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Privacy policy

Sarjik (“Sarjik”, “Company”, “we”, “us” or “our”) respects your privacy and is committed to handling personal information responsibly.

This Privacy Policy explains how Sarjik collects, uses, discloses, stores and protects personal information when you visit or interact with www.surjikholdings.com, including its webpages, forms, communications features and other online functions operated by Sarjik (collectively, the “Website”).

This Policy also explains certain privacy rights and choices that may be available to you under applicable law.

By accessing or using the Website, you acknowledge that you have reviewed this Privacy Policy. Where applicable law requires consent for a particular processing activity, Sarjik will obtain consent as required.

About Sarjik

Sarjik is a privately held internet investment company focused primarily on digital businesses and ventures.

The Company may establish, develop, own, invest in, acquire, support, manage or partner with businesses and ventures operating across different industries and markets.

The Website may contain information concerning Sarjik, its businesses, portfolio companies, investments, projects, partnerships, corporate activities, career opportunities and other ventures.

A business, brand or project appearing on the Website does not necessarily mean that it is wholly owned or directly operated by Sarjik.

Portfolio companies, subsidiaries, affiliates and other businesses associated with Sarjik may have their own websites, applications, privacy policies and terms. Those separate policies may govern information collected directly by those businesses.

Scope of This Privacy Policy

This Privacy Policy applies to personal information collected through the Sarjik corporate Website and through communications or forms directly operated by Sarjik.

It does not automatically apply to:

  • portfolio companies operating independently;

  • third-party websites;

  • third-party applications;

  • external recruitment platforms;

  • social media platforms;

  • payment processors;

  • service providers operating under their own privacy policies; or

  • websites linked from the Sarjik Website.

You should review the privacy policy applicable to the particular service or business with which you are interacting.

Information We Collect

The information we collect depends on how you use the Website and communicate with us.

Information You Provide

You may voluntarily provide personal information when you:

  • contact us;

  • submit an enquiry;

  • submit a business proposal;

  • submit an investment or partnership proposal;

  • apply for employment;

  • request information;

  • communicate with our team;

  • subscribe to communications where available;

  • participate in a survey or form; or

  • otherwise communicate with Sarjik.

This information may include:

  • name;

  • email address;

  • telephone number;

  • mailing or business address;

  • company or organization;

  • job title;

  • professional information;

  • employment history;

  • qualifications;

  • information in a CV or resumé;

  • information in a business or investment proposal;

  • correspondence;

  • attachments;

  • communication preferences; and

  • any other information you voluntarily provide.

Information Collected Automatically

When you access the Website, certain technical information may be collected automatically.

This may include:

  • IP address;

  • browser type;

  • device type;

  • operating system;

  • language settings;

  • referring website;

  • pages visited;

  • links clicked;

  • date and time of access;

  • approximate location derived from technical information;

  • device identifiers;

  • usage information; and

  • Website performance and security information.

Information From Other Sources

Where permitted by law, we may receive information from third parties such as:

  • business partners;

  • professional advisers;

  • recruitment providers;

  • publicly available sources;

  • corporate information services;

  • event or conference providers;

  • social media or professional networking platforms; and

  • other persons or organizations that have authorized the sharing of information.

We may combine information from these sources with information collected directly from you.

How We Use Personal Information

We may use personal information for the following purposes.

1. Website Operation

We may use information to:

  • operate the Website;

  • respond to enquiries;

  • provide requested information;

  • maintain functionality;

  • troubleshoot technical problems;

  • improve performance; and

  • maintain Website security.

2. Business Communications

We may use information to communicate with you regarding:

  • business enquiries;

  • partnerships;

  • investment opportunities;

  • acquisition opportunities;

  • corporate matters;

  • media enquiries;

  • recruitment;

  • meetings;

  • requests for information; and

  • other communications initiated by you.

3. Investment and Business Development

Where you submit a business, investment, acquisition or partnership proposal, we may use the information provided to:

  • evaluate the proposal;

  • communicate with you;

  • conduct due diligence;

  • coordinate internal review;

  • assess potential business relationships;

  • obtain professional advice;

  • evaluate potential transactions; and

  • maintain related business records.

Submitting a proposal does not create any obligation for Sarjik to pursue the proposed opportunity.

