A. This Policy

Summary: This Policy explains how we Process Personal Data. This Policy may be amended or updated from time to time, so please check it regularly for updates.

This Policy is issued by Palmstone Ventures LLC which is made up of each of the Controller entities that are listed in Section (U) below (together, “Palmstone Ventures LLC”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact in our course of business as a Merchant of Record, including customers, visitors to our Sites, other users of our products or services, personnel of corporate customers and vendors, applicants for employment, and visitors to our premises (together, “you”). Please note that not all provisions of this Policy will apply to you and your Personal Data, as this will depend on your specific relationship with Palmstone Ventures LLC.

Defined terms used in this Policy are explained in Section (V) below.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.

This Policy was last updated on 30 June 2023.

You may also have certain rights regarding the information we collect about you. Specifically, the rights of Data Subjects of the EEA are explained in Section (M) below. Similarly, Residents of certain US states, including California and Virginia, may find information on their rights as a Consumer in Sections (R), (S) and (T) below.

B. Collection of Personal Data

Summary: We collect or obtain Personal Data: when that data is provided to us (e.g., where you contact us); in the course of our relationship with you (e.g., if you appoint us as your Merchant of Record or if you make a purchase from Palmstone Ventures LLC); when you make Personal Data public (e.g., if you make a public post about us on social media); when you visit our Sites; when you register to use any of our Sites, products, or services; or when you interact with any third party content or advertising on a Site; we may also receive Personal Data about you from third parties (e.g., law enforcement authorities).

We collect or obtain Personal Data about you from the following sources:

Data provided to us: We obtain Personal Data when such data is provided to us (e.g., where you contact us via email or via our Sites, or by any other means, or when you provide us with your business card, or when you submit a job application).

Data we obtain in person: We obtain Personal Data during meetings, at trade shows, during visits from sales or marketing representatives, in person interviews or at events we attend.

Collaborations: We obtain Personal Data when you collaborate with us in research or in an advisory/consultancy capacity.

Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g. we provide a service to you, or to your employer).

Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g. we may collect information from your social media profile(s) or if you make a public post about us).

Site data: We may collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.

Registration details: We collect or obtain Personal Data when you use, or register to use, any of our Sites, products, or services.

Content and advertising information: If you interact with any third party content or advertising on a Site (including third party plugins and cookies) we may receive Personal Data from the relevant third party provider of that content or advertising.

Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g. credit reference agencies; law enforcement authorities; etc.).

C. Creation of Personal Data

Summary: We create Personal Data about you (e.g., records of your interactions with us).

We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine Personal Data from any of our Sites, products, or services, including where that data is collected from different sources.

D. Categories of Personal Data we Process

Summary: We Process: your personal details (e.g., your name); demographic data (e.g. your age); your contact details (e.g., your address); records of your consents; purchase details; payment details (e.g. billing address); information about your interaction with our Sites (e.g. the type of device you are using); details of your employer (where relevant); information about your interactions with our content or advertising; and any views or opinions you provide to us.

We Process the following categories of Personal Data about you:

Personal details: given name(s); preferred name.

Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.

Contact details: correspondence address; telephone number; email address; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media details.

Expertise: records of your expertise; professional history; practising details and qualification details; information about your experience; participation in meetings; seminars; advisory boards and conferences; information about your professional relationship with other individuals or institutions; language abilities and other professional skills.

Consent records: records of any consents you have given, together with the date and time; means of consent and any related information (e.g. the subject matter of the consent).

Purchase details: records of purchases and prices; and consignee name, address, contact telephone number and email address;

Payment details: invoice records; payment records; billing address; payment method; cardholder or account holder name; card payment identifiers; payment amount; and payment date.

Data relating to your use of our Sites: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; username; password; security login details; and usage data.

Employer details: where you interact with us in your capacity as an employee of a third party, the name, address, telephone number and email address of your employer, to the extent relevant.

Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.

Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

Please note that not all of the above will apply to you, as it will depend on your relationship with Palmstone Ventures LLC (e.g. Employee, customer, etc).

E. Sensitive Personal Data

Summary: We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business as a Merchant of Record. Where we need to Process Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.

Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);

Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);

Establishment, exercise or defence of legal claims: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal claims; or

Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.

F. Purposes of Processing and Legal Bases for Processing

Summary: We Process Personal Data for the following purposes: providing our Sites, products, and services to you; compliance checks; operating our business; communicating with you; managing our IT systems; health and safety; financial management; conducting surveys; ensuring the security of our premises and systems; conducting investigations where necessary; compliance with applicable law; improving our Sites, products, and services; fraud prevention; establishment, exercise and defence of legal claims; and recruitment and job applications.

