Lee Equity Partners Website Privacy Policy

Last Updated: December 10, 2025

This is the Website Privacy Policy (“Privacy Policy“) of Lee Equity Partners, LLC ("Lee Equity," "we," or "us"). An important part of our commitment to you is our respect for your privacy as a user of this website (the "Site"). If you are a California resident, please review our California Supplemental Privacy Policy (below).

This Privacy Policy seeks to help you understand whether and how we collect Personal Information from or about you when you visit the Site, and how we may use, share, and retain such information. The term “Personal Information” has the meaning given to it under applicable laws and regulations relating to data protection and privacy (including similar terms such as “personal data”) and, for the avoidance of doubt, refers to any information which directly or indirectly identifies or otherwise relates to a living individual.

Your visit to the Site is subject to this Privacy Policy, which is incorporated into our Terms of Use. By visiting the Site, you agree to this Privacy Policy, which may be updated by us at any time. You should review this Privacy Policy carefully and periodically. If you do not agree with it, you should not use the Site. By using the Site, you confirm that you understand and agree with the provisions of this Privacy Policy. Please note that if you do not provide certain Personal Information when requested, we may not be able to provide you with such associated service.

This Privacy Policy applies only to the Personal Information that we may collect through the Site and does not concern any third-party website to which the Site may link. If you are a Lee Equity investor, our policies and practices regarding the collection and processing of your Personal Information are detailed in our Lee Equity Investor Privacy Notice. If you are a Lee Equity employee, you will have separately received our Lee Equity Partners Employee Data Protection and Privacy Notice.

If you are based in the UK or EEA, Lee Equity is the data controller of your Personal Information.

1. The Information We Collect About You and How

We may collect the categories of Personal Information listed below about you in connection with your access and/or use of the Site.

Communications Data. When you contact us for any reason, such as to express an interest in obtaining additional information about our services, or to direct questions or concerns about our services to us we will process your Personal Information. For example, if you contact us using the contact details posted on the Site, you may provide your full name, email address, telephone number and any other Personal Information in order to allow us to contact you and to process your request.

2. How We Use Your Information

Depending on your interactions with the Site and us, and the permission you give us, your Personal Information may be collected, stored, disclosed, and processed by Lee Equity for the following purposes:

To operate, maintain, enhance, and provide all of the features of the Site;
To understand and analyze preferences of our users, to improve the Site, and to create new features and functionality;
For ongoing review and improvement of the information and content provided on the Site and to ensure it is user friendly;
For in-depth threat analysis, to prevent any potential disruptions such as cyber-attacks, and for statistical monitoring and analysis of current attacks on devices and systems for the on-going adaption of the solutions provided to secure systems and devices against current attacks;
To understand your needs and interests and respond to inquiries, and/or other requests or questions;
To detect, investigate, and prevent fraud and other crimes or malpractice, and to improve fraud detection and information security;
For the purpose of, or in connection with, any legal proceedings (including prospective legal proceedings), and to obtain legal advice or to establish, exercise, or defend legal rights;
To comply with and in order to assess compliance with applicable laws, rules and regulations, industry codes, voluntary codes we decide to adopt, or good practice and internal policies and procedures;
To confirm and verify your identity and to conduct due diligence, background and related checks;
For the management and administration of our business (including the storing of Personal Information);
To comply with our contractual obligations; and
For purposes otherwise set out in this Privacy Policy or any other notice provided to you at the time we collect your Personal Information.

3. Our Legal Basis For Processing Your Personal Information

Some jurisdictions require us to state the legal bases for processing your Personal Information. As applicable, Lee Equity is entitled to process your Personal Information under one or more of the following legal bases:

Lee Equity needs to do so in order to enter into and perform a contract with you (for example, in order to provide our services and verify the information you provide);
Lee Equity has legal or regulatory obligations that must be complied with;
Lee Equity may need to do so in order to establish, exercise, or defend its legal rights or for the purpose of legal proceedings; or
it is necessary for our legitimate interests or the legitimate interests of a third party, provided such interests are not overridden by your privacy and data protection rights, including (i) allowing Lee Equity to effectively and efficiently administer and manage the operation of its business and (ii) maintaining compliance with internal policies and procedures. If we use your Personal Information for this purpose, you are entitled to request information on the balancing of these interests using the contact information in Section 10.

4. When We Share Your Personal Information

Lee Equity may share your Personal Information with affiliates, to other people or non-affiliated companies (such as third parties), under the following circumstances:

For the purposes of management and administration of our business, in order to facilitate the provision and enhancement of services to you, and for the purpose of us receiving services (e.g. from our accountants, auditors, service providers, professional advisors, IT and communications providers or any entity we reasonably consider necessary for the purposes outlined in this Privacy Policy). These third parties will be expected to be subject to confidentiality requirements that require them to only use your Personal Information as described.

