PRIVACY POLICY

1. About This Privacy Policy

PACT Capital respects your privacy and is committed to protecting it. This Privacy Policy describes how we collect, use, and share personal information for our commercial and business purposes. It also explains related rights and choices you may have. You may be referred to this Policy or shown other privacy notices when you visit our website or when we collect your personal information for other services. The notices supplement this Policy. This Policy also contains statements specific to California residents based on special regulations in California. To the extent those statements differ from other parts of the Policy, the statements govern in their applicable areas. This Policy doesn’t apply to personal information controlled by a third party that we process only as a contracted service provider to that third party under applicable law. If you have a relationship with a third party organization that you believe is our partner, please consult that third party’s privacy policies.

2. What Is Personal Information?

Laws in different areas may define “personal information” differently. But generally, your “personal information” includes your unique identifiers (full name, phone number, email address, etc.); and information about your characteristics, conditions or behavior that is associated with one of your identifiers or could reasonably be linked to you. “Non-personal information,” on the other hand, has been aggregated, anonymized or de-identified so that it can’t reasonably be linked to an individual.

3. Personal Information We Collect

3.1 Information You Provide To Us We may collect some or all of the categories listed below when you fill out a form on our website; subscribe to one of our newsletters; apply for, open or use an account with us; introduce yourself to one of our representatives; or contact us with questions or feedback:

contact information (full name, address, email address, phone number)
other identifiers (social security number, driver’s license or state ID number, user name)
assets, income and other financial information;
employer or business information (for example, if you apply for financial services on behalf of your company)
content in your comments, posts or communications (for example, interests you express to us about different services)

If you decline to provide requested information, we may not be able to provide one or more services to you, or you may not receive access to certain features of a service. 3.2 Information We Log Automatically Online Like most internet services, our website gathers and logs some data about visitors automatically in order to provide a requested service, identify users, customize the user experience, or understand how the site is being used (“Log Data”). Log Data collected may include the following:

online identifiers (IP address, device ID, previously set cookies and related data)
device or system information (operating system, browser type)
online activity (the name of the site you were on before navigating to our site, other browsing history)
site activity (particular pages you visit on our site and how you interact with them)
location data

Some Log Data is collected through the use of “cookies” or similar tracking technologies.

4. How We Use Personal Information

We may use your personal information:

How We Use Personal Information

Example of Categories Used

To secure your account.

• Identifiers• Financial Information• Commercial Information• Internet Activity• Geolocation Data• Professional or Employment-Related Information

To process your orders.

• Identifiers• Financial Information• Protected Classification Information• Commercial Information• Internet Activity• Geolocation Data• Professional or Employment-Related Information

To process your requests to receive information about our products or services.

• Identifiers• Financial Information• Protected Classification Information• Commercial Information• Internet Activity• Professional or Employment-Related Information

To service your account with us.

• Identifiers• Financial Information• Protected Classification Information• Commercial Information• Internet Activity• Geolocation Data• Professional or Employment-Related Information

To provide any other Services you have requested.

• Identifiers• Financial Information• Protected Classification Information• Commercial Information• Internet Activity• Geolocation Data• Professional or Employment-Related Information

To respond to your inquiries.

• Identifiers• Financial Information• Protected Classification Information• Commercial Information• Internet Activity• Professional or Employment-Related Information

To contact you about products or services we think may be of interest to you.

• Identifiers• Financial Information• Protected Classification Information• Commercial Information• Internet Activity• Professional or Employment-Related Information

To tell you about material updates or changes to our terms of use or policies

• Identifiers• Financial Information• Protected Classification Information• Commercial Information• Internet Activity• Professional or Employment-Related Information

To contact you with surveys, legal notices or other information that may be relevant to your use of the Services

• Identifiers• Financial Information• Protected Classification Information• Commercial Information• Internet Activity• Professional or Employment-Related Information

To detect, investigate or prevent activities that may violate our policies, threaten security of our Services, or may be fraudulent or illegal

• Identifiers• Financial Information• Protected Classification Information• Commercial Information• Internet Activity• Geolocation Data• Professional or Employment-Related Information

Comply with other legal obligations.

