Privacy Policy

2. Personal Data We Collect

Categories of Personal Data We Collect

Sensitive Personal Information Notice: We collect certain categories of data that qualify as Sensitive Personal Information (SPI) under the CPRA, including precise geolocation, financial data, and demographic data. We use SPI only to the extent necessary to provide our products and services. You have the right to limit our use of your SPI. See Section 8 for details on how to exercise this right.

How We Collect Your Personal Data

Directly from you, when you:

• Create an account or purchase products on our website

• Use our products or services

• Create content through our products or services

• Express interest in our products or services

• Download software and/or our mobile application

• Subscribe to our newsletter

• Complete a voluntary market research survey

• Contact us with an inquiry or to report a problem (by phone, email, social media, or messaging service)

• Log in to our website via social media

Through automated technologies, including cookies, server logs, and similar technologies as you interact with our website. See our Cookie section below for further details.

From third parties, including:

• Account and payment information from another individual when they purchase a gift for you

• Device and usage data from analytics providers such as Google

• Account and payment data from social media platforms when you log in via those platforms

• Content from communication services when you grant us permission

• Account and payment data from fraud prevention organizations, law enforcement agencies, and credit risk reduction services

• Account, payment, and financial data from technical, payment, and delivery service providers

Purpose and Legal Basis for Processing

We collect and use your Personal Data to:

• Deliver your product or service and fulfill orders

• Maintain, debug, and improve our products and services

• Enable you to access PrideGlobal services and set up accounts

• Conduct research and development

• Send marketing communications (where you have consented)

• Comply with legal obligations

Where we process your Personal Data to provide a product or service, we do so because it is necessary to perform contractual obligations or because we have obtained your consent. New consent will be required if any changes are made to the type of data collected

Third-Party Categories We Share Data With

We disclose Personal Data to the following categories of third parties:

• Analytics providers (e.g., Google Analytics, Hotjar) — for website performance and usage analysis

• Advertising and marketing partners — for targeted advertising and personalized marketing

• Payment processors — to process transactions

• Email service providers — for communications

• Backup and disaster recovery providers — for data security

• Fraud prevention and law enforcement agencies — where legally required

• Business transaction parties — in the event of a merger, acquisition, or asset sale

3. Do Not Sell or Share My Personal Information

We share certain Personal Data with third-party advertising and marketing partners, which may constitute "sharing" of Personal Data under the CPRA.

Under California law, you have the right to opt out of the sale or sharing of your Personal Data. To exercise this right:

• Submit a request using the form in Section 8 of this Policy

• Use a Global Privacy Control (GPC) signal — if your browser or device is configured to send a GPC opt-out preference signal, we will honor it as a valid opt-out request for the sale and sharing of your Personal Data. No additional action is required on your part.

We do not sell or share the Personal Data of consumers we know to be under 16 years of age without affirmative authorization.

4. Cookies

What Are Cookies?

A cookie is a small file with information that your browser stores on your device. Information in this file is typically shared with the owner of the site in addition to potential partners and third parties to that business. The collection of this information may be used in the function of the site and/or to improve your experience.

How We Use Cookies

• Strictly Necessary: Required to run our service. These cannot be disabled.

• Preference: Help us remember the way you like to use our service, including location-based personalization.

• Analytics: Collect information about the types of people who visit our site to improve our service and product.

• Marketing: Shared with third-party advertisers and/or partners to provide a personalized marketing experience.

How to Control Your Cookies

So long as the cookie is not strictly necessary, you may opt in or out of cookie use at any time via our Cookie Manager. You may also configure your browser to refuse all cookies or notify you when a cookie is being sent. Note that disabling cookies may affect the functionality of certain features on our site.

Do Not Track (DNT) Signals

California's Online Privacy Protection Act (CalOPPA) requires us to disclose how we respond to Do Not Track signals. Our website does not currently alter its data collection or use practices in response to Do Not Track signals from browsers. You may, however, opt out of certain tracking through our Cookie Manager or by submitting a Global Privacy Control (GPC) signal, which we do honor.

Cookie Table

Functional Cookies

You can opt out of Google Analytics at any time here: https://tools.google.com/dlpage/gaoptout

You can read more about how Google uses your Personal Data here: https://www.google.com/intl/en/policies/privacy/

5. Data Retention

We retain your Personal Data only for as long as necessary for the purpose for which it was collected and to the extent required by applicable law. The following retention periods apply:

When we no longer need Personal Data, we will securely delete it from our systems and/or take steps to anonymize it.

6. International Data Transfer and Storage

Where possible, we store and process data on servers within the general geographical region where you reside. Your Personal Data may also be transferred to, and maintained on, servers residing outside of your state, province, country, or other governmental jurisdiction where the data laws may differ from those in your jurisdiction.