We work with third party service providers to provide Site development, hosting, data storage, and Site maintenance. To the extent it is necessary for these third-party service providers to complete their contractual obligations to us, these third parties may have access to or process information about you.

In some cases, in order to provide the Site and the services available in connection with the Site, we provide information about you to trusted partners who work on behalf of or with us.

We may share information about you in response to subpoenas, court orders, or legal process, or to establish or exercise our legal rights, or defend against legal claims.

We may share information about you in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by applicable law.

We may transfer or assign information about you if Lee Equity is acquired by or merged with another company, or in the unlikely event of a bankruptcy.

We may share information about you as part of a transaction, financing or for other business needs (e.g. if we sell any of our business or assets).

5. Your Rights

Depending on the jurisdiction in which you reside, you may have certain legal rights in relation to your Personal Information. Depending on the circumstances, these rights may include:

Refusing to share Personal Information with us (in which case, we may not be able to provide to you some of the features and functionality of the Site);
Objecting at any time to the processing of your Personal Information;

Confirming how we process your Personal Information and to obtain information regarding the processing of your Personal Information;

Where you provide your consent for certain processing activities, the right to withdraw your consent at any time. Please note that this will not affect the lawfulness of any collection, processing, use or disclosure undertaken before such withdrawal and that we may still be entitled to process the Personal Information if we have another legitimate reason (other than consent) or a consent exception for doing so;

Receiving a copy of the Personal Information that we have about you and/or request that we transmit that data to a third party (where this is technically feasible);

Requesting that Lee Equity correct your Personal Information if it is inaccurate or incomplete;

Requesting that we erase your Personal Information (but please note that there may be circumstances where we are legally entitled or required to retain Personal Information regardless of any such request);

Requesting that we restrict, anonymize or block our processing of your Personal Information; and

Where applicable, the right to lodge a complaint with the data protection regulator in your jurisdiction. If you are based in the UK this is the Information Commissioner’s Office and in the EEA this will depend on the country you are in.

You can inquire about and/or exercise your rights at any time by contacting us using the details listed below in Section 10. Please note that the exercise of certain of your rights may prevent us from providing services to you.

6. How We Protect Your Information

Data Security. We use have implemented technical and organization measures, including certain physical, managerial, and technical safeguards (such as access controls), to protect the integrity and security of your Personal Information. We cannot, however, ensure or warrant the security of any information you transmit to us through the Site and you do so at your own risk. When you contact us about your Personal Information, you may be asked to provide evidence of your identity (e.g., driver’s license or passport). These types of safeguards are designed to ensure that only you, or someone authorized by you, has access to your file. Further, your Personal Information is kept for as long as it is necessary for the purposes for which it was collected. Therefore, after this period data is destroyed or erased. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial We cannot control the actions of other users or other third parties with whom you may choose to share your information. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

Protecting Children. Our Site and our services are intended for use by individuals over the age of We do not knowingly collect information from individuals under the age of 18. If you are under 18 years of age, then please do not use or access the Site at any time or in any manner.

7. International Visitors

This Site is controlled and operated by Lee Equity in the United States. If you choose to access the Site from outside the United States, you acknowledge that you will be transferring your information, including Personal Information, outside of those regions to the United States for storage and processing, as necessary to provide to you the services available through the Site. If you are based in the UK or EEA we ensure that your Personal Information is transferred and protected by appropriate safeguards such as the EU Standard Contractual Clauses or the UK International Data Transfer Agreement. Please contact us (using the information in Section 10 below) if you would like more information about these safeguards.

8. Retention of Your Personal Information

If you are located in the EEA or UK, the period for which we will hold your Personal Information will vary and will be determined by the following criteria:

the purpose for which we are using it; we are required to retain the Personal Information for as long as is necessary to satisfy or meet the purposes for which it was obtained including applicable legal or regulatory requirements;

legal obligations; laws or regulations may set a minimum period for which we must retain your Personal Information;

for as long as you are our client; or

until you exercise your right asking us to stop processing your Personal Information and to delete it.

We take reasonable steps using appropriate technical methods in the circumstances to delete or destroy your Personal Information when we no longer have a legal basis to retain it or to ensure that the Personal Information is anonymized or irrecoverable.

9. Other Important Information

Changes and Updates to this Privacy Policy. We reserve the right to make changes to this Privacy Policy at any We will notify you about significant changes in the way we treat your information, including by placing a prominent notice on the Site so that you can choose whether to continue using the Site. Material modifications are effective 30 calendar days after our initial notification or upon your acceptance of the modified privacy policy. Immaterial modifications are effective upon posting of the updated privacy policy on the Site. Please revisit this page periodically to stay aware of any changes to this Privacy Policy. For the avoidance of doubt, disputes arising hereunder will be resolved in accordance with the Privacy Policy in effect at the time the dispute arose.

