PAL CAPITAL FACILITY

Last Updated: July 2026 Private Acquisition League (“PAL,” “we,” “us,” or “our”) respects privacy and is committed to protecting personal information collected through its websites, forms, communication systems, access environments, professional review processes, and related services. This Privacy Policy explains the types of information we may collect, how that information may be used, how it may be disclosed, and the choices available to individuals who interact with PAL. INFORMATION WE MAY COLLECT PAL may collect information that an individual or authorized representative voluntarily provides, including: name; business or professional email address; telephone or mobile number; business or entity information; professional background; licensing or credential information; geographic or market information; appointment and scheduling information; inquiry and support information; access-request information; submitted documents; acquisition-related information; communication preferences; website-form responses; consent records; and other information submitted through approved PAL channels. PAL may also collect technical information automatically, including: Internet Protocol address; browser type; device information; operating system; referral source; pages viewed; website-interaction data; cookies; form-submission records; access logs; and security and diagnostic information. HOW INFORMATION MAY BE USED PAL may use collected information to: respond to inquiries; administer website access; verify identity or professional information; review private-access requests; coordinate appointments; provide requested information; manage authorized accounts; process professional or operational submissions; communicate concerning documents, scheduling, onboarding, support, access administration, or transaction coordination; maintain security; prevent fraud, misuse, unauthorized access, or circumvention; comply with applicable legal or regulatory obligations; maintain internal business records; improve website functionality and service delivery; and send marketing or informational communications where separate consent has been provided. SMS AND MOBILE INFORMATION No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. PAL does not sell, rent, or transfer text-message opt-in information or mobile consent records to third parties or affiliates for their own marketing or promotional purposes. Message frequency varies. Message and data rates may apply. Recipients may text STOP to opt out and HELP for assistance. SERVICE PROVIDERS PAL may provide limited information to service providers that perform services on PAL’s behalf, including website hosting, communications, customer service, appointment scheduling, security, document processing, data storage, technical support, professional review, and related operational services. Such service providers may use the information only as necessary to provide the contracted services and remain subject to applicable confidentiality and data-protection restrictions. LEGAL AND SECURITY DISCLOSURES PAL may disclose information when reasonably necessary to: comply with applicable law, legal process, court order, or governmental request; enforce applicable terms, agreements, rights, or policies; protect PAL, its participants, counterparties, systems, or property; investigate fraud, security incidents, unauthorized activity, or potential violations; or prevent harm or unlawful conduct. COOKIES AND TECHNICAL TECHNOLOGIES PAL may use cookies, pixels, analytics tools, and similar technologies to maintain website functionality, understand website usage, remember preferences, support security, and improve user experience. Browser settings may allow users to restrict or disable cookies; however, some website functions may not operate correctly after cookies are disabled. DATA RETENTION PAL may retain personal information for the period reasonably necessary to fulfill the purposes described in this Privacy Policy, comply with applicable obligations, resolve disputes, maintain records, protect legal rights, and enforce agreements. DATA SECURITY PAL uses reasonable administrative, technical, and organizational safeguards intended to protect information against unauthorized access, loss, misuse, alteration, or disclosure. No electronic transmission or storage system can be guaranteed to be completely secure. INDIVIDUAL CHOICES Individuals may: decline optional marketing communications; decline optional SMS consent; reply STOP to discontinue SMS communications from the applicable PAL messaging program; reply HELP for assistance; request correction of inaccurate contact information; or contact PAL regarding privacy questions. Declining optional SMS or marketing consent will not prevent submission of a website form, private-access request, professional profile, or inquiry. THIRD-PARTY LINKS PAL websites may contain links to third-party websites or services. PAL does not control and is not responsible for the privacy practices, security, or content of third-party services. CHILDREN PAL’s websites and services are intended for adults and professional users. PAL does not knowingly collect personal information from children under the age required by applicable law. POLICY UPDATES PAL may update this Privacy Policy when appropriate. The current version will be posted through the applicable Governance Archive or legal-policy page with its updated month and year. PRIVACY CONTACT Questions concerning this Privacy Policy may be directed to: Private Acquisition League 18 King Street East Suite 1400 Toronto, Ontario M5C 1C4 Canada Email: [email protected] Telephone: 888-805-5520 Universal Private Equity Trust DBA Private Acquisition League (PAL)

