Legal disclosure

1.0 TERMS OF USE
Thanks for your interest in our Website at www.karlongroup.com. Your use of this Website, including the content, materials and information available on or through this Website (together, the “Materials”), is governed by these Terms of Use (these “Terms”). By using this Website, you acknowledge that you have read and agree to these Terms.

2.0 WHO WE ARE
This Website is maintained and operated by Karlon Group LLC (“Karlon Group” or the “Company”).

3.0 MATERIALS
ALL MATERIALS ARE PROVIDED “AS IS,” MAY NOT BE RELIED UPON FOR ANY PURPOSE, AND ARE NOT SUBJECT TO EXPRESS OR IMPLIED WARRANTIES OF ANY KIND. In particular, we make no representations or warranties with regard to the Materials’ accuracy, completeness, non-infringement or fitness for a particular purpose. You should be aware that a significant portion of the Materials include or consist of information that has been provided by third parties and has not been validated or verified by us. Without limitation on the effect of other warnings and disclaimers set forth in these Terms, you should interpret any statements we make (on this Website or otherwise) in that context. Please ensure that your own computer security is comprehensive and up to date. We accept no responsibility for viruses, malware or other malicious or damaging software contained in the Materials or otherwise.

4.0 THIRD-PARTY SITES
We accept no responsibility for third-party sites available through this Website, via hyperlink or otherwise. You are encouraged to review the terms of use applicable to those sites. Any access to, or use of, a third-party site is solely at your own risk.

5.0 RESTRICTIONS ON USE; NO LICENSE
We reserve all rights with respect to the design and content of this Website. In particular, you must not misappropriate the design or content of this Website and you must not alter or deface such design or content in any way. Nothing on this Website grants any license with respect to such design or content, except that you may download and use Materials solely for your own personal information.

6.0 PRIVACY POLICY
For information about our privacy practices, refer to our Online Privacy Policy, available below.

7.0 LIMITATION OF LIABILITY
NO KARLON GROUP INDIVIDUAL OR ENTITY SHALL HAVE ANY LIABILITY BASED UPON YOUR USE OF, OR RELIANCE UPON, THIS WEBSITE OR THE MATERIALS. Some jurisdictions limit our ability to disclaim liability. With regard to those jurisdictions, our liability shall be limited to the greatest extent permitted by applicable law.

8.0 MODIFICATION OF THESE TERMS
We reserve the right to modify these Terms at any time. Please check these Terms periodically for changes. Your continued use of this Website after the posting of changes constitutes your binding acceptance of such changes.

9.0 MISCELLANEOUS
This Website is operated and controlled by Karlo Group LLC in the United States of America. If it is illegal or prohibited in your country of origin to access or use this Website, then you should not do so. Those who choose to access this Website outside the United States of America access it on their own initiative and are responsible for compliance with all local laws and regulations. These Terms, and any disputes relating to these Terms or your use of this Website or the Materials, shall be governed in all respects by the laws of the State of California, without regard to conflicts of laws principles. Any disputes relating to these Terms shall be resolved exclusively in the state or federal courts located in Los Angeles County, California. These Terms set forth the entire agreement between you and us with respect to the subject matter hereof and supersede all prior agreements relating to such subject matter. All Karlon Group individuals are intended third-party beneficiaries of these Terms. Our rights under these Terms may be waived by us only in writing. These Terms are binding on you as well as your successors and permitted assigns. In the event any provision of these Terms is determined to be invalid or unenforceable, such provision shall be deemed severed from the remainder of these Terms and replaced with a valid and enforceable provision as similar in intent as reasonably possible to the provision so severed, and shall not cause the invalidity or unenforceability of the remainder of these Terms.

10.0 CONTACT INFORMATION
Any questions, concerns or complaints regarding these Terms should be sent to
info@karlongroup.com.

Effective Date: June 20, 2024

©2024 Karlon Group LLC. All Rights Reserved.

11.0 KARLON GROUP PRIVACY POLICY
Karlon Group LLC (“Karlon Group”, “us”, “our” or “we”) has created this Privacy Policy to explain how we collect, use, store, share and transfer personal data and information (“Personal Data”) we obtain through our website located at www.karlongroup.com (the “Sites”), the Internet services that we offer (together with the Sites, the “Internet Services”), as well as through other means, as described below.

When we use the term “Personal Data” in this Privacy Policy, we mean information relating to an identifiable individual person.Where permitted by law, by using the Internet Services you consent to such use of your Personal Data and agree to the terms of this Privacy Policy.

Depending on where you are located and your interactions with the Internet Services, certain processing of your Personal Data by Karlon Group may be subject to data protection and privacy laws, including the EU’s General Data Protection Regulation (the “GDPR”), the UK Data Protection Act of 2018 along with the “UK GDPR” as retained as UK law by the European Union (Withdrawal) Act 2018 (together, the “UK GDPR”). and the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”). For example, this may be the case where Karlon Group processes the Personal Data of individuals in the EU and the UK who use the Internet Services (the “EU/UK Processing”) or of users of the Sites who reside in California (the “CCPA Processing”).This Privacy Policy makes clear where its disclosures apply only to the EU/UK Processing or to the CCPA Processing. All other disclosures in this Privacy Policy relate to Personal Data to which the GDPR, the UK GDPR and the CCPA do not apply, as well as to the EU/UK Processing and the CCPA Processing.