Governing Law. This Privacy Policy is governed by Delaware law. Any dispute regarding this Privacy Policy or your use of the Site shall be resolved solely in the state or federal courts located in Delaware.

Third Party Websites. The Site may provide links to, or features from, other third party websites. If you link to or use such third party sites or features, you do so at your own risk. We do not control and are not responsible for the content or practices of any third party website, application, or other product or service.

10. Our Contact Information

If you have any questions or comments about this Privacy Policy or our practices in relation to your Personal Information you can email us at privacy@leeequity.com, call us at (212) 906-4900, or write to us at Attn: Privacy Policy; Lee Equity Partners, LLC 40 West 57^th Street, 16^th Floor, New York, NY 10019.

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Lee Equity Partners Supplemental California Policy

Last Updated: December 10, 2025

This privacy policy for California residents (this “California Policy”) is provided in addition to the information in any other privacy notice provided by Lee Equity Partners, LLC (“Lee Equity,” “we,” or us”), and explains Lee Equity’s online and offline collection, use, and disclosure of Personal Information (as defined by the CCPA) relating to residents of the State of California (collectively, “you”) covered by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, together with any applicable regulations (all together, the “CCPA”). Any terms defined in the CCPA have the same meaning when used in this California Policy. This California Policy is available in alternative formats upon request. Please call (212) 906-4900 or e-mail privacy@leeequity.com to request an alternative format.

This California Policy applies solely to California residents and does not apply to information collected, processed, or disclosed by Lee Equity pursuant to the Gramm-Leach-Bliley Act and its implementing regulations, or the California Financial Information Privacy Act. We may amend this California Policy from time to time, and will provide you with such amendments in the same manner in which you have received this form.

NOTICE OF COLLECTION, USE, RETENTION, AND DISCLOSURE OF PERSONAL INFORMATION.

Sales and Sharing of Personal Information. We do not and have not sold any categories of Personal Information to third parties or shared any categories of Personal Information for the purpose of cross-context behavioral advertising.
Categories of Personal Information. We may collect the following categories of Personal Information about you online and/or offline when you become an investor, as well as in the course of administering our investment program:
1. Identifiers, including your name and contact details (e.g., home and email address, home and mobile phone numbers), social security number, passport number, online identifier, Internet protocol address, and other similar identifiers;
2. Other Records, including your signature, physical characteristics or description, state identification card (including driver’s license) number, insurance policy number, education information, information obtained as a result of your investment in any of our funds (such as advisor details, investment details, banking details, and financial details), as well as banking and insurance information, tax information, your social insurance or Medicare or social security number or other tax identification number and details of tax residency, and other financial information;
3. Protected Classifications, including under California or federal law, such as national origin, age, sex, marital status, medical condition, and immigration or citizenship status;
4. Commercial Information, including your investment information, financial products or investment services purchased, obtained, or considered, and other investing or consuming histories or tendencies, as well as data about your capital account, capital contributions, profit and loss allocations and distributions and withdrawals from our funds, as well as information about other transactions with us, our affiliates or others, such as participation in our investment programs or products;
5. Online Activity, including your Internet and other electronic network activity information (e.g., information regarding your interaction with websites);
6. Employment Information, including your professional or employment-related information;
7. Inferences, including inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; and
8. Other Information, including the information you create or provide to us, such as the content of your communications with us and/or with our representatives, service providers and affiliates, including in-person discussions, telephone conversations, and electronic or other communications.
Collection, Sources, and Use of Personal Information. We have collected and used the following categories of Personal Information from the following sources and for the following business purposes during the 12-month period prior to the “Last Updated” date of this California Policy:

Categories

Sources

Business Purposes

Identifiers.

· Directly from you, including, for example, through subscription materials and other forms, through your use of our websites (together, the “Site”), when you send us an email, visit our premises, or otherwise contact or communicate with us;

· From within Lee Equity, including, for example, from our affiliates and/or entities owned or controlled by Lee Equity;

· From counterparties and intermediaries (e.g., broker- dealers);

· From businesses that we are evaluating, including, for example, in connection with a potential investment or business opportunity;

· From vendors, (e.g., background check providers), advisors other business partners;

· From recruiting sources, including, for example, agencies, social media networks, and other publicly available sources; and

· From service providers, including, but not limited to the fund administrators, brokers, contractors, or third parties responsible for conducting identity verification or anti-money laundering checks on prospective investors.