We will take appropriate steps to ensure that your Personal Data is treated securely and in accordance with this Policy and applicable data protection law, including the use of Standard Contractual Clauses where required. More information: https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32021D0914

7. Sharing and Disclosure

We will share your Personal Data with third parties only in the ways set out in this Policy or at the point when the Personal Data is collected.

Legal Requirements: We may use or disclose your Personal Data to comply with a legal obligation, in connection with a request from a public or government authority, in connection with court or tribunal proceedings, to prevent loss of life or injury, or to protect our rights or property. Where possible and practical, we will tell you in advance of such disclosure.

Service Providers: We may share your Personal Data with third-party service providers, independent contractors, agencies, or consultants to deliver and help us improve our products and services. These parties are contractually required to protect your data and process it only as directed by us.

Merger or Acquisition: If we are involved in a merger, acquisition, or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

8. Your Privacy Rights

Depending on your geographical location, your rights are subject to local data privacy regulations and may include the following:

Rights Available to California Residents (CCPA/CPRA)

Right to Know: You have the right to request disclosure of the categories and specific pieces of Personal Data we have collected about you, the categories of sources, the business or commercial purposes for collecting it, and the categories of third parties with whom we share it.

Right to Delete: You have the right to request deletion of Personal Data we have collected from you, subject to certain exceptions.

Right to Correct: You have the right to request correction of inaccurate Personal Data we maintain about you.

Right to Opt-Out of Sale or Sharing: You have the right to opt out of the sale or sharing of your Personal Data for cross-context behavioral advertising. To opt out, use the form below or configure your browser to send a Global Privacy Control (GPC) signal, which we will honor automatically.

Right to Limit Use of Sensitive Personal Information: You have the right to direct us to limit our use of your Sensitive Personal Information (SPI) — including precise geolocation, financial data, and demographic data — to only what is necessary to provide the services you request. To exercise this right, use the contact form in this section.

Right to Non-Discrimination: You have the right not to be denied service, charged a different price, or provided a different level of quality for exercising any of your privacy rights.

Additional Rights (by jurisdiction)

• Right to Rectification (PIPEDA, GDPR, CPRA, CPA, VCDPA, CTDPA, LGPD, POPIA)

• Right to Erasure/Deletion (GDPR, CCPA/CPRA, CPA, VCDPA, CTDPA, UCPA, LGPD, POPIA)

• Right to Restriction of Processing (GDPR, LGPD)

• Right to Data Portability (PIPEDA, GDPR, LGPD)

• Right to Object (GDPR, LGPD, POPIA)

• Right to Appeal (CPA, VCDPA, CTDPA) — See below

• Right to File a Complaint (GDPR, LGPD, POPIA) — See below

How to Exercise Your Rights

You can submit a request to exercise any of the above rights by contacting our privacy team using the information in the "Contact Us" section below. For your own privacy and security, we may require you to verify your identity before fulfilling a request.

We will respond to verified requests within 45 days. If we require additional time, we will inform you of the reason and the extension period in writing.

Filing an Appeal

• Colorado residents: https://coag.gov/file-complaint

• Virginia residents: https://www.oag.state.va.us/consumercomplaintform

• Connecticut residents: https://portal.ct.gov/AG

Filing a Complaint

• EEA residents: https://edpb.europa.eu/about-edpb/about-edpb/members_en

• Other jurisdictions: Contact your local data protection authority

Withdrawing Consent

If you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time, free of charge. Contact us using the information found at the bottom of this page.

9. SMS Policy

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

You agree to receive informational messages (appointment reminders, account notifications, etc.) from Pride Global. Message frequency varies. Message and data rates may apply. For help, reply HELP to (212) 235-5300. You can opt out at any time by replying STOP.

10. How We Keep Your Data Safe

We have appropriate organizational safeguards and security measures in place to protect your Personal Data from being accidentally lost, used, accessed in an unauthorized way, altered, or disclosed.

The communication between your browser and our website uses a secure encrypted connection wherever your Personal Data is involved.

We require any third party contracted to process your Personal Data on our behalf to have security measures in place to protect your data and to treat such data in accordance with the law.

In the event of a Personal Data breach, we will notify you and any applicable regulator when we are legally required to do so.

11. Children's Privacy

We do not knowingly collect Personal Data from children under the age of 18. If you believe we have inadvertently collected data from a minor, please contact us immediately using the information below and we will take steps to delete it.

12. Changes to This Policy

We may modify this Policy at any time. If we make material changes, we will post an updated version of this Policy on our website and update the "Last Updated" date at the top. When using our services, you will be asked to review and accept our Privacy Policy. We will record your acceptance and notify you of any future material changes.

13. Contact Us

To request a copy of your information, unsubscribe from our email list, request deletion of your data, exercise any privacy right, or ask a question about your data privacy, please contact us:

• Website: https://prideglobal.com/

• Email: datasecurity@prideglobal.com

• Phone: (212) 235-5300

For data protection matters in the EU/EEA, please contact our Data Protection Officer at the above address.