where requested by our clients regarding

founders or key executives to help inform investment decisions, we may also collect

information about you from public records such as information about your assets,

family connections or litigation or regulatory action you have been a party to.

In the EU and UK certain personal data is more sensitive and considered as special

category data. In our research this may include details about your religious or

philosophical beliefs, sex life, sexual orientation, political opinions, trade union

membership, and information about your health. We do not generally seek to collect

this information about you except in a small number of cases, where it is relevant to

a specific research project. In these cases, we rely only on information already in the

public domain, collect no more than is necessary for the project and apply

safeguards. Because our work involves interviews, there is also a possibility that

such information could be revealed to us unintentionally.

We do not process criminal offence or conviction data of those in the EU or UK.


HOW WE COLLECT AND RECEIVE PERSONAL DATA

We collect your personal data in the following ways, and we only collect the personal

data necessary to carry out our business for the purposes set out in the section

below headed “Why we use your personal data”:

Information you provide to us

We collect your personal data when you decide to interact with us. You may give us

your personal data directly, for example, when you agree to take part in our

research, or when you provide your Contact Data as part of an interview or survey,

contact us with enquiries, complete forms on our website, or provide feedback to us.

Information provided by third parties or publicly available sources

We may receive personal data about you from third parties. Such third parties may

include our clients, research respondents, market research sample and list suppliers,

analytics providers, data brokers and third party directories.

From time to time, we may collect personal data about you (Identity Data, Contact

Data, and to a more limited extent Public Records Data) that is contained in publicly

available sources (including open-source data sets or media reports) or that you or a

third party may otherwise make publicly available (for example through publishing

articles or other news stories or posts on social media platforms).

WHY WE USE YOUR PERSONAL DATA

We may use your personal data for the following purposes:

Purpose: Fulfilment of our Services and to conduct our business (for example,

carrying out interview-based qualitative research, surveys and/or questionnaires).

We collect, use and store the Identity and Contact Data of our clients; Identity,

Contact Data, Professional Data and Research data of those who participate in our

research, Identity, Contact, Professional, Publicly Available Media, Research and

Public Records Data of individuals we are instructed to research.

Legal Basis (EU & UK only): Contractual necessity (for client personal data only);

and/or our legitimate interest in operating our business and providing the services

requested by clients.

Purpose: To communicate with you, to schedule and facilitate online interviews and

to administer your participation in any of our events we collect, use and store your

Identity and Contact Data (for clients and research participants).

Legal Basis (EU & UK only): Our legitimate interest in operating our business

including conducting research via interviews and hosting events to promote our

business.

Purpose: To keep a record of your relationship with us we collect and store your

Identity and Contact Data.

Legal Basis (EU & UK only): Our legitimate interest in operating our business and

managing our relationships with our clients; and/or legal requirement

Purpose: Litigation management and conducting internal audits and investigations

(as needed to respond to regulatory or other compulsory document requests). For

this we collect, use and store Identity, Contact, Research, Professional, Publicly

Available Media, Research and Public Records Data.

Legal Basis (EU & UK only): Legal requirement; and/or our legitimate interest in

ensuring compliance with our policies and protecting our business interests.

Purpose: To obtain advice from our professional advisors, including lawyers and

accountants we may collect, use and store your Identity, Contact, Research,

Professional, Publicly Available Media, Research and Public Records Data.

Legal Basis (EU & UK only): Our legitimate interest in operating our business and

protecting our business interests.

Purpose: To make suggestions and recommendations to you, or to provide you with

updates or other information, about our business and services that may be of interest

to you (to communicate with you or to provide other updates and communications

regarding our business activities) we collect, use and store your Identity and Contact

data.

Legal Basis (EU & UK only): Consent; or our legitimate interest in marketing our

business to you and keeping you informed of updates to our business.

Note that we may process your personal data on more than one legal basis

depending on the specific purpose for which we are using your personal data. We

have set out where this applies above.

No solely automated decision making, including profiling, is used when processing

your personal data.

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 we need to use your personal data for an

unrelated purpose, we will notify you and explain the legal basis which allows us to

do so, if needed we will obtain your consent for this new purpose.

There are instances where we have a legitimate interest to use your personal data.

