OVERVIEW AND SCOPE
Welcome to our website for Transom Capital Group and its corporate affiliates (“TCG,” “we,” “us” or “our”). We value our relationship with you, our customer, and your privacy. This TCG website privacy notice (this “Privacy Notice”) explains how and why we collect, use, protect, and disclose Personal Information about you through websites or applications where this Privacy Notice is posted. This Privacy Notice applies when you visit our website or any other websites, applications, pages, or features we own or operate (collectively, our “Site”).

Please read this Privacy Notice carefully. In particular, please note that this Privacy Notice is supplemented by the additional notice to individuals in the European Economic Area and the United Kingdom (the “EEA-UK Privacy Notice”) and the additional notice to California Residents (the “California Privacy Notice”) (each, a “Jurisdiction-Specific Notice”) if and to the extent that EEA-UK Data Protection Laws or the CCPA (each as defined in the relevant Jurisdiction-Specific Notice below) apply to our processing of your Personal Information.

This Privacy Notice and the Jurisdiction-specific Notices do not apply to any processing of Personal Information by or on behalf of TCG that is covered by a more specific privacy notice (e.g., our employee and contractor privacy notices or our subscription agreement investor privacy notices).

Each time that you access or use our Site, to the extent permitted by laws in your country or state of residence, you acknowledge that you have read, understood, and agreed to be bound by this Privacy Notice and the TCG TERMS OF USE (or, for a visitor located in the European Economic Area or the United Kingdom, you acknowledge that you have read and understood this Privacy Notice and the TCG TERMS OF USE). Any dispute over privacy is subject to this Privacy Notice and our TERMS OF USE, including its applicable limitations on damages and the resolution of disputes.

Our TERMS OF USE are incorporated by reference into this Privacy Notice. If you do not agree with this Privacy Notice or our TERMS OF USE, you must stop using our Site.

If you have any questions about this Privacy Notice, or have a privacy-related complaint, please contact us by email or by mail using the information provided in the section below titled “Contact Us”.

PERSONAL INFORMATION WE COLLECT
The information we collect about you may include Personal Information. “Personal Information” is information that, directly or indirectly, identifies or is capable of identifying you as an individual, such as your name or contact information.

We collect Personal Information about you from a variety of sources, including:

• Information that we collect directly from you: includes your name and email address. We will also collect any information that you otherwise provide to us, such as any comments or questions that you submit to us through our Site.
• Information that we collect from third parties: If you interact with us on social networking platforms, we may also use that information from those social networking platforms, such as your Facebook username and other publicly available Facebook information.
• Information that we automatically collect about you when you use our Site: varies depending on the settings of your web browser or device, but it may include the content you view on our Site; the date and time you access our Site; how long you use our Site; the type of web browser you are using (for example, Firefox or Chrome); the type of device you are using (for example, whether you are using a mobile device); and your Internet Protocol address (which is a unique string of numbers to identify devices connected to a network). See the section below titled COOKIES AND TRACKING for more information.

We may combine Personal Information from any of the above sources. If you do not provide Personal Information to us, we may not be able to provide our services to (or communicate with) you.

USE OF PERSONAL INFORMATION
We use your Personal Information for a variety of purposes, including:

