Your Privacy Matters.

The Paskin Group, together with its subsidiaries and affiliates (“TPG,” “we,” “us,” or “our”), respects your privacy. This Privacy Policy explains what information we collect when you use our investor website, how we use and protect that information, and the choices and rights available to you. Please read it carefully.

1. Scope of This Policy

This Privacy Policy applies to the website located at investors.thepaskingroup.com, including any variation or successor of it and any domain that directs to it (the “Website”); any software or applications we make available through the Website (“Software”); and any services we provide through the Website (“Services”). We refer to the Website, Software, and Services together as the “Properties.”

This Privacy Policy is part of, and incorporated into, the Website’s Terms and Conditions (the “Terms and Conditions”). By accessing, using, or registering to use the Properties, you agree to be bound by this Privacy Policy and the Terms and Conditions. If you do not agree, please do not use the Properties.

In this Privacy Policy, “Content” means any documents, files, text, images, graphics, audio, video, or other materials, in any format, that you or anyone acting on your behalf upload, post, or otherwise provide to us through the Properties.

2. Information We Collect

Personal Information

“Personal Information” is information that identifies you or could reasonably be used to identify, contact, or locate you. Depending on how you use the Properties, it may include:

We collect Personal Information when you create an account, upload or download Content, communicate with us, or otherwise provide information to us through the Properties.

Non-Personal Information

“Non-Personal Information” is information that does not, on its own, identify you as a specific individual, such as general demographic information and records of the pages you visit or actions you take on the Website. We may collect Non-Personal Information in the ways described above and automatically through the technologies described in Section 3.

3. How We Collect Information

Account Registration

Before you can use some or all of the Properties, we may ask you to provide certain information to create an account (an “Account”) or to enable particular features. If you do not provide the required information, you may be unable to access some or all of the Properties. If the information you provide is not kept accurate, we may suspend or terminate your access.

Uploading and Downloading Content

When you upload, post, or download Content through the Properties, that Content may contain or be transmitted with related data, such as the type of device used to create it, the device’s IP address, and the domain name of your Internet service provider. We necessarily receive this data when Content is uploaded to or downloaded from the Properties.

Information Collected Automatically

You may browse the Website without creating an Account. Even so, we and our service providers may automatically collect information about your use of the Properties, such as your browser type, operating system, IP address, connection speed, and the domain name of your Internet service provider. We use the following technologies to do so:

• Cookies.Cookies (including local shared objects) are small data files that your browser stores on your computer or device. They assign your device a unique identifier that has no meaning outside the Website and generally do not contain Personal Information. Most browsers accept cookies automatically, but you can usually change your settings to block them. If you do, some features of the Properties may not be available or may not work properly.
• IP Addresses.An IP address is a number automatically assigned to your computer or device by your Internet service provider. Our servers log your IP address each time you visit the Website or request a page, whether or not you have an Account.
• Web Beacons.Web beacons are small pieces of code embedded in web pages and emails. We may use them in HTML emails we send you to learn whether you opened an email or clicked a link in it. This information may be collected in a form that identifies you.
• Account Activity.For registered Accounts, we record Personal Information and Non-Personal Information associated with uploading, posting, and downloading Content, including to or from third-party websites.

4. How We Use Information

We use the information we collect to:

• Operate and maintain the Properties,including system administration, diagnosing server problems, monitoring system performance and site traffic, and understanding the general demographics of our users. We generally use Non-Personal Information for these purposes.
• Personalize your experience,including using cookies and IP addresses to present Content relevant to your interests and to tell you about new services or relevant offerings.
• Provide services to Account holders,including sending payments to you, receiving payments from you, preparing tax information, providing services to you, and communicating with you about these activities.
• Send Account notices,such as emails confirming your registration, verifying the accuracy of information you have provided, explaining how to upload Content or make or receive a payment or refund, verifying your identity, or notifying you if we believe your use of the Properties violates an applicable agreement.
• Respond to you.If you contact us, we may keep a record of your contact information and correspondence. If you report a problem with the Properties, we may keep that information in a file specific to you.

5. How We Share Information

We do not sell, trade, or rent Personal Information collected through the Properties to any third party.

We may share Personal Information only as we determine, in good faith, is reasonably necessary:

• To operate the Properties, including with service providers and third-party integrations that support them;
• To cooperate with law enforcement agencies, or to comply with a court order, subpoena, or other legal process;
• If we believe your actions violate any law or regulation, the Terms and Conditions, or the permitted use of the Properties; and
• In connection with an actual or proposed merger, acquisition, sale, joint venture, or other business combination, or in the event of insolvency or bankruptcy.

6. Accessing, Correcting, and Deleting Your Information

You may ask us to update or correct Personal Information you have previously provided. We will do so to the extent the change does not compromise privacy or security interests, as we determine in our sole discretion.

You may also ask us to delete your Personal Information. Because of the way data backups are maintained, some residual information may remain in our systems after deletion.

To make any of these requests, please contact us using the information in Section 12. California residents have additional rights, described in Section 8.

