Privacy Notice

The privacy of your personal data is important to Harris Williams (the “Firm” or “Harris Williams”) (comprised collectively of Harris Williams LLC, Harris Williams & Co. Ltd, Harris Williams & Co. Corporate Finance Advisors GmbH, Harris Williams Private Capital Advisory UK Ltd., an Appointed Representative of Sturgeon Venture Partners. This Privacy Policy (the “Policy”) describes Harris Williams’ privacy policy as it pertains www.harriswilliams.com (the “Website”), digital marketing programs (such as the Firm’s marketing emails, e-Newsletters, and digital advertising programs) and other information we may collect.

If you are an EU national and reside in the EU, or are a non-EU national residing in the EU, the data controller (as defined under EU data protection law) will be the Harris Williams’ relevant entity that you engage with. You may find the contact details of the data controller, including its representative, and of the relevant Data Protection Officer (“DPO”) under www.harriswilliams.de, https://www.harriswilliams.com/de/kontakt and dpo.germany@harriswilliams.com.

If you are a California resident, please click https://www.harriswilliams.com/privacy-notice-for-california-residents to review our Privacy Policy for California Consumers to learn about your rights under the California Consumer Privacy Act, as amended.

INFORMATION WE COLLECT

Harris Williams may ask for and collect from you personally identifiable information including name, gender, email address, telephone number, mailing address, other personal or preference information, details about your operating system, internet service provider, browser, IP address, the company name that the relevant IP address is affiliated with, the pages you visited on the Website, and websites you linked to and from.  Harris Williams is entitled to process your personal data as necessary for the performance of the engagement with you, or in order to take steps at your request prior to entering into an engagement (legal basis: performance of contract). Apart from this, the information we collect upon your visit to our Website is collected based on our legitimate interest to provide the Website and our online services to you in the most efficient way (legal basis: legitimate interests).

Harris Williams is subject to certain regulatory requirements under various anti-money laundering laws in Europe and the United States which require us to verify the identity of clients and other parties.  So the Firm may need to make certain inquiries and obtain certain information from you for that purpose.  You confirm that all information you supply will be accurate and that we may disclose such information as we consider necessary to comply with any reporting or legal and regulatory requirements. Therefore, such processing of your personal data is lawful, as it is necessary for compliance with certain legal obligations to which Harris Williams may be subject (legal basis: compliance with a legal obligation).

USES OF COLLECTED INFORMATION

The purposes for which we process and store your Personal Information are:

• To administer, monitor, understand Website performance and use, and to improve the user experience;

• To administer, monitor, understand marketing email performance and use, and to improve the user experience;

• To enable us to aggregate user profiles;

• Where you have requested it or in accordance with privacy laws, to provide you (by email, phone and/or mail) with marketing, promotional, or other information that we think may be of interest to you;

• To execute events and other programs, which you have opted into, or not opted out of;

• To execute digital advertising campaigns which you have opted into, or not opted out of;

• As part of current or future legal or similar proceedings; and

• To enable us to comply with our legal and regulatory obligations.

Any promotional correspondence to you will provide you with the ability to opt-out of receiving future promotional material from us, such as by clicking on the “unsubscribe” link in any of our promotional emails that you may receive. Please note that promotional emails are different from emails related to events (described further below), such as event invitations, updates or event-related promotions. If you wish to opt-out of event-related emails, you must click on the “unsubscribe” link in those emails as well, because unsubscribing from non-event related promotional emails does not unsubscribe you from event-related invitations and promotional emails (and vice versa). Thus, to opt-out of both event (including invitations) and non-event related promotional emails, you must click on the “unsubscribe” link on both types of emails whenever you receive them in order to be unsubscribed for both. You may also contact us at any time to tell us that you do not want to receive marketing, promotional and/or event information from us by emailing us at the email address below.

Please note that Harris Williams will store and use your Personal Information only as long as it is necessary for the purposes stated above. If such purposes have been fulfilled or cannot be reached anymore, we will erase your personal data and delete any documents immediately, unless we need to retain the data due to legal obligations or for the establishment, exercise or defense of legal claims.

