Privacy Policy

Last updated: September 12, 2025

This Privacy Policy for PanEuro Special Situations Ltd (doing business as PanEuro Corporate Advisory) ("PanEuro," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your personal information when you interact with us or use our services ("Services"), such as when you:

Visit our website at https://www.paneuro.co.uk/, or any website of ours that links to this Privacy Policy.
Engage with us in other related ways, including through advisory mandates, investments, communications, or events related to our corporate advisory and investment activities.

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services or engage with us. If you still have any questions or concerns, please contact us at admin@paneuro.co.uk.

This Privacy Policy applies to our operations in all countries worldwide except those designated as Islamic states (e.g., countries where Islamic law or Sharia is the primary legal system, such as Iran, Saudi Arabia, and Pakistan). We comply with applicable data protection laws in the jurisdictions where we operate, including but not limited to the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada, the Australian Privacy Principles (APP) under the Privacy Act 1988, the Act on the Protection of Personal Information (APPI) in Japan, and equivalent laws in other relevant jurisdictions.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Policy, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

What personal information do we process? When you interact with PanEuro or use our Services, we may process personal information depending on how you engage with us, the choices you make, and the nature of our advisory or investment activities.

Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law (e.g., financial data that may reveal sensitive categories in certain contexts).

Do we receive any information from third parties? We may receive information from public databases, business partners, regulatory bodies, and other outside sources.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, to comply with legal obligations, and to facilitate our advisory and investment activities. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties, such as regulated counterparties, special purpose vehicles (SPVs), and professional service providers.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information, such as access, rectification, erasure, and objection.

How do I exercise my rights? The easiest way to exercise your rights is by contacting us at compliance@paneuro.co.uk. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what PanEuro does with any information we collect? Review the policy in full below.

WHAT INFORMATION DO WE COLLECT?
HOW DO WE PROCESS YOUR INFORMATION?
WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
HOW LONG DO WE KEEP YOUR INFORMATION?
HOW DO WE KEEP YOUR INFORMATION SAFE?
DO WE COLLECT INFORMATION FROM MINORS?
WHAT ARE YOUR PRIVACY RIGHTS?
CONTROLS FOR DO-NOT-TRACK FEATURES
DO RESIDENTS OF SPECIFIC JURISDICTIONS HAVE ADDITIONAL PRIVACY RIGHTS?
DO WE MAKE UPDATES TO THIS POLICY?
HOW CAN YOU CONTACT US ABOUT THIS POLICY?
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our Services, when you participate in activities related to our Services (such as advisory consultations, due diligence processes, or investment opportunities), or otherwise when you contact us.

The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the features you use. The personal information we may collect includes the following:

Contact Information: Names, phone numbers, email addresses, mailing addresses, job titles, and other similar contact details.
Professional and Financial Information: Company affiliations, financial details (e.g., bank account information, investment history, credit references), identification documents (e.g., passports or IDs for compliance purposes), and other data necessary for providing advisory services in equity/debt markets, M&A, restructuring, or investments.
Transaction Data: Details related to advisory mandates, investments, or SPV structures.
Sensitive Personal Information: We may collect sensitive personal information (such as data revealing racial or ethnic origin, health, or biometric data from ID documents) only when necessary for legal compliance (e.g., anti-money laundering checks) and with your explicit consent or as permitted by law.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our website.

We automatically collect certain information when you visit, use, or navigate the website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our website, and other technical information. This information is primarily needed to maintain the security and operation of our website, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy (if applicable) or Section 6 below.

The information we collect includes:

Log and Usage Data: Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity on the website (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports, and hardware settings).
Device Data: We collect device data such as information about your computer, phone, tablet, or other device you use to access the website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Location Data: We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate advisory and investment activities: We may process your information to provide corporate advisory services, manage M&A processes, restructuring support, capital market strategies, and investment opportunities via SPVs.
To manage client relationships and fulfill mandates: We may process your information to onboard clients, conduct due diligence, negotiate transactions, and perform post-engagement integration or stabilization.
To request feedback: We may process your information when necessary to request feedback and to contact you about your use of our Services.
To send you marketing and promotional communications: We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.
To deliver targeted advertising to you: We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
To protect our Services: We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
To identify usage trends: We may process information about how you use our Services to better understand how they are being used so we can improve them.
To determine the effectiveness of our marketing and promotional campaigns: We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
To comply with our legal obligations: We may process your information to comply with our legal obligations, such as anti-money laundering (AML) requirements, know-your-client (KYC) checks, and regulatory reporting in the jurisdictions where we operate.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the UK or EU, this section applies to you.

