Online Privacy Notice

This Online Privacy Notice describes the personal information Pershing Square Holdings, Ltd. (“PSH”) collects or receives from or about you, in its capacity as a data controller, when you visit https://pershingsquareholdings.com/ (“Website”) and the ways in which we use and share it. This Online Privacy Notice does not apply to information we collect from you offline such as when you submit an application or other form to us or one of our affiliates via mail or by telephone.

If you are a prospective, current or former shareholder of PSH, some of the information we may collect from you online may constitute “non-public personal information.” Our collection, sharing and use of non-public personal information is governed by the privacy notice we deliver to you pursuant to federal law, which is also available here.

Information We Collect About You

We collect information about you in various ways. Some of this information may be considered “personal information” or “personal data” (together, “personal information”) under applicable law. The personal information that you provide and that we collect or receive from you depends on the context of your interaction with us and our Website, the choices you make when you use our Website, and the features that you use.

You may provide information to us directly. This information may include your name and contact details.

You may provide information to third parties or service providers who act on our behalf. We collect and receive information when you provide your information to our third-party service providers and other partners who we engage to assist us in providing services to you. Such third parties may include website providers and entities that assist us in holding events. The information collected by such entities may include your name, contact details, IP address and other online identifiers.

We may collect information from you automatically through tracking technologies. When you visit our Website we collect certain information from you automatically. We may collect this information through cookies, web beacons, tags and scripts and other tracking technologies. We may combine this information with other information we collect about you on our Website or via other sources.

The information we collect automatically may include the following:

Your IP address.
Your device identifier.
The location associated with your device.
The type of browser and/or operating system you are using.
The domain name of your Internet service provider.
Information regarding when you access or how you use our Website.
The URLs of the pages that you visit and information regarding how long you use various pages or aspects of our Website.

For more information regarding how we and third parties we engage may collect information from you automatically via cookies and other tracking technologies, please see, Cookies and Online Tracking below.

How We Use Your Information

We may use the information we collect from you in a variety of ways, including:

To present our Website and its contents to you and to operate our Website. Our lawful basis for processing your personal information for these purposes is the performance of our contract and/or our legitimate interests in engaging in marketing our business through our Website and making information available to visitors to our Website.
To deliver the information, products or services you have requested from us. Our lawful basis for processing your personal information for these purposes is the performance of our contract
To reach out to you about and market or promote new information, products or services to you that we believe you may be interested in. Our lawful basis is our legitimate interests in engaging in such marketing and to grow our business.
To communicate with you, including to notify you about changes to our Website or products or services. Our lawful basis for processing your personal information for these purposes is the performance of our contract with you and/or our legitimate interests in providing you with such communications.
To help us improve our Website and deliver a more personalized experience. This includes by enabling us to estimate and analyze our audience size and usage patterns, store information about your preferences, speed up your searches and recognize you when you return to our Website. Our lawful basis is our legitimate interests in understanding, customizing and improving our Services.
To carry out our obligations and enforce our rights. This includes what we believe is necessary or appropriate to protect, enforce or defend the legal rights, privacy, safety or property of the Website, its employees or agents, or other users or to comply with law.
To address or respond to communications sent to us. Our lawful basis is our legitimate interest in engaging with matters and queries brought to our attention that may be relevant to our business and addressing queries and concerns.
In any other way we may describe when you provide the information, or otherwise at your direction or with your consent. Our lawful basis is the performance of our contract with you and/or compliance with our legal obligations and/or our legitimate interests in managing our business.
As permitted by law or as we may notify you. Our lawful basis is the performance of our contract with you and/or compliance with our legal obligations and/or our legitimate interests in managing our business.

How We Disclose Information

We may disclose the information that we collect pursuant to this Online Privacy Notice as follows:

With our affiliates.
With our service providers, business partners and vendors. These parties may include companies that host our Website, provide web analytics, perform data processing, distribute emails to you, serve targeted ads or measure ad performance, or help us communicate with you.
When you request any of our products or services. We will share your information to the extent necessary or appropriate to fulfill your request.
When required to do so by law. For example, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency’s request.

In addition, please note that if PSH or any of its affiliates, subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of or dissolved, including through merger, consolidation, sale or divestiture of assets, the relevant customer database, including personal information we may possess about you, and information collected pursuant to this Online Privacy Notice, may, in whole or in part, be sold, disposed of, transferred, divested, or otherwise disclosed as part of that transaction or proceeding.

Cookies and Online Tracking

Cookies and Other Tracking Technologies

We and third-party partners we engage may use cookies (i.e., small text files that are stored on your browser, computer, or mobile device), web beacons, pixel tags, browser analysis tools, server logs and other tracking technologies to automatically collect information, including personal information such as your IP address, from your browser.

Our Website may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use our Website.

Our Website may use cookies and other tracking technologies for a variety of purposes, including functional and analytics purposes. For example, we, our service providers and other partners we engage use cookies and other tracking technologies:

For functional purposes, such as to provide the Website and its content to you.
For analytics purposes, such as to provide us with information about which portions of our Website are the most popular, enabling us to see what web pages a user visits and how much time a user spends on each page.
To personalize your experience on our website (e.g., to recognize you by name when you return to our site, to save your password in password-protected areas, or to tailor content, or product and service offerings to you).

Google Analytics

Our website may use Google Analytics, a web analytics service offered by Google. You may learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy at https://www.google.com/policies/privacy/partners

Your Choices:

You can generally manage your cookie preferences through your web browser. Most web browsers will tell you how to stop accepting new cookies and how to disable existing cookies. For more information regarding how to manage your preferences, please consult the information made available by your particular browser or visit https://www.allaboutcookies.org

With respect to Google Analytics, you can also view Google’s currently available opt-out options at https://tools.google.com/dlpage/gaoptout in an effort to opt-out of being tracked by Google Analytics.

For users located in the European Economic Area (“EEA”) or United Kingdom (“UK”), you can manage your cookie preferences via the cookie tool available on the Website.

Please note that if you choose not to accept cookies, you may be unable to use certain features of our Website.

Data Retention

We will retain your personal information for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. To determine the appropriate retention period for your personal information, we will consider the amount, nature and sensitivity of the personal information, the potential risk from unauthorized use or disclosure, the purposes for which we process personal information and whether we can achieve those purposes through other means, and applicable legal requirements.

In some circumstances we may anonymize your personal information so that it can no longer be associated with you, in which case it is no longer personal information.

Links to Third-Party Websites

Our Website contains links to third-party sites and services whose privacy practices may be different than ours. We may also allow you to connect with other third-party sites and services. We are not responsible for the privacy practices of third-party sites and services and you should consult the other third-party sites’ and services’ privacy notices in order to better understand their privacy practices.

Additional Information for California Residents

The California Consumer Privacy Act (“CCPA”) provides California residents privacy rights with respect to certain personal information. If you are a California resident, please visit our California Privacy Notice for more information. The California Privacy Notice supplements and should be read in conjunction with this Online Privacy Notice.

Additional Information for Individuals in the EEA or UK

GDPR Rights

Where personal data relating to you is processed within scope of the GDPR/UK GDPR, you have certain rights regarding the “personal data” about you that you can exercise in certain circumstances. The General Data Protection Regulation (“GDPR”) defines “personal data” as any information which is related to an identified or identifiable natural person but does not include data where you can no longer be identified from it such as anonymized aggregated data. These rights are to:

Access the personal data we have about you (commonly known as a “data subject access request”) and request certain information in relation to its processing.
Correct the personal data we have about you.
Restrict the processing of your personal data.
Have your personal data deleted (i.e., the “right to be forgotten”).
Object to the processing of your personal data.
Not be subject to automated decision-making.
Take your personal data somewhere else (i.e., the right to portability).

Submission of Requests

Please contact [email protected] to make any of these requests.

We may require you to provide proof of your identity to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights) before we are able to fully review your request. This is an appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it. Please note that, where we determine that we can grant your request, we will do so as soon as possible, but it may take us more time in some cases, for example for full erasure of your personal data stored in our backup systems. There may be situations where we are not required to comply with your request and we will let you know if one of those situations arises.

You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact [email protected]. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless we now have an alternative legal basis for doing so.

Accuracy of information

It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data which we hold changes during your relationship with us.

Change of purpose

We may use your personal data for purposes other than the purposes identified above in the ‘How We Use Your Information’ section where such other purposes are not incompatible with the purposes identified in this notice.

Special categories of personal data and personal data relating to other individuals

We do not intend to collect personal data which reveals or contains racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life and sexual orientation. Similarly, there are fewer bases for processing criminal convictions and offences data. Whilst we will use reasonable efforts to limit our holding of such data, please be aware that we may hold such data incidentally. For example, where you volunteer such data to us or one of our processors, such as if you send us an email or fill out an online form containing such data. Please do not submit such data or personal information relating to other individuals to us through our Website unless it is strictly necessary for the purposes you are contacting us.

Concerns

We hope that you don’t ever have an issue with the way that we handle your personal data, but if you do, please contact [email protected] to let us know so that we can make it right. If you’re ever not happy with the way that we handle your request, you also have the right to file a complaint at any time with your local supervisory authority for data protection issues.

Data Transfers

Our Website is hosted in the United States and we and our services are also located in the United States. Each is governed by United States law. If you are visiting or using the Website from outside the United States, please be aware that your personal data may be transferred to, stored, and processed in the United States. The data protection and other laws of the United States and other countries might differ from, and not be as comprehensive as, those in your country. Where we further transfer your personal data in the United States and where required by law, we have put in place appropriate safeguards to protect your personal data such as approved standard contractual clauses to ensure that your personal data is treated in a manner that is consistent with and respects the EEA and UK laws on data protection. If you would like further information about this you can request it from [email protected].

Security

PSH takes seriously the obligation to safeguard personal information. PSH has implemented procedures that are designed to restrict access to personal information to its personnel who need to know that information to perform their jobs. Physical, electronic, and procedural safeguards are in place to guard your personal information.

Children’s Privacy and Permissible Age for Use of Services.

Our Website is not intended for users under the age of 16, and PSH does not knowingly collect information from anyone under the age of 16. No one under the age of 16 is permitted to access or use this Website or provide us with personal information.

Changes to the Online Privacy Notice

From time to time, PSH may update or revise this Online Privacy Notice. If there are changes to the terms of this Online Privacy Notice, documents containing the revised policy on the relevant website(s) will be updated.

How to Contact Us

If you have any questions or concerns about this Online Privacy Notice, please contact us at [email protected].

Last updated April 2025