Last Updated: 19 December 2025 Summit Ventures & Capital Montenegro d.o.o. This Privacy Policy explains how Summit Ventures & Capital Montenegro d.o.o. (“we”, “us”, “our”) collects, uses, and protects your personal data when you visit our website www.summit-ventures-and-capital.com (“Website”). We process personal data in accordance with the Law on Personal Data Protection of Montenegro, the Law on Electronic Commerce, and EU-aligned data protection principles (GDPR standards). By using our Website, you agree to the terms of this Privacy Policy. 1. Data Controller Summit Ventures & Capital Montenegro d.o.o. Budva, Montenegro

Company Registration Number: [insert] Email: info@summitventurescapital.com (“Data Controller”) 2. What Personal Data We Collect We collect only the data that is necessary for communication, investment inquiries, and website functionality. 2.1. Data you provide voluntarily: Name Email address Phone number Company or investor information Messages submitted through our contact form Subscription information (if you sign up for updates) 2.2. Data collected automatically (via cookies/analytics): IP address Browser type/version Device information Pages visited and time spent Referring website Basic geolocation (non-precise) We do not use any automated profiling, credit scoring, or decision-making tools. 3. Purpose and Legal Basis for Processing Your data is processed strictly for the following purposes: 3.1. Communication and inquiries To respond to messages, investment interest, partnership requests, or general contact. Legal basis: Legitimate interest / Consent 3.2. Investor relations To provide information about land development, chalet investments, or project updates. Legal basis: Legitimate interest 3.3. Website analytics and performance To ensure secure, optimized, and user-friendly website functionality. Legal basis: Legitimate interest 3.4. Legal or regulatory compliance To comply with obligations under Montenegrin law. Legal basis: Legal obligation We do not sell or rent personal data. 4. How We Use Your Personal Data We use your data to: respond to your inquiries evaluate investor interest send updates (only if you subscribed or requested them) maintain and improve our Website protect our Website against misuse comply with legal obligations Your data is never used for automated decision-making or mass marketing without consent. 5. Data Sharing We may share your personal data only in these cases: Service providers (e.g., website hosting, analytics tools) Legal authorities if required by Montenegrin law Professional advisors (tax, legal, accounting) when necessary Business partners only with your explicit consent All third parties must comply with Montenegrin data protection standards. We never sell personal data to third parties. 6. International Transfers If personal data is transferred outside of Montenegro (e.g., website hosting providers), we ensure that: the country has adequate protection, or appropriate safeguards (EU Standard Contractual Clauses) are in place. 7. Data Retention We store your data only as long as necessary:

Contact inquiries: up to 24 months Investor communications: up to 5 years Website analytics data: 6–24 months Legal obligations: as required by Montenegrin law When data is no longer required, it is securely deleted. 8. Cookies & Tracking Technologies Our Website may use cookies for: essential site functionality performance analytics (e.g., Google Analytics) security and load balancing You may disable cookies in your browser settings, but some site features may not function properly. A separate Cookie Policy can be provided if required. 9. Your Rights (Under Montenegrin Law) You have the right to: Access your personal data Rectify inaccurate or incomplete data Request deletion (“right to be forgotten”) Restrict processing Object to processing Withdraw consent at any time Request data portability (if applicable) To exercise these rights, contact us at: 📧 info@summit-ventures-and-capital.com We will respond within the legal timeframe (typically 15–30 days). 10. Data Security We implement appropriate technical and organizational measures to protect your data, including: encrypted communication (HTTPS) restricted access to personal data secure server environments regular monitoring for unauthorized access No system is entirely risk-free, but we take reasonable measures to protect your data. 11. Links to External Websites Our Website may contain links to third-party sites. We are not responsible for their privacy practices or content. We recommend reviewing their privacy policies separately. 12. Changes to This Privacy Policy We may update this Privacy Policy from time to time. The latest version will always be posted on this page with the updated date. Continued use of the Website following any changes signifies acceptance of the revised policy. 13. Contact Information For privacy inquiries or requests, please contact: 📧 info@summitventurescapital.com Summit Ventures & Capital Montenegro d.o.o. Budva, Montenegro