• Identifiers• Financial Information• Protected Classification Information• Commercial Information• Internet Activity• Geolocation Data• Professional or Employment-Related Information

As otherwise described to you at the point of collection or pursuant to your consent

• Identifiers• Financial Information• Medical or Health Insurance Information• Protected Classification Information• Commercial Information• Internet Activity• Geolocation Data• Professional or Employment-Related Information

To fulfill any other purpose permitted under applicable law

We may use non-personal information for any purpose, consistent with applicable law.

5. How We Share Personal Information

5.1 Affiliates We may share your information with our corporate parents, subsidiaries, and other affiliated entities for a variety of purposes, including business, operational and marketing purposes. 5.2 Vendors We may share your information with vendors that perform services on our behalf, such as hosting our online services, managing databases, performing analyses, conducting surveys, or sending communications and newsletters for us. Where necessary and appropriate, our agreements with vendors prohibit them from retaining, using or disclosing the personal information we share with them for any other purpose. 5.3 Mandatory Disclosures And Legal Proceedings We may have a legal obligation to disclose personal information to government authorities or other third parties pursuant to a valid regulatory request, subpoena or court order. We may also need to disclose and otherwise process your personal information in accordance with applicable law to defend our legitimate interests, for example, in civil or criminal legal proceedings. 5.4 Change In Control Or Merger If we decide to sell, buy, merge or otherwise reorganize our businesses, this can involve us disclosing personal information to prospective or actual purchasers and their advisers, or receiving personal information from sellers and their advisers. 5.5 With Your Consent We will share your personal information with other third parties as you may direct, or if you otherwise consent.

6. Cookies And Our Website

A cookie is a small piece of information sent by a website that is saved by your computer’s browser. It holds information that our site or another site may need to function properly, recognize your device, or personalize your experience. We use the following types of cookies:

Essential Cookies: Essential cookies are necessary in order to enable you to move around our website and use its features, such as accessing secure areas of the site
Analytics Cookies: Analytics cookies allow us to analyze use of our website to evaluate and improve performance. Where feasible, these cookies only use aggregated or other non-personal information.

We use analytics cookies and related services provided by Google Analytics. Our agreement with Google prohibits Google from using the data we may share in connection with those cookies for any other purpose. For information about Google’s own privacy practices, go here: www.google.com/policies/privacy/partners/, We don’t allow advertisers or other third parties to set, view or collect cookies through our site. You can block, disable or delete cookies on your device at any time by changing the settings in your browser. However, blocking, disabling, or deleting cookies may limit your ability to view all the pages of our site or other sites. You can find more information about cookies at www.cookiesandyou.com/ and www.youronlinechoices.com.

7. Your Rights And Choices

7.1 Access And Correct Your Personal Information If you have provided us with your contact details or other personal information, or if you are a customer of ours, we want to help make sure that your data is correct. Where feasible, we will let you review personal information that you have provided to us and will take reasonable steps to delete such information if you so request. 7.2 Opt-Out Of Email Communications If you have subscribed to one of our newsletters or are receiving marketing emails from us and would like to opt-out, you can opt-out by using the “unsubscribe” link provided in the email or by submitting your opt-out request here. 7.3 Area-Specific Rights If you are a California resident, you may have additional rights.

8. California Residents

This statement makes additional disclosures to California residents (i.e., “consumers”), and describes rights they may have, under the California Consumer Privacy Act of 2018, as amended, effective January 1, 2020 (the “CCPA”). California’s Attorney General has published proposed implementing regulations for the CCPA, but the regulations have not yet taken effect and remain subject to change. The final regulations may alter how businesses have to comply with the CCPA, and we may update this Policy when the regulations take effect. This statement and the consumer rights described do not cover certain collection and handling of personal information that is regulated under federal laws regarding financial services or credit reporting. You can learn more about the CCPA here:

https://oag.ca.gov/privacy/ccpa 8.1 Collection Of Personal Information The following table describes which categories of personal information we collected about consumers within the past 12 months. For each category, we collected one or more of the examples listed.

Identifiers

real name, signature, alias, address, telephone number, email address, Internet Protocol address, device identifier, browser cookies, web beacon, pixel tag, mobile ad identifier, other unique personal identifier, online identifier, account name, Social Security number, driver’s license or state ID number, passport number, insurance policy number, physical characteristics or description, or other similar identifiers.

Financial Information

bank account number, credit card number, debit card number, or any other financial information.