Last Updated: July 2026 These Terms and Conditions govern access to and use of websites, forms, communication systems, information, materials, access environments, and related services operated under the Private Acquisition League brand. By accessing or using a PAL website, submitting information, or using an authorized PAL communication channel, the user acknowledges these Terms and Conditions. BUSINESS IDENTITY The website and related communication environment are operated under the business name Private Acquisition League. Universal Private Equity Trust DBA Private Acquisition League (PAL) INFORMATIONAL PURPOSE Unless PAL expressly provides written authorization or a separate written agreement, website content is provided for general informational and administrative purposes only. Nothing on a PAL website constitutes: a public offer; public solicitation; investment advice; legal advice; tax advice; financial advice; guaranteed access; guaranteed approval; guaranteed funding; guaranteed acquisition; guaranteed settlement; guaranteed compensation; employment; partnership; agency authority; brokerage authority; or authorization to bind PAL. PRIVATE OPERATING POSTURE PAL does not operate as: a public employment board; a retail investment platform; an open membership association; a public acquisition marketplace; a public fundraising venue; a real-estate coaching program; or a public promotional network. Access, participation, authority, professional activity, compensation eligibility, and protected materials remain subject to separate review, documentation, approval, and written authorization. NO PUBLIC PROMOTION OR REPRESENTATION PAL does not participate in public promotional venues, public advertising campaigns, public recruitment campaigns, open public solicitations, or unauthorized public marketing concerning its private operating activities. No person may advertise, market, promote, publicly represent, solicit for, publish on behalf of, or otherwise hold themselves out as an authorized representative of PAL without specific written authorization. Where an authorized participant communicates with an appropriate acquisition counterparty, the participant may describe their relationship only within the scope of the applicable written authority and approved communication procedures. Unauthorized use of PAL’s name, marks, identity, materials, relationships, or private operating framework is prohibited. AUTHORIZED ACCESS Access to protected PAL information, systems, environments, documents, opportunities, or communications may require: identity verification; professional review; credential verification; executed agreements; compliance review; written authorization; access credentials; or other approval procedures. Submission of an inquiry, profile, form, or payment does not independently create authority, acceptance, approval, compensation eligibility, or a contractual relationship unless established by a separate written agreement. ACCEPTABLE USE Users must not: violate applicable law; misrepresent identity, authority, credentials, or affiliation; interfere with website operation or security; attempt unauthorized access; upload malicious code; harvest information; reverse engineer protected systems; circumvent access controls; reproduce proprietary materials without authorization; disclose confidential information; misuse contact information; submit false or misleading information; impersonate PAL or an authorized participant; or authorize to use PAL systems for unlawful, deceptive, abusive, or unauthorized activity. INTELLECTUAL PROPERTY All website content, branding, designs, graphics, marks, text, systems, methodologies, notices, documentation, workflows, materials, and proprietary concepts are owned by or licensed to PAL and are protected by applicable intellectual-property rights. No PAL content may be copied, reproduced, distributed, republished, transmitted, displayed, modified, reverse engineered, commercially exploited, or used to create derivative works without express authorization. THIRD-PARTY SERVICES PAL may use third-party platforms, communications providers, hosting services, scheduling systems, payment institutions, document systems, title services, professional providers, or other operational vendors. PAL is not responsible for the independent acts, availability, security, policies, or performance of third-party providers except as required by applicable law or an express written agreement. SMS MESSAGING PROGRAM Program Name: Private Acquisition League Communications Program Description: PAL may send operational, administrative, professional-service, access-related, scheduling, verification, onboarding, document-request, support, acquisition-coordination, account-notification, informational, or marketing text messages where the recipient has provided the applicable consent. Message frequency varies. Message and data rates may apply. Carriers are not liable for delayed or undelivered messages. SMS consent is not a condition of purchase, payment, submitting a profile, requesting access, receiving review, approval, participation, or receiving services. OPT-OUT INSTRUCTIONS You can cancel the SMS service at any time. Text STOP to the applicable Private Acquisition League messaging number. After you send STOP, PAL may send a confirmation message confirming that you have been unsubscribed. After processing the request, you will no longer receive messages from that messaging program unless you complete an applicable opt-in process again. REJOINING After opting out, a recipient may rejoin an applicable messaging program by completing the relevant opt-in form or otherwise providing a new compliant consent through an approved PAL channel. HELP INSTRUCTIONS For assistance, text HELP or contact: Private Acquisition League [email protected] 888-805-5520 PRIVACY Use of PAL websites and communications is also governed by the PAL Privacy Policy. LIMITATION OF LIABILITY To the fullest extent permitted by applicable law, PAL and its authorized service providers will not be liable for indirect, incidental, special, consequential, exemplary, or punitive damages arising from website use, inability to use the website, reliance on website information, delayed communications, third-party services, unauthorized access, or interruption of services. Nothing in these Terms excludes liability that cannot lawfully be excluded. INDEMNIFICATION To the extent permitted by law, a user agrees to indemnify and hold PAL harmless from claims, liabilities, losses, damages, and reasonable costs arising from the user’s unlawful conduct, misrepresentation, unauthorized activity, infringement, breach of these Terms, or misuse of PAL systems or information. SUSPENSION OR TERMINATION PAL may restrict, suspend, or terminate website or system access where PAL reasonably determines that a user has violated applicable policies, agreements, access restrictions, security requirements, professional standards, or law. GOVERNING PROCEDURES Any separate participation, professional, transaction, confidentiality, acquisition, payment, or access agreement controls over these general website Terms concerning its specific subject matter. CHANGES TO THESE TERMS PAL may update these Terms and Conditions. The current version will be posted through the Governance Archive or applicable legal-policy page with its updated month and year. CONTACT Private Acquisition League 18 King Street East Suite 1400 Toronto, Ontario M5C 1C4 Canada Email: [email protected] Telephone: 888-805-5520 Universal Private Equity Trust DBA Private Acquisition League (PAL)

