Securities Screener — Privacy Policy

Last Updated: 8 March 2026

Introduction

This Privacy Policy explains how AGPB Ltd (company number 17050962), whose registered office is 3rd Floor, 86-90 Paul Street, London, England, EC2A 4NE (AGPB, we, us or our), and Benchwalk Advisors Limited of 1 Bow Lane, London, EC4M 9EE (Benchwalk) collect, use, store and protect personal data in connection with the Securities Screener application (the Application).

AGPB owns and makes the Application available. Benchwalk administers, hosts, supports and promotes the Application, and may also use certain personal data for its own business relationship, business development and related communications purposes as described in this Privacy Policy.

For the purposes of UK data protection law, including the UK GDPR and the Data Protection Act 2018:

• AGPB is the controller of personal data processed for the purpose of providing, operating, securing and administering the Application; and
• Benchwalk is a separate controller of personal data that it uses for its own business relationship management, business development, product development and related communications purposes as described in this Privacy Policy.

Where Benchwalk handles personal data solely on AGPB's instructions in support of the Application, it does so on AGPB's behalf.

1. Personal data we collect

• Identity and contact data, including your name, business email address, business telephone number, job title, employer or organisation and other account profile information.
• Account and access data, including usernames, passwords or authentication credentials, account status, permissions and related records.
• Usage data, including information about how you use the Application, such as pages viewed, features used, search inputs, screening parameters selected, reports generated and dates and times of activity.
• Technical data, including IP address, device identifiers, browser type and version, operating system, session data and other technical information generated when you access the Application.
• Communications and relationship data, including correspondence with AGPB or Benchwalk concerning the Application, support requests, feedback, records of onboarding or access-related communications, meeting notes, records of commercial discussions, and information about your interest in the Application or related services.
• Organisation-supplied data, including information provided by your employer, organisation or an authorised administrator arranging or managing your access to the Application.

The Application also uses publicly available corporate and market information, such as share prices, financial statements, regulatory announcements and filing data. That information is generally not personal data, except to the extent it relates to an identifiable individual.

2. How we collect personal data

• directly from you, for example when you request access, log in, use the Application, contact us, attend a meeting or demonstration, or provide feedback;
• from your employer, organisation, or an authorised administrator who arranges or manages access on your behalf;
• from your interactions with Benchwalk in connection with the Application, including commercial, relationship-management and business-development discussions; and
• automatically from your device or browser when you use the Application, including through server logs and strictly necessary technologies used to operate and secure the Application.

3. How we use personal data and our lawful bases

AGPB and Benchwalk use personal data for the following purposes and on the following lawful bases.

AGPB uses personal data for the following purposes:

• Providing access to and operating the Application, using identity and contact data, account and access data, and technical data, on the basis of legitimate interests and, where applicable, performance of a contract;
• Authenticating users and managing permissions, using identity and contact data, account and access data, and technical data, on the basis of legitimate interests;
• Monitoring usage, troubleshooting issues and improving functionality, using usage data and technical data, on the basis of legitimate interests;
• Maintaining security logs, audit trails and related records, using account and access data, usage data and technical data, on the basis of legitimate interests and, where applicable, legal obligation; and
• Responding to enquiries, onboarding requests, support matters and feedback, using identity and contact data, communications and relationship data, and account and access data, on the basis of legitimate interests.

Benchwalk uses personal data for the following purposes:

• Responding to enquiries, onboarding requests, support matters and feedback, using identity and contact data, communications and relationship data, and account and access data, on the basis of legitimate interests;
• Managing business relationships with users and their organisations, including commercial discussions, product development, relationship management and internal record-keeping relating to the Application and related services, using identity and contact data, communications and relationship data, organisation-supplied data and limited usage data where relevant to the relationship, on the basis of legitimate interests;
• Sending business-to-business updates and communications about the Application, related events, opportunities and Benchwalk services where permitted by applicable law, using identity and contact data and communications and relationship data, on the basis of legitimate interests and, where required by law, consent; and
• Establishing, exercising or defending legal rights and complying with law or regulation, using any categories of personal data relevant to the issue, on the basis of legitimate interests and, where applicable, legal obligation.

AGPB may also use personal data to establish, exercise or defend legal rights and to comply with law or regulation, using any categories of personal data relevant to the issue, on the basis of legitimate interests and, where applicable, legal obligation.