7. How We Protect Information

Security Measures

We maintain appropriate physical, administrative, technical, and organizational safeguards designed to protect the information we process against unauthorized or unlawful access, use, or disclosure, and against accidental loss, damage, alteration, or destruction. Access to Personal Information is limited to those with a business need for it. We also maintain policies and procedures for responding to security incidents involving unauthorized access to personal data.

While we work hard to protect your information, no security program is completely secure, and we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use, or disclose personal information.

Third-Party Websites and Services

The Properties may contain links to third-party websites that collect information directly from you, and we may use third parties to provide parts of the Properties. These third parties have their own privacy policies and data practices, which are independent of ours. Accordingly, we:

• Are not responsible or liable for their policies or actions;
• Are not responsible for the privacy practices or content of their websites; and
• Make no warranties or representations about the information, content, products, or services they offer, or the security of any information you provide to them.

8. California Privacy Rights (CCPA)

The California Consumer Privacy Act (“CCPA”) gives California residents specific rights regarding their personal information. When you make a request under the CCPA, we must verify your identity and respond as the law requires. This section describes those rights and how to exercise them.

Right to Know and Data Portability

You may request a summary of how we have collected, used, and disclosed your personal information over the past 12 months. After receiving a verifiable request, we will tell you:

• The categories, specific types, and sources of personal information we collected about you;
• Our business purpose for collecting that personal information; and
• The categories of third parties with whom we shared it and the purpose of the disclosure.

You may also request a copy of this personal information in a readily usable format that can be transferred to another entity (“data portability”). We may be restricted from providing certain sensitive personal information in response, or may be unable to fulfill the request entirely if doing so would present an unreasonable security risk.

Right to Delete

You may request that we delete personal information we have collected from you and retained, subject to certain exceptions. Once we receive and verify your request, we will delete or de-identify your personal information, and direct our service providers to do the same, unless an exception applies. We may deny a deletion request if keeping the information is necessary for us or our service providers to:

• Complete the transaction for which the information was collected, provide Properties you requested, take actions reasonably anticipated in our ongoing business relationship with you, or otherwise perform our contract with you;
• Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible;
• Debug the Properties to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure another consumer’s right to exercise free speech, or exercise another right provided by law;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that complies with applicable ethics and privacy laws, where deletion would likely make the research impossible or seriously impair it, if you previously gave informed consent;
• Enable solely internal uses reasonably aligned with your expectations based on your relationship with us;
• Comply with a legal obligation; or
• Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

How to Submit a Request

To exercise your right to know, data portability, or deletion, please submit a verifiable request by:

• Calling us at 805.962.1011; or
• Emailing us at info@thepaskingroup.com.

Only you, or someone legally authorized to act on your behalf, may make a verifiable request related to your personal information. You may make a request for access or data portability no more than twice in a 12-month period. Your request must:

• Include enough information for us to confirm that you are the person about whom we collected personal information (or an authorized representative of that person); and
• Describe your request in enough detail for us to understand, evaluate, and respond to it.

We cannot respond to your request or provide personal information if we cannot verify your identity or authority to make the request, or confirm that the personal information relates to you. We will use personal information provided in a request only to verify the requester’s identity or authority.

Response Timing and Format

We aim to respond to a verifiable request within 45 days of receiving it. If we need more time, we may extend that period by up to an additional 45 days (90 days in total), and we will tell you in writing why the extension is needed.

If you have an Account, we will deliver our written response to that Account where possible. Otherwise, we will send it to the email address you designate. Any disclosures will cover only the 12-month period before we received your request. If we cannot comply with a request, our response will explain why.

We do not charge a fee to process or respond to a verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we decide a fee is warranted, we will explain why and give you a cost estimate before completing your request.

No Sale of Personal Information

We do not sell personal information collected through the Properties and have not done so in the past 12 months. If this practice changes, we will notify affected individuals in advance and offer the ability to opt in or opt out as the CCPA requires.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless the CCPA permits it, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through discounts, other benefits, or penalties;
• Provide you a different level or quality of goods or services; or
• Suggest that you may receive a different price, rate, level, or quality of goods or services.

9. Other California Privacy Rights

“Shine the Light” Requests

California Civil Code § 1798.83 permits California residents to request certain information about our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please email us at the address listed in Section 12.

Do Not Track Signals

We do not track users over time and across third-party websites to provide targeted advertising, so we do not respond to Do Not Track (“DNT”) signals. Some third-party websites, however, do track your browsing activity to tailor the content they show you. If you visit those sites, your browser may allow you to turn on a DNT signal so that third parties, particularly advertisers, know you do not want to be tracked.

10. Minors

The Properties are not intended for anyone under the age of 18 (“Minors”). Minors are not authorized to use the Properties, even if they create an Account or accept the terms of any agreement or policy relating to the Properties.

11. Changes to This Privacy Policy

We may update this Privacy Policy at any time in our sole discretion. When we do, we will post the updated policy on this Website along with its effective date. Your continued use of the Properties after changes are posted means you accept the updated policy.

12. Contact Us

If you have any questions about this Privacy Policy, please contact us: