It is Global Frontier Capital’s (“GFC” or “Our”) policy to respect privacy rights and comply with any applicable law and regulation regarding personal information we may collect about users, including across our website, https://globalfrontiercapital.com (“Website”), and any other virtual spaces we own and operate (other websites, social listing, and data rooms).

Personal information, for the purposes of our privacy policy, is any information about a user that can be used to identify them and their position (such as investor status). This includes information about them as a person (such as name, address, and date of birth), their devices, payment details, and even information about how their use a website or online service.

In the event our site contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies, and users are subject to those accordingly. After following a link to any third-party content, users should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of their activities after their leave our site. Additionally, any links to third-party sites do not represent affiliation, sponsorship, or formal relationships between the representatives of those sites and GFC.

Information We Collect

Information we collect falls into one of three categories: information provided voluntarily by the user, automatically-collected information, and third-party provided information.

Information provided voluntarily refers to any information a user knowingly and actively provide us when using or participating in any of our services and promotions.

Automatically collected information refers to any information automatically sent by a user’s devices in the course of accessing our products and services, or related to engagement activity with the website content.

Third-party provided information refers to any information afforded to GFC as part of screening or vetting processes related to confirming investor status. Third-party information will only be collected if the user initiates communications with GFC of their of volition with potential intent to invest in our products and services.

Log Data

When users visit the GFC website, our servers may automatically log the standard data provided by a user’s web browser. It may include, but is not necessarily limited to, a device’s Internet Protocol (IP) address, browser type and version, the pages visited, the time and date of the visit, the time spent on pages, and other session and engagement-based details about a user’s visit.

Additionally, should users encounter certain errors while using the site, we may automatically collect data about these errors and the circumstances surrounding their occurrence, so we may troubleshoot and improve the website experience for all users. This data may include technical details about user devices, what users were trying to do when the error happened, and other technical information relating to the problem. Users may or may not receive notice of such errors, even at the moment they occur, that they have occurred, or what the nature of said errors may be.

Please be aware that while this information may not be personally identified by itself, it may be possible to combine it with other data to personally identify individual persons. GFC does not actively pursue data combining of this nature unless there is legal or regulatory necessity to do so.

Personal Information

GFC may ask users for their personal information — for example, if a user subscribes to a newsletter or use a contact us form — which may require the provision of one or more of the following:

• Name
• Email
• Phone/mobile number
• Home/mailing address

Additional information may need to provided by users to access privileged information about products or services. This information varies, but will be limited to that necessitated by law or regulation.

Legitimate Reasons for Processing Personal Information

GFC only collects and uses personal information when there is a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our products and services.

Collection and Use of Information

GFC may collect personal information from users when any of the following on our website:

• Sign up to receive updates from us via email, social media channels, newsletters, and other professional communications
• Use a mobile device or web browser to access our content
• Contact us via email, social media, or on any similar technologies
• Mention GFC on social media

GFC may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

• to provide access to our platform’s core features and services
• to enable users to customize or personalize their experience of our website
• to contact and communicate with users
• for analytics, market research, and business development, including operating and improving our website, associated applications, and associated social media platforms
• for advertising and marketing, including sending users promotional information about our products and services and information about third parties that we consider may be of interest to users
• for internal record keeping and administrative purposes
• to attribute any content (e.g., posts and comments) a user submits that we publish on our website
• for security and fraud prevention, and to ensure that our sites and apps are safe, secure, and used in line with our terms of service

GFC may combine voluntarily-provided, automatically-collected, and third-party personal information with general information or research data we receive from other trusted sources. For example, our market research activities may uncover data and insights, that we may combine with website user information to improve our site and the user experience on it.

Security of Personal Information

When GFC collects and processes personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.

Although GFC will do our best to protect the personal information a user provides to us, it is our responsibility to advise users that no method of electronic transmission or data storage is perfect or 100% secure, and no one can guarantee absolute data security.

Users are responsible for limiting the information they provide to GFC to what is absolutely necessary. It is GFC’s responsibility to only retain personal information that is necessary to do business with users, and only for the length of time necessary to provide products and services.