This Privacy Policy was updated as of June 20, 2024.

11.1 Personal data we collect
We collect and use Personal Data in a number of ways, depending on how you interact with us. These include when you interact with us on our Sites and Internet Services, when you contact us by email, telephone or by other means, and when you visit one of our offices.  If you provide Personal Data about any person other than yourself, you must ensure they understand how their Personal Data will be used and that they have given their permission for you to disclose the Personal Data to us and our outsourced service providers to use.

Information You Submit Through the Internet Services. When you interact with our Sites and other Internet Services, we may collect information you voluntarily provide to us, such as when you complete one of our online forms, join our mailing list or login to our investor portals.  This information may include:

(1) Identifiers, such as your name, user name and password, as well as contact details, such as your personal or work postal address, email address and phone number;

(2) Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, address and telephone number;

(3) Information about your communications with us, including the Personal Data you provide to us in email or in conversations with our employees and personnel; and

(4) Your marketing preferences, including any consents you have given us.

Information We Collect Automatically Through Our Internet Services. We automatically collect certain Personal Data including internet and other electronic activity information to help us understand how you use the Internet Services (which we will refer to in this Privacy Policy collectively as “Usage Data”). For example, each time you visit the Sites, we may automatically collect your IP address, browser and computer or device type, access time, the webpage from which you came and the webpage(s) that you access during your visit. We may combine Usage Data with other Personal Data in a manner that enables us to trace Usage Data to an individual user. Some web browsers may have “do not track” settings. The Sites do not honor “do not track” settings. 

Information We Collect From Third Parties. On occasion, we may receive Personal Data from third party sources, such as where our trusted suppliers provide web analytics and reporting services to us.

Information We Collect When You Visit One of Our Offices.  When you visit one of our offices, we may collect Personal Data from you, including identifiers such as your name when you sign in at our front desk, and visual information collected through security cameras.

Sensitive Personal Information. We may collect information that is considered “sensitive” under some laws including the CCPA, such as your account log-in if you log into our portal.  When we do so, we use such information only for lawful purposes in compliance with the CCPA, GDPR and other applicable privacy laws, such as to perform the services or provide the goods requested by you and to resist malicious, deceptive, fraudulent or illegal actions.  Where required by applicable law, we will obtain your consent prior to processing.

Cookies. We may use cookies (which are small amounts of data sent from a web server to your browser that are stored on your computer’s hard drive) to keep track of your use of the Internet Services, to validate your identity, to remember your password and preferences, to tailor the Internet Services to your account and to meet your interests and to improve the quality of the Internet Services. Generally, you can set your browser not to accept cookies or to notify you if you are sent a cookie, giving you the opportunity to choose whether or not to accept the cookie. Please note that if you do set your browser not to accept cookies, certain Internet Services may not function properly.  We use Google Analytics to understand Site traffic. To learn more about the use of Cookies by Google for analytics and to exercise choice regarding those Cookies, please visit the Google Analytics Opt-out Browser Add-on. 

Children. We do not knowingly collect Personal Data from minors under the age of 16 nor do we target the Sites to minors.

Our Use of Personal Data The following table describes the purposes for which we process the Personal Data referred to above, and any information you give us, as well as the legal basis for the use of Personal Data that is subject to the EU/UK Processing.

Purpose of Processing	EU/UK Disclosure: Legal Basis
Verifying your identity. Communicating with you in relation to the products and services we provide (including the Internet Services).	Where necessary to fulfil a contract or purchase, or take steps linked to a contract or purchase.
In response to requests from government law enforcement authorities conducting an investigation.	Where necessary to comply with a legal obligation.
Providing services to our clients and other individuals. Promoting our services (including the Internet Services) to clients, potential clients and other individuals and advising you of news and industry updates. Monitoring the use of the Sites and using Personal Data to help us improve and protect the Internet Services, both online and offline. Investigating any complaints received from you or others about the Internet Services. In connection with legal claims and for compliance, regulatory and investigatory purposes.	Where necessary for Karlon Group’s or another party’s legitimate interests and where those interests are not overridden by your data protection rights.
Sending you direct marketing by email in relation to our services (including the Internet Services). On other occasions where we ask you for consent, we will use your Personal Data for the purpose(s) that we explain at that time.	Where you give us your consent.

EU/UK Disclosure: Where we require Personal Data to comply with our legal or contractual obligations, the provision of such Personal Data is mandatory. If it is not provided, then we may not be able to provide the Internet Services. In all other cases, the provision of requested Personal Data is optional.

EU/UK Disclosure: We will not use Personal Data to formulate a decision based solely on automated processing (including profiling) which produces legal effects or similarly significantly impacts you.