4. Recruitment

Where you submit an employment application, we may use the information to:

  • assess your qualifications;

  • review your application;

  • communicate with you;

  • arrange interviews;

  • evaluate employment suitability;

  • administer recruitment activities; and

  • maintain recruitment records.

Additional privacy notices may apply to particular recruitment processes.

5. Analytics and Website Improvement

We may use technical and usage information to understand how users interact with the Website and to improve:

  • content;

  • navigation;

  • functionality;

  • performance;

  • accessibility; and

  • user experience.

6. Security and Fraud Prevention

We may process information to:

  • protect the Website;

  • investigate suspected misuse;

  • detect fraud;

  • prevent unauthorized access;

  • investigate security incidents;

  • enforce our policies; and

  • protect the Company, users and third parties.

7. Legal and Regulatory Purposes

We may use personal information where reasonably necessary to:

  • comply with law;

  • respond to lawful requests;

  • comply with court orders or legal processes;

  • cooperate with government authorities;

  • establish or defend legal claims;

  • protect our rights and property; or

  • fulfil other legal obligations.

Legal Bases for Processing

Depending on the jurisdiction applicable to the individual and the circumstances of the processing, Sarjik may process personal information on the basis of:

  • consent;

  • contractual necessity;

  • steps taken at your request before entering into a contract;

  • legitimate business interests;

  • compliance with legal obligations;

  • protection of rights, safety or security; or

  • another lawful basis recognized by applicable law.

Where processing relies on consent, you may withdraw consent where permitted by applicable law.

Withdrawal of consent does not affect processing that occurred before the withdrawal.

7. Categories of Personal Information

The categories of personal information potentially processed through the Website include:

CategoryExamples
Identity informationName, title and professional identity
Contact informationEmail address, telephone number and address
Professional informationEmployer, job title, qualifications and experience
Recruitment informationCV/resumé, employment history and application information
Communication informationEnquiries, messages and correspondence
Business informationCompany details, proposals and business interests
Technical informationIP address, browser, device and operating system
Usage informationPages viewed, interactions and access times
Preference informationCommunication or Website preferences
Security informationSecurity and fraud-prevention information

The information actually collected depends on the Website feature you use and the nature of your interaction with us.

Sensitive Personal Information

We do not generally seek sensitive personal information through ordinary Website functions.

Sensitive information may include information such as government identifiers, precise geolocation, biometric information, health information, racial or ethnic information, religious beliefs or other categories defined as sensitive by applicable law.

You should not voluntarily submit sensitive information through a general contact form unless Sarjik specifically requests it through an appropriate process.

Where sensitive personal information is collected, we will handle it in accordance with applicable law.

Cookies and Similar Technologies

The Website may use cookies and similar technologies, including pixels, tags, local storage and related technologies.

These technologies may be used for:

  • essential Website functions;

  • security;

  • remembering preferences;

  • analytics;

  • measuring performance;

  • understanding Website usage;

  • improving functionality; and

  • other lawful purposes.

Cookies may include:

Essential cookies — necessary for certain Website functions.

Functional cookies — used to remember preferences.

Analytics cookies — used to measure traffic and Website usage.

Advertising or measurement technologies — where applicable, used for advertising, attribution or related purposes.

You may manage cookies through your browser settings and, where available, through Website cookie controls.

Disabling certain cookies may affect Website functionality.

Third-Party Analytics and Technologies

Sarjik may use third-party technologies to support Website hosting, analytics, security, communications, content delivery, performance monitoring and other functions.

These providers may receive technical information such as:

  • IP address;

  • browser information;

  • device information;

  • Website activity;

  • referral information; and

  • performance information.

Third parties may process information pursuant to their own privacy policies and agreements with Sarjik.

How We Share Personal Information

We may disclose personal information where reasonably necessary and permitted by law.

Recipients may include:

1. Affiliates and Related Businesses

Information may be shared with affiliates, subsidiaries, portfolio companies or related entities where reasonably necessary for legitimate corporate, administrative, operational, technology, recruitment, security or business purposes.

A portfolio company that receives information may operate under its own privacy policy.

2. Service Providers

We may engage third-party service providers for:

  • Website hosting;

  • cloud services;

  • analytics;

  • cybersecurity;

  • communications;

  • email;

  • recruitment;

  • document management;

  • technical support;

  • professional services; and

  • other business functions.

