Commitment to Discretion

ASM Holdings and its subsidiaries (“the Group,” “we,” “us”) operate with the highest regard for the privacy of our partners, investors, and stakeholders. This Privacy Policy outlines our standards for the collection, use, and protection of information obtained through our digital platforms and professional engagements.

Information Collection and Use

As a private investment group, we do not engage in the mass collection of consumer data. We only collect information that is voluntarily provided through strategic inquiries or during the course of professional due diligence. This may include:

• Identification Data: Name, professional title, and entity affiliation.

• Contact Information: Professional email addresses and telephone numbers.

• Inquiry Details: Information provided regarding potential partnerships, acquisitions, or project mandates.

This data is used exclusively to facilitate confidential communications and to evaluate the alignment of opportunities with our investment framework.

Data Security and Confidentiality

Information security is central to our operational integrity. We implement robust technical and organizational measures to protect data against unauthorized access, disclosure, or alteration.

• Restricted Access: Access to sensitive information is strictly limited to authorized members of our investment committee and executive leadership.

• Non-Disclosure: We do not sell, trade, or rent professional data to third parties. Information is only shared with service providers or legal authorities when necessary to fulfill contractual obligations or comply with statutory requirements.

Global Compliance Standards

ASM Holdings operates in accordance with international data protection principles, including the General Data Protection Regulation (GDPR) and the relevant data privacy laws of the United Arab Emirates (DIFC/ADGM) and other operating jurisdictions. We ensure that cross-border data transfers are handled with the same level of protection as required by global institutional standards.

Data Retention and Rights

We retain professional information only for as long as necessary to fulfill the purposes for which it was collected, or as required by financial and legal retention mandates. Individuals may request access to, or the correction of, their personal data held by the Group by contacting our Compliance Office.

Policy Updates

This policy may be updated periodically to reflect changes in our operational environment or global regulatory requirements. The current version will always be accessible via our digital platform.

Contact Our Compliance Office

For matters regarding data privacy or the handling of confidential information, please contact: Email: compliance@asmholdings.com