1. Introduction This Privacy Policy explains how Novalure CLG (“we”, “us”, “our”) collects, uses, stores and protects personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Irish Data Protection Act 2018. We are committed to protecting your privacy and handling your personal data in a transparent and lawful manner. 2. Data Controller Data Controller: Novalure CLG 20 Harcourt Street Dublin 2 D02 H364 Ireland Email: hello@novalure.eu Website: www.novalure.eu 3. Scope of Application This Privacy Policy applies to: +visitors of our website +prospective clients, investors and business partners +users contacting us via email, contact forms or other communication channels 4. Legal Basis for Processing We process personal data on the basis of one or more of the following legal grounds (Article 6 GDPR): +Consent (Art. 6(1)(a)) +Performance of a contract or pre-contractual measures (Art. 6(1)(b)) +Legal obligation (Art. 6(1)(c)) +Legitimate interests (Art. 6(1)(f)), in particular business communication, website security and marketing, provided such interests are not overridden by your rights 5. Categories of Personal Data Depending on the interaction, we may process the following categories of data: +Identification data (name, company name) +Contact data (email address, phone number) +Business and project-related information +Communication content (emails, inquiries) +Technical data (IP address, browser type, device information) 6. Purpose of Data Processing Personal data is processed for the following purposes: +operation and security of the website +responding to inquiries and communication +provision of advisory and consulting services +contractual and pre-contractual relations +compliance with legal and regulatory obligations +internal administration and documentation 7. Cookies and Similar Technologies Our website may use cookies and similar technologies. Depending on configuration, this may include: +technically necessary cookies (essential for website operation) +optional analytics or marketing cookies (only with prior consent) Detailed information is provided in our Cookie Policy (if applicable). 8. Hosting and Technical Infrastructure Our website is hosted by professional service providers within the European Union or in jurisdictions with an adequacy decision or appropriate safeguards pursuant to Articles 44–49 GDPR. Appropriate technical and organisational measures are implemented to ensure data security. 9. Disclosure of Data to Third Parties We do not sell or rent personal data. Data may be disclosed only: +to service providers acting as processors under GDPR (e.g. hosting, IT services) +to authorities where legally required +within professional advisory frameworks (legal, tax, compliance), subject to confidentiality

All processors are contractually bound by Data Processing Agreements (DPAs).

10. International Data Transfers Where data is transferred outside the EU/EEA, this occurs only: +to countries with an adequacy decision, or +based on Standard Contractual Clauses (SCCs), or +other lawful safeguards under GDPR 11. Data Retention Personal data is retained only for as long as necessary for the respective purpose or as required by statutory retention obligations under Irish or EU law. 12. Data Subject Rights You have the following rights under the GDPR: +right of access (Art. 15) +right to rectification (Art. 16) +right to erasure (“right to be forgotten”, Art. 17) +right to restriction of processing (Art. 18) +right to data portability (Art. 20) +right to object to processing (Art. 21) +right to withdraw consent at any time Requests may be submitted to: hello@novalure.eu 13. Right to Lodge a Complaint You have the right to lodge a complaint with a supervisory authority. The competent authority for Ireland is the Data Protection Commission (DPC). 14. Security Measures We implement appropriate technical and organisational measures to protect personal data against loss, misuse, unauthorised access, disclosure or destruction. 15. Changes to This Privacy Policy We reserve the right to amend this Privacy Policy where necessary to reflect legal, technical or business changes. The current version is always available on our website. 16. Contact If you have any questions regarding data protection or this Privacy Policy, please contact: Novalure CLG Email: hello@novalure.eu

Legal Notice / Imprint Company name: Novalure CLG Legal form: Company Limited by Guarantee (CLG), incorporated in Ireland Registered office: 20 Harcourt Street Dublin 2 D02 H364 Ireland Registration number: 796735 Register: Companies Registration Office (CRO), Ireland Email: hello@novalure.eu Website: www.novalure.eu Business activity International real estate advisory, investor sourcing, structuring and consulting services. Novalure CLG provides non-regulated advisory services. No activities requiring authorization under Irish or EU financial services law (including MiFID II) are carried out unless explicitly stated otherwise. VAT information VAT registration number: [“VAT not registered/pending”] Disclaimer (Liability for content) The content of this website has been created with the greatest possible care. However, no guarantee is given for the accuracy, completeness or timeliness of the content. As a service provider, Novalure CLG is responsible for its own content on these pages in accordance with general laws. Liability for links This website may contain links to external third-party websites. Novalure CLG has no influence over the content of those websites and therefore assumes no liability for external content. Intellectual property All content, texts, graphics and logos on this website are subject to copyright and other intellectual property laws. Any reproduction, distribution or use beyond the scope of copyright law requires prior written consent. Governing law and jurisdiction This website and its legal notice are governed by the laws of Ireland. Place of jurisdiction, insofar as legally permissible, is Dublin, Ireland.