Our legitimate interest will vary depending on what we are using your data for, and

we explain above what the interest is and how it relates to the processing operations

that we are carrying out. Where we process personal data on the basis of a

legitimate interest, then – as required by data protection law – we have carried out a

balancing test to document our interests, to consider what the impact of the

processing will be on individuals and to determine whether individuals’ interests

outweigh our interests in the processing taking place. You can obtain more

information about this balancing test by using the contact details at the end of this

Privacy Notice.

IF YOU FAIL TO PROVIDE YOUR PERSONAL DATA

If we require your personal information due to a legal requirement or obligation or in

order to perform a contract with you, we will make you aware of this at the time we

collect your personal data, and the possible consequences of you failing to provide

this personal data. Failure to provide this information means that we cannot conduct

business with you. In this case, we may have to cancel an existing business

arrangement with you but we will notify you if this is the case at the time.

DISCLOSURE AND TRANSFER OF PERSONAL INFORMATION

We take the security of your personal data seriously and do our best to protect your

personal data, however we cannot guarantee the security of any information or data

transmitted to or through our website; any transmission of information or data by you

to or through this website is at your sole risk.

We only share personal data with others when we are legally permitted to do so.

When we share personal data with others, we put contractual arrangements and

security mechanisms in place to protect the personal data shared and to comply with

our data protection, confidentiality and security standards and obligations. When

processing your personal data, we may need to share it with third parties, as set out

below. This list is non-exhaustive and there may be circumstances where we need to

share personal data with other third parties.

Our clients, who we may share personal data with for the purposes of providing

them with our Services, and who may use your personal data to evaluate

prospective investments.

Our service providers that provide a wide range of services including our legal and

financial professional advisors, our auditors, consultants, IT and data security

providers, data hosting providers and on specific occasions independent

researchers; and

Other third parties. We reserve the right to disclose your personal data as required

by law, or when we believe that disclosure is necessary to protect our rights and/or

comply with a judicial proceeding, court order, request from a regulator, national

security, for the purposes of public importance or any other legal or investigatory

process involving us. Should we, or any of our affiliated entities, be the subject of a

takeover, divestment or acquisition we may disclose your personal data to the new

owner of the relevant business and their advisors.

We make sure anyone who provides a service to, or for us, enters into an agreement

with us and meets our standards for data security.

As a US headquartered company we process your personal data in the US. We may

also transfer your personal data to countries outside of the UK, EU or the European

Economic Area (“ EEA”) to fulfil the purposes described in the Privacy Notice and in

accordance with applicable laws. Such transfers will only be made in accordance

with applicable laws and we will implement an appropriate transfer mechanism such

as standard contractual clauses (if you are in the UK or EEA) where the transfer is to

a country which is not considered to provide an adequate level of data protection.

For further information about the safeguards used, please contact

privacy@laurelinsights.com.

SECURITY AND RETENTION OF PERSONAL DATA

We are committed to protecting the personal data you entrust to us. We adopt robust

and appropriate data security technologies, measures and policies, so the

information we have about you is protected to the extent possible from unauthorized

access and disclosure, improper use and accidental loss. 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 and required to keep your

personal data secure.

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.

We will keep your personal data only for as long as is reasonably necessary for the

purposes set out in this Privacy Notice, unless a longer retention period is required

by law. Generally, client personal data is kept for the duration of our business

relationship and for six years after. Personal data of participants and the subjects of

our research is kept for five years from completing our research and providing this to

the client that commissioned it.

We will not keep more personal data than we need for the purposes set out in this

Privacy Notice. For further information about how long we will keep your personal

data, please contact privacy@laurelinsights.com.

CAPACITY

This website is only intended for individuals who are at least 13 years of age. We do

not knowingly encourage or solicit visitors to this website who are under the age of

13 or knowingly collect personal data from anyone under the age of 13 without

parental consent. If we learn we have collected or received personal data from an

individual under the age of 13, we will delete that information.

YOUR RIGHTS

Depending on where you reside, as a data subject you may have the following rights

in respect of the personal data we hold on you. You have the right to access the

personal data we hold about you, and there are a number of ways you can control

the way in which and what personal data we store and process about you. To

exercise these rights and controls, please contact privacy@laurelinsights.com.

Access: You have the right to ask for a copy of the personal data that we hold and

process about you free of charge, however we may charge a ‘reasonable fee’, if we

think that your request is excessive, to help us cover the costs of locating the

information you have requested.

Correction: You may notify us of changes to your personal data if the information we

hold and process about you is inaccurate, incomplete or it needs to be updated.

Deletion: If you think that we shouldn’t be holding or processing your personal data

any more, you may request that we delete it in certain circumstances.

Restrictions: You may request that we stop processing your personal data (other

than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii)

you believe the processing is against the law; (iii) you believe that we no longer need

your personal data for the purposes for which it was collected, but you still need your

personal data to establish or defend a legal claim; or (iv) you object to the

processing, and we are verifying whether our legitimate grounds to process your

personal data, override your own rights.

Object: You have the right to object to us processing your personal data on the basis

of our legitimate interests (or those of a third party), including processing for direct

marketing purposes or profiling for purposes of direct marketing, or where we are

performing a task in the public interest - your objection will be upheld, and we will

cease processing your personal data, unless the processing is based on compelling

legitimate grounds or is needed for the exercise or defence of legal claims that may

be brought by or against us.

Portability: If you wish to transfer the personal data that you provided to us to

another organisation (and certain conditions are satisfied), you may ask us to do so,

and we will send it directly if we have the technical means or provide you with a copy

to send yourself.

These rights may be limited, for example if fulfilling your request would reveal

personal data about another person, or if you ask us to delete information which we

are required by law or have compelling legitimate interests to keep.

If you wish to exercise any of these rights, please contact us at the contact details

set out below.

Withdrawal of consent: If you previously gave us your consent (by a clear affirmative

action) to allow us to process your personal data for a particular purpose but you no

longer wish to consent to us doing so, you can contact us to let us know that you

withdraw that consent at any time without affecting the lawfulness of the processing

based on consent before its withdrawal. We may however have other legal grounds

for processing your personal data for other purposes, such as those set out above.

We may need to request specific information from you to help us confirm your

identity and ensure your right to access your personal data (or to exercise any of

your other rights). This is a security measure to ensure that personal data is not

disclosed to any person who has no right to receive it. We may also contact you to

ask you for further information to clarify your request.

From time to time we may contact you directly to ask whether you would be willing to

take part in an interview for a specific research project. Where we do so, we rely on

our legitimate interests as explained above. You have the right to ask us to stop

contacting you at any time, by replying to the relevant message or by contacting us

using the details set out below.

If you have unresolved concerns, you have the right to make a complaint to us

and to the data protection authority in the country that you reside in or, the country of

your place of work or the country where the alleged infringement took place. In the

UK, this will be the Information Commissioner. For information on how exercise your

right to do this please see the contact details below.

If you are a US resident, please see the section below regarding our processing

under US state privacy laws.

US PRIVACY & DATA PROTECTION LAWS

If you are a resident of the United States, please also refer to our US Privacy Notice

at https://laurelinsights.com/privacy-us for information about how we collect, use and

disclose your personal information.

NOTIFICATION OF CHANGES

We reserve the right to amend this Privacy Notice from time to time by updating this

Privacy Notice. If we decide to change our Privacy Notice, we will post those

changes so our users are always aware of what information we collect, how we use

it, and under what circumstances, if any, we disclose it. If at any point we decide to

collect personal data or use any collected personal data in a manner different from

that stated at the time it was collected, we will notify applicable users. We will use

information only in accordance with the Privacy Notice under which the personal

information was collected.

CONTACT US

If you have any questions or concerns about this Privacy Notice, please contact

privacy@laurelinsights.com.

Our EEA/UK Representative

If you are located in the EEA or the United Kingdom and have questions about

your personal data or would like to request to access, update, or delete it, you

may contact our representative at:

Bird & Bird GDPR Representative Services SRL

Avenue Louise 235

1050 Bruxelles

Belgium

EUrepresentative.laurelinsights@twobirds.com

AND

Bird & Bird GDPR Representative Services UK

12 New Fetter Lane

London

EC4A 1JP

United Kingdom

UKrepresentative.laurelinsights@twobirds.com