HOW WE COLLECT INFORMATION

Harris Williams may ask for and collect from you personally identifiable information. This processing and use of information as described above is lawful as far as it is necessary for the performance of the engagement with you, or in order to take steps at your request prior to entering into an engagement (legal basis: performance of contract). Content available to website visitors may be different for each visitor based on their prior pages accessed and cookie selection.

We also collect information through our service providers (e.g. Google Analytics, YouTube, Google Ads, LeadLander, and LinkedIn) and through cookies, web beacons, pixel tags or similar digital marker technologies. These methods permit us to collect various types of information, including which pages you visit, which of our newsletter articles you clicked on, and ads you clicked on. This data is used to more efficiently operate Harris Williams’ business, promote our services and administer the Website. Harris Williams may combine this information with the personally identifiable and other information it collects. The collection of data on your device that is strictly necessary for operating the Website and ensuring its stability or security (e.g. storing and accessing data on your device through Strictly Necessary Cookies set on the device) is legally permitted. The subsequent processing of this data is based on our legitimate interest whereby the above purposes constitute our legitimate interest. Other collection of data on your device through cookies and other technologies and the subsequent processing of this data through our service providers are based on your consents. You can revoke a consent once given at any time with future effect in our Privacy Preference Center Manage Cookies. In addition to the above, we note that “Do Not Track” is a type of privacy setting that web site visitors can set in certain web browsers. Harris Williams does not currently recognize or respond to “Do Not Track” signals from browsers. To learn more about Do Not Track, click https://allaboutdnt.com.

Please also refer to our Cookie Policy, which explains the use of cookies. For instructions on rejecting or deleting cookies, please visit allaboutcookies.org.

Please note that automated decision making, including profiling, will not take place at Harris Williams.

EVENTS BY HARRIS WILLIAMS

The Firm is the data controller of information you provide to us in relation to events hosted or organized by HW which you attend or express an interest in attending (an “Event”). The following information provides details of the processing of your personal data which may be carried out to allow you to participate in an Event and to ensure your experience at the Event is as smooth and comfortable as possible (legal bases: legitimate interests and, where specified, consent).

Personal Data Collected

The personal data which may be processed in connection with an Event is usually the information which you provide to us through the registration process. The type of personal data collected will depend on the Event but will normally include your name, title, contact details (email, phone number and address), company name, fund size and certain other biographical information.

Event Information Sharing and Storing

In relation to some Events, we arrange specific activities, such as sporting or social activities, and it may be necessary to provide certain information you provide to us to third parties who we engage to provide such activities.

If you provide us with information in relation to allergies and dietary requirements you will be asked for your consent to us providing that information to the relevant provider (such as a restaurant or hotel) so that this information can be taken into account in any food presented to you. If you do not consent, you will need to inform the relevant provider of any allergies and dietary requirements directly. You may withdraw your consent at any time, but this will not affect the sharing of data which has already happened by the time you withdraw consent.

If we arrange travel or accommodation on your behalf in connection with an Event, your name and the dates for which you wish to book accommodation will be provided to the relevant travel provider, hotel or other accommodation provider for the purposes of booking your travel or accommodation. If you provide us with your flight details, this information will may be provided to the relevant hotel or other accommodation provider in order to give them an indication of your expected arrival time. Your flight details may also be provided to your contacts at Harris Williams so they can know when you will be expected.

Certain information that you provide to us, such as your name, title, phone number, company name, fund size and certain other biographical information may be provided to other delegates at an Event for the purposes of networking (legal bases: performance of contract and/or legitimate interests and, where specified, consent). The sharing of this information may include the provision of information through an app provided for use by delegates. The provider of the app may commonly be located in the United States and your information will therefore be transferred to the United States for the purpose of inclusion in the app. We will ensure that the transfer is carried out in accordance with data protection legislation.

As a general matter, if you tell us you wish to attend an Event, your name and organization will be shared with the venue. We may also share your information when legally required to do so (legal basis: compliance with a legal obligation).

We will only retain the information you provide in connection with an Event for as long as it remains necessary for us to keep it for the purposes set out above. This does not affect our ongoing use of your personal data which has been collected or is collected in the future for other purposes.

