Privacy Notice for US and Canada Advisory Business

/ Introduction

Your privacy is very important to us. This privacy notice (“Privacy Notice”) is provided by Perella Weinberg Partners LP, Tudor, Pickering, Holt & Co. Securities – Canada, ULC, and Devon Park Securities, LLC (“PWP”, “we” or “us”) and sets forth the policies for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of your personal information. We may change this privacy notice from time to time without prior notice to you. Any changes will be effective immediately upon posting to our Site.

The policies and procedures described herein are reasonably designed to safeguard your customer information against unauthorized access and use in accordance with these regulatory requirements.

/ The types of personal data we may collect and use

The categories of personal data we may collect include names, residential addresses or other contact details, telephone number(s), account numbers, nationality, tax identification number, date of birth, place of birth, copies of identification documents, bank account details, information about assets or net worth, credit history, and/or other sensitive information.

/ How we collect personal data

We may collect personal data about you through: (i) information provided directly to us by you, or another person on your behalf; (ii) information we obtain through or in connection with the provision of products and services; (iii) through our websites and (iv) recording and monitoring of telephone conversations and electronic communications with you.

We also may receive your personal information from third parties or other sources, such as our affiliates, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the Internet.

/ Using your personal data: the legal basis and purposes

We may process your personal data for the purposes of administering the relationship between you and us (including communications and reporting), direct marketing of our products and services, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities with competent jurisdiction over our business). Your personal data will be processed in accordance with Data Protection Law and may be processed with your consent, upon your instruction, or for any of the purposes set out herein, including where we or a third-party consider there to be any other lawful purpose to do so.

Where personal data is required to satisfy a statutory obligation (including compliance with applicable anti-money laundering or sanctions requirements) or a contractual requirement, failure to provide such information may result in us being unable to provide services to you. Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.

/ How we may share your personal data

We may disclose information about you to our affiliates or third parties for the purpose of providing services to us (e.g. accountants, professional advisors, IT and communications providers, data storage vendors and other service providers), for our everyday business purposes, such as to enable that we can provide services to you, or to respond to court orders and legal investigations. We will also release information about you if you direct us to do so.

We may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by contacting us as described below (see “Who to contact about this Privacy Notice”). We may also disclose information about your transactions and experiences with us to our affiliates for their everyday business purposes.

/ Monitoring of communications

We may record and monitor telephone conversations and electronic communications with you for the purposes of: (i) ascertaining the details of instructions given in connection with the delivery of our services to you; (ii) ensuring compliance with our regulatory obligations; and/or (iii) detecting and preventing the commission of financial crime.

/ Retention periods and security measures

We will not retain personal data for longer than is necessary in relation to the purpose for which it is collected, subject to Data Protection Law. How long we will hold your personal data will be determined by: (a) the purpose of which we are using it- we will need to keep the data for as long as it is necessary for that purpose; and (b) legal and regulatory obligations- laws or regulation may set the minimum period for which we have to keep your personal data. From time to time, we will review the purpose for which personal data has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us.

To protect your personal information from unauthorized access and use, we apply organizational and technical security measures in accordance with Data Protection Law and Regulation S-P. These measures include computer safeguards and secured files and buildings. We maintain written policies and procedures reasonably designed to safeguard customer information and ensure the security and confidentiality of all nonpublic personal information. We will notify you of any material personal data breaches affecting you in accordance with the requirements of Data Protection Law.

/ Incident Response and Breach Notification

In the event of any unauthorized access to or use of your sensitive customer information, we have implemented an incident response program reasonably designed to detect, respond to, and recover from such incidents.

Should PWP become aware of a significant breach that exposes your personal information, we will make all reasonable efforts to notify you promptly, in accordance with applicable legal requirements.

/ International transfers and Data Protection

Because of the international nature of PWP, personal data may be transferred outside your home country, such as to jurisdictions where we conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by your own. Personal data transfers to jurisdictions outside the EEA, United Kingdom, or other data protection regimes are made only with appropriate safeguards, including:

  • Standard contractual clauses approved by applicable data protection authorities;
  • Adequacy decisions from relevant regulators;
  • Your explicit consent where required by applicable law; or
  • Other legal mechanisms recognized under Data Protection Law.

In such cases, we will take appropriate measures to ensure your personal information is handled as described in this privacy notice in accordance with Regulation S-P, Data Protection Law, and applicable cross-border data transfer requirements.

/ Your rights

Federal law gives you the right to limit only the following information sharing: (1) sharing with affiliates for everyday business purposes information about your creditworthiness; and (2) sharing with non-affiliates for the purpose of marketing products or services to you. If you would like to limit any of the foregoing sharing purposes, please contact us in writing at the address below.

You may contact us at any time to limit our sharing of your personal information.

/  California Residents rights under CCPA

Where applicable, California residents have the following privacy rights under the California Consumer Privacy Act of 2018 (the “CCPA”). For the purposes of this section of the policy, “Personal Information” means any data that defines, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household, which is in the possession of, or is likely to come into the possession of, any PWP entity.

These rights include, to the extent required by the CCPA and subject to verification and any applicable exceptions:

  • the right to request information regarding Personal Information collected about you as described below:
  • the categories of Personal Information we have collected about you;
  • the categories of sources from which that Personal Information we have collected;
  • the specific pieces of Personal Information we have collected about you;
  • the categories of third parties to whom such Personal Information was disclosed;
  • the business or commercial purpose for which the Personal Information was collected;
  • the right to request that we erase your Personal Information in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Information but we are legally entitled to retain it; and
  • the right to be free from unlawful discrimination for exercising any of the rights above.

We will need to verify your identity prior to addressing or fulfilling a request made pursuant to the CCPA. Your request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to Personal Information collected about you. To designate an authorized agent, the authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on their behalf.

Please note that PWP does not, and will not, sell Personal Information collected about you.

You can exercise your rights by contacting us using the details listed below under the section titled “Who to Contact about this Privacy Notice.”

/ Who to contact about this Privacy Notice

If you have any questions about our Privacy Notice please contact our Compliance Department in writing at 767 Fifth Avenue, New York, NY 10153, or by email at Compliance@pwpartners.com

Date effective and last updated: December 2025

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