PXN Group Limited Privacy Notice and Policy

Last updated: 19 November 2025

This website (“Site”) is maintained by PXN Group Limited on its own behalf and on behalf of its subsidiary and affiliate companies. These entities are collectively known as “PXN,” “we,” “us,” or “our,” and include:

Par Fund Management Limited (trading as Par Equity)
Par Equity Holdings Limited
Par Advisers Limited
Par Equity Managements (US) LLC
Praetura Ventures Limited (trading as Praetura Investments and Praetura Ventures)

PXN respects your privacy and is committed to protecting your Personal Data (as defined, unless otherwise stated, under the UK General Data Protection Regulation (“UK GDPR”)). This notice informs you how we look after your Personal Data when you visit our website and tells you about your privacy rights.

Introduction and Purpose

The purpose of this notice is to supply you with the required information at the time of providing us with your personal data. This will cover the what, where, when, and how in relation to the personal information collected.

The General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018 govern the controlling and processing of personal data (any information about identifiable living individuals), and also give those individuals certain rights.

Important information and who we are
The data we collect about you
How is your personal data collected
How we use your personal data
Disclosures of your personal data
International transfers
Data security
Data retention
Your legal rights
Glossary

1. Important information about this notice

Purpose of this privacy notice

This notice aims to give you information on how PXN collects and processes your personal data through your use of our websites and services. This includes personal data you provide, for example, personal details in our Application Management System (AMS) for seeking investment, or details used to sign into our Client Management System (CMS).

It is important to read this notice together with any other privacy notice we may provide on specific occasions. This notice supplements other notices and is not intended to override them.

Controllers

The operating subsidiaries of PXN that act as Data Controllers and are responsible for your personal data are: Praetura Ventures Limited and Par Fund Management Limited.

Contact details:

Name: Rosie Bhattacharjee
Role: Data Protection Officer
Company: PXN Group Limited
Email: dpo@pxngroup.co.uk

Please use these details if you have any questions about this privacy notice, including requests to exercise your legal rights.

Changes to the Notice

This version was last updated on the date shown at the top of this page (19 November 2025).

Changes to your data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

Third-party links

Our website may include links to third-party websites, plug-ins, and applications. Clicking on these may allow third parties to collect or share data about you. We do not control these websites and are not responsible for their privacy statements. We encourage you to read the privacy notice of every website you visit when you leave ours.

2. The data we collect about you

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data, which include:

Identity Data: First name, last name, former names, username and password, marital status, title, date of birth, and gender.
Contact Data: Home address, business address, email address, and telephone numbers.
Financial Data: Bank account card details, tax status, and National Insurance Number.
Transaction Data: Details about investments, shareholdings, and other details pertaining to the services we provide.
Profile Data: The names of companies you have invested in, your past investment experience, and investment interest.
Optional Professional Experience Data: You may choose to share this to help us screen opportunities, provide due diligence, and offer ongoing help with the portfolio.
Visual Identification: Photographs and videos you may appear in.
Voice Recordings: Including any telephone recordings we may have access to.
Technical Data: Internet protocol (IP) address, login data, browser type and version, time zone setting, location, browser plug-ins, operating system, and other technology on devices you use to access the website.
Usage Data: Information about how you use our websites, information systems, and services.
Marketing and Communications Data: Your preferences in receiving information from us and your communication preferences.

Aggregated Data

We may collect, use, and share aggregated data (statistical or demographic data) for research or analytic purposes. This data may be derived from your personal data, but we remove your identity when processing it (e.g., aggregating Usage Data to calculate the percentage of users accessing a feature). However, we may combine aggregated data with other data to directly or indirectly identify you.

Data Not Collected

We do not collect any Special Categories of Personal Data (e.g., race, ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, health information, or genetic/biometric data). Nor do we collect any information about criminal convictions and offences.

Required Personal Data

Where we need to collect personal data by law (e.g., for Anti Money Laundering (AML) or Know Your Client (KYC) checks) or under the terms of a contract, and you fail to provide that data, we will not be able to perform or enter into the contract with you. We will notify and discuss this with you at the time.

3. How is your personal data collected?

We use different methods to collect data, including:

Direct interactions

You may provide details of your Identity, Contact, Financial Data, Past Investment Experience by filling in forms or corresponding with us by post, phone, or email. This includes when you:

Apply to become a Syndicate Investor
Apply to invest in one of our managed funds
Apply to become a member of the one of our Advisory Panels, or enquire about becoming involved in the investment process in an advisory capacity
Apply for investment for a company you are associated with
Apply to PXN for a job vacancy or placement
Create an account on our website or information systems
Subscribe to our communications; or
Give us feedback on our services.

Automated technologies or interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns using cookies, server logs, and other similar technologies. We may also receive Technical Data if you visit other websites employing our cookies. We do not use automated data processing.

Third parties or publicly available sources

We may receive personal data about you from various third parties and public sources as set out below:

Introductions from our staff, contacts from within our professional network or financial intermediaries e.g. wealth managers, other investment managers or angel networks
Introductions from our investee companies
Introductions from our existing clients and
Various electronic databases and networks e.g. LinkedIn

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we use your data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you
Where it is necessary for our legitimate interests (or those of a third party) and unless your interests and fundamental rights override those interests.
Where we need to comply with a legal or regulatory obligation, for example anti money laundering checks
Where it is necessary to fulfil a service that you have elected into e.g. subscription to our periodic news updates or events

We may process your personal data for more than one lawful ground depending on the specific purpose.

Information relating to an investment

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think may be of interest to you. This is how we decide which potential investments and services and may be relevant for you. You will receive important and time sensitive information from us if it relates to an investment you have made, or has been made on your behalf, or relates to a company that you have a relationship with. You will receive this important information by virtue of successfully completing an application process for investment or are a member of one of our investee companies or have asked to be sent information.

Provision of confidential information to third-parties

We will get your express opt-in consent before we share your personal data with any individual or company outside the PXN group of companies. For example, your data may be provided to 3rd party client relationship managers.

However, where a third-party is contracted by us for example for the purposes of executing a transaction with the a custodian or registrar, we will not explicitly request your permission. Similarly, your personal information may be provided to investee companies, for example as part of an investment process.

Opting out

You can ask us or third parties with whom we have shared data to stop sending you information at any time by contacting us at the DPO email address above (dpo@pxngroup.co.uk).

Where you opt out of receiving marketing information, this will not apply to personal data provided to us as a result of becoming a member of the our investment syndicates or investor of one of our managed funds. It will also not apply to the investee companies that you may have investments in as they have a legal responsibility to keep a record of their investors.

Cookies

Our Website makes use of cookies (files which our server uses to identify your computer) to understand site usage and to improve the content and offerings on our site. Cookies cannot identify which person is using the computer. We may use cookies to personalise your experience and provide you with a better service.

Cookies can only be placed on a computer where the user has given their express consent. You can choose to accept or decline cookies when you first access our Site via an automated “pop-up” box. Most web browsers automatically accept cookies, but you can also usually modify your browser setting to decline cookies if you prefer. If you decline to accept our use of cookies or set your web browser to decline their use, you will have only limited functionality in the use of our site.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless a different, compatible reason arises. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis. Please note that we may process your personal data without your knowledge or consent, in compliance with anti-money laundering and any other regulatory requirement, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with both internal and external parties. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We will share your personal data within the PXN Group. This may involve transferring your data outside the United Kingdom (UK).

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to access it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any actual or suspected personal data breach and will notify you and the applicable regulators of a breach where we are legally required to do so.

8. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for satisfying any legal, accounting, or reporting requirements.

By law we have to keep basic information about our investors (including Contact, Identity, Financial, Transaction Data and Investment Experience) until they cease being customers for regulatory purposes. We will also keep information about the companies we have invested in (investee companies) including personal data relating to employees of those companies.

In some circumstances you can ask us to delete your data (see Request erasure below).

9. Your legal rights

You have the following rights under data protection laws in relation to your personal data:

Request access to your personal data held by us, known as a Data Subject Access Request.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

Note: We may not be able to respond to a request to delete or transfer data from our encrypted archive storage systems.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly repetitive or excessive in terms of the volume of data requested or is unfounded.

What we may need from you

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 in relation to your request to speed up our response, for example, a set time frame for the search to be conducted.

Time limit to respond

We try to respond to all requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Privacy Policy