Data Upload & Confidentiality Agreement

Data Upload & Confidentiality Agreement v2

Governing the Upload and Use of Strategy Data by Portfolio Manager Account Holders

Effective Date: September 1, 2026

Last Updated: September 1, 2026

1. Definitions

In this Agreement, the following terms have the meanings set out below. Capitalized terms not defined here have the meanings given in the Pyrite Website Terms & Conditions.

"Aggregate Data" means statistical outputs derived from Strategy Data that have been combined with data from other funds available to Pyrite and processed such that no individual fund can be identified, including percentile rankings, medians, interquartile ranges, style distributions, and other summary statistics

"Anonymized Data" means Strategy Data or derivatives thereof from which all directly and indirectly identifying information has been removed or generalized such that the data cannot reasonably be attributed to a specific fund, manager, or organization, applying the standards described in Section 8

"Strategy Data" means all performance data, return series, risk metrics, portfolio characteristics, strategy descriptions, fee information, and any other data or information relating to any fund that you upload or transmit to the Platform

"AI Model" means Pyrite's proprietary artificial intelligence and machine learning models, algorithms, and related systems used to power the Platform's analytics, classification, and intelligent agent features

"Permitted Uses" means the uses of Strategy Data that Pyrite is authorized to make under Section 4 of this Agreement

"Processed Output" means any analytical result, metric, score, ranking, classification, benchmark, or other output generated by the Platform using Strategy Data, whether displayed to you or used internally by Pyrite

2. Data Ownership

2.1 Your ownership is not affected

You retain full ownership of all Strategy Data you upload to the Platform. Nothing in this Agreement or in the Pyrite Terms & Conditions transfers any ownership interest in Strategy Data from you to Pyrite. Pyrite's rights with respect to Strategy Data are limited to the license expressly granted in Section 4.

2.2 Pyrite's ownership of outputs

Pyrite owns all Processed Outputs, Aggregate Data, Anonymized Data, and AI Model improvements generated using Strategy Data. These are proprietary outputs of Pyrite's analytical systems and do not constitute Strategy Data or give rise to any ownership claim by you in Platform outputs beyond the analytics displayed to you under your subscription.

2.3 No transfer of confidential information status

The fact that Pyrite processes Strategy Data under the license in Section 4 does not alter the confidential character of Strategy Data. Strategy Data remains subject to the confidentiality protections in Section 5 regardless of the form in which Pyrite processes it.

3. Your Representations and Warranties

By uploading Strategy Data to the Platform, you represent and warrant to Pyrite, on a continuing basis for as long as Strategy Data remains on the Platform, and permanently, should you publish your Strategy Data to third parties or other platform users:

3.1 Right to upload

You have full legal authority to upload the Strategy Data to the Platform and to grant Pyrite the license set out in Section 4. The Strategy Data you upload is data you own, manage, or administer in a professional capacity, or for which you have obtained all necessary authorizations from the data owner. You are not uploading data belonging to a third party without authorization, data obtained through unauthorized means, or data subject to confidentiality obligations that would prohibit its upload to the Platform.

3.2 Accuracy

The Strategy Data you upload is, to the best of your knowledge and belief, true, accurate, and not misleading in any material respect. You will promptly correct or remove Strategy Data that you become aware is inaccurate or out of date.

3.3 No third-party rights violation

The upload of Strategy Data and Pyrite's use of it in accordance with the Permitted Uses will not infringe the intellectual property rights, confidentiality rights, contractual rights, or privacy rights of any third party, including any fund investor, limited partner, or service provider.

3.4 Compliance with applicable law

Your upload of Strategy Data complies with all applicable laws, including laws governing the disclosure of fund performance data, investor privacy, and data protection. You have obtained all consents or authorizations required under applicable law before uploading Strategy Data that relates to or may identify any natural person.