Any event invitations or other event-related promotional emails to you will provide you with the ability to opt-out of receiving future event-related promotional material from us, such as by clicking on the “unsubscribe” link in any of our event-related promotional emails that you may receive. As noted above, promotional emails are different from event invitations and other event-related promotional emails. Thus, if you wish to opt-out of non-event related promotional emails, you must click on the “unsubscribe” link in those emails as well, as unsubscribing from non-event related promotional emails will not stop event-related invitations and promotional emails (and vice versa). You may also contact us at any time to tell us that you do not want to receive marketing, promotional and/or event information from us by emailing us at the email address below.

INFORMATION SHARING

Unless otherwise stated in this Privacy Policy, Harris Williams may disclose your personal data to another entity (i) for purposes of outsourcing one or more of its services or the functions described above; (ii) to confirm or update information provided by you; (iii) to inform you of Events, information about its services, and other important information, (iv) for other purposes disclosed at or before the time the information is collected, or (v) for purposes you have explicitly consented to. In cases where information is shared, we will seek assurances where practicable that the receiving party has implemented appropriate technical and organizational measures to ensure the security of your personal data. The legal basis for the transfer of your personal data under data protection legislation will be that it is necessary for the fulfillment of our engagement, that it is necessary for the purpose of our legitimate interest to provide you with our services and run our Events in the most efficient way, or, when you have consented to the sharing of data, your consent.

We may provide your personal data to our affiliates, including without limitation The PNC Financial Services Group, Inc. to the extent permitted by applicable law. For this purpose, we may transfer the information you provide outside your country to another country that does not have similar data protection legislation and may provide a lower level of protection for your information. We may share your Personal Information with vendors we have hired to provide services for us where it is necessary for the service. We are permitted to share your personal data with our affiliates or vendors where they process data on our behalf and with whom we have concluded a contract on commissioned data processing. We may also release Personal Information about you if you explicitly consent to the sharing of your data, or if we are required or authorized by law, or if we reasonably believe that the disclosure is necessary in order to (a) fulfill a government request; (b) conform with the requirements of law or to comply with legal process served on us; or (c) protect or defend our legal rights or property or third party licensors of any material on the Website.

PROTECTING YOUR INFORMATION

Harris Williams attempts to protect against the loss, misuse and alteration of your Personal Information. Appropriate measures have been taken to safeguard your Personal Information to prevent unauthorized access, and to comply with applicable laws regarding the protection of such information. These measures may include physical, electronic or other procedural protections, such as passwords, firewalls, and encryption or authentication technology. While we do our best to protect your Personal Information, we cannot ensure or warrant the security of any information that you transmit to us. The information you provide to us is sent over an open network, such as the Internet or email, and may be accessed by anyone. We cannot guarantee the confidentiality of any communications or materials sent to us over such open networks. We therefore do not accept any liability for direct or indirect losses in relation to security of any data that you send to us over an open network.

UPDATING YOUR PERSONAL INFORMATION.

To ensure that you have as much control over your personally identifiable and other information as possible, you may update your information by contacting us as provided in the “Contacts” section below. We will use reasonable efforts to process any change you make; provided, however, that requests to delete information are subject to Harris Williams` internal reporting and retention policies and all applicable legal obligations.

INTERNATIONAL TRANSFERS

We are an international practice and your data might be passed on to our international offices, some of which are in countries outside the European Economic Area, including the United States. The Website is hosted on servers in the United States. Of course, we have implemented the necessary guarantees to protect the transmission of your data as well as its processing on our servers and to ensure an adequate level of data protection.

CONSENT

Upon entering the Firm`s website you have the opportunity to explicitly consent to our collecting and using your Personal Information in the manner described in this Policy.

WEBSITE

The www.harriswilliams.com Website collects Personally Identifiable Information outlined above, and uses cookies and tracking mechanisms. To comply with privacy regulations, visitors will identify their country and be directed to a site compliant with local regulations. Visitors that indicate that they are an EU national or reside in the EU will be directed to a version of the website on which tracking mechanisms have been removed. Certain Personal Information, such as name, email and company, may still be collected for EU residents or nationals when it is shared by those visitors directly, such as to opt into our e-newsletter program and provide consent.

The Website includes all web pages accessible by the public. Any reference to “you” in this Policy shall mean any user of the Website, including without limitation employees of Harris Williams.

