Service Privacy Policy

Service Privacy Policy

Last Updated: February 12, 2026

1. Introduction

This Service Privacy Policy (“Service Privacy Policy”) explains how Solen Software Group, Inc. (“Solen,” “we,” “us,” or “our”) processes personal information in the course of conducting our private equity business and in connection with non-public interactions with counterparties, potential sellers, advisors, and other business contacts (“Business Contacts”).

This Service Privacy Policy applies only to personal information that Solen receives outside of the Website, including, but not limited to, information provided to Solen: (a) during preliminary or advanced discussions regarding a potential transaction; (b) under a non-disclosure agreement (“NDA”); (c) through due diligence processes or data rooms; (d) through communications with advisors, brokers, intermediaries, lenders, or portfolio companies; (e) in connection with portfolio-company oversight or governance activities; (f) in the ordinary course of Solen’s investment and private equity operations; or (g) employment related communications and negotiations relating to prospective, current, or former employees, officers, directors, or contractors of Solen or of a potential or actual portfolio company, to the extent such information is provided to Solen in connection with an investment evaluation, governance responsibilities, or Solen’s own internal hiring processes.

This policy does not apply to information collected through the Website. For Website-collected personal information, please see Solen’s Website Privacy Policy.

Nothing in this Service Privacy Policy constitutes an offer to sell, or a solicitation of an offer to buy, any securities. Such matters are governed exclusively by applicable offering documents and securities laws.

2. Relationship to Confidentiality Agreements and Transaction Documents

In connection with potential or actual transactions, Solen typically enters into a mutual NDA, confidentiality agreement, or other written contract with counterparties.

If there is any conflict between this Service Privacy Policy and an applicable NDA or transaction agreement, the NDA or transaction agreement will control with respect to the treatment, use, disclosure, retention, and protection of confidential information.

This Service Privacy Policy does not modify or waive the terms of any NDA or other binding agreement.

3. Categories of Personal Information We Process

In the context of our investment, diligence, employment-related, and portfolio activities, we may receive or generate personal information relating to Business Contacts, including:

3.1 Business Contact Information

• • Name
  • Business title
  • Business email address
  • Business telephone number
  • Organization and role
  • Professional qualifications or affiliations

3.2 Information Provided in Connection With a Potential Transaction

Depending on the nature and scope of a proposed transaction, personal information may appear within diligence materials, including: (a) information about owners, executives, key personnel, or customers of a target company; (b) employment-related data (e.g., compensation bands, organizational charts, résumés of key personnel); (c) limited financial or contract-related data that includes personal information; and (d) information embedded in commercial, operational, or legal diligence documents.

Such information is generally not requested for its own sake, but may be included within business records provided by counterparties during ordinary diligence.

3.3 Information From Advisors, Brokers, and Intermediaries

We may receive personal or business contact information about individuals from: (a) M&A advisors and brokers; (b) legal or financial advisors; (c) portfolio-company personnel; or (d) lenders or financing sources.

3.4 Information from Portfolio Companies

Where Solen holds an investment, personal information may be processed in connection with: (a) board-level reporting, (b) governance and oversight obligations, (c) risk, audit, compliance, or performance monitoring; and (d) value-creation initiatives.

3.5 Employment Related Information

Solen may also receive or process limited personal information relating to employment matters, including: (a) information submitted to Solen by job applicants or candidates for employment; (b) information about officers, directors, or employees of target companies or portfolio companies provided to Solen for diligence or governance purposes; (c) compensation, equity, benefits, or contractual information relating to key personnel of a potential or actual investment; and (d) compliance-related information necessary to assess management suitability, background checks (where permitted by law), or executive-employment risks.

4. How We Use Personal Information

Solen uses personal information for legitimate business purposes, including to: (a) evaluate, negotiate, structure, and close potential acquisitions or investments; (b) conduct due diligence, risk assessments, and financial or operational analyses; (c) communicate with counterparties, advisors, and portfolio companies; (d) comply with legal, regulatory, and reporting obligations; (e) manage post-investment governance activities; (f) protect Solen’s rights, interests, and contractual obligations; (g) respond to requests, inquiries, or instructions from Business Contacts; (h) maintain records of dealings, communications, and investment history; and (i) evaluate and manage Solen’s own employment-related decisions, including recruitment, hiring, onboarding, compensation review, compliance obligations, and related processes).

We do not use personal information for marketing to consumers, nor do we provide “services” to the individuals whose personal information may be included in diligence or transaction materials.

5. Legal Bases for Processing (UK/EEA/Swiss Personal Data)

Where the GDPR, UK GDPR, or Swiss privacy laws apply, our legal bases for processing personal data include: (a) legitimate interests in evaluating and pursuing investments, managing governance rights, and conducting diligence and legitimate interests in managing Solen’s internal employment processes; (b) performance of a contract or steps taken at the request of a counterparty prior to entering into a contract; (c) compliance with legal obligations, including regulatory requirements applicable to private equity operations; and (d) consent, only where explicitly required and provided (typically not applicable in transaction contexts).

6. How We Share Personal Information

We may disclose personal information to: (a) legal, financial, and commercial advisors assisting in a potential or actual transaction; (b) brokers, intermediaries, and investment bankers; (c) lenders, financing sources, or co-investors; (d) service providers supporting diligence, analytics, or transaction processes; (e) portfolio companies (where appropriate in connection with an investment); (f) government authorities or regulators where required by law; (g) third parties in connection with mergers, acquisitions, financing, restructurings, or dispositions; and (h) third-party background check providers or employment-related advisors engaged by Solen in connection with internal hiring or executive diligence, where permitted by law.

We do not sell personal information.

Any sharing is subject to NDAs where applicable.

7. International Data Transfers

As a U.S.-based private equity firm operating internationally, we may transfer personal information across borders, including to the United States, Canada, the United Kingdom, and the EEA.

Where required, we use legally recognized safeguards such as: (a) Standard Contractual Clauses (EU/UK); (b) contractual protections for Canadian data (PIPEDA); or (c) other appropriate measures under applicable law.

8. Data Retention

We retain personal information only as long as necessary to fulfill the purposes described above, including: (a) maintaining transaction records, (b) meeting regulatory, legal, or audit obligations; (c) maintaining appropriate records relating to Solen’s internal employment processes); and (d) maintaining appropriate records relating to investments or potential investments.

When information is no longer needed, we delete or anonymize it, unless retention is legally required.

9. Security Measures

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, loss, misuse, or alteration. However, no method of transmission or storage is completely secure.

10. Rights of Individuals

Depending on your jurisdiction, you may have rights under applicable privacy laws, including the right to: (a) access your personal information; (b) request correction or deletion; (c) object to certain processing; (d) request data portability; or (e) withdraw consent (if processing is based on consent).

To exercise rights, contact us at: contact@solensoftwaregroup.com

These rights do not apply to information governed by an NDA or transaction documents, which are subject to their own contractual terms.

11. Changes to This Service Privacy Policy

We may update this Service Privacy Policy from time to time. Material changes may be communicated as appropriate.

12. Contact Information

For questions about this Service Privacy Policy or to exercise your rights:

Solen Software Group, Inc.
Attn: Privacy
6995 South Union Park Center, Suite 340
Salt Lake City, Utah 84047
Email: contact@solensoftwaregroup.com