ALTRATA PRODUCT TERMS

Updated: FEBRUARY 2026

1. Introduction

1.1 The following words shall have the meanings set out against them below:

“Affiliate” means all entities which from time to time, control, are controlled by or are under common control of a party, where control/ controlled in this context means that a person possesses, directly or indirectly, the power to direct or cause the direction of the management and policies of the entity, whether through the ownership of voting shares, by contract or otherwise;

“Agreement” means the Terms and the Order Form into which the Terms are incorporated;

“Artificial Intelligence Tools” means any and all machine learning, deep learning, and other artificial intelligence technologies, including statistical learning algorithms, models (including large language models), neural networks, computer systems that simulate and can perform tasks (as range of diverse tasks or any single task) normally requiring human intelligence such as but not limited to, learning, reading, writing, creating, analyzing, decision-making and generation of data using generative models such as text, images, audio, and videos, and other artificial intelligence tools or methodologies, and all software implementations of the foregoing and related hardware or equipment;

“Authorized Users” means the employees, agents or individuals authorized or enabled by Client to have access to the Products;

“Client” means the client identified as such in the applicable Order Form;

“Client Personal Data” means the personal data shared by Client to Company in order to deliver the Products and shall include

the personal data of any Authorized Users and personnel;

“Company” means the company identified as such in the applicable Order Form;

“Confidential Information” means all information (however recorded or disclosed and whether or not identified as confidential) conveyed by one party or its representatives and received by the other party or its representatives including, but not limited to:

(a) Company’s Product(s) and Licensed Data; (b) any information that would be regarded as confidential by a reasonable business person, relating to a party’s business, systems, existing and planned products and services, employees, customers, clients, third party suppliers, plans and strategies, financial and technical information and any information which is, by its nature, confidential or which a party advises the other is confidential and includes the existence and terms of the Agreement. Confidential Information does not include information which the parties agree in writing to exclude from the terms of the Agreement and information which is, at the date of the Agreement, already properly in the possession of the other party and can be demonstrated by written record to be previously known or information which either party reasonably requires in order to effectively manage its business where such information does not include personal data;

“Data Protection Law” shall mean all laws and regulations applicable to a party relating to the processing, privacy and use of personal data in connection with or pursuant to the Agreement to the extent applicable to the parties including, without limitation, General Data Protection Regulation 2016/679 (“GDPR”), California Consumer Privacy Act of 2018 (“CCPA”), Personal Information Protection Law of the People’s Republic of China, any national laws, regulations or secondary legislation implementing the GDPR or Council Directive 2002/58/EC and any corresponding or equivalent national laws or regulations all as may be updated or replaced from time to time;

“data protection rights” “personal data” “processing” “controller” “special category” “data breach” “data processor” and “sensitive personal data” shall have the meaning given to it in Data Protection Law or to similar terms in Data Protection Law such as “personal information” and “business”;

“Deliverables” shall mean any deliverable provided by Company to Client and as may be further detailed in an applicable Order Form;

“Effective Date” shall mean the date the Order Form is fully executed;

“Fees” means such charges specified in the Order Form for provision of the Products plus VAT where applicable and any and all charges Company may incur as a result of being mandated by Client to utilize any specific named system, and any bank or other transactional charges of a similar nature;

“Intellectual Property” shall mean without limitation, any trademarks, logos, copyright, proprietary processes, databases, software, methodologies, tools, data procedures, algorithms, specifications, source code, object code, know-how, trade secrets, technology or modifications to the foregoing and all copies whether tangible or intangible embodiments of the foregoing, in whatever form or medium;

“Licensed Data” means the data available to Client within the Products and the Platform and may include personal data;

“Order Form” means one or more order forms for Client’s purchase and/or subscription to any Product(s) from Company which

shall incorporate the Terms by reference;

“On-Demand Products” means Client’s diligence products, dossiers, screening services, analytics, core reports, and any other

product identified in the Order Form as an on-demand/one-time product;

“Platform” means the online SaaS platform and/ or mobile app which enables the delivery of the Products;

“Products” means On-Demand Products or Subscription Products and reference to Products shall include Licensed Data,

Deliverables, downloads and Platform;

“Subscription Products” means Company’s Platform, integrations, data feeds screening software, and any other product identified in the Order Form as a subscription product, including licenses for access and use of any Product by Client’s Authorized Users; and

“Terms” means these Altrata Product Terms.

Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the Order Form.

2. Commencement and Term

2.1 The Agreement commences on the Effective Date and shall remain in place until the Order Form expires or is terminated, or the Agreement has otherwise terminated in accordance with the termination provisions below, or until Client ceases to use the Products if this date is after the expiry of an Order Form, whichever is the later (the “Term”).

2.2 Subscription Products

a) The Order Form for Subscription Products shall become effective on the Start Date and shall continue for the period to the End Date, as specified in the Order Form (“Initial Term”).

b) Following the Initial Term, the Order Form shall renew automatically for successive twelve (12) month periods (each a “Renewal Term”) unless written notice is given by either party at least sixty (60) days before the expiry of the Initial Term or applicable Renewal Term. Such renewal will be notified to Client at least ninety (90) days in advance of a Renewal Term commencing.

c) Company may increase the Fees by: 1) 6% of Fees in the Initial Term or Renewal Term; or 2) the then published Consumer Price Index, (along with the removal of any Initial Term or Renewal Term based discount) for any upcoming Renewal Term. Such changes will be notified to Client in writing at least ninety (90) days in advance of such Renewal Term commencing.

3. License

3.1 Company hereby grants to Client a limited, non-exclusive, non-sublicensable, non-transferable license to access and use the Products as described in the applicable Order Form solely for its own internal commercial use and in accordance with the Agreement.

3.2 Company does not provide investment, commercial, business or financial advice or services through the Products or otherwise. Client agrees that the Products and use thereof does not and will not constitute an offer or sale of any security, financial product, instrument or trading strategy (or the solicitation or recommendation thereof).

3.3 Company may, at its discretion, change, remove, suspend or discontinue any aspect of the Products at any time, provided that such change does not materially diminish the Products.

4. Client obligations and warranties

4.1 Client warrants that it:

a) shall not use any deep-link, page-scrape, spider, robot, index, internet agent or other automatic device, program, algorithm or any other technology which does the same actions to use, access, copy, acquire, input or store any Products or information from the Platform, or to search, generate searches or monitor any portion of the Products;

b) shall not use the Products or Licensed Data to train or improve any Artificial Intelligence Tools, nor shall it enter Licensed Data into any external Artificial Intelligence Tools. Client is only permitted to use Licensed Data in internal Artificial Intelligence Tools provided: (i) such usage occurs within a closed or self-hosted environment solely for internal use by Client and Authorized Users, (ii) the outputs or any derivative thereof is always consumed internally by Client and Authorized Users, and (iii) such usage does not result in the third-party provider of any such Artificial Intelligence Tools retaining any portions of the Licensed Data;

c) shall not resell or re-license, share in any way, or reverse engineer the Product or Licensed Data, or develop or attempt to develop any competing products or services;

d) shall not use the Product or Licensed Data for any purpose that is unlawful or prohibited by the Agreement;

e) shall not upload or introduce in any way, any Client Personal Data which may consist of special category, sensitive personal data, or personal data of anyone under the age of 18 or any personal data consisting of national identifier number (including but not limited to social security number, National Insurance number or Passport number), credit card or insurance information to the Platform;

f) shall abide by any limitations associated with the Products as detailed in the Order Form;

g) has the right, power and authority to enter into this Agreement; and

h) is capable of performing its obligations under this Agreement.