Purpose	Legal Basis (relevant to the EEA-UK Privacy Notice)
To conduct business with you or to provide you with the services you have requested, including responding to your enquiries and requests and providing you with support.	Contractual necessity; and/or our legitimate interest in operating our business and providing investment services.
To communicate with you, including to respond to requests for assistance and updates relevant to you. We may communicate with you in a variety of ways, including postal mail, email, and/or telephone.	Our legitimate interest in operating our business; contractual necessity; and/or consent.
Complying with our legal obligations and corporate governance practices, which may require recording or monitoring telephone calls or other communications with you.	Legal requirement; our legitimate interest in operating our business; and/or consent.
Litigation management and conducting internal audits and investigations.	Legal requirement; and/or our legitimate interest in operating our   business.
To keep a record of and manage your relationship with us.	Our legitimate interest in operating our business and providing   services; and/or legal requirement.
To help us better understand how our customers access   and use our Site; to provide reports to prospective partners, service   providers, regulators, and others; to implement and maintain security,   anti-piracy, fraud prevention, and other services.	Our legitimate interest in operating our business and/or legal   requirement.
To improve our Site, products, services, and customer experience; to understand our customer demographics; and for other research   and analytical purposes.	Our legitimate interest in operating our business.
To provide advertising and marketing services. Including to provide you with news, and newsletters; to   contact you about products and services we think may interest you; to target   advertisements to you; and for other marketing, advertising, and promotional   purposes. Our marketing communications with you may include communications   via postal mail, email, and/or telephone.	Our legitimate interest in operating our business.
To protect ourselves and others where we believe it necessary,   including to prevent or investigate a possible crime, such as fraud or   identity theft; to enforce a contract; to protect the legal rights, our Site,   or safety of you, TCG, its corporate relatives, and their respective   employees, clients, partners, agents, other users, or the public in general;   to enforce our TERMS OF USE or this Privacy Notice; and to monitor and   remediate security issues.	Our legitimate interest in operating our business; legal requirement; and/or contractual necessity.
To evaluate or conduct a merger, divestiture, restructuring,   reorganization, dissolution, or other sale or transfer of some or all of our   assets, whether as a going concern or as part of bankruptcy, liquidation, or   similar proceeding, in which Personal Information held by us about the   website users is among the assets transferred.	Our legitimate interest in operating our business.
To conduct marketing, advertising or research activities.	Our legitimate interest in operating our business.
For any other purpose that has been notified in writing.	Consent.

 

DISCLOSURE OF PERSONAL INFORMATION
We may disclose your Personal Information to the following entities for any of the above purposes:

• Corporate Relatives. We may disclose your Personal Information to any current or future parent company, affiliate, or subsidiary of TCG.
• Service Providers. We may disclose your Personal Information to our contractors, vendors, service providers, agents, or others who perform functions on our behalf. For example, we may disclose your Personal Information to service providers who host our Site, coordinate mailings, or analyze aggregate information about our customers.
• TCG Unaffiliated Third Parties. We may disclose the Personal Information we collect about you to other unaffiliated third parties, such as social media and networking platforms. These third parties may use such Personal Information for their own direct marketing purposes. The use of Personal Information by these unaffiliated third parties is governed by the privacy policies of those third parties. See the section titled YOUR CHOICES below for additional information regarding your right to opt-out of our direct marketing activities and the relevant Jurisdiction-Specific Notice below for more information about your rights under EEA-UK Data Protection Laws or the CCPA (each as defined in the relevant Jurisdiction-Specific Notice below) regarding our disclosures to third parties.
• In Response to Legal Process. We may disclose your Personal Information when we believe it is appropriate to comply with the law or a regulatory requirement; to comply with governmental, administrative, or judicial process or other similar requirement or order, such as a subpoena or court order; to cooperate with law enforcement or other governmental investigations (without necessarily requiring the law enforcement or government agency requesting the information to formally serve us with a subpoena); or as evidence in litigation in which we are involved. We also reserve the right to report to appropriate law enforcement or governmental agencies any activities that we believe are in violation of applicable laws, rules, or regulations without providing notice.
• Aggregated and De-Identified Personal Information. We may disclose aggregated or de-identified Personal Information about our customers for marketing, advertising, research, or other purposes.

YOUR CHOICES
You have certain choices regarding the Personal Information we collect about you. For example, you may:

• Request to Modify the Personal Information We Have Collected About You. You may request to modify your Personal Information by emailing us at info@transomcap.com and specifying the addition, deletion, or other modification to your Personal Information that you would like us to make.
• Request to Modify Content You Have Posted. You may request to modify content that you have posted to our Site by emailing us at info@transomcap.com and specifying the content (such as comments or reviews) that you would like modified or deleted. In some cases, we may not be able to remove your content. If this is the case, we will let you know if we are unable to do so and why. Even if we are able to anonymize or make your content or information no longer visible, there is no way to ensure complete or comprehensive removal of your content from the Internet because third parties may have archives of the Site. We therefore cannot prevent such information from being used in a manner that may violate this Privacy Notice, the law, or your personal privacy.
• Opt Out of Promotional Email Communications. You may opt out of marketing emails by clicking on the unsubscribe link in the email, or by emailing us at info@transomcap.com. Please also note that if you have previously added your contact information to the mailing list of one of our clients or partners and later withdraw your permission, you will have to contact that third party (or use an opt-out link provided in an email communication from that client or partner) to request removal from that mailing list as well.
• Opt Out of Promotional Mail Communications. You may opt out of promotional mail communications by following the instructions provided in the mailing, or by emailing us at info@transomcap.com, and briefly describing the mailing that you would like to unsubscribe from.
• Opt Out of Interest-Based Advertising. We may use third-party service providers such as Google’s AdSense and AdWords to help us provide advertisements to you that are tailored to you based on interests that you have expressed on our Site or elsewhere (“Interest-Based Ads”). Any advertisements served by Google, Inc., and affiliated companies may be controlled using cookies. These cookies allow Google to display ads based on your visits to our Site. Any tracking done by Google through cookies and other mechanisms is subject to Google’s own privacy policies. You may decide to disable all the Google cookies by clicking on: www.google.com/settings/ads/onweb/optout?hl=en. You can use Ads Settings to manage the Google ads you see and opt out of interest-based ads delivered by Google. You also may opt out of receiving Interest-Based Ads from many third-party ad networks, such as those provided by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding Interest-Based Ads by NAI members and DAA members, including how to opt out of Interest-Based Ads provided by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp (NAI) and www.aboutads.info/choices (DAA). If you are in the European Union, go to www.youronlinechoices.eu for information about your choices with respect to third-party advertising, including instructions on how to opt out of participating ad networks. Please note that opting out of participating ad networks does not mean that you will not see advertisements at all; you will continue to receive advertisements on other websites and from companies that do not participate in the above programs. Even if you opt out of Interest-Based Ads, you may still see ads based on factors such as your general location derived from your IP address, your browser type and recent, previous searches related to your current search.

Please note that even if you opt out of receiving marketing communications from us, we will still respond to your inquiries and requests for information.

COOKIES AND TRACKING
We and our service providers use various tracking technologies, such as cookies and other similar technologies (collectively, “Tracking Technologies”) to track information automatically about your use of our Site. We or our service providers may combine this information with other Personal Information we collect about you.

• Cookies. We or our service providers may use cookies to track visitor activity on our Site. A cookie is a text file that a website transfers to your device for record-keeping purposes. We or our service providers may use cookies to track user activities on our Site, such as the web pages you view and time you spend on our Site. The help section on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies may not be able to browse certain areas of our Site.
• Clear GIFs, Pixel Tags and Other Technologies. Clear GIFs are tiny graphics with a unique identifier, similar in functionality to cookies, which are embedded invisibly on web pages. We or our service providers may use clear GIFs (also known as web beacons, web bugs, pixel tags, or action tags, among other names), in connection with our Site to perform functions like tracking the activities of visitors to our Site, helping us manage content, and compiling statistics about usage of our Site. We or our service providers may also use clear GIFs in emails to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
• Embedded Scripts. We use embedded scripts, which is code designed to collect information about how visitors interact with a website, such as the website which linked them to our Site.
• Third-Party Analytics. We use service providers, such as Google Analytics, to evaluate the use of our Site and our services. We or our service providers use automated devices and applications to evaluate use of our Site and services. We or our service providers use these tools to help us improve our Site, services, performance, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or Flash locally shared objects, to perform their services.
• Do Not Track. Our Site does not respond to Do Not Track signals. You may disable certain tracking as discussed in this section (e.g., by disabling cookies).

Where Tracking Technologies are not necessary for us to provide the services you have requested or for the functioning of our Site, we will ask you to consent to their use. You may opt-in to accept Tracking Technologies automatically by changing the settings on your browser. If you opt-out of certain Tracking Technologies, you may not be able to access certain parts of our Site. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences.

Subject to your consent to the placement of non-essential cookies, the Site uses the cookies listed below:

 

Cookie ID	Type	Duration	Description
__cf_bm	Necessary	29 minutes 53 seconds	This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website.
cf_clearance	Necessary	11 months 4 weeks	This cookie is used by the CloudFlare service to identify trusted web traffic and override any security restrictions based on the visitor’s IP address. It is essential for supporting a website’s security features and in providing protection against malicious visitors.
cookieyes-consent	Necessary	11 months 4 weeks	This cookie is used to remember the user’s consent to the use of cookies on the website.
_ga	Performance	1 year 1 month	This cookie name is associated with Google Universal Analytics – which is a significant update to Google’s more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports.
_ga_G8CCKPL22Q	Performance	1 year 1 month	This cookie is used by Google Analytics to persist session state.