4. License Grant and Permitted Uses

4.1 License grant

You grant Pyrite a non-exclusive, worldwide, royalty-free license to use Strategy Data for the Permitted Uses described in Sections 4.2 through 4.5 below. This license is granted for the duration of your subscription and, with respect to Sections 4.4 and 4.5 (aggregate and AI uses), survives termination of your account with regard to Anonymized Data or AI Model improvements derived from your Strategy Data that have already been incorporated into Pyrite's systems.

4.2 Analytics services — primary use

4.3 Peer benchmarking — aggregate and anonymized use

4.4 AI model training and improvement

4.5 Platform operations

Pyrite may additionally process Strategy Data as necessary for: (a) platform security, fraud detection, and abuse prevention; (b) backup, disaster recovery, and data integrity purposes; (c) complying with legal obligations or responding to lawful requests from competent authorities.

5. Pyrite's Confidentiality Obligations

5.1 Strict confidentiality

Pyrite shall treat all Strategy Data as strictly confidential. Pyrite shall not disclose Strategy Data to any other user of the Platform, to any third party, or to the public, except as expressly permitted by this Agreement or as required by applicable law.

Should you publish this information to third parties or allocator users on the platform, these Confidentiality Obligations will be waived and replaced by those included in the Publication Disclaimer.

5.2 No exposure to other users

Strategy Data uploaded by you will not be made visible, accessible, searchable, or downloadable by any other user of the Platform, whether directly or indirectly. Your Strategy Data will not appear in the Platform's fund universe or search results unless you have separately submitted and Pyrite has approved a Strategy Publication Declaration. Even in aggregate outputs disclosed to other users (see Section 4.3), your fund is not identified by name, identifier, or any characteristic that would allow a third party to attribute a specific data point to your fund.

5.3 Internal access controls

Access to Strategy Data within Pyrite is limited to Pyrite personnel who require access to perform the Permitted Uses. Pyrite will implement and maintain appropriate technical and organizational access controls to enforce this restriction.

5.4 Disclosure required by law

If Pyrite is required by applicable law, court order, regulatory requirement, or a lawful request from a competent authority to disclose Strategy Data, Pyrite will: (a) notify you promptly in writing before disclosure where legally permitted to do so; (b) cooperate with any reasonable request by you to seek a protective order or other appropriate remedy; and (c) disclose only the minimum Strategy Data required to satisfy the legal obligation.

5.5 Subprocessors

Pyrite may engage third-party subprocessors (such as cloud infrastructure providers, AI compute providers, and security services) to process Strategy Data on Pyrite's behalf in connection with the Permitted Uses. All subprocessors are subject to contractual confidentiality and data security obligations at least as protective as those in this Agreement. Pyrite remains responsible for subprocessors' compliance with this Agreement.

6. Prohibited Uses

Pyrite shall not:

• sell, license, or otherwise transfer Strategy Data to any third party for the third party's own use or benefit; provided that this restriction does not apply to Published Strategy Data (as defined in the Strategy Publication Declaration) that you have voluntarily made available through the Platform's fund publication feature
• use Strategy Data to compete with your fund, to create a competing investment product, or to replicate your investment strategy
• disclose Strategy Data to any other Platform user, whether or not that user is a competitor of yours
• use Strategy Data for advertising or marketing purposes beyond what is necessary to describe Pyrite's services in aggregate terms (e.g., 'Pyrite analyzes over X funds')
• reverse-engineer or attempt to identify your fund from Anonymized Data incorporated into AI Model training sets, after it has been anonymized in accordance with Section 8

Carve-out for Published Strategy Data. Notwithstanding the prohibitions in this Section 6, where a Data Provider has executed a Strategy Publication Declaration and voluntarily published a strategy to the Platform, Pyrite may freely repackage, redistribute, sublicense, and otherwise commercialize the Published Strategy Data, including by incorporating it into data products, licensing it to Track C subscribers or to third parties, and referencing it in Pyrite's marketing and commercial materials. The prohibitions in this Section 6 apply exclusively to Strategy Data that the Data Provider has uploaded privately and has not designated for publication. For the avoidance of doubt, partial publication — publishing some but not all data relating to a Strategy — does not relax Pyrite's obligations with respect to the unpublished portion, which remains subject to the full protections of this Agreement.

