Unlocking value before the market does

Last updated — April 2026

1. Introduction

Pie Capital Partners ("the Firm", "we", "us", "our") respects your privacy and is committed to handling personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (collectively, "Applicable Data Protection Law"). This Privacy Policy describes how we collect, use, and safeguard personal data received in connection with our website and our business activities as a facilitator of secondary market transactions in pre-IPO securities. It does not form part of any contract between you and the Firm.

2. Data controller

Pie Capital Partners is the data controller in respect of the personal data described in this policy. Enquiries regarding this policy, or the exercise of any rights under Applicable Data Protection Law, should be directed to [email protected].

3. Scope of activities

The Firm acts solely as a transaction facilitator. We do not provide investment advice, do not exercise discretion over client assets, do not make investment decisions on behalf of any person, and do not act as a regulated investment adviser, investment manager, or broker-dealer. Any personal data we process is used exclusively for the purposes of operating our facilitation business, meeting legal and regulatory obligations, and communicating with counterparties at their request.

4. Categories of personal data

Depending on the nature of your interaction with the Firm, we may collect: (a) identification data (name, date of birth, nationality, identity document details); (b) contact data (business email, telephone, postal address); (c) professional data (employer, role, professional classification, regulatory status); (d) financial and transactional data (source of funds, source of wealth, transaction history, and information required for Know Your Customer and Anti-Money Laundering purposes); (e) communications data (correspondence, enquiry form submissions, meeting notes); and (f) technical data (IP address, device identifiers, browser type, and aggregated usage data).

5. Sources of personal data

We collect personal data directly from you, from persons acting on your behalf, from public registers and databases, from sanctions and politically-exposed-persons screening providers, from credit reference agencies, and from counterparties to transactions you have authorised. Where we obtain data from third parties, we rely on those parties to have collected the data lawfully.

6. Purposes and legal bases

We process personal data on one or more of the following legal bases: (a) the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract; (b) compliance with a legal or regulatory obligation to which the Firm is subject, including AML/CTF, sanctions, and tax reporting obligations; (c) our legitimate interests in operating, protecting, and developing our business, provided such interests are not overridden by your rights; and (d) your consent, where processing is based on consent (in which case you may withdraw that consent at any time without affecting the lawfulness of prior processing).

7. Disclosure of personal data

We do not sell personal data. We may disclose personal data to: (a) regulated professional advisers (legal counsel, auditors, tax advisers, compliance consultants); (b) service providers engaged to support our operations (fund administrators, KYC/AML vendors, IT and cloud infrastructure providers), each of which is bound by written confidentiality and data-processing obligations; (c) counterparties to a transaction you have authorised, to the extent necessary to effect or settle that transaction; (d) regulators, law enforcement agencies, and other public authorities, where disclosure is required or permitted by law; and (e) any successor in interest in the event of a corporate reorganisation, sale, or transfer of the Firm's business.

8. International transfers

Where personal data is transferred outside the United Kingdom, we do so only where an adequate level of protection is ensured through one or more of the safeguards permitted by Applicable Data Protection Law, including adequacy decisions, the International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or an applicable derogation.

9. Retention

We retain personal data only for as long as necessary for the purposes set out in this policy, or for longer periods where retention is required to comply with legal, regulatory, tax, or reporting obligations. Records relating to financial transactions and AML/KYC documentation are typically retained for at least six years from the termination of the relevant business relationship.

10. Your rights

Subject to Applicable Data Protection Law and any exemptions, you may have the right to: (a) access personal data we hold about you; (b) request rectification of inaccurate data; (c) request erasure of personal data in certain circumstances; (d) restrict or object to certain processing; (e) receive a portable copy of data you have provided to us; and (f) lodge a complaint with the UK Information Commissioner's Office (ico.org.uk). Requests should be sent to [email protected]. We may request information to verify your identity before responding.

11. Security

We implement technical and organisational measures appropriate to the risks posed by our processing activities, including access controls, encryption in transit, and staff confidentiality obligations. No system can, however, be guaranteed to be entirely secure, and you acknowledge that transmission of data over the internet carries inherent risk.