4.2 Client acknowledges and agrees that:

a) its and its Authorized Users’ use of the Products is at its sole risk;

b) the Products are each provided “as is” and “as available”, and only for the limited and specified purposes as detailed within the Agreement; and

c) Company makes no guarantees with respect to any business results relating to or resulting from use of the Products.

5. Permitted Use

Client hereby warrants and covenants that it shall only use the Products in accordance with the intended purposes as detailed in the Order Form, and in particular shall not use the Products in any way that would put Company in breach of any relevant legislation, including but not limited to Data Protection Law, the Controlling the Assault of Non-Solicited Pornography And Marketing Act of 2003 (Can-Spam), the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR), the Health Insurance Portability and Accountability Act of 1996 (HIPAA), any other applicable marketing legislation and any legislation which addresses protected characteristics including special category personal data (as defined in Data Protection Law) or subject Company to the obligations of a consumer reporting agency under the Fair Credit Reporting Act 2015, 15 U.S.C. § 1681 (“FCRA”). Company is not a business associate under HIPAA or a consumer reporting agency and none of the information provided through any of its Products constitutes a “consumer report” as such term is defined by FCRA. By accessing and using the Products, Client agrees that they will not use the Products for any non-permissible purpose covered by FCRA or Data Protection Law. Moreover, Client agrees not to take any adverse action, which is based in whole or in part on the Products, against any consumer. The terms “adverse action” and “consumer” shall have the same respective meaning, as those terms are defined in FCRA. Company may assess Client’s compliance with its obligations under the Agreement if it, acting reasonably, has grounds for concern regarding Client’s use of the Products and its compliance with Data Protection Laws. Client shall reasonably cooperate with Company to address any findings of such assessments.

6. Intellectual Property

6.1 Each party shall retain rights to their respective Intellectual Property and no Intellectual Property is deemed to have transferred to the other party by virtue of executing the Agreement. Client shall not remove any copyright, trademark, service marks or logos or similar notice contained in the Products without the prior written consent of Company.

7. Authorized Users

7.1 Client is responsible for all acts and omissions related to the use of the Products by any Authorized User.

7.2 Client shall ensure that all Authorized Users understand and comply with, the terms of the Agreement and that Authorized Users are required to keep all usernames and passwords secure and limited to individual use and shall directly have full responsibility for the security of such information.

7.3 If Client becomes aware of any loss or potential loss of an Authorized User’s username and/or password or any other incident prejudicing or potentially prejudicing the terms of the Agreement or the security of the Licensed Data, it

shall promptly notify Company and provide all such reasonable assistance in response or mitigation of the same.

7.4 Client is hereby notified that Company may monitor both Client’s and Client’s Authorized Users’ use of the Platform and Products to ensure compliance with the terms of the Agreement. Such tracking may also be used to inform marketing and advertising campaigns, benchmarking, statistical analysis or to improve its products and services, but only to the extent that such tracking consists of purely anonymized data and no personal data.

8. Confidentiality

8.1 Subject to clause 8.2, each party shall:

a) treat all Confidential Information of the other party as confidential regardless of when or how it is disclosed;

b) not use any Confidential Information in any way other than for purposes related to the Agreement;

c) not disclose Confidential Information to any third-party without the prior written consent of the other party and without first obtaining confidentiality undertakings from said third-party on terms equivalent to the terms of the Agreement; and

d) maintain the Confidential Information using the same degree of care as it uses to protect its own confidential information.

8.2 Client may, subject to clause 9, disclose any Confidential Information to any of its employees, officers, representatives or advisers (Representatives) who need to know the relevant Confidential Information for the purposes of the performance of any obligations under the Agreement, provided that such party must ensure that each of its Representatives to whom Confidential Information is disclosed is aware of its confidential nature and agrees to comply with this clause 8 as if it were a party.