Pyrite will not have any confidentiality obligations with regard to the Strategy Data or specific portion thereof, if Pyrite can demonstrate with competent evidence that the Strategy Data or specific portion thereof:

• was in the public domain at the time it was disclosed on the Pyrite Platform;
• entered the public domain subsequent to the time it was disclosed on the Pyrite Platform, through no fault of Pyrite;
• was in Pyrite’s possession free of any obligation of confidence at the time it was disclosed on the Pyrite Platform; or
• was rightfully disclosed on the Pyrite Platform by a third party without breach of any obligation of confidentiality and without restriction on disclosure.

7. Data Security

7.1 Security measures

Pyrite shall implement and maintain industry-standard technical and organizational security measures to protect Strategy Data against unauthorized access, accidental loss, alteration, destruction, or disclosure. These measures include, at minimum: encryption of Strategy Data in transit (TLS 1.2 or higher) and at rest; role-based access controls limiting internal access to authorized personnel; regular security assessments and vulnerability testing; and incident response procedures.

7.2 Security incidents

If Pyrite becomes aware of a security incident that results in unauthorized access to, disclosure of, or loss of Strategy Data, Pyrite will notify you without undue delay and in any event within 72 hours of becoming aware of the incident. The notification will describe the nature of the incident, the Strategy Data affected, the likely consequences, and the measures Pyrite has taken or proposes to take in response. Pyrite will cooperate with your reasonable requests in connection with managing and mitigating the incident.

8. Anonymization Standards

When Strategy Data is used for peer benchmarking (Section 4.3) or AI model training (Section 4.4), Pyrite will apply the following anonymization standards before incorporating Strategy Data into any output accessible to third parties or into AI training sets:

8.1 Identifier removal

All direct identifiers are removed: fund name, fund manager name, ISIN, ticker, LEI, CRD number, or any other code or label that could directly identify the fund.

8.2 Aggregation threshold

No Aggregate Data statistic derived from Strategy Data is disclosed to any user unless it is computed across a minimum of twenty (20) funds. Where a style or strategy peer group contains fewer than twenty funds, Pyrite will use the next broader category for aggregation purposes. This threshold is designed to prevent, to the extent possible, reverse-engineering of individual Strategy data from aggregate outputs.

8.3 Residual risk assessment

Pyrite will take reasonable steps to assess whether Anonymized Data, when combined with other publicly available information, could enable re-identification of your strategy. If Pyrite identifies a material re-identification risk, it will apply additional generalization, suppression, or noise-addition techniques before disclosing the relevant output.

8.4 AI training data handling

For AI model training purposes, Strategy Data is processed to extract statistical patterns, relationships between variables, and structural features. The AI Model is trained on these patterns, not on Strategy Data records as such. Pyrite implements technical controls to prevent the AI Model from memorizing or reproducing specific Strategy Data values, fund names, or identifying characteristics in its outputs.

9. Data Retention and Deletion

9.1 Retention during account lifetime

Pyrite will retain Strategy Data for the duration of your Portfolio Manager account subscription. You may delete individual fund records from the Platform at any time through the Platform's account management interface.

9.2 Deletion on account termination

• Upon termination or expiry of your Portfolio Manager account subscription, Pyrite will delete or return Strategy Data held in your account within thirty (30) days of the termination date, unless: (a) you have requested the return of Strategy Data in writing prior to termination (in which case Pyrite will return it in a standard machine-readable format within thirty days); (b) retention is required by applicable law or a lawful regulatory requirement; or (c) Strategy Data is required by Pyrite as evidence in connection with an ongoing legal or regulatory proceeding. Notwithstanding the foregoing, we will not be required to destroy, delete, or modify any backup tapes or other media made pursuant to our automated archival processes in their ordinary course of business.