12. Cookies

Our website uses only strictly necessary cookies and, where enabled, aggregated analytics cookies. We do not use advertising, profiling, or cross-site tracking cookies. You may control cookies through your browser settings.

13. Changes to this policy

We may update this Privacy Policy from time to time. The "Last updated" date above reflects the most recent revision. Continued use of the Site following publication of an updated policy constitutes acceptance of that revised policy.

Last updated — April 2026

1. Agreement to these terms

These Terms of Use ("Terms") govern your access to and use of the website operated by Pie Capital Partners ("the Firm", "we", "us", "our"), located at piecapitalpartners.com and any associated subdomains (together, the "Site"). By accessing or using the Site, you agree to be bound by these Terms. If you do not agree to these Terms, you must not access or use the Site. We may amend these Terms at any time by posting a revised version; continued use of the Site following publication constitutes acceptance of the amended Terms.

2. Nature of the Firm's role

Pie Capital Partners operates solely as a facilitator of secondary market transactions in pre-IPO securities between informed, self-directed counterparties. The Firm does not: (a) provide investment advice, personal recommendations, or suitability assessments; (b) act as an investment manager, fiduciary, custodian, or trustee; (c) make investment decisions on behalf of any person; (d) guarantee the availability, pricing, terms, legal title, transferability, or future performance of any security; or (e) hold itself out as a regulated investment professional. Any decision to participate in a transaction is made independently by the counterparty on the basis of its own judgement and its own professional advisers.

3. Informational purpose only

All content on the Site is provided for general information only. Nothing on the Site constitutes, or should be construed as: (a) an offer, invitation, or solicitation to buy, sell, subscribe for, or otherwise transact in any security or financial instrument; (b) investment, legal, tax, accounting, or regulatory advice; (c) a recommendation to pursue any particular strategy or transaction; or (d) a representation that any investment is suitable for any person. Any specific investment opportunity will be made available exclusively by means of definitive private offering documentation delivered directly to qualified recipients in jurisdictions where such offering is lawful.

4. Eligibility and restricted audience

The Site and its contents are intended solely for persons who qualify as professional clients, eligible counterparties, institutional investors, or equivalent classifications under the laws of their jurisdiction of residence. The Site is not directed at, and its contents must not be relied upon by, retail investors or the general public. You represent and warrant, by accessing the Site, that you meet such eligibility criteria and that access does not contravene any law applicable to you.

5. No warranty

The Site and all content on it are provided on an "as is" and "as available" basis. To the fullest extent permitted by law, the Firm expressly disclaims all warranties, representations, and conditions of any kind, whether express, implied, or statutory, including (without limitation) warranties of accuracy, completeness, currency, fitness for a particular purpose, non-infringement, merchantability, uninterrupted availability, and freedom from error or malicious code. Any reliance you place on the Site is strictly at your own risk.

6. Investment risk

Pre-IPO securities and secondary market transactions involve substantial risk. Without limitation: (a) such securities are unregistered, illiquid, and subject to contractual and regulatory transfer restrictions; (b) reliable current valuations may not exist and prices may be highly volatile; (c) information available on the underlying issuer may be limited, stale, or incomplete; (d) rights of first refusal, co-sale, transfer restrictions, and issuer consent requirements may frustrate or void a transaction after it has been agreed; (e) there is no guarantee of a liquidity event; and (f) an investor may lose the entire amount invested. Past performance is not indicative of future results. Prospective participants must consult their own independent professional advisers before taking any action.