Medical or Health Insurance Information

medical conditions, medical treatment, medical history, or any other medical or health insurance information.

Protected Classification Information

age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Commercial Information

records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Internet Activity.

browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Geolocation Data

Physical location or movements

Professional or Employment-Related Information

Current or past job history or performance evaluations.

8.2 Sale Or Disclosure Of Personal Information Under the CCPA, a “sale” of personal information includes transferring, disclosing, or otherwise making personal information available to a third party in exchange for money or something else of value. We do not sell personal information. We do not sell the personal information of minors under 16 years of age without affirmative authorization. Within the past 12 months, we did not sell personal information for money. Until June 2019, we used Google Analytics services without restricting associated information sharing with Google or Google’s ability to use information shared about visitors to our site in connection with Google’s other products and services. As a result, for the first six months of 2019, we “sold” the following categories of personal information as part of a relationship with Google in which we received a non-monetary benefit (the use of Google Analytics):

Identifiers (IP address)
Internet Activity

In June 2019, we activated the IP address anonymization feature in Google Analytics and disabled Google’s ability to use personal information shared through Google Analytics with other Google products and services. For information about steps Google is taking in light of CCPA, go here: https://privacy.google.com/businesses/rdp/ Other than data sharing through Google Analytics during the first six months of 2019 as described above, we did not otherwise sell personal information in the last 12 months. Within the past 12 months, we disclosed the following categories of personal information to one or more third parties for a business or commercial purpose:

Identifiers
Internet Activity

8.3 Your Rights Consumers have the right to make the following requests to covered businesses. The requests may be made by a consumer, by a consumer on behalf of the consumer’s minor child, or by a person authorized by the consumer to act on the consumer’s behalf: Right to Know About Collection, Disclosure or Sale of Personal Information You have the right to request that a business disclose to you: (i) the categories and specific pieces of personal information the business has collected about you within the past 12 months, (ii) the categories of sources from which the personal information is collected, (iii) the business or commercial purposes for collecting or selling personal information, and (iv) the categories of third parties with whom the business shares personal information. If a business sells personal information, or discloses it for a business purpose, you also have the right to request that the business disclose the following with respect to the 12-month period preceding your request: (i) the categories of personal information that the business sold about you and the categories of third parties to whom the personal information was sold, and (ii) the categories of personal information that the business disclosed about you for a business purpose. This type of request may be referred to as a “Request to Know.” Before we can honor a Request to Know, we need to verify that the person making it is the consumer whose personal information we have. Our method for verifying any particular request weighs information we receive as part of the request, the sensitivity of the consumer information at issue, and the risk of harm to the consumer from unauthorized disclosure. Right to Request Deletion of Personal Information You have the right to request that a business delete any personal information that the business has collected from you. This type of request may be referred to as a “Request to Delete.” Before we can honor a Request to Delete, we need to verify that the person making the request is the consumer whose personal information we have. Our method for verifying any particular request weighs information we receive as part of the request, the sensitivity of the consumer information at issue, and the risk of harm to the consumer from unauthorized deletion. We are not required to delete personal information if we still need it in order to complete the transaction for which the information was collected, provide a good or service requested by you (or that we reasonably anticipate based on our relationship with you), perform a contract with you, comply with legal obligations, or accomplish any other objective recognized as an exception to the right to deletion under applicable law. Right to Opt-Out of the Sale of Personal Information You have the right to direct a business that sells personal information about you to third parties not to sell your personal information. This type of request may be referred to as a “Request to Opt-Out.” We do not sell personal information. If we decide to sell personal information in the future, we will post an appropriate notice and opt-out method, and we will not sell any personal information previously collected. Right to Non-Discrimination You have the right not to receive discriminatory treatment by a business for the exercise of your privacy rights under the CCPA. 8.4 How to Submit a Request To “Know” You can submit a Request to Know via email at info@pactcap.com. Emailed requests must state “CCPA Request to Know” in the subject line and include:

your first and last name;
the California county in which you reside;
the disclosure(s) you are requesting; and
the reason(s) you believe we have collected, disclosed or sold your personal information, specifically, within the past 12 months (for example, you used our website or received a marketing communication from us)