4. Legitimate interests pursued

• operating, administering and improving the Application;
• managing authorised user access and providing support;
• maintaining the security, confidentiality and integrity of the Application and its data;
• protecting AGPB's and Benchwalk's businesses, systems, intellectual property and legal rights;
• understanding how the Application is used and how it can be improved; and
• developing and managing business relationships, related services and permitted business-to-business communications concerning the Application and associated offerings.

5. Sharing personal data

• Between AGPB and Benchwalk, where reasonably necessary for the purposes described in this Privacy Policy; where either receives personal data for its own purposes described in this Privacy Policy, it will handle that data as a controller for those purposes;
• Technology, hosting, authentication, analytics, security and IT support providers who assist with the operation of the Application;
• Market data providers and other third-party integrations, where technical request data such as IP address or device information may be transmitted in the course of providing requested functionality;
• Professional advisers, insurers, auditors and other advisers where disclosure is reasonably necessary for advice, compliance, risk management or legal claims; and
• Regulators, courts, law enforcement bodies or other public authorities where disclosure is required by law or reasonably necessary to establish, exercise or defend legal rights.

We do not sell personal data to third parties for their own marketing purposes.

6. International transfers

Some service providers may process personal data outside the United Kingdom. Where that occurs, the relevant controller will ensure that transfers are made using a lawful transfer mechanism and with appropriate safeguards, such as adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU standard contractual clauses, or another valid safeguard under UK data protection law.

Further information about relevant safeguards may be requested using the contact details below.

7. Data retention

• Account and access data: retained for as long as your account remains active and ordinarily for up to 12 months after access ends, unless longer retention is needed for security, legal or audit reasons.
• Usage data: ordinarily retained for up to 24 months, unless a longer period is justified for security, troubleshooting, legal or evidential purposes.
• Technical and security log data: ordinarily retained for up to 12 months, unless longer retention is reasonably required for investigation, incident response or legal purposes.
• Communications and relationship data: retained for the duration of the relevant relationship or matter and ordinarily for up to 6 years afterwards, where needed for record-keeping, relationship management or legal purposes.
• Marketing suppression and opt-out records: retained for as long as reasonably necessary to ensure that your preferences are respected.

AGPB and Benchwalk may retain personal data for longer where required by law or where reasonably necessary to establish, exercise or defend legal claims.

8. Data security

• appropriate access controls, authentication measures and role-based permissions;
• encryption of data in transit;
• security monitoring, logging and incident management processes; and
• the use of reputable infrastructure and service providers with appropriate security measures.

No method of transmission over the internet or electronic storage is completely secure, so absolute security cannot be guaranteed.

9. Your rights

• the right of access;
• the right to rectification;
• the right to erasure, in certain circumstances;
• the right to restrict processing, in certain circumstances;
• the right to data portability, where applicable;
• the right to object, particularly where processing is based on legitimate interests; and
• rights in relation to automated decision-making, although the Application is not intended to make decisions based solely on automated processing that produce legal or similarly significant effects for individuals.

You may exercise these rights in relation to AGPB processing, Benchwalk processing, or both. Requests may be sent using the contact details below and will be routed to the relevant controller.

10. Cookies and similar technologies

The Application uses strictly necessary cookies or similar technologies required for authentication, session management, security and core functionality.

If AGPB or Benchwalk introduces analytics or any other non-essential cookies or similar technologies, an appropriate consent mechanism will be implemented and this Privacy Policy and any cookie notice will be updated accordingly.

You can also configure your browser to block cookies, although this may affect the functionality of the Application.

11. Changes to this Privacy Policy

AGPB and Benchwalk may update this Privacy Policy from time to time to reflect changes to the Application, their processing activities or applicable law. The latest version will be made available through the Application or otherwise notified to users as appropriate.

12. Complaints

If you have concerns about how personal data is handled, please contact AGPB and/or Benchwalk first using the details below.

You also have the right to lodge a complaint with the Information Commissioner's Office.

13. Contact details

AGPB Ltd

(controller for Application provision, operation and administration)

Benchwalk Advisors Limited

(controller for the separate Benchwalk purposes described in this Privacy Policy, and administrative contact for the Application)

Please indicate whether your query concerns AGPB, Benchwalk, or both.