7. Limitation of liability

To the fullest extent permitted by applicable law, the Firm, its affiliates, and their respective directors, officers, employees, agents, consultants, and contractors (the "Protected Persons") shall not be liable to any person for any loss, damage, cost, or expense of any kind, whether direct, indirect, incidental, special, consequential, or punitive, including (without limitation) loss of profits, loss of opportunity, loss of goodwill, loss of data, or loss of anticipated savings, arising out of or in connection with: (a) access to or use of, or inability to access or use, the Site; (b) any information, opinion, statement, or omission on the Site; (c) any decision made or action taken in reliance on the Site; (d) any transaction entered into between counterparties, including the terms, settlement, or performance of that transaction; or (e) the acts or omissions of any third party, including any issuer, counterparty, service provider, introducer, or regulatory authority. Nothing in these Terms excludes or limits liability that cannot lawfully be excluded or limited, including liability for death or personal injury caused by negligence, or for fraud or fraudulent misrepresentation.

8. Indemnity

You agree to indemnify and hold harmless the Protected Persons from and against any claim, liability, loss, damage, cost, or expense (including reasonable legal fees) arising out of or in connection with: (a) your breach of these Terms; (b) your violation of any law or regulation; (c) your misrepresentation of your eligibility, status, or authority; or (d) any transaction you enter into with a counterparty introduced or facilitated through the Firm.

9. Intellectual property

All content on the Site, including text, graphics, logos, marks, images, and design elements, is owned by or licensed to the Firm and is protected by copyright, trade mark, and other intellectual property laws. You are granted a limited, non-exclusive, non-transferable, revocable licence to access the Site for lawful personal and business purposes. You may not reproduce, distribute, publish, transmit, modify, create derivative works from, or commercially exploit any content without the Firm's prior written consent.

10. Third-party links and content

The Site may contain links to or content from third-party websites or services. The Firm does not endorse, monitor, or control such third-party content and accepts no responsibility for its accuracy, legality, or any loss or damage arising from reliance on it. Access to third-party sites is at your own risk and subject to their own terms.

11. Prohibited conduct

You must not use the Site to: (a) breach any applicable law or regulation; (b) infringe the rights of others; (c) upload or transmit malicious code; (d) attempt to gain unauthorised access to any part of the Site; (e) reverse engineer or scrape content except as permitted by law; or (f) use the Site to transmit unsolicited communications.

12. Suspension and termination

The Firm may, at its sole discretion and without notice or liability, suspend, restrict, or terminate your access to the Site at any time.

13. Governing law and jurisdiction

These Terms and any non-contractual obligations arising out of or in connection with them are governed by the laws of England and Wales. The courts of England and Wales have exclusive jurisdiction to resolve any dispute arising out of or in connection with these Terms, save that the Firm reserves the right to bring proceedings against you in the courts of any jurisdiction in which you are resident or in which your relevant assets are located.

14. Severability and entire agreement

If any provision of these Terms is held to be invalid or unenforceable, that provision shall be modified to the minimum extent necessary to render it enforceable, or shall be severed, without affecting the remainder of these Terms. These Terms, together with any document expressly referred to in them, constitute the entire agreement between you and the Firm in respect of the Site and supersede all prior understandings in relation to such subject matter.

Last updated — April 2026

1. Nature of the Firm's business

Pie Capital Partners ("the Firm") is a private transaction facilitator specialising in secondary market introductions involving unregistered pre-IPO securities. The Firm's role is limited to bringing together sophisticated counterparties who have independently identified an interest in a potential transaction, and to coordinating the documentation, diligence materials, and settlement logistics that such counterparties choose to progress. All substantive economic decisions are made by the counterparties themselves.

2. No regulated activities; no advice

The Firm does not hold itself out as, and does not act as, an authorised person within the meaning of the Financial Services and Markets Act 2000 ("FSMA") or any equivalent legislation in any other jurisdiction. The Firm does not perform, and will not be deemed to have performed: (a) the giving of investment advice or personal recommendations; (b) the management of investments on a discretionary or advisory basis; (c) the safeguarding or administration of client assets; (d) the arrangement of deals for retail clients; or (e) any other activity that would constitute a regulated activity requiring authorisation. Where any particular interaction would, in the Firm's reasonable assessment, require authorisation, the Firm will either decline to proceed or refer the interaction to an appropriately authorised third party.