The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

Provision of Sites, products, and services: providing our Sites, products, or services; providing promotional items upon request; and communicating with you in relation to those Sites, products, or services.

The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or

We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, products, or services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way)

Compliance checks: fulfilling our regulatory compliance obligations; ‘Know Your Client’ checks; and confirming and verifying your identity; use of credit reference agencies; and screening against government and/or law enforcement agency sanctions lists and other legal restrictions.

The Processing is necessary for compliance with a legal obligation; or

The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or

We have a legitimate interest in carrying out the Processing for the purpose of fulfilling our regulatory and compliance obligations (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Operating our business: operating and managing our Sites, our products, and our services; providing content to you; displaying advertising and other information to you; communicating and interacting with you via our Sites, our products, or our services; and notifying you of changes to any of our Sites, our products, or our services.

The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or

We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, our products, or our services to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Communications and marketing: communicating with you via any means (including via email, telephone, text message, social media, post or in person) to provide news items and other information in which you may be interested, subject always to obtaining your prior opt-in consent to the extent required under applicable law; personalising our Sites, products and services for you; maintaining and updating your contact information where appropriate; obtaining your prior, opt-in consent where required; enabling and recording your choice to opt-out or unsubscribe, where applicable.

The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or

We have a legitimate interest in carrying out the Processing for the purpose of contacting you, subject always to compliance with applicable law (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Management of IT systems: management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems.

The Processing is necessary for compliance with a legal obligation; or

We have a legitimate interest in carrying out the Processing for the purpose of managing and maintaining our communications and IT systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

Health and safety: health and safety assessments and record keeping; providing a safe and secure environment at our premises; and compliance with related legal obligations.

The Processing is necessary for compliance with a legal obligation; or

We have a legitimate interest in carrying out the Processing for the purpose of ensuring a safe environment at our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

The Processing is necessary to protect the vital interests of any individual.

Financial management: sales; finance; corporate audit; and vendor management.

We have a legitimate interest in carrying out the Processing for the purpose of managing and operating the financial affairs of our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Surveys: engaging with you for the purposes of obtaining your views on our Sites, our products, or our services.

We have a legitimate interest in carrying out the Processing for the purpose of conducting surveys, satisfaction reports and market research (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Security: physical security of our premises (including records of visits to our premises); CCTV recordings; and electronic security (including login records and access details).

The Processing is necessary for compliance with a legal obligation ; or

We have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business and our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.

The Processing is necessary for compliance with a legal obligation ; or

We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, breaches of our policies and applicable laws (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

Legal compliance: compliance with our legal and regulatory obligations under applicable law.

The Processing is necessary for compliance with a legal obligation.

Improving our Sites, products, and services: identifying issues with our Sites, our products, or our services; planning improvements to our Sites, our products, or our services; and creating new Sites, products, or services.

We have a legitimate interest in carrying out the Processing for the purpose of improving our Sites, our products, or our services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Fraud prevention: Detecting, preventing and investigating fraud.

The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or

We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

Establishment, exercise and defence of legal claims: management of legal claims; establishment of facts and claims, including collection, review and production of documents, facts, evidence and witness statements; exercise and defence of legal rights and claims, including formal legal proceedings.

The Processing is necessary for compliance with a legal obligation;

We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

The Processing is necessary for the establishment, exercise or defence of legal claims.

Recruitment and job applications: recruitment activities; advertising of positions; interview activities; analysis of suitability for the relevant position; records of hiring decisions; offer details; and acceptance details.

The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or

We have a legitimate interest in carrying out the Processing for the purpose of recruitment activities and handling job applications (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

G. Disclosure of Personal Data to Third Parties

Summary: We disclose Personal Data to: legal and regulatory authorities; our external advisors; our Processors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business or successor in title to our obligations under a contract; and any third party providers of advertising, plugins or content used on our Sites.

