Privacy Policy

Privileged and confidential

SUI Group Holdings (“SUIG”, “we”, “our” or “us”) value the confidence and trust placed in us and strive to protect that trust by holding Personal Data (as defined below) in the strictest confidence. Accordingly, we have adopted and implemented this privacy policy (the “Privacy Policy”) which sets out how we collect, use, and share any Personal Data we obtain through your use of the website at https://suig.io/ (the “Website”) and any services provided and operated by us via the Website (collectively, the “Services”). 

By using the Services, you acknowledge that you are at least 18 years old and acknowledge that you have read and understood the statements in relation to our collection, use, disclosure and retention of your Personal Data as described in this Privacy Policy. The Services are intended only for those who are over the age of 18.

For more information or if you have any questions about this Privacy Policy, please contact us via the details set out at https://suig.io/investor-relations#contact.

Personal Data We Collect

The term “Personal Data” in this Privacy Policy has the meaning given under applicable laws. In general, it means nonpublic personal information and other personal information about you, including information that can help us directly or indirectly identify you. Personal Data includes information that may identify your device even if it does not directly identify you.

Direct collection:

To provide you with the Services, we may ask you to provide Personal Data in order for you to benefit from the specified features of our Services or to participate in a particular activity. For example, you may voluntarily provide Personal Data to us in the following ways:

  • Contact Us: If you send us communication via the “contact us” page or similar means, we collect the Personal Data that you provide, such as your name, email address, and any Personal Data in the message you send to us.
  • Careers: If you apply for an employment opportunity with us, you may provide us with certain Personal Data about yourself (such as information contained in a resume, cover letter or similar employment-related materials, or any applicable pre-screening questions).

Indirect collection:

We may also receive Personal Data about you that you do not directly provide to us, such as:

  • Third Party Sources: We may receive information about you from other sources, such as from our sales agents, from publicly available information sources, and from our service providers (such as where you provide your email address to sign up for investor updates). Where permitted by applicable law, we may combine your Personal Data with other information we have collected from you.  

Website use collection:

When you visit our website, we may use IP addresses, browser types, and access times to analyze trends, administer the site, improve site performance and gather broad demographic information for aggregate use. When you request a page from our Website, our servers may log the information provided in the HTTP request header including the IP number, the time of the request, the URL of your request, and other information that is provided in the HTTP header. We collect the HTTP request header information in order to make our Website function correctly and provide you with the functionality you see on the Website. We also use this information to better understand how visitors use our website and how we can better fine-tune it, its contents, and functionality to best meet your needs.

[Some web browsers may transmit “do not track” (“DNT”) signals. We currently do not respond to DNT settings in your web browser.]

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Purposes for Personal Data Use

We may use your Personal Data for any of the following purposes:

  • to provide the Services to you and to improve the Services;
  • to manage communications with us;
  • to resolve disputes and troubleshoot problems;
  • to respond to inquiries and fulfill requests;
  • to promote our Services to you, as permitted under applicable law;
  • for security, to detect and protect us against error, fraud and other criminal activity , and for archival and backup purposes in connection with the provision of the Services;
  • for our business purposes, such as data analysis, audits, developing new products and services, enhancing our Services, identifying Service usage trends, and determining the effectiveness of our promotional campaigns;
  • as we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this Privacy Policy and our Terms of Use; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain; and
  • as otherwise described to you at the time of collection.

Our lawful bases for processing your Personal Data, if applicable, include:

  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; 
  • to comply with certain legal and regulatory requirements; 
  • depending on the circumstances, we may need to process your Personal Data for the performance of a contract to which you are a party, or related pre-contractual steps; and 
  • with your consent, as and to the extent required by applicable laws.

Disclosing Your Personal Data to Others

We may disclose your Personal Data to others in the following ways:

  • to affiliated entities, including subsidiaries and parent companies as applicable, companies related by common ownership or control, and joint ventures, to provide our products and services and for our internal business purposes;
  • to business partners, suppliers, third party service providers (including professional providers such as lawyers and auditors) or contractors/subcontractors;
  • to service providers that may (i) process Personal Data on our behalf; (ii) provide infrastructure, products, or services to us or on our behalf; and (iii) manage and provide our digital offerings, including the Website;
  • at your request or direction or with your consent; 
  • as otherwise permitted or required by law or regulation, including, but not limited to, sharing information with governmental organizations and self-regulatory organizations;
  • in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

We do not sell to or share your Personal Data with third parties.

Links to Other Websites

This Website contains links to other sites such as affiliates as well as other third parties that are not owned or controlled by us. Please be aware that this Privacy Policy only addresses the use and disclosure of your information collected on this Website or through use of our Services.

Security of Your Personal Data

We will take reasonable steps to use security measures appropriate to the nature of the information to protect Personal Data against unauthorized access, exfiltration, acquisition, theft, or disclosure. Given the nature of information security, there is no guarantee that such safeguards will always be successful.

Changes to this Privacy Policy

We may modify this Privacy Policy at any time, and we will post the current version on our Website. We encourage you to regularly review the Website and review the most current Privacy Policy provided there. 

Where We Process Your Personal Data

We are based in the U.S. When you provide Personal Data to us from outside of the U.S., we may receive and process it in the U.S.; U.S. data protection laws may be different from those of your country of residence.

How Long We Keep Your Personal Data

How long we keep your Personal Data will vary primarily depending on the purpose for which we are using your Personal Data and our legal obligations. The retention period will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes) and our legal obligations (as laws or regulations may set a minimum period for which we have to keep your Personal Data). In general, we will retain your Personal Data for as long as is necessary to provide the relevant services and where laws or regulations set a minimum period for which we are required to keep certain of your Personal Data.

Your Rights and Choices

Depending on how you interact with us and where you are located, you may have certain rights to your Personal Data, each of which you may exercise by contacting us using the details in Contact Us below, including to: (i) request access to and correction / rectification of your Personal Data; (ii) restrict the processing of your Personal Data in certain circumstances; (iii) object to the processing of your Personal Data in certain circumstances, including where we process Personal Data for direct marketing purposes or where we have processed such data on the basis of our legitimate interests; (iv) request that we erase your Personal Data under certain circumstances; (v) ask for a copy of your Personal Data to be provided to you, or to a third party, in a digital form; (vi) opt out of marketing communication, or opt out of the sale or sharing of your Personal Data; (vii) otherwise withdraw your consent to the processing of your Personal Data (where applicable); and (viii) lodge a complaint about the processing of your Personal Data with your local privacy enforcement agency or data protection authority.

Contact Us

This Privacy Policy is available in alternative formats upon request. Should you have any questions regarding our policies or about this notice, or to request this Privacy Policy in an alternative format, please contact us via the details set out at https://suig.io/investor-relations#contact.

Effective Date: March 10, 2026