3. Eligible counterparties only

The Firm communicates and transacts exclusively with persons who represent themselves to be, and whom the Firm reasonably classifies as, professional clients, eligible counterparties, institutional investors, high-net-worth individuals or companies, or sophisticated investors in each case under the laws of their jurisdiction. In the United Kingdom, the Firm's communications are directed only at persons falling within the exemptions in Articles 19 (investment professionals), 49 (high net worth companies), or 50 (sophisticated investors) of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005, as amended, or other applicable exemption. The Firm does not deal with, and expressly disclaims any intention to deal with, retail investors or members of the general public.

4. No offer or solicitation

Nothing on the Firm's website or in any communication from the Firm constitutes an offer to sell, or a solicitation of an offer to buy, any security in any jurisdiction. Any transaction that is progressed will be documented by means of definitive private transaction documentation executed directly between the relevant counterparties. Such documentation, and not the Firm's website or any marketing materials, will govern the rights and obligations of the transacting parties.

5. No reliance on Firm statements

Counterparties transact on the basis of their own independent investigation and the advice of their own professional advisers. The Firm makes no representation or warranty, express or implied, as to the accuracy, completeness, or reliability of any information relating to an underlying issuer, security, valuation, capitalisation, or proposed transaction, whether such information originates from the issuer, a counterparty, a third party, or the Firm itself. No statement made by the Firm should be relied upon as investment advice, a recommendation, or a representation of suitability.

6. Anti-Money Laundering and sanctions compliance

The Firm complies with all anti-money laundering and counter-terrorist financing obligations applicable to it, including (where applicable) the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended, and the Proceeds of Crime Act 2002. All counterparties are subject to customer due diligence appropriate to the risk presented by the relationship, including identity verification, beneficial ownership verification, source of funds and source of wealth enquiry, and screening against applicable sanctions and politically-exposed-persons lists. The Firm reserves the right to decline or terminate any relationship where, in its sole judgement, to continue would be inconsistent with its legal, regulatory, or risk obligations, and is under no obligation to disclose its reasons for doing so.

7. Conflicts of interest

The Firm maintains a written conflicts of interest policy designed to identify, prevent, and (where appropriate) disclose or manage actual or potential conflicts arising in the course of its activities. By engaging with the Firm, counterparties acknowledge that the Firm may, subject to applicable law, act for multiple counterparties in respect of the same or similar securities, may earn fees from one or more sides of a facilitated transaction, and may have commercial relationships with service providers referenced or used in the course of its activities.

8. Risk warnings

Secondary market transactions in pre-IPO securities involve significant risk and are suitable only for persons able to bear a complete loss of their investment. Without limitation: (a) pre-IPO securities are unregistered, illiquid, and subject to transfer restrictions, rights of first refusal, and issuer consent requirements that may prevent, delay, or unwind a transaction; (b) reliable market valuations and timely financial information may not be available; (c) there is no guarantee of any liquidity event, and exit timing is outside the control of the Firm or any counterparty; (d) tax treatment depends on individual circumstances and may change; and (e) fees, expenses, and special purpose vehicle costs may materially reduce net returns. Prospective participants should obtain independent legal, tax, and financial advice before taking any action.

9. Complaints

Whilst the Firm does not carry on regulated activities and is accordingly outside the jurisdiction of the Financial Ombudsman Service, the Firm takes all expressions of dissatisfaction seriously. Complaints should be directed in writing to [email protected]. The Firm will acknowledge complaints within five business days and aim to provide a substantive response within eight weeks. Nothing in this paragraph creates or implies any entitlement to compensation outside the express terms of a written agreement between the complainant and the Firm.

10. No client money; no Financial Services Compensation Scheme

The Firm does not hold client money or client assets. Counterparties to a facilitated transaction are not entitled to the protections of the Financial Services Compensation Scheme or to any equivalent statutory compensation scheme in any other jurisdiction in respect of the Firm's activities.

11. Changes

The Firm may update this Regulatory Information page at any time. The "Last updated" date reflects the most recent revision. Prospective participants should review this page periodically.