Praxos Privacy Notice

This Privacy Policy (“Privacy Policy” or “Policy”) explains how Praxos Capital Management LLC (“Praxos,” “we,” “us,” or “our”) collects, uses, and discloses Personal Information. It applies to your use of our website at https://www.praxoscapital.com and https://www.praxoscapital.com (the “Site”), any online service where we post this Policy, your email communications with us, and certain offline interactions (together, the “Services”). The Services are intended for users located in the United States. Personal Information is processed in the United States and is subject to U.S. law; if you access the Services from outside the United States, you understand that your information will be transferred to, stored in, and processed in the United States and will be governed by U.S. law. By using the Services, you agree that we may collect, use, and disclose Personal Information as described in this Policy and that you are bound by our Terms of Use.

For purposes of this Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include deidentified or aggregate information.

Information We Collect

We collect information about you in connection with the Services. We collect information directly from you, automatically when you use our Services, and from unaffiliated third parties.

Information you provide to us: We may collect information you choose to share when you use our Services, request information, provide us your details at an event, or otherwise communicate with us.

Information collected automatically: We and our vendors may use cookies and similar technologies for analytics and to improve the Site. These tools may, for example, help tailor content, track pages you visit, manage and measure content, and compile usage statistics. Most browsers accept cookies by default, but you may change your settings to decline them. If you disable cookies, parts of the Site may not work properly. As we adopt additional technologies, we may collect additional information through other methods.

Information from others: We may receive information about you from our affiliates and from unaffiliated parties. For example, users may share colleagues’ information with us, or we may collect information when you interact with us on social media services such as LinkedIn and Twitter. We may combine information we collect through the Services with information from other parties and with information derived from other products or services we provide.

The categories of Personal Information we may collect include:

• Personal identifiers: for example, name, address, email address, telephone numbers, IP address or other unique identifier, and similar information. We do not collect account credentials or governmentissued identification numbers.
• Commercial information: for example, information about interactions you have with us (such as event attendance or inquiries). We do not collect payment or billing information, and we do not collect financial account numbers or access codes.
• Internet or other electronic activity information: for example, device and browser type, your browsing and search history on our Site, and information regarding your interactions with our Site and our advertisements.
• Other information: for example, information you choose to provide when you contact us with general inquiries.
• Inferences drawn from the Personal Information identified above.

We do not collect the following: account credentials (such as passwords), payment or billing data, financial account numbers or access codes, support tickets, CCTV footage, professional or employment information, education data, government IDs, precise geolocation, racial or ethnic origin, health data, union membership, or genetic or biometric data.

You are not required to provide information to us, but if you choose not to, certain features of the Services may not be available or may not function properly.

How We Use Your Personal Information

We use Personal Information for business and commercial purposes, including:

• to provide you with information you request from us,
• to contact you from time to time with news and other information about Praxos, or in response to your inquiries or other requests,
• to provide and improve the Services,
• to monitor or improve our Site,
• for internal business analysis,
• to prevent fraud, activities that violate our Terms of Use, or other illegal activities,
• to protect our rights and the rights and safety of our users or others,
• to comply with our legal obligations or as permitted by law, and
• to administer and troubleshoot the Services.

We do not use Personal Information for automated decisionmaking that produces legal or similarly significant effects, including decisions about credit or eligibility.

We may aggregate and/or deidentify information collected through the Services. We may use deidentified or aggregated data for any purpose, including for research and marketing, and we may disclose such data to other parties, including advertisers, promotional partners, sponsors, event promoters, and others.

When We Share Personal Information

In the 12 months prior to the date of this Policy, we have disclosed the following categories of Personal Information to unaffiliated parties for a business purpose:

• personal identifiers, and
• inferences from the foregoing.