9. Data Protection

9.1 Each party shall:

a) comply with Data Protection Laws in relation to any processing of personal data in connection with the Agreement as independent separate controllers and shall only process and share such personal data as is reasonably necessary to perform its obligations and exercise its rights under the Agreement. While each party is an independent and separate controller, each party shall provide the other party with reasonable cooperation that is requested by the other party to enable it to comply with Data Protection Laws;

b) use its commercially reasonable efforts to ensure all appropriate technical, organizational and security measures are in place to ensure the secure and lawful processing of personal data and that such measures are in material compliance with the standards set forth in the Data Protection Laws including but not limited to ISO/IEC 27001 and ISO/IEC 27002;

c) be solely responsible for complying with and monitoring changes to Data Protection Laws and/or the passage of new privacy laws and/or regulation which may apply to that party in relation to the processing of personal data under the Agreement;

d) apply data minimization practices to ensure data retention is in accordance with law and best practice as is reasonable during the Term and upon termination; and

e) be independently responsible for ensuring compliance with all data subject requests in accordance with Data Protection Law, and Client shall take all such appropriate measures to ensure that all data subject rights are protected.

9.2 Client shall:

a) independently confirm the lawfulness of any and all processing (including any marketing) they undertake and any appropriate lawful bases for such processing; and

b) immediately inform Company that Client has been, or is, unable to comply with the provisions of this clause 9.

9.3 The parties agree: a) in the event the Standard Contractual Clauses (“SCCs”) are applicable to the Agreement, such SCCs are hereby incorporated herein and deemed signed by both parties;

b) where Company is a data processor in relation to Client Personal Data, that they will each comply with the provisions of the Data Protection Addendum.

10. Payment

10.1 Company shall invoice in accordance with the Agreement.

10.2 Client shall pay all invoices for Fees for the duration of the Term and other amounts validly due, within thirty (30) days from the date that the invoice is issued (“Due Date”) in full without any set-off, counterclaim, deduction or withholding (other than as required by law).

11. Suspension and Termination

11.1 Company may suspend Client’s access to the Products if:

a) any undisputed Fees remain unpaid for thirty (30) days following the Due Date;

b) the Client breaches, or is otherwise unable to comply with, the Agreement.

11.2 Either party may terminate the Agreement on written notice to the other party, in any of the following events:

a) the other party is in material breach of this Agreement that is irremediable or which the other party fails to cure within thirty (30) days of such notice (breach by Client of clause 9 and/or 10 of this Agreement being examples of such material breach);

b) there is a change in law or binding regulation which would, should the Agreement continue, put the terminating party in breach of that law or regulation;

c) the other party is deemed unable to pay its debts;

d) a petition is filed, a notice is given, a resolution is passed, or an order is made, for or in connection with the winding up of the other party;

e) an application is made to court, or an order is made, for the appointment of an administrator or if a notice of intention to appoint an administrator is given or if an administrator is appointed over the other party;

f) a third party becomes entitled to, or does, appoint a receiver over the assets of the other party; or

g) the other party starts negotiations with creditors or makes a proposal for or enters into any compromise or arrangement with its creditors.

11.3 Upon the expiration or termination of the Agreement, Client shall immediately cease using all Products, including all Licensed Data and Platform access. Client shall promptly delete all Licensed Data, including that downloaded, in its possession save for any Licensed Data it is required to retain by applicable law and any licensed Deliverables.

11.4 The parties agree that the provisions of the Terms with the following titles shall survive termination of the Agreement: Data Protection, Confidentiality, Intellectual Property, Indemnities, Limitation of Liability.

12. Publicity

Neither party shall, without the other party’s written consent, use, or permit the use of, the other party’s name and/or company logo in any public documentation of any nature.

13. Force Majeure

Neither party shall be in breach of the Agreement, or be otherwise liable, if it is prevented, hindered or delayed in performing any of its obligations under the Agreement as a result of any circumstance which is beyond the reasonable control of that party and which is reasonably likely to make it impracticable, illegal, or impossible for that party to perform its obligations as originally contracted under the Agreement, including (but not be limited to) any significant change in law applicable to that party, acts of god, acts of terror, wars, insurrections or riots, strikes, epidemics, floods, earthquakes, fires, storms, civil disturbances or any action or restraint by a governmental authority. For the avoidance of doubt Client’s inability to pay the Fees for whatsoever reason shall not be classed as a force majeure event.

