Privacy Policy

Last updated: 1 July 2026

1. Overview

SmartFlex Solutions Ltd ("SmartFlex," "we," "us," or "our") respects your privacy and is committed to protecting personal data. This Privacy Policy explains what information we collect through smartflex-solutions.com and in the course of providing our transfer agency, shareholder registry, fund administration, public company support and IPO advisory services, how we use it, and the choices available to you.

2. Information We Collect

We may collect the following categories of information:

• Contact information you provide, such as your name, email address, phone number, and company, when you submit an enquiry through our Site;
• Shareholder and investor data processed on behalf of our issuer and fund manager clients as part of our registry and administration services, in accordance with each client's instructions and applicable data protection agreements;
• Technical data, including IP address, browser type, device information and pages visited, collected automatically through cookies and similar technologies; and
• Communications you send us, including correspondence and support requests.

3. How We Use Your Information

We use personal data to: respond to enquiries submitted through the Site; provide, maintain, and improve our registry, fund administration, and advisory services; comply with applicable legal, regulatory and anti-money-laundering obligations; communicate with shareholders and investors on behalf of our clients; and safeguard the security and integrity of our systems.

4. Legal Basis for Processing

Where applicable data protection law requires a legal basis, we rely on: performance of a contract (for example, providing registry services to an issuer); compliance with a legal obligation (for example, regulatory reporting and AML checks); our legitimate interests in operating and improving our business; and, where required, your consent.

5. How We Share Information

We do not sell personal data. We may share information with: regulators and government authorities where legally required; sub-processors and service providers who support our technology platform under confidentiality and data protection obligations; professional advisers such as auditors and legal counsel; and, in relation to shareholder or investor data, the issuing company or fund manager on whose behalf we administer the register.

6. Cookies & Tracking Technologies

Our Site uses cookies and similar technologies to remember preferences, understand how visitors use the Site, and improve functionality. You can control cookies through your browser settings; disabling cookies may affect certain features of the Site.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, including to satisfy legal, regulatory, accounting, or reporting requirements applicable to shareholder registries and fund records, after which it is securely deleted or anonymised.

8. Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal data against unauthorised access, alteration, disclosure, or destruction, consistent with information security practices aligned to ISO 27001 principles. No system can be guaranteed completely secure, and we continually review and update our safeguards.

9. Your Rights

Depending on your location, you may have the right to access, correct, delete, or restrict the processing of your personal data, to object to certain processing, and to request data portability. To exercise any of these rights, contact us at info@smartflex-solutions.com. If your data is held as part of a shareholder register or fund we administer on behalf of a client, we may direct your request to that client where they act as the primary data controller.

10. International Data Transfers

As a global business with offices in the United Kingdom, United States, Singapore, Hong Kong, Germany and Canada, we may transfer personal data across borders. Where required, we rely on appropriate safeguards, such as standard contractual clauses, to protect data transferred internationally.

11. Children's Privacy

Our Site and Services are intended for business use and are not directed at individuals under the age of 18. We do not knowingly collect personal data from children.

12. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or applicable law. The "Last updated" date above indicates the most recent revision. We encourage you to review this Policy periodically.

13. Contact Us

If you have questions about this Privacy Policy or how we handle personal data, please contact us at info@smartflex-solutions.com or write to us at 33 Cannon Street, London EC4M 5SB, United Kingdom.