In the 12 months prior to the date of this Policy, we have disclosed Personal Information for a business purpose to the following categories of unaffiliated parties:

• Vendors that provide customer relationship management (CRM) services; assist us in operating, analyzing, and displaying content on our website; provide analytics information; advertise or market our products; provide website hosting; and provide legal and accounting services.
• Vendors that provide data security services and cloudbased data storage; host our Site and assist with other ITrelated functions; advertise and market our products; and provide analytics information.
• Vendors that host our Site and assist with other ITrelated functions; advertise and market our products; provide analytics information; and provide legal and accounting services.

We may also disclose Personal Information as required or permitted by law, such as to comply with a subpoena, similar legal process, or government request, or when we believe in good faith that disclosure is legally required or necessary to protect our rights, property, or safety, or that of others (including to law enforcement and judicial or regulatory authorities). We may disclose information to help detect and protect against fraud or data security vulnerabilities. We may transfer Personal Information in connection with an actual or contemplated sale, merger, reorganization, or other restructuring. We may disclose information to our affiliates. We may also disclose Personal Information to others with your consent.

Cookies and Similar Technologies

Cookies are small, sometimes encrypted text files stored on your device by websites you visit. They help users navigate websites efficiently and provide information to website owners. To learn more about cookies, including how to see which cookies have been set and how to manage or delete them, visit www.allaboutcookies.org.

When you visit our Site, we may place a “cookie” or use other online tracking tools (e.g., web beacons) that recognize you. These technologies may collect information about your IP address and your actions on the Site. We use cookies and similar tools to capture information about Site use, including to improve your experience.

We use Google Analytics to evaluate use of our website. Google Analytics uses cookies and other identifiers to collect information such as how often users visit a website, what pages they visit, and what other websites they visited before visiting a website. To learn more about how Google Analytics collects personal information, review Google’s Privacy Policy.

Your California Privacy Rights

If you are a California resident, you may have additional rights regarding your Personal Information under California law.

CCPA Disclosures

Throughout this Policy, we describe the specific pieces and categories of personal information and sensitive personal information we collect, the sources of that information, and how we disclose it. Under the California Consumer Privacy Act (“CCPA”), we also must provide the categories of personal information and sensitive personal information we collect and disclose for business or commercial purposes. As used in this section, “personal information,” “sensitive personal information,” “business purposes,” “commercial purposes,” and “categories” have the meanings given in the CCPA.

In the twelve months preceding the effective date of this Policy, we collected and disclosed for business or commercial purposes the categories of personal information described above in “Information We Collect”: (1) personal identifiers; (2) commercial information (excluding any payment or billing data and excluding financial account numbers or access codes); (3) internet or other electronic activity information; and (4) inferences drawn from the personal information identified above. We did not collect professional or employment information, education data, support tickets, government IDs, precise geolocation, or biometric/genetic data.

We do not collect sensitive personal information as defined by the CCPA (for example, racial or ethnic origin, health data, union membership, precise geolocation, government IDs, financial account numbers and access codes, or genetic/biometric data), and we ask that you do not send this information to us.

We collect the categories of personal information identified above from: (1) you directly; (2) your use of the Services; and (3) third parties such as social media networks.

We process the categories of personal information identified above for the purposes described in the section titled “How We Use Your Personal Information.”

The California Consumer Privacy Act (CCPA) gives California residents the rights described below. This section applies only to California residents. It covers personal information we collect on or through the Services and through other channels (for example, offline or by phone). It does not apply to personal information we collect from Praxos employees or job applicants in those roles.

Your California Privacy Rights (CCPA/CPRA)

If you are a California resident, you may have certain rights under the California Consumer Privacy Act (the “CCPA”) (Cal. Civ. Code § 1798.100 et seq.). California law may permit you to request that we: We do not offer financial incentive or loyalty programs related to your Personal Information.

• Provide you the categories of personal information we have collected or disclosed about you; the categories of sources of such information; the business or commercial purpose for collecting, “selling,” or “sharing” your personal information; the categories of third parties (which may include our affiliates) to whom we disclose or “sell,” or with whom we “share,” personal information; and the categories of personal information we “sell” or “share.”
• Provide access to and/or a copy of certain information we maintain about you.
• Delete certain information we maintain about you.
• Correct inaccurate personal information we maintain about you.