14. Indemnities

14.1 Client shall indemnify Company from and against all liabilities, costs, expenses, damages and losses arising out of or in connection with any misuse of the Licensed Data, Products or Platform by Client or any Authorized User and/or any breach by Client of clause 7 (Permitted Use) and/or clause 9 (Data Protection).

14.2 Company shall indemnify Client from and against all liabilities, costs, expenses, damages, and losses arising out of or in connection with any actual infringement of a third-party’s intellectual property rights arising out of the authorized use of the Product(s) and the Platform by Client or any Authorized User and/or against all direct losses, damages, fines and reasonable third-party claims, costs and expenses that arise solely and directly from the Company’s proven breach of clause 9 (Data Protection). Company may at its option: a) procure for the Client the right to continue using the relevant Product(s); or b) modify or replace the infringing part of the Product(s) so as to avoid the infringement. The Company’s obligations under this clause 14.2 shall not apply to any Product(s) modified or used by the Client other than in accordance with the Agreement or the Company’s reasonable written instructions. 14.3 Upon receipt by a party entitled to indemnification under this clause 14 (an “Indemnified Party”) of notice of a claim, action or proceeding in respect of which indemnity may be sought hereunder, the Indemnified Party shall promptly notify the other party (the “Indemnifying Party”) in writing. The Indemnifying Party shall, at its own expense, assume and control the defense in a timely manner of any litigation or proceeding in respect of which indemnity is sought and shall not settle any claim, action or proceeding, to which an Indemnified Party is a party and in respect of which indemnity is sought, without the Indemnified Party’s written consent, which shall not be unreasonably withheld, and the Indemnified Party shall provide the Indemnifying Party with such assistance (at the Indemnifying Party’s cost) as is reasonably required by the Indemnifying Party.

15. Limitation of liability

15.1 Nothing in the Agreement shall exclude or limit either party’s liability: a) for fraud or fraudulent misrepresentation; b) for willful breach or intentional unlawful conduct; c) for death or personal injury resulting from negligence; or d) for any other liability that cannot be limited or excluded by applicable law.

15.2 Company makes no representations or warranties and, to the fullest extent allowed by law, excludes all implied warranties (including, but not limited to, warranties of satisfactory quality, completeness, title and fitness for a particular purpose) regarding the Products and any use of the Products.

15.3 Neither party shall be liable to the other for: a) any loss of any actual or anticipated revenue or profits; and/or b) any incidental, punitive, indirect, special or consequential damage, loss or expense, including but not limited to, any loss of business, contracts, any business interruption, loss of goodwill or reputation, wasted expenditure or other pecuniary loss suffered by the other party.

15.4 Each party’s liability under or in connection with the Agreement (regardless of whether such liability arises in tort, contract or in any other way and whether or not caused by negligence or misrepresentation) shall be limited in the aggregate to the greater of $100,000 or an amount equal to the Fees paid or payable by Client to Company for the twelve (12) month period preceding the date on which the claim arose.

15.5 Each party’s liability under or in connection with the Indemnities at clause 14, shall be limited in the aggregate to the greater of $250,000 or an amount equal to the Fees paid or payable by Client to Company for the twelve (12) month period preceding the date on which the claim arose.

15.6 During the Agreement, Company will continuously maintain in effect all appropriate insurance, having full regard to its obligations, activities and warranties in the Agreement.

16. Anti-bribery and corruption

Each party warrants and represents that, in connection with the Agreement, it has not violated nor is in violation of, and undertakes that it shall continue to comply with, any applicable anti-corruption law, statute and regulation, including but not limited to, the Bribery Act 2010 and the US Foreign Corrupt Practices Act.