 

You may access any Personal Information we have about you by contacting us at info@transomcap.com.

THIRD-PARTY LINKS
Our Site may contain links to non-TCG websites and applications. Any access to and use of such non-TCG websites and applications are not governed by this Privacy Notice. Instead, your use of non-TCG websites or applications is governed by the privacy policies of those third-party websites or applications. We are not responsible for the information practices of such third-party websites and we encourage you to read their privacy policies.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
Our Site is intended to be used by customers located in the United States. If you are located anywhere outside of the United States, please be aware that information we collect about you, including Personal Information, will be transferred to, processed and stored in the United States. The data protection and privacy laws in the United States may differ from those of the country in which you are located. U.S. governmental agencies, courts, or law enforcement may be able to access or obtain your Personal Information (for example, in response to a court order). Please refer to the EEA-UK Privacy Notice for additional information relating to transfers of Personal Information outside the EEA or UK, including to the United States if you are located in the EEA or UK or if EEA-UK Data Protection Laws (as defined therein) apply to our processing of your Personal Information.

CHILDREN
Our Site is for general audiences and is not targeted to children under eighteen (18) years of age. We do not knowingly collect any Personal Information from children younger than the age of eighteen (18), and we will delete any Personal Information collected that we later know to be from an individual under the age of eighteen (18). If you believe a child under the age of eighteen (18) has disclosed Personal Information to us, please contact us at info@transomcap.com and specify the customer and information you believe to be from the child under eighteen (18).

SECURITY AND RETENTION
We have taken steps to help protect the information (including Personal Information) we collect about you from loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, no data security measures can guarantee 100% security. Please note that we cannot guarantee the security of any information (including Personal Information) we have collected about you, and any transmission of information or data by you to or through the internet, including, our Site is at your sole risk.
We have put in place procedures to deal with any suspected or actual Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We review the Personal Information we hold periodically and delete it securely. We will keep your Personal Information only for as long as is reasonably necessary for the purposes set out in this Privacy Notice unless a longer retention period is required by law. We will not keep more Personal Information than we need for those purposes. For further information about how long we will keep your Personal Information, please contact us at info@transomcap.com.

CHANGES TO THIS PRIVACY NOTICE
This Privacy Notice (including the Jurisdiction-Specific Notices) may be updated from time to time for any reason, in our sole discretion. Changes to this Privacy Notice will go into effect when posted. Accordingly, you are strongly encouraged to review this Privacy Notice regularly. If revisions to this Privacy Notice materially affect how we use Personal information that we collected from you prior to the date of the revised Privacy Notice, we will provide you with advance notice such as via email or by posting a notice on our Site. We will use your Personal Information only in accordance with the Privacy Notice under which the Personal Information was collected. We will post any updated Privacy Notice to our Site.

CONTACT
By email: info@transomcap.com
By mail: Transom Capital Group
100 N Pacific Coast Hwy
Suite 1725
El Segundo, CA 90245

EEA-UK Privacy Notice

This EEA-UK Privacy Notice only applies if and to the extent that EEA-UK Data Protection Laws (as defined below) applies to our processing of Personal Information. Information required to be disclosed under EEA-UK Data Protection Laws regarding the collection of your Personal Information that is not set forth in this EEA-UK Privacy Notice is otherwise set forth in the general Privacy Notice.

For the purposes of this EEA-UK Privacy Notice, the “EEA-UK Data Protection Laws” means all applicable legislation and regulations relating to the processing or protection of Personal Information in force from time to time in the European Economic Area (and its member states) or the United Kingdom (collectively, the “European Countries”), including (without limitation) the General Data Protection Regulation (EU) 2016/679 (“EU GDPR”), the EU GDPR as it forms part of the laws of England and Wales, Scotland and Northern Ireland (“UK GDPR”) and the UK Data Protection Act 2018, and any national implementing or successor legislation, and any amendment or re-enactment, of any of the foregoing. References to Personal Information shall have the same meaning as “personal data”, and the terms “controller”, “processor”, “data subject”, “personal data” and “processing” in this EEA-UK Privacy Notice shall be interpreted in accordance with the applicable EEA-UK Data Protection Laws. If you have any questions regarding our use of your Personal Information, or this EEA-UK Privacy Notice, please contact us at info@transomcap.com.