9.3 Aggregate and AI-incorporated data

Anonymized Data that has already been incorporated into Aggregate Data outputs or into AI Model training sets prior to account termination cannot be isolated and removed without invalidating or recomputing those outputs or retraining the AI Model. Accordingly, such Anonymized Data — which is by definition no longer attributable to your fund — will not be deleted following termination. This is consistent with standard industry practice for statistical databases and AI systems and does not affect the confidentiality protections applicable to your Strategy Data.

9.4 Deletion confirmation

Upon request, Pyrite will provide written confirmation that Strategy Data has been deleted in accordance with this Section 9, within 30 days of the deletion being completed.

10. AI Model — Additional Provisions

10.1 No reproduction of Strategy Data in AI outputs

Pyrite will implement and maintain industry standard technical safeguards to ensure that the AI Model does not reproduce Strategy Data, fund names, specific return series, or any other Strategy Data in its responses to user queries. If you become aware of any AI Model output that appears to reproduce or identify specific Strategy Data, you should report it to Pyrite at Legal@PyriteRE.com and Pyrite will investigate promptly.

10.2 Improvement of outputs for your benefit

The use of Strategy Data in AI model training is intended, in part, to improve the accuracy and relevance of the AI Model's analytical outputs for all Platform users, including you. Improved benchmark statistics, better style classifications, and more accurate factor models benefit Portfolio Manager users directly.

10.3 No investment advice through AI

The AI Model does not provide investment advice. AI outputs are analytical observations based on quantitative methods applied to historical Strategy Data. Nothing the AI Model produces constitutes a recommendation to change your investment strategy, portfolio positioning, or business operations.

11. Term and Effect of Termination

This Agreement commences on the date you first upload Strategy Data to the Platform and continues for the duration of your Portfolio Manager account subscription. Termination of your subscription terminates the license in Section 4.2 (analytics services), Section 4.3 (peer benchmarking, to the extent of new incorporations) and Sections 4.4 (AI training, for already-incorporated Anonymized Data)., .

12. Governing Law and Dispute Resolution

This Agreement shall be governed by the laws of the State of New York, USA, without regard to conflict of laws principles, consistent with the governing law and dispute resolution provisions of the Pyrite Website Terms & Conditions.(/terms#section-15)

13. General Provisions

13.1 Relationship to Terms & Conditions

This Agreement supplements and is incorporated into the Pyrite Website Terms & Conditions. In the event of any conflict between this Agreement and the Terms & Conditions with respect to the upload and use of Strategy Data specifically, this Agreement prevails. All other provisions of the Terms & Conditions, including limitation of liability, indemnification, and IP ownership, continue to apply.

13.2 Entire agreement on Strategy Data

This Agreement, together with the Terms & Conditions and Privacy Policy, constitutes the entire agreement between Pyrite and you with respect to the upload, processing, and use of Strategy Data and supersedes all prior understandings on that subject.

13.3 Amendments

Pyrite may amend this Agreement by posting a revised version on the Platform and notifying you by email at least 30 days before the changes take effect. Continued uploading of Strategy Data after the effective date of any amendment constitutes acceptance. We will also update the “Last Updated” date. If you do not accept the amended Agreement, you must delete all Strategy Data from the Platform and/or terminate your Portfolio Manager subscription.

13.4 Severability

If any provision of this Agreement is held to be unenforceable, it shall be modified to the minimum extent necessary and the remaining provisions shall continue in full force.

13.5 No waiver

Pyrite's failure to enforce any provision of this Agreement does not constitute a waiver of that provision.

14. Acceptance

Online acceptance (Portfolio Manager registration)

This Agreement is accepted electronically by checking the corresponding box during the Portfolio Manager account registration process. Electronic acceptance has the same legal effect as a written signature. The date, time, and IP address of acceptance are recorded in Pyrite's registration system.