3. Professional Advisers

We may disclose information to:

  • lawyers;

  • accountants;

  • auditors;

  • consultants;

  • insurers;

  • financial advisers; and

  • other professional advisers

where reasonably necessary for business or legal purposes.

4. Corporate Transactions

Information may be disclosed in connection with an actual or proposed:

  • merger;

  • acquisition;

  • financing;

  • investment;

  • restructuring;

  • reorganization;

  • sale of assets;

  • joint venture; or

  • similar corporate transaction.

5. Legal and Government Authorities

We may disclose information where required or reasonably necessary to:

  • comply with law;

  • comply with legal process;

  • respond to lawful government requests;

  • investigate suspected unlawful activity;

  • protect individuals; or

  • protect the Company's rights, property or systems.

6. With Your Direction

We may disclose information where you specifically request or authorize us to do so.

Sale of Personal Information

Sarjik does not intend for the ordinary operation of its corporate Website to involve selling personal information in exchange for monetary consideration.

However, privacy laws in some jurisdictions use broader definitions of terms such as “sale”, “sharing” or “targeted advertising”.

Where applicable law classifies a particular activity as a regulated sale or sharing of personal information, Sarjik will comply with the applicable requirements.

Marketing Communications

Where we send optional marketing communications, you may unsubscribe using the mechanism provided in the communication or by contacting us.

You may continue to receive essential administrative, transactional, security or legal communications where necessary.

Data Retention

We retain personal information for as long as reasonably necessary for the purpose for which it was collected, including to:

  • respond to enquiries;

  • maintain business records;

  • manage relationships;

  • administer recruitment;

  • comply with legal obligations;

  • resolve disputes;

  • enforce agreements; and

  • protect our legitimate interests.

Retention periods may vary depending on the nature of the information and applicable legal requirements.

When information is no longer reasonably required, it may be deleted, anonymized, aggregated or securely disposed of, subject to applicable recordkeeping obligations.

Data Security

Sarjik uses reasonable administrative, technical and physical safeguards intended to protect personal information against unauthorized access, misuse, loss, alteration or disclosure.

No internet transmission or electronic storage system can be guaranteed to be completely secure.

Accordingly, we cannot guarantee absolute security.

Data Security Incidents and Breach Notification

If Sarjik becomes aware of a security incident involving personal identifying information, we will investigate and take reasonable steps appropriate to the circumstances.

Where a security breach triggers notification requirements under applicable law, we will provide notice as required.

For Wyoming residents, Wyoming law requires a business or other covered entity conducting business in Wyoming and owning or licensing certain computerized personal identifying information to investigate a security breach and, where misuse has occurred or is reasonably likely to occur, provide notice to affected Wyoming residents without unreasonable delay, subject to the statutory requirements and exceptions.

Wyoming Privacy and Consumer Protection Law

U.S. State Privacy Rights

Residents of U.S. states with applicable comprehensive privacy laws may have rights including, depending on the applicable statute:

  • access;

  • correction;

  • deletion;

  • portability;

  • objection;

  • withdrawal of consent;

  • opt-out of certain targeted advertising;

  • opt-out of certain sales or sharing; and

  • other rights established by applicable law.

Not every right applies to every person or processing activity.

Exemptions and statutory limitations may also apply.

California Residents

California residents may have additional privacy rights under applicable California privacy legislation.

Depending on the applicable law and circumstances, these may include rights concerning:

  • access;

  • correction;

  • deletion;

  • portability;

  • certain uses of sensitive personal information;

  • sale or sharing of personal information; and

  • targeted advertising.

Where applicable law requires Sarjik to provide California-specific disclosures or request mechanisms, those mechanisms will be made available.

European Economic Area and United Kingdom

Where applicable data-protection laws in the European Economic Area, United Kingdom or another jurisdiction apply to our processing, individuals may have rights concerning:

  • access;

  • correction;

  • deletion;

  • restriction;

  • objection;

  • portability; and

  • withdrawal of consent.

Individuals may also have the right to complain to an applicable data-protection authority.

The availability and scope of these rights depend on the applicable law and circumstances.

International Data Transfers

Sarjik may use service providers, affiliates and business partners in countries other than the country where you live.