We disclose Personal Data to other entities within the Palmstone Ventures LLC, for legitimate business purposes and the operation of our Sites, products, or services to you, in accordance with applicable law. In addition, we disclose Personal Data to:

you and, where appropriate, your appointed representatives;

legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;

accountants, auditors, consultants, lawyers and other outside professional advisors to Palmstone Ventures LLC, subject to binding contractual obligations of confidentiality;

third party Processors (such as payment services providers etc.), located anywhere in the world, subject to the requirements noted below in this Section (G);

any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims and with applicable jurisdiction;

any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;

any alternative payment provider or reseller appointed by the Supplier or other third party acquirer(s) or successor(s) in title, including but not limited to in the event that we sell or transfer all or any relevant portion of our business or assets (including in

the event of a reorganisation, dissolution or liquidation); and

any relevant third party provider, where our Sites use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

Suppliers to the extent necessary to provide a product requested by you.

any other relevant third party outsourced service providers, where our Sites use third parties to perform certain functions otherwise performed by Paddle, subject to binding contractual obligations of confidentiality.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law, including the provisions at Section (H) below, with respect to international transfers.

H. International Transfer of Personal Data

Summary: We transfer Personal Data to recipients in other countries. Where we transfer Personal Data from the UK/EEA to a recipient outside the UK/EEA that is not in an Adequate Jurisdiction, we do so on the basis of Standard Contractual Clauses and in the presence of appropriate safeguards.

Because of the international nature of our business, we transfer Personal Data within the Palmstone Ventures LLC, and to third parties as noted in Section (G) above, in connection with the purposes set out in this Policy. For this reason, we may transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

If an exemption or derogation applies (e.g., where a transfer is necessary to establish, exercise or defend a legal claim) we may rely on that exemption or derogation, as appropriate. Where no exemption or derogation applies, and we transfer your Personal Data from the UK/EEA to recipients located outside the UK/EEA who are not in an Adequate Jurisdiction, we do so on the basis of Standard Contractual Clauses and the presence of appropriate safeguards. Please contact the privacy team at support@Palmstone Ventures LLC.io below if you wish to request a copy of our Standard Contractual Clauses.

Please note that when you transfer any Personal Data directly to any Palmstone Ventures LLC entity established outside the UK/EEA, we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Policy.

I. Data Security

Summary: We have implemented appropriate technical and organisational security measures to protect your Personal Data against unauthorised or unlawful Processing, and against accidental loss, destruction or damage.

Insofar as you are able, please ensure that any Personal Data that you send to us is sent securely.

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, from the point of collection to the point of destruction, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

J. Data Accuracy

Summary: We take reasonable steps to ensure that your Personal Data is kept accurate and up-to-date and is erased or rectified if we become aware of inaccuracies.

We take reasonable steps to ensure that:

your Personal Data that we Process is accurate and, where necessary, kept up-to-date; and

any of your Personal Data that we Process that is inaccurate (having regard to the purposes for which it was Processed) is erased or rectified without delay;

From time to time we may ask you to confirm the accuracy of your Personal Data.

K. Data Minimisation

Summary: We take reasonable steps to limit the volume of your Personal Data that we Process to what is necessary.

We take reasonable steps to ensure that your Personal Data that we Process is limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy.

L. Data Retention

Summary: We take reasonable steps to ensure that your Personal Data is only retained for as long as it is needed in connection with its lawful purpose.

We take reasonable steps to ensure that your Personal Data is only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain your Personal Data is as follows:

1. We will retain Personal Data in a form that permits identification as long as:

we maintain an ongoing relationship with you (e.g., where you are lawfully included in our mailing list and have not unsubscribed); or

your Personal Data is necessary in connection with the lawful purposes set out in this Policy, for which we have a valid legal basis (e.g., where your Personal Data is included in a contract between us and your employer, and we have a legitimate interest in Processing that Personal Data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data)

Plus:

2. The duration of:

any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data is relevant); and

an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that is relevant to that claim),

And:

3. In addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.

During the periods noted above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods noted above, each to the extent applicable, have concluded, we will either:

permanently delete or destroy the relevant Personal Data; or

anonymise the relevant Personal Data.

M. Your Legal Rights

Summary: Subject to applicable law, you may have a number of rights, including: the right not to provide your Personal Data to us; the right of access to your Personal Data; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Data; the right to object to the Processing of your Personal Data; the right to have your Personal Data transferred to another Controller; the right to withdraw consent; and the right to lodge complaints with Data Protection Authorities. In some cases it will be necessary to provide evidence of your identity before we can give effect to these rights.

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our Sites, products, or services, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details);

the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of that Relevant Personal Data;

the right to request rectification (or correction) of any inaccuracies in your Relevant Personal Data;

the right to request, on legitimate grounds: erasure of your Relevant Personal Data or restriction of Processing of your Relevant Personal Data

the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;

where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and

the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (in particular, the Data Protection Authority of the EU Member State in which you live, or in which you work, or in which the alleged infringement occurred, each if applicable).

Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:

the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf, where such processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the GDPR;

the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes; and

opt you out of the automated processing of your Personal Data in furtherance of decisions that produce legal or similarly significant effects, if applicable.

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, you may submit your request via email support@Palmstone Ventures LLC.io

Please note that:

in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights;

where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take; and

certain information may be exempt from such requests under applicable law.

Depending on applicable law, you may have the right to appeal our decision to deny your request. You can contact us as set forth above to appeal such decision.

N. Cookies and Similar Technologies

Summary: We Process Personal Data by using Cookies and similar technologies. For more information, please see our Cookie Policy.

When you visit a Site we will typically place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We Process Personal Data through Cookies and similar technologies, in accordance with our Cookie Policy.

O. Terms of Use

Summary: All Suppliers are subject to Terms of Use that govern all use of our Site.

All use of our Merchant of Record services is subject to each Supplier’s Terms of Use. We recommend that you review your applicable Terms of Use to ensure that you are aware of your obligations and where applicable, regularly in order to review any changes we might make from time to time as this may influence your rights under this Policy.

P. Terms of Sale

Summary: Our Buyer Terms and Conditions govern the sale of all Products by the Palmstone Ventures LLC.

All sales of Products are subject to our Buyer Terms and Conditions. We recommend that you review these regularly, in order to review any changes we might make from time to time as this may influence your rights under this Policy.

Q. Direct Marketing

Summary: We Process Personal Data to contact you with information regarding Sites, products, or services that may be of interest to you. You may unsubscribe for free at any time.

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, products, or services that may be of interest to you. We also Process Personal Data for the purposes of displaying content tailored to your use of our Sites, products, or services. If we provide Sites, products, or services to you, we may send or display information to you regarding our Sites, products, or services, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law.

You may change your preferences, or unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional electronic communication and updating your communication preferences. Please note that it may take up to a month to process your unsubscribe request during which time you may continue to receive communications from us. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, products, or services you have requested (for example, we may send you emails about your Paddle projects or our ongoing business relationship). R. California Consumer Privacy Act Disclosures

R. California Disclosures

Summary: Under the California Consumer Privacy Act as amended (“CCPA”), we must disclose our practices regarding the collection, use, and disclosure of the Personal Information of California Residents (“Consumers”). Consumers are also afforded additional rights with regard to the Personal Information that we collect about them that include the rights of access, deletion, and to be free from discrimination. This section of our Privacy Policy includes the disclosures required by the CCPA.

Collection of Personal Information:

We have collected and will collect the following general categories of Personal Information about Consumers, relative to your relationship with Palmstone Ventures LLC:

Personal identifiers, such as names, aliases, postal addresses, unique personal identifiers, online identifiers, internet protocol addresses, email addresses, account names, social security numbers, driver’s license numbers, and passport numbers,

Categories of Personal Information enumerated in Cal. Civ. Code § 1798.80(e) including names, addresses, telephone numbers, credit and debit card identifiers;

Protected classifications, including sex, age, and national origin;

Commercial information, including products or Services you have purchased, and your purchasing history;

Internet or other electronic network activity information;

Geolocation data;

Audio, visual or similar information;

Professional or employment related information;

Education information; and

Inferences drawn from your personal information for use in creating a consumer profile (e.g. behaviour).

Please note that not all of the above will apply to you, as it will depend on your relationship with Paddle (e.g. Employee, customer, etc).

Use of Personal Information

We may use the categories of Personal Information described above for the following business or commercial purposes:

Advancing our commercial or economic business interests through our services and products to our Suppliers and customers;

Maintaining and servicing Supplier accounts;

Auditing Supplier activity on our Sites;

Processing or fulfilling orders and transactions;

Processing, managing, and accounting for transactions;

Providing customer support and support to Suppliers;

Verifying customer and Supplier information;

For short term, transient uses (such as contextual advertising);

To understand and enhance your experience on our Sites or with our services by utilising analytic services;

Advertising our services;

Linking or combining it with information received from third parties to help understand your needs and provide you with an enhanced service;

Performing internal research for technological development;

Ensuring and improving the quality and safety of our services and products;

Debugging to address impairments to operational functionality;

Detecting security incidents;

Complying with applicable law and law enforcement requirements;

Protecting against malicious, deceptive, fraudulent or illegal activity and assisting in the prosecution of those responsible for such activities; and

Defending against or bringing legal action, claims and other liabilities.