Users are also responsible for selecting any password and its overall security strength for data rooms or user-specific secure spaces (such as data rooms or investor portals), ensuring the security of their own information within the bounds of our services.

For example, ensuring users do not make their personal information publicly available via our platform.

How Long We Keep Personal Information

GFC keeps personal information only for as long as we need to. This time period may depend on what we are using the information for, in accordance with this privacy policy. For example, if a user has provided us with personal information such as an email address when contacting us about a specific inquiry, we may retain this information for the duration of the user’s enquiry remaining open as well as for our own records, so we may effectively address similar enquiries in future. If a user’s personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify them.

However, if necessary, we may retain personal information for our compliance with a legal, accounting, regulatory, or reporting obligation, or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.

Children’s Privacy

GFC does not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13.

Disclosure of Personal Information to Third Parties

GFC may disclose personal information to:

• a parent, subsidiary, or affiliate of our company
• third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, maintenance or problem-solving providers, marketing providers, professional advisors, and payment systems operators
• third-party service providers for the purpose of verifying qualified or accredited investor status, in accordance with SEC compliance and regulation
• our employees, contractors, and/or related entities
• our existing or potential agents or business partners
• credit reporting agencies, courts, tribunals, and regulatory authorities, in the event a user fails to pay for goods or services we have provided to them
• courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights
• third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to a user
• third parties to collect and process data
• an entity that buys, or to which we transfer all or substantially all of our assets and business

Third parties we currently use include:

• Google Analytics
• WP Engine

International Transfers of Personal Information

The personal information GFC collects is stored and/or processed in the United States, or where we or our partners, affiliates, and third-party providers maintain facilities.

The countries to which we store, process, or transfer user personal information may not have the same data protection laws as the country in which a user resides or where a user initially provided the information. If we transfer personal information to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this privacy policy.

Rights and Controlling Personal Information

User choice: By providing personal information to GFC, users understand we will collect, hold, use, and disclose personal information in accordance with this privacy policy. Users do not have to provide personal information to us, however, if they do not, it may affect their use of our website or the products and/or services offered on or through it.

Information from third parties: If GFC receives personal information about a user from a third party, we will protect it as set out in this privacy policy. If the user is a representative of a third party providing personal information about somebody else, that user represents and warrants that they have such person’s consent to provide the personal information to us, and that user bears any legal, regulatory, or compliance burden associated with the provision of that information to GFC.

Should GFC be notified that it is in possession of personal information provided by a third party that is not relevant or meant to be in GFC’s possession, the information will be deleted in accordance with this privacy policy.

Marketing permission: If a user has previously agreed to GFC using their personal information for direct marketing purposes, they may change their mind at any time by contacting us using the details below.

Access: Users may request details of the personal information that GFC holds about them at any time.

Correction: If a user believes that any information GFC holds about them is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date, or delete the information in accordance with this privacy policy.

Non-discrimination: GFC will not discriminate against a user for exercising any of their rights over personal information. Unless a user’s personal information is required to provide them with a particular product, service, or offer (for example providing user support), we will not deny goods or services and/or charge different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties, or providing with a different level or quality of products or services.

Notification of data breaches: GFC will comply with laws applicable to us in respect of any data breach.

Complaints: If a user believes that GFC has breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate the complaint and respond, in writing, setting out the outcome of our investigation and the steps we will take to deal with the complaint. Users also have the right to contact a regulatory body or data protection authority in relation to a complaint.

Unsubscribe: To unsubscribe from the GFC email database or opt-out of communications (including marketing communications), please contact us using the details provided in this privacy policy or opt-out using the opt-out facilities provided in the communication. We may need to request specific information from the user to help confirm their identity. Please note that provision of products and services may require communications, and if unsubscribing would impact the ability to provide that which has been asked by or promised to the user, GFC will notify them, so they may decide accordingly how we should proceed.

Use of Cookies and Pixels

GFC uses “cookies” to collect information about users and their activity across our site, and this portion of the privacy policy covers the use of cookies between a user’s device and our site.

Cookies help GFC serve content based on the preferences a user has specified. We also provide basic information on third-party services we may use, who may also use cookies as part of their service. This policy does not cover their cookies.