Please note that this Policy does not apply to other organizations to which we link. We are not responsible for their privacy policies or practices of any other third party websites and you should make your own inquiries regarding them.

We take your privacy very seriously. Your use of the Website, including any disputes arising from it, is subject to this Policy as well as our Terms of Use, Disclosures, and Cookie Policy and all dispute resolution provisions therein, including the limitation of liability and choice of law provisions.

CHILDREN

Children under 16 years old are not the target audience for the Website. To protect their privacy, we prohibit the solicitation of Personal Information from these children. If you are under the age of 16, please do not submit your email address or any other personal information to us through the Website.

YOUR RIGHTS AS A DATA SUBJECT

If we process your Personal Information, you have the right to request a copy of the Personal Information that we hold about you, including a confirmation as to whether or not your personal data are being processed according to GDPR, or similar privacy regulations. If you discover any inaccuracy, please let us know so that we can make whatever corrections are appropriate. Moreover, you have the right to ask us to erase your personal data, if there are no legal reasons for us to retain it (such as freedom of expression, legal requirements, public interest or if required as evidence in legal disputes). When we delete data that we've shared with third parties, we will also contact those third parties and ensure that your data are erased there as well. Apart from this, you can assert your right to limit the processing of your personal data when (i) you contest the accuracy of your personal data, during the time necessary to verify the accuracy of such data; (ii) the processing of your personal data is unlawful but you oppose the erasure thereof and instead demand the limitation of processing; (iii) we no longer need your personal data but you still need such personal data for the establishment, exercise or defense of legal claims; or (iv) you have objected to processing pending the verification whether our legitimate grounds override those claimed by you.

You further have the right to receive personal data you have provided to us in a structured, commonly used and machine-readable format, and to transmit such data to another controller or other party without hindrance from Harris Williams. Whenever this is technically feasible, you may also request that your personal data be transmitted directly to another data controller or other party by Harris Williams.

If we process your personal data on the legal basis of your consent, you have the right to withdraw your consent at any time with future effect. Please note that a revocation of your consent does not affect the lawfulness of processing carried out prior to such revocation.

You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on legitimate interests, including profiling. In this case Harris Williams will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

You may also ask us at any time to remove your name from our marketing databases and if you do that we will comply as soon as practicable.

If, despite our efforts to protect the confidentiality of your personal data, you consider that your rights have not been respected, you have the right to file a complaint with the national data protection authority, or similar authority, in your country.

If you wish to request access to your personal information or wish to exercise one of your rights described above, please email or write to us at the email address or postal address set out below in the “Contact Us” section.

CANDIDATES

If you apply for a role with the Firm, including in the EU or UK, the Firm will collect certain Personal Information from you as part of the application process, which will include any information you provide through the “Join Harris Williams” function available on the Website.  The information will be used for the purposes of considering your application for employment. The lawful basis for the processing of this information is that it is necessary in order to take steps at your request prior to potentially entering into a contract with you and in some cases it will also be necessary for our legitimate interests in selecting the best candidate for a role, as well as complying with legal obligations (such as verifying a person’s right to work in the jurisdiction relevant to their application).  

The Firm uses an external service provider for the purpose of processing reference checks relating to candidates for employment, which is located in the United States. As part of the engagement of this service provider, we may provide them with your name, email address and mobile phone number.

CALIFORNIA RESIDENTS

As noted above, California recently passed consumer privacy laws, including the California Consumer Privacy Act of 2018 and several amendments thereto (collectively, the “CCPA”), which provides California residents, including employees of Harris Williams, with specific rights regarding their personal information. If you are a California resident, please click https://www.harriswilliams.com/privacy-notice-for-california-residents to review our Privacy Policy for California Consumers to learn about your rights under the California Consumer Privacy Act, as amended.

SHARING OF CLIENT INFORMATION (EXCLUDING PERSONAL INFORMATION)

In certain instances, we share, subject to confidentiality and non-disclosure obligations to us, client business information with an unaffiliated third party (a “Third-Party Co-investor”) for the purpose of such third party identifying and pursuing possible co-investments. Such information includes information and facts for use by such Third-Party Co-investor in identifying potential transactions that are consistent with the Third-Party Co-investor’s investment strategy, and arranging for introductions of clients to such Third-Party Co-investors, as well as facts related to our due diligence inquiries into the client business, operations, properties, financial condition, market(s), industry and prospects of the business that is the subject of a potential transaction, including, as permitted, making marketing materials provided to third parties available to the Third-Party Co-investor. Such information will not include Personal Information. Harris Williams will not make any investment recommendations and shall have no responsibility for these determinations.