Last Updated: July 2026 PAL may communicate through approved channels including email, telephone, SMS, MMS, website chat, voicemail, scheduling systems, secure portals, and other authorized business communication systems. Communications may concern: inquiries; requested information; access administration; identity or credential verification; document requests; appointment scheduling; reminders; account notices; professional review; onboarding; acquisition submissions; transaction coordination; support requests; operational updates; security; private briefings; and other authorized business matters. Providing an email address or telephone number permits PAL to respond to the individual’s request through an appropriate communication channel. Providing a telephone number alone does not constitute consent to receive recurring automated text messages. SMS consent must be obtained separately through an applicable optional opt-in checkbox or another approved consent method. Operational and marketing SMS consent must remain separate. Individuals may choose one, both, or neither SMS option. Consent boxes must not be preselected. SMS consent is not a condition of: submitting a form; requesting information; requesting private review; making a payment; receiving consideration; receiving professional services; maintaining access; or participating in an approved PAL environment. Message frequency varies. Message and data rates may apply. Text STOP to opt out. Text HELP for assistance. Carriers are not liable for delayed or undelivered messages. Consent may be withdrawn through the applicable opt-out method. Withdrawal does not affect communications already lawfully sent. Certain non-promotional administrative, security, account, or service communications may continue where legally permitted and reasonably necessary to administer an existing authorized relationship or respond to a pending request. For assistance, contact: [email protected] 888-805-5520