Categories of Sources of Personal Information

We collect or obtain Personal Information about you from the following sources:

You: We obtain Personal Information when you provide it to us (e.g., where you create an account, purchase products, participate in research, where you contact us via email or telephone, provide us information during meetings, at trade shows, during visits from sales or marketing representatives, or at events we attend, or by any other means, or when you submit a job application), and when you visit any of our Sites or use any features or resources available on or through a Site.

Collaborations: We obtain Personal Information when you collaborate with us in research or in an advisory/consultancy capacity.

Public sources: We collect or obtain Personal Information that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).

Registration details: We collect or obtain Personal Information when you use, or register to use, any of our Sites or services.

Third Party content and advertising partners: If you interact with any third party content or advertising on a Site (including third party plugins and cookies) we receive Personal Information from the relevant third party provider of that content or advertising.

Other third party sources: We collect or obtain Personal Information from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).

Disclosures of Personal Information

We do not Sell any Personal Information to third parties. In particular, we do not Sell the personal information of minors under 16 years of age.

In the preceding 12 months, we have disclosed the following categories of personal information to the following categories of recipients.

The following is the categories of recipients to which we disclose information and the categories of Personal Information disclosed:

To:

Legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;

Personal Identifiers;

Categories of personal information enumerated in Cal. Civ. Code § 1798.80(e)

Commercial Information

Internet or other electronic network activity information

Geolocation data;

Inferences for use in creating a consumer profile

Accountants, auditors, consultants, lawyers and other outside professional advisors to Palmstone Ventures LLC, subject to binding contractual obligations of confidentiality;

Personal identifiers;

Categories of Personal Information enumerated in Cal. Civ. Code § 1798.80(e);

Protected classifications (if provided);

Commercial information;

Geolocation data;

Professional or employment related information;

Inferences drawn from your personal information for use in creating a consumer profile.

Third-party Processors (such as payment services providers etc.), located anywhere in the world, subject to the requirements noted in Section (G);

Personal identifiers;

Categories of Personal Information enumerated in Cal. Civ. Code § 1798.80(e);

Commercial information;

Internet or other electronic network activity information;

Geolocation data;

Professional or employment related information;

Education information;

Inferences drawn from your personal information for use in creating a consumer profile.

Any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims;

Personal identifiers;

Categories of Personal Information enumerated in Cal. Civ. Code § 1798.80(e)

Protected classifications;

Commercial information;

Internet or other electronic network activity information;

Geolocation data;

Professional or employment related information;

Inferences drawn from your personal information for use in creating a consumer profile.

Any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;

Personal identifiers;

Categories of Personal Information enumerated in Cal. Civ. Code § 1798.80(e);

Commercial information;

Internet or other electronic network activity information;

Geolocation data;

Any relevant third party provider, where our Sites use third party advertising, plugins or content;

Personal identifiers;

Commercial information;

Internet or other electronic network activity information;

Inferences drawn from your personal information for use in creating a consumer profile.

Retention

We determine the duration for which we will retain your Personal Data is as follows:

The status of our ongoing relationship with you (e.g. where you are lawfully included in our mailing list and have not unsubscribed); or

If your Personal Data is necessary in connection with the lawful purposes set out in this Policy, for which we have a valid legal basis (e.g. where your Personal Data is included in a contract between us and your employer, and we have a legitimate interest in Processing that Personal Data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data).

Plus, the duration of:

any applicable limitation period under applicable law (i.e. any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data is relevant); and

an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that is relevant to that claim).

And:

In addition, if any relevant legal claim are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.

S. Consumer Rights Under the CCPA

Summary: Subject to the CCPA, you may have a number of rights, including: the right to know about your Personal Information, right to request the deletion of your Personal Information, the right to opt out of a Sale or Sharing of your Personal Information, the right to correct inaccurate records of your Personal Information, the right to limit the use and disclosure of any Sensitive Personal Information and the right to non-discrimination when you exercise your rights under the CCPA

You may make a request to exercise a right as set forth above. Generally, in order to verify your request, we will compare the Personal Information we already hold about you to the Personal Information we will request in the course of processing your request. The Personal Information required for verification may include your name and email address, or further information if we reasonably believe it is necessary to verify you. To exercise your rights under the CCPA, please follow the instructions described in this section.

Right to Know About Personal Information. Consumers have the right to request that we disclose the following information, in a readily useable format, covering the 12 month period preceding the request:

The categories of Personal Information we collected about you.

The purposes for which the categories of Personal Information collected about you will be used.