Personal information may therefore be transferred internationally.

Where applicable law requires safeguards for international transfers, we will implement appropriate legal mechanisms and protections.

Business and Professional Contacts

Because Sarjik operates as an investment and corporate organization, we may process professional information concerning:

  • founders;

  • entrepreneurs;

  • investors;

  • executives;

  • advisers;

  • business partners;

  • vendors;

  • consultants;

  • applicants;

  • journalists and media representatives; and

  • other professional contacts.

Such information may be processed for legitimate business, corporate, communication, recruitment, investment, compliance and relationship-management purposes.

Publicly Available Information

Where permitted by law, we may process information lawfully available from public sources for legitimate purposes such as:

  • business research;

  • due diligence;

  • recruitment;

  • corporate administration;

  • compliance;

  • security; and

  • business development.

Public availability does not mean that information may be used for every purpose without restriction.

Portfolio Companies and Affiliated Businesses

Sarjik may share information with affiliates or businesses in which it has an ownership, investment, management or strategic relationship, where lawful and reasonably necessary.

However, portfolio companies may be separate legal entities and may maintain their own privacy policies.

Where you interact directly with a portfolio company's website, application, product or service, that company's privacy policy may govern the relevant processing.

Automated Decision-Making

Sarjik does not intend for the ordinary operation of its corporate Website to make legally or similarly significant decisions about individuals solely through automated processing.

Where automated decision-making or profiling is subject to specific legal requirements, Sarjik will comply with the applicable requirements.

Children's Privacy

The Website is intended primarily for general corporate, business and informational purposes.

Sarjik does not knowingly seek to collect personal information from children through ordinary Website functions.

Where applicable law requires parental consent or other safeguards for the collection of a child's information, we will comply with those requirements.

Third-Party Websites

The Website may link to third-party websites and services.

Those third parties may independently collect, use or disclose information according to their own privacy policies.

Sarjik is not responsible for the privacy practices of websites or services that it does not control.

Social Media

Sarjik may maintain social media accounts or provide links to social media platforms.

Interactions with those platforms may result in the relevant platform collecting information about you.

Your use of such platforms is governed by their respective terms and privacy policies.

Data Minimization

Sarjik seeks to collect personal information that is reasonably necessary for legitimate and identified purposes.

We do not intend to collect unnecessary personal information through ordinary Website functions.

Accuracy of Information

We seek to maintain personal information that is reasonably accurate for the purposes for which it is used.

You are responsible for providing accurate information and for notifying us where relevant information changes.

Where applicable law provides a right to correction, you may request correction of inaccurate information.

Privacy Requests

Where applicable law grants you a privacy right, you may contact Sarjik to exercise that right.

A request should generally include:

  • your name;

  • your contact details;

  • a description of the request; and

  • sufficient information for us to identify the relevant records.

We may request reasonable information necessary to verify your identity before completing a request.

Authorized Agents

Where applicable law permits an authorized agent to submit a privacy request on your behalf, we may require evidence of:

  • your identity;

  • the agent's identity; and

  • the agent's authority to act for you.

We may contact you directly to verify the request.

Appeals

Where applicable law gives you a right to appeal a decision concerning a privacy request, you may submit an appeal through the applicable privacy contact channel.

The appeal should explain why you believe the original decision should be reconsidered.

We will review and respond to the appeal in accordance with applicable law.

Do Not Track and Privacy Signals

Some browsers and devices provide “Do Not Track” or other privacy preference signals.

The Website may not respond to every such signal unless required by applicable law.

Where a particular privacy signal is legally recognized and applicable to Sarjik, we will honor it as required.

Changes to This Privacy Policy

We may revise this Privacy Policy from time to time to reflect:

  • changes to the Website;

  • changes to our business;

  • changes to our information practices;

  • changes to technology;

  • legal or regulatory developments; or

  • improvements to our privacy program.

The “Last Updated” date will be changed when the Policy is revised.

Where required by law, we may provide additional notice concerning material changes.

Contact Us

Questions regarding this Privacy Policy or requests relating to personal information may be submitted to Sarjik through the official contact information published on www.surjikholdings.com.

Effective Date

This Privacy Policy is effective from 30 September 2026.

Sarjik
www.surjikholdings.com

Last Updated: 30 September 2026