Last Updated: July 2026 Program Name: Private Acquisition League Communications Private Acquisition League may operate SMS and MMS messaging programs for recipients who have provided the applicable consent. TYPES OF MESSAGES Operational and non-marketing messages may include: responses to inquiries; identity or credential verification; access administration; document requests; appointment scheduling; appointment reminders; onboarding coordination; account notifications; acquisition-submission updates; transaction coordination; professional-service notifications; security alerts; support communications; and related administrative matters. Marketing and informational messages may include: professional updates; private briefings; PAL announcements; events; resources; future participation opportunities; educational information; service information; and other authorized promotional or informational communications. CONSENT Operational and marketing SMS consent are separate and optional. Users may select one, both, or neither option. Consent boxes must remain unchecked by default. Providing a mobile number, submitting a form, making a payment, requesting review, or accessing a website does not independently constitute recurring SMS consent. MESSAGE FREQUENCY Message frequency varies based on the recipient’s interaction, requests, account activity, appointments, submissions, and selected communication preferences. RATES Message and data rates may apply. OPT OUT Text STOP to the applicable PAL messaging number to opt out. PAL may send one confirmation message after an opt-out request. After the opt-out is processed, no additional messages will be sent from that messaging program unless the recipient provides new consent. REJOINING A recipient who has opted out may rejoin an applicable PAL messaging program by completing the applicable opt-in form or otherwise providing new compliant consent through an approved PAL channel. HELP Text HELP for assistance. Recipients may also contact: [email protected] 888-805-5520 CARRIER DISCLAIMER Carriers are not liable for delayed or undelivered messages. NO CONDITION Consent to receive SMS messages is not a condition of purchase, payment, private-access review, approval, participation, submission of an acquisition, maintaining access, or receipt of services. PRIVACY Mobile information and SMS opt-in consent will be handled in accordance with the PAL Privacy Policy. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. PAL does not sell, rent, or transfer mobile telephone numbers, SMS opt-in data, or SMS consent records to third parties or affiliates for their independent marketing or promotional purposes.

This website provides information concerning Private Acquisition League and its controlled operating environments. Nothing on this website constitutes: public recruitment; public membership; a public offer; a public investment solicitation; authority to represent PAL; authority to bind PAL; guaranteed access; guaranteed acquisition; guaranteed closing; guaranteed compensation; or guaranteed advancement. Certain information, systems, documents, communications, professional activities, or opportunities may require separate review, verification, documentation, approval, and written authorization. Access to protected PAL environments is private, controlled, individually issued, non-transferable, and subject to continuing authorization. Credential sharing, unauthorized access, account lending, bypassing security, public distribution of protected links, impersonation, false submissions, scraping, interference, and use outside authorized purposes are prohibited. PAL may refuse, suspend, limit, or revoke access without creating a right to compensation or continued participation, subject to applicable contractual rights. Access logs, account activity, document access, and security events may be reviewed for system protection, fraud prevention, compliance, and enforcement. PAL reserves all rights concerning access, participation, communications, credentials, and protected operating environments. PAL does not authorize any participant to publicly advertise, market, promote, recruit for, or represent PAL without specific written authority.

Private Acquisition League websites, access environments, portals, operating systems, communications, documents, and protected materials may contain confidential, proprietary, restricted, privileged, or non-public information. Protected materials may include: standard operating procedures; acquisition criteria; Buy Box materials; scripts; seller and property information; contact records; title and lender relationships; settlement structures; transaction documents; forms; templates; workflows; methodologies; internal communications; training; videos; operational notices; pricing or compensation information; private briefings; advancement information; technical systems; access credentials; and other non-public business information. Unless PAL provides express written authorization, protected materials may not be: copied; photographed; screen-captured; downloaded; recorded; published; forwarded; transmitted; distributed; resold; disclosed; reverse engineered; used competitively; used to circumvent PAL; used to interfere with PAL relationships; or used outside the scope of authorized PAL activity. Access to protected information does not transfer ownership, licensing rights, agency authority, publication rights, or authority to use PAL information for an independent purpose. Confidentiality and restricted-use obligations may also be governed by separately executed nondisclosure, non-circumvention, participation, professional, transaction, or access agreements. Where a separate executed agreement applies, that agreement controls concerning its specific subject matter. Confidentiality obligations may survive expiration, termination, denial, suspension, or revocation of access to the extent provided by an applicable agreement or law.