If you are emailing a request on behalf of another consumer as their authorized representative, you must include the foregoing information about the consumer and attach to the email a copy of a power of attorney appointing you as a duly authorized representative under California Probate Code sections 4000 to 4465 or written permission from the consumer to make the request. If you prefer, you can call to submit your request: 213-799-7228. After confirming receipt of your request, we’ll contact you if we need more information in order to verify it. If we can’t verify a request, we may deny it. 8.5 How to Submit a Request To “Delete” You can submit a Request to Delete via email us at info@pactcap.com. Emailed requests must state “CCPA Request to Delete” in the subject line and include:

your first and last name,
the California county in which you reside,
a clear statement that you want us to delete your personal information
the reason(s) you believe we have your personal information (for example, you used our website or received a marketing communication from us)

If you are emailing a request on behalf of another consumer as their authorized representative, you must include the foregoing information about the consumer and attach to the email a copy of a power of attorney appointing you as a duly authorized representative under California Probate Code sections 4000 to 4465 or written permission from the consumer to make the request. If you prefer, you can call this toll-free number to submit your request: 213-799-7228. After confirming receipt of your request, we’ll contact you if we need more information in order to verify it. If we can’t verify a request, we may deny it.

9. Other Important Information

9.1 Data Security In order to safeguard personal information against unauthorized access, removal, theft, or disclosure, we strive to use reasonable security measures appropriate to the nature of the information. Unfortunately, in our increasingly connected digital world, no one can guarantee perfect data security, and we cannot promise that our measures will always prevent a breach of personal information. Should we detect such a breach, we will promptly take remedial measures and notify affected individuals, third parties and law enforcement agencies as required by applicable law. We encourage you to help maximize security by applying your own personal security measures. For more information about what you can do to protect your data, please see the tips and resources offered by the U.S. Federal Trade Commission at https://www.consumer.ftc.gov/topics/privacy-identity-online-security and the California Attorney General at https://www.oag.ca.gov/privacy/consumer-privacy-resources. 9.2 Email And Use Of Online Forms If you are communicating to us by email, please be aware that your transmission is not necessarily secure against interception and could be read by third parties. However, if you use one of our online forms to communicate with us, those forms are encrypted. If you are sending us information that is sensitive, such as your bank account number, a charge card or debit card number or social security number, you should send your correspondence to us via postal mail to PACT Capital, Inc., 2041 Rosecrans Ave. Suite 355, El Segundo, CA 90245, or contact us at 213-799-7228. 9.3 Quality And Retention of Personal Information We take reasonable steps to keep the personal information we possess accurate and to delete incorrect or unnecessary personal information. We retain personal information only as long as necessary to fulfill the purposes outlined in this Privacy Policy or otherwise communicated to you, unless a longer period is required by applicable law. We encourage you to access your personal information through your account from time to time to help us ensure that it is up to date. 9.4 Third Party Sites And Services Our website may contain links to third-party websites, products or services. Information those companies collect when you click on their links is governed by their privacy policies, not ours. We encourage you to learn about the privacy practices of those third parties. 9.5 Third-Party Direct Marketing We do not disclose, and have not disclosed, personal information to third parties for their direct marketing purposes. 9.6 “Do Not Track” Signals Your browser may offer a Do Not Track (DNT) setting. If you turn that setting on, your browser sends a signal to websites indicating that you don’t want to be tracked over time or across third party sites. We don’t currently respond to these signals. because there is not yet a common understanding of how to process them or a consensus on what “tracking” means. 9.7 Children’s Privacy Our services are not intended for children (individuals under the age of 16). We do not knowingly collect, maintain, or process personal information from children without parental consent or another form of consent that may be required under applicable law. Visit the Federal Trade Commission website for more information about protecting children’s online privacy: https://www.ftc.gov/tips-advice/business-center/privacy-and-security/children%27s-privacy . 9.8 Changes To This Policy We will update this Policy at least once every 12 months to reflect any material changes in applicable law, our privacy practices, or our services. If we have your contact information, we will send you notice of material changes, and you should periodically review this Policy to remain aware of our current practices.

10. Contact Us

If you have any questions or concerns about this Policy or our practices, or wish to exercise your rights regarding your personal information under applicable law, please contact us by email at info@pactcap.com, by phone at 213-799-7228, or at the following address: PACT Capital 2041 Rosecrans Ave. Suite 355, El Segundo, CA 90245