The UK GDPR and EU GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent: We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
Performance of a Contract: We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
Legitimate Interests: We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to conduct due diligence, manage cross-border transactions, and ensure compliance with financial regulations.
Legal Obligations: We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital Interests: We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.
For investigations and fraud detection and prevention.
For business transactions provided certain conditions are met.
If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.
For identifying injured, ill, or deceased persons and communicating with next of kin.
If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse.
If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.
If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.
If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced.
If the collection is solely for journalistic, artistic, or literary purposes.
If the information is publicly available and is specified by the regulations.

For other jurisdictions (e.g., US, Australia, Japan), we rely on similar bases such as consent, contractual necessity, legitimate interests, and compliance with local laws like CCPA, APP, or APPI.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

We may need to share your personal information in the following situations:

Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
Business Partners: We may share your information with our business partners to offer you certain products, services, or promotions, such as regulated counterparties, SPVs for investment mandates, or professional service providers (e.g., lawyers, accountants, due diligence firms).
Other Users: When you share personal information or otherwise interact with public areas of the Services, such information may be viewed by all users and may be publicly made available outside the Services in perpetuity.

We also may share your personal information with the following categories of third parties:

Cloud storage providers
Data analytics services
Finance and payment processors
Government authorities (for compliance)
Performance monitoring tools
Testing tools
User engagement services

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this Privacy Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United Kingdom. If you are accessing our Services from outside the United Kingdom, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, in the United States, Australia, Japan, Canada, and other countries where we operate (excluding Islamic states).

If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law. Such measures may include the use of Standard Contractual Clauses (SCCs) approved by the European Commission or UK Information Commissioner's Office, or other appropriate safeguards for international data transfers under GDPR/UK GDPR, CCPA, or equivalent laws.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an active engagement with us, plus any additional periods required for legal compliance (e.g., 7 years for financial records under UK law).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

10. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at admin@paneuro.co.uk.

Given the nature of our Services (targeted at professional clients and eligible counterparties), we do not anticipate collecting data from minors.

11. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the UK, EEA, Canada, and certain US states, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your information at any time.

In some regions (like the UK, EEA, Canada, Australia, and Japan), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS POLICY?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://edpb.europa.eu/about-edpb/board/members_en (for EEA) or https://ico.org.uk/ (for UK).

If you are located in Canada, you may contact the Office of the Privacy Commissioner of Canada at https://www.priv.gc.ca/.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us.

However, please note that this will not affect the lawfulness of processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

13. DO RESIDENTS OF SPECIFIC JURISDICTIONS HAVE ADDITIONAL PRIVACY RIGHTS?

In Short: Yes, if you are a resident of certain jurisdictions like California or Virginia, you may have additional rights regarding access to and use of your personal information.

California-Specific Rights under CCPA/CPRA

If you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

Under the CCPA, as amended by CPRA, California residents have the right to:

Request that a business that collects a consumer's personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
Request that a business delete any personal data about the consumer that a business has collected.
Request that a business that sells or shares a consumer's personal data, not sell or share the consumer's personal data.
If you make a request, we have one month to respond to you (extendable by two more months where necessary).

We do not sell or share personal information as defined under CCPA. To exercise these rights, contact us at admin@paneuro.co.uk.

Virginia-Specific Rights under VCDPA

Under the Virginia Consumer Data Protection Act (VCDPA), if you are a resident of Virginia, you have the right to:

Confirm whether or not we are processing your personal data and access it.
Correct inaccuracies in your personal data.
Delete your personal data.
Obtain a copy of your personal data that you previously provided to us in a portable and usable format.
Opt out of the processing of your personal data for purposes of targeted advertising, sale, or profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise these rights, contact us at admin@paneuro.co.uk.

For residents of other jurisdictions (e.g., Australia under APP or Japan under APPI), similar rights apply, such as access, correction, and deletion. Contact us for details.

14. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Last updated" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

15. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may email us at admin@paneuro.co.uk

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us at admin@paneuro.co.uk