PRIVACY POLICY

LAST UPDATED: OCTOBER 2, 2025

Synply, Inc. and any subsidiaries and affiliates (collectively “Synply,” “we,” “our,” or “us”) operate the https://synply.io/ website (“Site”) and provide platform services for syndicated lending and portfolio management (“Platform Services,” together with the Site, collectively, the “Services”).

This Privacy Policy (“Privacy Policy”) informs you of our policies and procedures regarding the collection, use, disclosure, and security of certain information that we collect through the Services and the choices you have associated with that information.

Please note that by accessing, visiting or using the Services, you are accepting, consenting, and agreeing to the practices described in this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of the Services after we make changes is deemed to be an acceptance of those changes, so please check this Privacy Policy periodically for updates. This Privacy Policy is incorporated by reference into our Terms of Use.

The Platform Services allow a Synply customer (“Customer”), as the lead lender in a syndicated loan or other transaction (each, an “Opportunity”), to invite third party banks, institutions, or other persons involved in the Opportunity (each, a “Participating User”) to access certain features of the Platform Services relating to the Opportunity. If you have been invited to the Platform Services as a Participating User, you have been so invited by our Customer. By accepting the invitation to the Platform Services, you are accepting, consenting, and agreeing to the use of your personal data in accordance with this Privacy Policy. If you request access to the Platform Services, you are accepting, consenting, and agreeing to the use of your Personal Data in accordance with this Privacy Policy.

Types of Data Collected

Personal Data

While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Employer’s name and address
  • Job title
  • First-party Cookies and Usage Data (as defined below)
  • Geolocation Data

Usage Data

We may also collect information on how the Services are accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (“IP address”), browser type, browser version, language settings, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

The Usage Data will also include a history of Participating User access to the Services and actions taken as described above, and we may make such Usage Data available to our Customer as the lead lender of a respective Opportunity accordingly as part of our detailed user activity reporting / sharing analytics capabilities.

Tracking Data

We use cookies and similar tracking technologies to track the activity on our Services.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Site.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.

Examples of Cookies we use:

  • Essential Cookies: Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of the Services.
  • Functional Cookies: Functional Cookies are used to remember your preferences and various settings regarding the Services.
  • Security Cookies: Security Cookies are used for security purposes.

Synply as a Service Provider or Processor

Some of the Platform Services require Synply to process data that has been uploaded, stored and shared via a Customer or a Participating User. Synply does not review or analyze the content of such data. However, it may contain Personal Data which Synply processes pursuant to a Customer’s instructions as the lead lender of a respective Opportunity. Synply does not control such data; rather it handles this type of data as a data processor only. Synply processes such data as governed by written agreements in place with its Customers and to the extent necessary to comply with applicable laws. As a result, each Customer is responsible for obtaining and providing all appropriate notifications and consents when it or any of the respective Participating Users collect Personal Data and upload, store, or share the Personal Data through the Platform Services. Personal Data that is transferred to Synply by Customers or Participating Users to be processed shall be deemed to have been collected with appropriate notifications and consents. Synply assumes no responsibility for obtaining or validating that appropriate consent has been obtained or notifications provided with respect to data provided by Customer(s) or Participating User(s).

With respect to the Platform Services, the Customer may add you as a Participating User and provide certain Personal Data, such as your work e-mail. We will use the work e-mail to provide you an E-mail ID and account activation e-mail to access the Platform Services and create a user profile for the uses described herein. You will be able to update or correct any of the Personal Data in your user profile by logging into the Platform Services.

Sources of Personal Data

We collect the categories of Personal Data listed above from the following categories of sources:

  • Directly from you, such as from the forms or other information you provide to us.
  • Indirectly from you, such as from your interactions with the Services.
  • From our service providers and business partners, or other third parties, such as providers used for email or single sign-on services (e.g., Microsoft, Google).
  • As otherwise described to you at the point of collection or with your consent.

Use of Data

We use the collected data for various purposes as described below, including to advance the Company’s business purposes.

  • To provide and maintain our Services.
  • To notify you about changes to our Services.
  • To allow you to participate in interactive features of our Services when you choose to do so.
  • To provide customer support or communicate with you.
  • To gather analysis or valuable information so that we can improve our Site.
  • To monitor the usage of our Services.
  • To detect, prevent and address technical issues.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or inquired about unless you have opted not to receive such information. If you wish to opt out of our using your information in this way, you may do so by following the unsubscribe link or following the instructions in any email we send.
  • To fulfill any other purpose for which you provide it.
  • For any other purpose with your consent.

Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. By submitting your personal data or engaging with our Websites, you consent to this transfer, storing, or processing.

Disclosure of Personal Data

We may disclose the Personal Data we collect to service providers, vendors, contractors, sub-processors or subcontractors to perform certain services on our behalf and for the business purposes described above. For example, we may disclose information from your visits to the Site to a cybersecurity consultant to help secure the website.

We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, prohibit using the disclosed information for any purpose except performing the contract, and other legal contract requirements for engaging service providers.

We may also disclose your Personal Data:

  • To our subsidiaries, affiliates, and parent company.
  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • To a buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the Personal Data we hold.
  • To comply with any court order, law, or legal process, including responding to any government or regulatory request.
  • To enforce or apply our Terms of Use https://www.synply.io/terms-of-use and other agreements.
  • To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may use or disclose information that is anonymized or in an aggregated form that does not directly identify you and we may use or disclose any such information for any purpose without restriction so long as it does not violate the terms of this Privacy Policy or any applicable law.

We will not share, sell or distribute your Personal Data to unrelated third parties. All Personal Data may be disclosed only to third parties who directly support the use cases for Personal Data as summarized above. Customers as lead lenders of Opportunities are responsible for maintaining the access controls over their data and have access to personal user information and user activity related to their Opportunity. This information is required to securely access and use the Services but is administered by the Customer as lead lender of each respective Opportunity. Synply or a Customer as lead lender of an Opportunity may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We offer collaboration features or other integrated tools, which allow you to share your content (including Personal Data, documents, or other materials) through the Services. Because these features are based on the (a) collaborative nature of the Services, and (b) permissions and settings you choose, their use enables you to share content with other people, including Participating Users, you want to collaborate with. You can choose to change your settings at any time for a file or folder through your account.

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. Any transmission of Personal Data is at your own risk.

“Do Not Track” Signals

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Links to Other Sites

Our Site may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Minors Under the Age of 18

We do not knowingly collect Personal Data from anyone under the age of 18. If you believe we have collected Personal Data from someone under the age of 18, please contact us. If we become aware that we have collected Personal Data from someone under the age of 18 without verification of parental consent, we will take steps to delete that information. If you believe we might have any information from or about someone under the age of 18, please contact us by email at help@synply.io.

Your Rights and Choices

Depending on your state or country of residence, you may have certain rights with respect to your Personal Data, as described in more detail below. Specifically, you may request that we:

  • Provide access to and/or a copy of your Personal Data (including in portable form).
  • Provide additional information regarding the Personal Data that we have collected about you, including the categories of Personal Data, the categories of sources from which the Personal Data was collected, the business or commercial purpose for collecting or disclosing Personal Data, and the categories of third parties to whom we disclose Personal Data.
  • Prevent the processing of your Personal Data for direct-marketing purposes (including any direct-marketing processing based on profiling).
  • Correct Personal Data that is out of date or incorrect.
  • Delete certain Personal Data which we are holding about you; provided that the Personal Data is not required by us for (i) compliance with a legal obligation under applicable law or (ii) the establishment, exercise or defense of a legal claim
  • Restrict, object or limit the way we process and disclose certain of your Personal Data.
  • Transfer your personal data to a third party to the extent technically feasible.
  • Honor a revocation of your consent for the processing of your Personal Data (without retroactive effect).
  • If applicable, opt you out of the sale or sharing of your Personal Data.
  • Limit the use and disclosure of your sensitive Personal Data.

Important: The exact scope of these rights vary by state. There are also several exceptions where we may not have an obligation to fulfill your request. We will not discriminate against you for exercising any of your rights.

To exercise any of these rights, please contact us by e-mail at help@synply.io.

Changes to Our Privacy Policy

We may modify this Privacy Policy from time to time by publishing a new version on our Site. You should check this Site periodically to ensure that you agree with and approve any changes to this Privacy Policy. Your continued use of our Services or the continued conduct of business with us after an update to this Privacy Policy constitutes your consent to the then current version of this Privacy Policy.

Contact Us

To ask questions or to provide comments about this Privacy Policy and our privacy practices, or if you have to reach us for any other reason, you may contact us by e-mail at help@synply.io, or by mail at 1741 Tiburon Drive, Wilmington, NC 28403, USA.