The universal PAL Governance Archive does not replace any relationship-specific agreement. Depending on the applicable relationship, activity, transaction, access level, or professional role, PAL may require separate documents including: nondisclosure agreements; non-circumvention agreements; participation agreements; representation agreements; independent contractor agreements; professional access agreements; institutional capital relations agreements; private representative agreements; acquisition agreements; assignment agreements; settlement agreements; transaction documents; compensation schedules; compliance acknowledgments; or other PAL-approved documentation. Each separate agreement applies only to its stated subject matter. Viewing a website, opening an accordion, receiving a document, submitting an inquiry, completing a profile, or entering an access environment does not independently constitute execution of a separate agreement. Where electronic acceptance or electronic signature is used, the applicable agreement must be presented for review and must identify the action that constitutes acceptance. Website Terms acceptance, privacy acknowledgment, SMS consent, payment authorization, and execution of a separate agreement must remain separate actions unless applicable law and the actual document expressly permit otherwise. SMS consent may not be bundled into execution of a separate agreement. Marketing SMS consent may not be required as a condition of executing an agreement, submitting a form, requesting review, making a payment, receiving consideration, maintaining access, or receiving services. A separate agreement may control over the universal Terms and Conditions concerning its specific subject matter. Do not display a “Review or Execute Agreement” button unless the actual agreement and execution workflow are connected and functional. Do not mark an agreement as executed merely because a person visited a page, opened a notice, or clicked a navigation button.

All content, branding, names, logos, shield marks, eagle-and-globe imagery, map marks, designs, graphics, text, systems, methodologies, workflows, slogans, notices, documentation, forms, communication frameworks, access environments, training, scripts, videos, templates, and materials appearing on or distributed through Private Acquisition League-controlled environments are protected by applicable intellectual-property rights. Protected PAL identity and materials include, where applicable: Private Acquisition League; PAL; PAL shield and emblem designs; PAL globe and map imagery; “Where Solutions Become Reality.”; “Every generation gets a golden moment.”; website and portal designs; institutional films; governance documents; operating systems; workflows; standard operating procedures; acquisition criteria; Buy Box materials; forms; templates; scripts; training; access environments; and other original or licensed materials. No portion may be reproduced, copied, adapted, distributed, republished, transmitted, displayed, modified, scraped, reverse engineered, commercially exploited, disclosed, or used to create derivative or confusingly similar works without express written authorization. No person may use PAL names, marks, content, designs, documents, or systems in a manner that falsely suggests sponsorship, affiliation, endorsement, appointment, approval, or authorization. Removal or concealment of copyright, trademark, proprietary, confidentiality, or access notices is prohibited. Written permission requests may be directed to: [email protected] All rights reserved.

BURGESS COMMON LAW COPYRIGHT NOTICE The Private Acquisition League and its affiliated participants, including but not limited to its private acquisition workflows, access-controlled dashboards, governance frameworks, participation-based ownership pathways, transaction coordination processes, and internal execution methodologies, constitutes proprietary intellectual property protected under common law copyright. Public notice is hereby given pursuant to Burgess Common Law Copyright doctrine. Unauthorized duplication, misrepresentation, reverse engineering, circumvention, derivative use, or exploitation of this system, its materials, or its operational framework is strictly prohibited. PRIVATE NOTICE OF ENFORCEMENT Any unauthorized use, misrepresentation, or attempted circumvention of the Private Acquisition League may trigger immediate enforcement actions. Violations may result in, but are not limited to: Immediate termination of access and participation Assessment of contractual and statutory damages Enforcement of predefined violation fee schedules Attachment of equitable remedies across affected transactions Where applicable and permitted by law, enforcement remedies may include the attachment of security interests, claims, or liens arising from violations connected to transactions, counterparties, or assets directly or indirectly involved in such violations. These remedies are designed to protect the integrity of the network, its participants, and its private acquisition framework. INSTITUTIONAL NOTICE Private Acquisition League operates as a private, access-controlled environment governed by enforceable participation standards. Entry into this environment constitutes acknowledgment of these protections and remedies. This is not a public system. This is not an open platform. This is a private acquisition and ownership network structured to defend its integrity. All rights reserved.