The categories of sources for the Personal Information we collected about you.

The categories of third parties with whom we share Personal Information.

Our business or commercial purpose for collecting Personal Information.

The specific pieces of Personal Information we collected about you.

The categories of Personal Information we have disclosed for a business purpose.

Right to Request Deletion of Personal Information. Consumers have the right to request that we delete any Personal Information that we have collected from them. Your request may be subject to certain exemptions under applicable laws.

We may keep a record of deletion requests solely as a record of compliance.

Right to correct inaccurate records of your Personal Information. Consumers have the right to request that we use commercially reasonable efforts to correct any inaccurate Personal Information.

Right to opt out of a Sale or the Sharing of your Personal Information. Please note that Palmstone Ventures LLC does not Sell or Share your information within the meaning of the California Privacy Acts.

Right to limit the use and disclosure of any Sensitive Personal Information. Consumers have the right to direct a business to limit its use and disclosure of Sensitive Personal Information. Please note that Paddle will only collect and use Sensitive Personal Information where it is absolutely required to do so in the course of its relationship with you and all information collected is subjected to record retention timeframes based on law and industry standards.

Right to Non-Discrimination. Consumers have the right to be free from discrimination as set forth in the CCPA when they exercise their Consumer rights under the CCPA.

Notice of Financial Incentive. We do not offer financial incentives or a price or service difference to incentivise consumers to provide personal information.

Authorised Agent. Under the CCPA, you may appoint an authorised agent to submit requests to exercise your rights on your behalf. Should you choose to do so, for your and our protection, we will require your authorised agent to provide us with a signed permission demonstrating that they are authorised to submit a request on your behalf. Should your authorised agent fail to submit proof that they have been authorised to act on your behalf, we will deny their request.

T. California's "Shine the Light" Law

Summary: California residents are entitled to request a notice describing what categories of personal customer information We share with third parties.

Under California’s “Shine the Light” law, California residents are entitled to ask us for a notice describing what categories of personal customer information we share with third parties for the purposes of their direct marketing.

U. Definitions

“Adequate Jurisdiction” means a country or territory recognised as providing an adequate level of protection for Personal Data under an adequacy decision made, from time to time, by (as applicable) (i) the Information Commissioner’s Office and/or under applicable UK law (including the UK GDPR), and/ or (ii) the European Commission under the EU GDPR.

“California Resident” or “Consumer” means (1) every individual who is residing in the State of California for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the State of California who is outside the state for a temporary or transitory purpose.

“Controller” means the entity that decides how and why Personal Data is Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.

“Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Policy, a reference to a “Cookie” includes analogous technologies.

“Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.

“EEA” means the European Economic Area.

“GDPR” means the General Data Protection Regulation ((EU) 2016/679) (“EU GDPR”); the Data Protection Act 2018 and the UK General Data Protection Regulation 2016/679 (as implemented by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 and the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2020) (the "UK GDPR"), as applicable;

“Merchant of Record” means the licensed reseller of software and digital products and the business that is carried on by Palmstone Ventures LLC.

“Personal Data” and “Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

“Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).

“Product” means the Supplier’s software product(s) and/or digital content and any subsequent updates and upgrades thereto agreed to be resold or distributed by Palmstone Ventures LLC.

“Relevant Personal Data” means Personal Data in respect of which we are the Controller.

“Sell” has the meaning ascribed to it in section 1798.140 of the CCPA.

“Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, biometric data, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that is deemed to be sensitive under applicable law.

“Sensitive Personal Information” means Personal Information that reveals an Consumer’s social security, driver’s license, state identification card, passport number, account log-in, financial account, debit card or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, or union membership or the contents of a Consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; or genetic data

“Share” means communicating orally, in writing, or by electronic or other means, a Consumer’s Personal Information to a third party for cross-context behavioural advertising, whether or not for monetary or other valuable consideration

“Site” means any website operated, or maintained, by us or on our behalf.

“Standard Contractual Clauses” means i) where the EU GDPR applies, the contractual clauses annexed to the European Commission's Implementing Decision 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council incorporating Module 1 (Controller to Controller transfers) (EU SCCs); and ii) where the UK GDPR applies, the template Addendum B.1.0 issued by the UK's Information Commissioner's Office and approved by Parliament in accordance with s119A of the Data Protection Act 2018 (UK Approved Addendum) and the accompanying Mandatory Clauses of the UK Approved Addendum, as updated from time to time and/or replaced by any further version published by the Information Commissioner's Office (UK Mandatory Clauses)