· Performing and providing the services that we offer;

· Marketing purposes, including sending correspondences and analyzing trends;

· Recruiting purposes, including the evaluation of candidates and onboarding process;

· Auditing and verifications, including (i) auditing related to a current interaction with you and concurrent transactions; (ii) undertaking activities to verify the quality and effectiveness of services, managing and mitigating risk, assessing compliance with applicable laws, legal requirements, and our policies (including to maintain the privacy and security of our data), conducting internal audits or investigations, and obtaining legal advice or to establish, exercise or defend legal rights and compliance activities); (iii) and undertaking internal research for technological development and demonstration;

· Short-term, transient uses;

· Protecting our systems, including by detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, prosecuting those responsible for that activity (including to protect our assets and to investigate or defend against any claims of illegality or wrongdoing or in response to a court order or judicial or other government subpoena or warrant), and debugging to identify and repair errors that impair intended functionality;

· To comply with legal obligations, such as in connection with a valid court order, judicial subpoena, or regulatory inquiry, and as required by law enforcement agencies, federal or state regulatory agencies or self-regulatory organizations; and

· In connection with business transactions, such as (i) a sale, merger, or other change in corporate control or a restructuring event, or (ii) an investment, acquisition, or other business transaction involving our portfolio companies.

Other Records.

· Directly from you;

· From within Lee Equity;

· From counterparties and intermediaries;

· From businesses that we are evaluating;

· From vendors;

· From recruiting sources; and

· From service providers.

· Performing and providing the services;

· Recruiting purposes;

· Auditing and verifications;

· Complying with legal obligations; and

· In connection with business transactions.

Protected Classifications.

· Directly from you;

· From within Lee Equity;

· From counterparties and intermediaries;

· From businesses that we are evaluating;

· From vendors;

· From recruiting sources; and

· From service providers.

· Auditing and verifications;

· Complying with legal obligations; and

· In connection with business transactions.

Commercial Information.

· Directly from you;

· From within Lee Equity;

· From counterparties and intermediaries;

· From businesses that we are evaluating; and

· From vendors.

· Performing and providing the services;

· Marketing purposes;

· Recruiting purposes;

· Auditing and verifications;

· Protecting our systems;

· Complying with legal obligations; and

· In connection with business transactions.

Online Activity.

· Directly from you; and

· From service providers.

· Performing and providing the services;

· Marketing purposes;

· Recruiting purposes;

· Auditing and verifications;

· Short-term transient uses;

· Protecting our systems;

· Complying with legal obligations; and

· In connection with business transactions.

Employment Information.

· Directly from you;

· From within Lee Equity;

· From counterparties and intermediaries;

· From businesses that we are evaluating;

· From vendors;

· From recruiting sources; and

· From service providers.

· Performing and providing the services;

· Recruiting purposes;

· Auditing and verifications;

· Protecting our systems;

· Complying with legal obligations; and

· In connection with business transactions.

Inferences.

· From within Lee Equity;

· From counterparties and intermediaries;

· From businesses we are evaluating;

· From vendors;

· From recruiting sources; and

· From service providers.

· Performing and providing the services;

· Marketing purposes;

· Auditing and verifications;

· Protecting our systems; and

· In connection with business transactions.

Other Information.

· Directly from you;

· From within Lee Equity;

· From counterparties and intermediaries;

· From vendors; and

· From recruiting sources.

· Performing and providing the services;

· Marketing purposes;

· Recruiting purposes;

· Auditing and verifications;

· Short-term, transient uses;

· Protecting our systems;

· Complying with legal obligations; and

· In connection with business transactions.

Protecting Children. Our services are intended for use by individuals over the age of 18. We do not knowingly collect or solicit any categories of Personal Information from any individual under the age of 18. If you are under 18 years of age, then please do not use or access the services at any time or in any manner.
Sensitive Personal Information. Sensitive Personal Information may include social security numbers, driver’s license numbers, passport numbers; and account credentials. To the extent we collect your Sensitive Personal Information, we will not use or disclose such information for purposes other than (i) to perform services/goods that you reasonably expect from us; (ii) to prevent, detect, and investigate security incidents; (iii) to resist illegal actions directed at the business and prosecute defend our rights; (iv) to ensure the physical safety of others; (v) for short-term, transient uses; (vi) to perform services necessary for the business; (vii) to verify and maintain the quality and safety of our services; and (viii) generally for purposes that do not infer characteristics about you.
Retention of Personal Information. We retain Personal Information for as long as is reasonably necessary in connection with the purposes for which the Personal Information was collected. For additional information on how we store your Personal Information, please refer to our Website Privacy Policy (above).
Disclosures of Personal Information for Business Purposes. We may have disclosed the following categories of Personal Information to the following categories of recipients for the following business purposes during the 12-month period prior to the “Last Updated” date of this California Policy:

Business Purposes

Recipients