Nevertheless, we will obtain our client’s consent before such Third Party Co-Investor contacts any prospective purchaser regarding a co-investment opportunity involving a client or a client’s transaction. Following client consent, and if the co-investment proceeds, Managing Directors and certain other personnel of Harris Williams and its subsidiaries may indirectly acquire an interest in the counterparty to, or entity resulting from, certain clients’ transactions.

Notwithstanding the foregoing, Harris Williams is not an investment adviser and will not provide investment advice (including advice as to the advisability of investing in, purchasing, or selling securities or analyses or reports concerning securities) to any third-party co-investor.

CONTACT US

Should you feel that your privacy or security is being compromised, wish to make a request for access to any personal data we may hold about you or wish to exercise one of your rights as described further on the “Your Rights As A Data Subject” section above, or have any questions on this policy, please contact us at Harris Williams, 1001 Haxall Point, 9th Floor, Richmond, Virginia 23219 or email data.privacy@harriswilliams.com.

POLICY CHANGES

We reserve the right to change our Privacy Policy at any time. We encourage you to refer to this Policy on an ongoing basis so that you understand our current Privacy Policy.

APPENDIX: AUSTRALIAN PRIVACY STATEMENT

This Australian Privacy Statement supplements and incorporates and should be read together with the information contained in our Privacy Policy to which this is an appendix by providing additional information about our privacy practices in relation to our Australian Related activities. To the extent this Australian Privacy Statement applies (i.e. if you or the transaction are Australian Related), any matters expressly addressed in this Australian Privacy Statement will, unless otherwise noted, apply to the exclusion of the terms of the Privacy Policy. Also, if there is any conflict between the terms of this Australian Privacy Statement and our Privacy Policy, the terms of this Australian Privacy Statement will prevail. Otherwise, the terms of the Privacy Policy apply and are incorporated into this Australian Privacy Statement.

References to “personal data”, “personally identifiable information” and “personal information” in our Privacy Policy will, for the purposes of this Australian Privacy Statement, be taken to have the same meaning as “personal information” under the Australian Privacy Act 1988 (Cth) (the “Privacy Act”) for the purposes of this Australia Privacy Statement. Also, references to “sensitive information” in this Australian Privacy Statement have the same meaning as “sensitive information” under the Privacy Act. Unless otherwise specified, for the purposes of this Australian Privacy Statement, all references to “personal data”, “personally identifiable information” and “personal information” in the Privacy Policy and all references to “personal information” in this Australian Privacy Statement include “sensitive information”.

References to “data subjects” in the Privacy Policy are taken to have the same meaning as “individuals” under the Privacy Act for the purposes of this Australian Privacy Statement.

You are not required to provide personal information to us, but we do rely on your personal information to conduct our Australian Related activities. For example, we need your personal information to comply with various anti-money laundering laws before undertaking our Australian Related activities. If you choose not to provide us with your personal information, we may not be able to verify your identity, respond to your inquiry, address your requests or complaints or otherwise interact with you.

The Privacy Act and this Australian Privacy Statement do not differentiate between “controllers” and “processors” of personal information and apply irrespective of whether we would be considered a controller or processor under the Privacy Policy or any privacy law.

Where additional personal information or sensitive information not detailed in this Australian Privacy Statement is to be collected, we will provide you with a separate privacy collection notice (“PCN”) for that collection. Any such PCN is to be read together with this Australian Privacy Statement in relation to that collection.

The specific types of personal information and sensitive information we collect about you depend on our investment decisions concerning companies, trusts or other entities to which you are related. By providing us with any of your sensitive information, you consent to us collecting, using and disclosing that sensitive information in accordance with this Australian Privacy Statement and any relevant PCN. This consent remains valid unless and until you notify us in writing (using the details set out in the section “Contact Us” in the Privacy Policy) of the withdrawal of your consent to our processing of your sensitive information. However, if you do withdraw your consent or if you do not provide us with the sensitive information requested for the relevant purpose(s), we will be unable to provide you with the relevant services for which we are seeking to collect, use and disclose your sensitive information.