If any terms in this EEA-UK Privacy Notice conflict with other terms contained in the general Privacy Notice, the terms in this EEA-UK Privacy Notice shall apply to individuals whose processing of Personal Information is subject to EEA-UK Data Protection Laws.

For the purposes of EEA-UK Data Protection Laws, TCG will be a controller of any Personal Information collected by us. In simple terms, this means that we: (i) “control” the Personal Information that we collect; and (ii) make certain decisions on how to use and protect such Personal Information.

ANY ADDITIONAL PERSONAL INFORMATION COLLECTED BY US
The types of Personal Information we collect about you depends on the product or service you have requested from us and/or the nature of your interaction with us, as discussed above in the [PERSONAL INFORMATION WE COLLECT] section in the general Privacy Notice.
[We do not collect any special categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) or any information about criminal convictions and offences.]

If we require your Personal Information due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your Personal Information, and the possible consequences of you failing to provide this Personal Information. Failure to provide this Personal Information means that we cannot provide our services or products to you. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

PURPOSES AND LEGAL BASES

We rely on various legal bases under the EEA-UK Data Protection Laws in order to process your Personal Information, as we have set forth in the section titled [USE OF PERSONAL INFORMATION] in the general Privacy Notice.

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

[No automated decision making, including profiling, is used when processing your Personal Information.]

DISCLOSURE AND TRANSFERS OF PERSONAL INFORMATION
Your Personal Information may be transferred to, or processed by, us, our affiliates or third parties located in Non-Equivalent Countries (as defined below), including in the United States. Further information about who we may disclose your Personal Information to is included in the section of the general Privacy Notice headed [SHARING OF PERSONAL INFORMATION] . To the extent your Personal Information is transferred to a Non-Equivalent Country, such transfers will only be made in accordance with EEA-UK Data Protection Laws. For the purposes of this EEA-UK Privacy Notice, “Non-Equivalent Country” means a country or territory other than (i) a member state of the EEA; (ii) the UK; or (iii) a country or territory which has at the relevant time been decided by the European Commission, the Government of the UK, or the UK Information Commissioner (as applicable) in accordance with the applicable EEA-UK Data Protection Laws to ensure an adequate level of protection for Personal Information. For further information about the safeguards/derogations used, please contact us at info@transomcap.com.

YOUR RIGHTS
To the extent the EEA-UK Data Protection Laws apply to our processing of your Personal Information, you may have the following rights:

• Access: You have the right to ask for a copy of the Personal Information that we hold about you free of charge, however we may charge a ‘reasonable fee’, if we think that your request is excessive, to help us cover the costs of locating the Personal Information you have requested.
• Correction: You may notify us of changes to your Personal Information if the Personal Information we hold and process about you is inaccurate or it needs to be updated.
• Deletion: If you think that we shouldn’t be holding or processing your Personal Information anymore, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
• Restrictions on use: You may request that we stop processing your Personal Information (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your Personal Information for the purposes for which it was collected, but you still need your Personal Information to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your Personal Information, override your own rights.
• Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests unless we reasonably demonstrate compelling legitimate grounds for the processing.
• Portability: If you wish to transfer your Personal Information that we hold and process about you on the legal ground of contractual necessity to another organisation (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
• Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your Personal Information for a particular purpose not specified in this EEA-UK Privacy Notice, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.
• Not be subject to automated decision-making: You have the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects.
• Lodge a complaint: If you have a concern about our privacy practices, including the way we handled your Personal Information, you can report it to the data protection authority that is authorized to hear those concerns. We would, however, appreciate the opportunity to address your concerns before you approach the relevant supervisory authority, so please contact us in the first instance.

These rights are not absolute and in certain circumstances their exercise may not be possible including when Personal Information must be maintained to comply with applicable laws. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.