The CCPA, as amended by the California Privacy Rights Act of 2020 (“CPRA”), also allows you to limit the use or disclosure of your sensitive personal information if your sensitive personal information is used for certain purposes. We do not use or disclose sensitive personal information for purposes that require an optout under the CCPA. We do not use automated decisionmaking to make credit, lending, or other eligibility decisions. We also do not collect the following types of information: account credentials; payment or billing data; support tickets; CCTV footage; professional or employment information; education data; governmentissued identifiers; financial account numbers or access codes; precise geolocation; racial or ethnic origin; health data; union membership; or genetic or biometric data.

You also have the right to opt out of “sales” and “sharing” of personal information. We have not “sold” or “shared” your personal information (as those terms are defined under the CCPA) in the 12 months preceding the effective date of this Policy. As our Site and Services are not directed to minors, we do not knowingly “sell” or “share” the personal information of children under 16.

We do not offer financial incentive or loyalty programs in exchange for your personal information. You also have the right to not be discriminated against (as provided for in applicable law) for exercising your rights. Certain information may be exempt from requests under applicable law. We need certain types of information to provide the Services to you. If you ask us to delete that information, you may no longer be able to access or use the Services.

How to Submit a Request

To exercise any of the rights above, or to ask a question, contact Praxos at contact@praxoscapital.com.

No Discrimination for Exercising Your Rights

You also have the right not to be discriminated against (as provided for in California law) for exercising your rights.

Identity Verification for Access or Deletion Requests

We will take reasonable steps to verify your identity before responding to a request. For example, we may ask for identifying information and try to match it to information that we maintain about you. If we are unable to verify you through this method, we may request additional information from you.

If we are unable to verify your identity with the degree of certainty required, we will not be able to honor your request. We will notify you to explain the basis of the denial.

Using an Authorized Agent

You may designate an authorized agent to submit requests on your behalf.

If you would like to designate an agent to act on your behalf, you and the agent will need to provide us with a power of attorney or your signed permission indicating the agent has been authorized to submit the request on your behalf. We may also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.

Do Not Track Signals

Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, our Site does not respond to browsers' “DNT” signals.

How Long We Keep Personal Information

The personal information we collect will be retained for as long as necessary to fulfill the purposes of the collection or to meet our legal obligations as set forth in this Privacy Policy. These purposes may include complying with reporting, legal, and accounting obligations.

Children’s Privacy

The Services are not intended for minors under 16. If we discover that an individual under 16 has provided us with Personal Information, we will delete the Personal Information to the extent required by the Children's Online Privacy Protection Act or other applicable law.

ThirdParty Websites

Our Site may contain social media buttons or links to thirdparty websites or services, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on those social media platforms or thirdparty websites. We recommend that you review the privacy policies posted on any platform or website that you may access through our Site.

How We Protect Personal Information

We implement and maintain security measures appropriate to the nature of the Personal Information that we collect, use, retain, transfer or otherwise process. Those measures include administrative, physical and technical safeguards to protect the security, confidentiality and integrity of Personal Information. However, data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security.

International Users

The Site and Services are intended for users located in the United States. Personal Information collected through the Site will be collected, processed, and stored in the United States and is subject to U.S. law. If you access the Site or Services from outside the United States, you understand and agree that your information will be transferred to and processed in the United States and that your use of the Site is governed by U.S. law.

Updates to This Privacy Policy

We will review and update this Policy periodically. We will notify you of material changes in accordance with applicable law. By continuing to use the Services, you acknowledge the applicability of the updated Privacy Policy. If you disagree with any changes and do not wish your information to be subject to a revised Privacy Policy, you will need to stop using the Services.

How to Contact Praxos

If there are any questions regarding this Policy, you may contact us at contact@praxoscapital.com.