Where you provide us with personal information about any individual, you warrant that you have the authority of that individual to disclose such information and that you have referred that individual to the Privacy Policy, this Australian Privacy Statement and any relevant PCN regarding how we collect, use and disclose the personal information.

Where you provide us with sensitive information about any individual, you warrant that you have the consent of that individual to disclose such information and that you have referred that person to the Privacy Policy, this Australian Privacy Statement an any relevant PCN and they consent to us collecting, using and disclosing the sensitive information in accordance with the Privacy Policy, this Australian Privacy Statement and any relevant PCN until that consent is withdrawn by notifying us in writing (using the details set out in the section “Contact Us” in the Privacy Policy) of the withdrawal of the consent to our processing of the sensitive information.

On entering the Website, your continued use of the Website or our services in respect of our Australian Related activities or providing any personal information will be deemed to your notification of the Privacy Policy and this Australian Privacy Statement.

INFORMATION WE COLLECT

If we are required to verify your identity under various anti-money laundering laws, we collect and hold the following kinds of personal information about you:

• Name, date of birth and gender

• Contact information such as email address, telephone number and address

• Information in identification documents such as passport and driver’s licence, nationality and other government related identifiers

• Country of residence and job title

• Identity information of your family members

• Financial information such as bank account information, beneficial ownership, information of your assets and liabilities, and transaction information

USES OF COLLECTED INFORMATION

All purposes of us collecting, using, processing, storing or disclosing personal information as detailed under this heading and anywhere else in our Privacy Policy, despite the wording used in the Privacy Policy, are “primary purposes” for our collection, use and disclosure of that personal information under the Privacy Act.

HOW WE COLLECT INFORMATION

If we are required to verify your identity under various anti-money laundering laws, we may collect your personal information:

• Indirectly from companies of which you are a shareholder, director, beneficial owner or trusts of which you are a trustee or beneficiary or in which you have an interest

• Indirectly from your authorized representative

• Directly from you when you provide us with your personal information by mail, email or phone

PROTECTING YOUR INFORMATION

The steps that we take to protect your personal information are those that are reasonable in the circumstances to protect the information from misuse, interference, loss and unauthorised access, modification or disclosure.

UPDATING YOUR PERSONAL INFORMATION

Please refer to your rights set out in the section “Accessing and Correcting Your Personal Information” below.

INTERNATIONAL TRANSFERS

In addition to the United States, we may disclose your personal information outside of Australia to, or store, access, or process personal information in the United States.

ACCESSING AND CORRETING YOUR PERSONAL INFORMATION

Subject to certain exceptions, the Privacy Act gives you the right to request access to the personal information we hold about you and the right to request correction of personal information about you that is inaccurate, out-of-date, incomplete, irrelevant or misleading.

You can request to exercise these rights to access or correct your personal information by contacting us using our contact details in the “Contact Us” section in the Privacy Policy. Once we verify your identity, subject to any applicable exceptions we will give you access to or correct that personal information as required under the Privacy Act.

COMPLAINTS

If you have a complaint about our privacy practices or believe that we have breached your privacy in relation to your personal information, please contact us using our contact details in the “Contact Us” section in the Privacy Policy. We will investigate your complaint and attempt to resolve it.

We will investigate your complaint, respond within a reasonable time and attempt to resolve it. If we cannot resolve your complaint to your satisfaction you may then contact the Office of the Australian Information Commissioner for consideration of your complaint online (here) or by phone at 1300-363-992 (from within Australia) or +61-2-9942-4099 (from outside Australia).

POLICY CHANGES

The Privacy Policy and this Australian Privacy Statement will be reviewed and updated from time to time and we will note this on the Website. If any changes are significant or substantial we will let you know of this on the Website or by email if you have provided us with your email address.

Your provision of further personal information to us after notice that the Privacy Policy and/or this Australian Privacy Statement has been revised will be deemed to be your acknowledgement of (and in the case of sensitive information, your consent to) the revised Privacy Policy and/or Australian Privacy Statement.

This Australian Privacy Statement was last updated on November 5, 2025.