At all times, a user may decline cookies from our site if their browser permits. Most browsers allow users to activate settings on their browser to refuse the setting of all or some cookies. Accordingly, a user’s ability to limit cookies is based only on their browser’s capabilities.

If a user does not wish to accept cookies from us, a user should instruct their browser to refuse cookies from https://globalfrontiercapiltal.com. In such a case, we may be unable to provide some of a user’s desired content and services.

What is a cookie?

A cookie is a small piece of data that a website stores on a device when a user visits the GFC site. It typically contains information about the website itself, a unique identifier that allows the site to recognize a user’s web browser when they return, additional data that serves the cookie’s purpose, and the lifespan of the cookie itself.

Cookies are used to enable certain features (e.g., logging in), track site usage (e.g., analytics), store user settings (e.g., time zone, notification preferences), and personalize content (e.g., advertising, language).

Cookies set by the website users are visiting are usually referred to as first-party cookies. They typically only track activity on that particular site.

Cookies set by other sites and companies (i.e., third parties) are called third-party cookies They can be used to track a user on other websites that use the same third-party service.

Types of cookies and how we use them

Essential cookies

Essential cookies are crucial to a user’s experience of a website, enabling core features like user logins, account management, shopping carts, and payment processing.

GFC does not use this type of cookie on our site.

Performance cookies

Performance cookies track how a user uses a website during their visit. Typically, this information is anonymous and aggregated, with information tracked across all site users. They help companies understand visitor usage patterns, identify, and diagnose problems or errors their users may encounter, and make better strategic decisions in improving their audience’s overall website experience. These cookies may be set by the website a user is visiting (first-party) or by third-party services. They do not collect personal information about the user.

GFC uses performance cookies on our site.

Functionality cookies

Functionality cookies are used to collect information about a user’s device and any settings they may configure on the website they are visiting (like language and time zone settings). With this information, websites can provide customized, enhanced, or optimized content and services. These cookies may be set by the website a user is visiting (first-party) or by third-party services.

GFC uses functionality cookies for selected features on our site.

Targeting/advertising cookies

Targeting/advertising cookies help determine what promotional content is most relevant and appropriate to a user and their interests. Websites may use them to deliver targeted advertising or limit the number of times a user sees an advertisement. This helps companies improve the effectiveness of their campaigns and the quality of content presented to them. These cookies may be set by the website a user is visiting (first-party) or by third-party services. Targeting/advertising cookies set by third parties may be used to track a user on other websites that use the same third-party service.

GFC uses targeting/advertising cookies on our site.

Business Transfers

If GFC or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including user personal information, among the assets transferred to any parties who acquire us. User acknowledge that such transfers may occur and that any parties who acquire us may, to the extent permitted by applicable law, continue to use personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information

Limits of Our Policy

The GFC website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites and cannot accept responsibility or liability for their respective privacy practices.

Changes to This Policy

At GFC’s discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which users are accessing this privacy policy.

If required by law, we will get user permission or give users the opportunity to opt in to or opt-out of, as applicable, any new uses of a user’s personal information.

Additional Disclosures for California Compliance (US)

Under California Civil Code Section 1798.83, if a user live in California and they business relationship with us is mainly for personal, family, or household purposes, they may ask us about the information we release to other organizations for their marketing purposes.

To make such a request, please contact us using the details provided in this privacy policy with “Request for California privacy information” in the subject line. Users may make this type of request once every calendar year. We will email them a list of categories of personal information we revealed to other organizations for their marketing purposes in the last calendar year, along with their names and addresses. Not all personal information shared in this way is covered by Section 1798.83 of the California Civil Code.

Do Not Track

Some browsers have a “Do Not Track” feature that lets a user tell websites that they do not want to have their online activities tracked. At this time, we do not respond to browser “Do Not Track” signals.

We adhere to the standards outlined in this privacy policy, ensuring we collect and process personal information lawfully, fairly, transparently, and with legitimate, legal reasons for doing so.

Cookies and Pixels

At all times, users may decline cookies from our site if their browser permits. Most browsers allow users to activate settings on their browser to refuse the setting of all or some cookies. Accordingly, a user’s ability to limit cookies is based only on their browser’s capabilities. Please refer to the Cookies section of this privacy policy for more information.