17. Trade Sanctions

17.1 Each party warrants and represents that neither it, nor, so far as it is aware, any agents or other persons acting on its behalf (nor, in the case of Client, any Authorized Users or any other parties accessing the Products from Client):

a) is listed on the “Specially Designated Nationals and Blocked Persons” list maintained by the Office of Foreign Assets Control of the United States Department of the Treasury (OFAC) or any designated parties’ list maintained by the United Nations, the European Union, the United Kingdom or any other relevant governmental entity;

b) directly or indirectly, has conducted, conducts or is otherwise involved with, any business with or involving any government (or any sub-division thereof), or any person, entity or project, targeted by, or located in any country that is the subject of, any of the sanctions administered by OFAC or any equivalent sanctions or measures imposed by the United Nations, the European Union, the United Kingdom or any other relevant governmental entity (collectively “Sanctions”);

c) directly or indirectly supports or facilitates, or plans to support or facilitate or otherwise become involved with, any such person, government, entity or project; or

d) is or ever has been in violation of, or subject to, an investigation relating to Sanctions.

18. Political Data

If Client is a registered business entity in the United States, then Federal, state and local political contributions (“Political Data”) shall not be used as the source data to create a list or as the sole data input for developing any direct marketing program. Client’s use of Political Data presumes that Client has already identified a source list and that the Political Data is being added as an additional element to Client’s pre-existing list. Client is solely responsible for its compliance with the use restrictions applicable to Federal Election Commission (“FEC”) data.

19. Order of precedence

In the event of any conflict, inconsistency or ambiguity between the Terms and any Order Form, the Order Form shall take precedence. Any purchase orders or similar documentation submitted by Client will be for administrative purposes only and will have no force or effect under the Agreement.

20. General

20.1 Client may not license, assign or transfer any of its rights under the Agreement. Company may assign or transfer any of its rights or obligations under the Agreement to any company within its current ownership structure or to any purchaser of the business and assets of any such company.

20.2 If any provision of the Agreement is found to be invalid by any court having competent jurisdiction, the invalidity of that provision will not affect the validity of the remaining provisions of the Agreement, which shall remain in full force and effect.

20.3 The failure of either party to exercise or enforce any right or provision of the Agreement shall not constitute a waiver of such right or provision.

20.4 All notices required by or relating to the Agreement shall be in writing and shall be sent by post or email, for the purposes of the client, to the authorized representatives named in the Order Form and for the purposes of Company to [email protected]. Notices are deemed received at 9am on the second business day after posting, or on receipt of an email. Company shall be entitled to request proof to demonstrate compliance with this clause.

20.5 Each party acknowledges and agrees that the relationship arising from the Agreement does not constitute or create any joint venture, partnership, employment relationship or franchise, and the parties are acting as independent contractors in making and performing the Agreement.

20.6 The Agreement represents the entire agreement between the parties and shall supersede and replace all prior agreements and understandings, oral or written, between the parties regarding the Products covered herein.

20.7 The Agreement may not be amended or modified except by a written instrument signed by the authorized representatives of both parties.

20.8 The Agreement may be signed in multiple counterparts, each of which will be deemed an original, and all such counterparts will constitute the same Agreement.

20.9 A person who is not a party to the Agreement shall not have any rights under the Contracts (Rights of Third Parties) Act 1999 to enforce any term of the Agreement.

21. Choice of Law and Jurisdiction

The Agreement and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with it or its subject matter or formation shall be governed by and construed in accordance with the laws of the state of New York in instances when the client is located in the United States of America, or in accordance with the laws of England & Wales in all other cases. Notwithstanding the preceding sentence, where the Agreement is bound by state law, the law of that state will prevail. The parties agree to submit to the exclusive jurisdiction and governing laws, as set forth herein, regardless of whether any dispute should arise in contract, tort or otherwise.