CCPA-permitted financial incentives

In accordance with a user’s right to non-discrimination, we may offer certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels for the goods or services we provide.

Any CCPA-permitted financial incentive we offer will reasonably relate to the value of a user’s personal information, and we will provide written terms that clearly describe the nature of such an offer. Participation in a financial incentive program requires a user prior opt-in consent, which they may revoke at any time.

California Notice of Collection

In the past 12 months, we have collected the following categories of personal information enumerated in the California Consumer Privacy Act:

• Identifiers, such as name, email address, phone number account name, IP address, and an ID or number assigned to a user’s account.
• Demographics, such as a user’s age or gender. This category includes data that may qualify as protected classifications under other California or federal laws.

For more information on the information we collect, including the sources we receive information from, review the “Information We Collect” section. We collect and use these categories of personal information for the business purposes described in the “Collection and Use of Information” section, including to provide and manage our Service.

Right to Know and Delete

If a user is a California resident, they have the right to delete the personal information we collected and know certain information about our data practices in the preceding 12 months. In particular, users have the right to request the following from us:

• The categories of personal information we have collected about the user.
• The categories of sources from which personal information was collected.
• The categories of personal information about the user we disclosed for a business purpose or sold.
• The categories of third parties to whom the personal information was disclosed for a business purpose or sold.
• The business or commercial purpose for collecting or selling the personal information; and
• The specific pieces of personal information we have collected about the user.

To exercise any of these rights, please contact us using the details provided in this privacy policy.

Shine the Light

If the user is a California resident, in addition to the rights discussed above, they have the right to request information from us regarding the manner in which we share certain personal information as defined by California’s “Shine the Light” with third parties and affiliates for their own direct marketing purposes.

To receive this information, send us a request using the contact details provided in this privacy policy. Requests must include “California Privacy Rights Request” in the first line of the description and include the user’s name, street address, city, state, and ZIP code.

Global Data Protection Regulation (GDPR)

If a user chooses to use our site, products, and/or services from the EU, EEA, or other regions of the world, they acknowledge that GFC will transfer their personal information to the US. Users should not provide personal information to us if they do not want this information transferred outside their country, or if the laws in their country restrict these types of transfers.

If the user is a resident of the European Union, GFC will process their personal information in compliance with the EU General Data Protection Regulation (“GDPR”). GFC will act as the Data Controller, as defined under GDPR. Personal information will be collected and processed in compliance with these principles, as required by GDPR: lawfulness and transparency, purpose limitation, data minimization, accuracy, storage limitation, and confidentiality. In addition, users for which this applies will be entitled to certain rights with respect to the personal information that we collect about them:

• Right to be informed: The right to know how user personal information will be used;
• Right of access and portability: The right to obtain access to user personal information, along with certain related information, and to receive that information in a commonly used format and to have it transferred to another data controller;
• Right to rectification: The right to obtain rectification of the user’s personal information without undue delay where that personal information is inaccurate or incomplete;
• Right to erasure: The right to obtain the erasure of the user’s personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed;
• Right to restriction: The right to obtain the restriction of the processing undertaken by us on the user’s personal information in certain circumstances, such as where the accuracy of the personal information is contested by the user, for a period enabling us to verify the accuracy of that information;
• Right to object: The right to object, on grounds relating to the user’s situation, to the processing of personal information, and to object to processing of the user’s personal information for direct marketing purposes, to the extent it is related to such direct marketing; and
• Right to lodge a complaint with a supervisory authority if the user believes that their rights herein have been infringed.

To exercise these rights, please use the contact information in this privacy policy.

How Long GFC Retains Personal Information

If GDPR applies to the user, they also have the right to know the period for which their personal information will be stored, or, if not possible, to know the criteria used to determine that time period. We will retain personal information for no longer than necessary. This length of time depends on any legal obligations that we have, the nature of any contracts that we have with the user, and our legitimate interests as a business.

Contact Us

For any questions or concerns regarding privacy, users may contact us using the following details:

• Phone: 206-254-1313
• Email: [email protected]