11.2 Our personal data sharing practices
We employ other companies and individuals to perform functions on our behalf, such as for analyzing data and providing certain of the Internet Services. These third-party service providers have access to Personal Data needed to perform their functions, but we require that they do not use Personal Data for other purposes. Personal Data is not shared with any unaffiliated third parties for their marketing purposes unless we have obtained your consent to do so in accordance with applicable law.We may share Personal Data with third parties: (1) in response to subpoenas, court orders, regulatory requests or legal process, or to establish, protect or exercise our legal rights and interests or to defend against legal claims; (2) if we believe it is necessary in order to investigate, prevent or take action regarding inappropriate or illegal activities, fraud or situations involving potential threats to the safety of any person or property; (3) if we believe it is necessary to investigate, prevent or take action regarding inappropriate use of the Internet Services; (4) to our parent company, subsidiaries, joint ventures or other companies under common control with us (in which case we will require such entities to honor this Privacy Policy); and (5) as part of a corporate transaction with a successor or affiliate or in connected with any acquisition, merger or sale of assets.

CCPA Disclosure: We may disclose the following categories of Personal Data to third parties for the business or commercial purposes described above: (1) identifiers, including your name, user name and password and contact details, such as your personal or work postal address, email address and phone number; (2) commercial information, including your marketing preferences and any consents you have given us; (3) Internet or other electronic network activity information, including information related to the browser or device you use to access the Sites, your IP address and your cookie preferences; (4) professional and employment information, such as where we are making employment references; and (5) visual information collected through our security cameras for legal or regulatory compliance or investigatory purposes. We do not sell your Personal Data, nor do we share it for purposes of cross-context behavioral advertising, and we have not done so in the last 12 months. We do not sell or share the Personal Data of minors.

EU/UK Disclosure: Your Personal Data may be transferred to, processed in and accessed from jurisdictions outside the EU and the UK by Karlon Group and the third parties with which we share your Personal Data. Specifically, your Personal Data will be transferred to Karlon Group and third parties in the United States of America. When we transfer your Personal Data among Karlon Group entities, or to other third party organizations, we will do in accordance with the GDPR and/or the UK GDPR, including through the use of European Commission-approved standard contractual clauses, a third party’s binding corporate rules or we where are entitled to rely on one of the other safeguards permitted by the GDPR and/or the UK GDPR.

11.3 Your rights
We have controls in place designed to ensure that the Personal Data we collect and process is relevant, accurate and appropriate for the purposes it is used. If you believe that any Personal Data about you is inaccurate, please let us know by contacting us at info@karlongroup.com. Please note that any Personal Data we have copied may remain in back-up storage for some period of time after your request, and that if you delete certain Personal Data, you may not be able to use the Internet Services in the future without re-submitting such information. Please also note that we will maintain Personal Data whenever we are required to do so by law or regulation.

Individuals in a number of jurisdictions may have certain rights in relation to their Personal Data. These rights vary, but they may include the right to: (1) request access to and rectification or erasure of their Personal Data; (2) restrict or object to the processing of their Personal Data; and (3) obtain a copy of their Personal Data in a portable format. Individuals may also have the right to lodge a complaint about Karlon Group’s processing of their Personal Data with a data protection authority. The rights described herein are not absolute and may not be applicable to you. We reserve all of our rights available to us at law in this regard. If you wish to exercise any of the rights described in this Your Rights section, please email info@karlongroup.com or call 800-203-0398.

If you wish to exercise your rights, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously, as well as, in some instances, ask you to provide a signed declaration under penalty of perjury that you are the individual whose Personal Data is the subject of the request. If it is necessary to collect additional information (including Personal Data) from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. For requests related to particularly sensitive Personal Data, we may require additional proof of identification. If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf. We will process your request within the time provided by applicable law.

EU/UK Disclosure: You may be entitled to ask Karlon Group for a copy of your Personal Data, to correct, delete or restrict processing of it, and to obtain the Personal Data you provide in a structured, machine-readable format and ask us to share this Personal Data with other organizations. You may also have the right to object to processing in some circumstances and can ask us not to send you direct marketing or to carry out profiling at any time. You have the right to lodge a complaint about Karlon Group’s processing of your Personal Data with a data protection authority in the place you live, work or where the breach occurred. Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Karlon Group processing your Personal Data, this will not affect any processing that has already taken place. These rights may be limited, for example, if fulfilling your request would reveal Personal Data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete Personal Data that we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make.

CCPA Disclosure: If you are a California resident, you may be entitled to request access to the categories or specific pieces of Personal Data that Karlon Group collects about you, to request that Karlon Group deletes or corrects your Personal Data and to opt out of the sale and/or sharing of your Personal Data. Although California residents may have the right to opt out of the sale and sharing of Personal Data, Karlon Group does not sell or share Personal Data as the terms “sell” and “share” are used under the CCPA to third parties, including Personal Data of individuals under 16 years of age, and we have not sold or shared such Personal Data in the last 12 months. The CCPA prohibits Karlon Group from discriminating against you for exercising your applicable CCPA rights. 

If you wish to exercise any of the rights described in this CCPA Disclosure section, please email info@karlongroup.com. In order to respond to a request, you will be required to supply a valid means of identification as a security precaution. Depending on the sensitivity of the information in question, we may require additional proof of identification.  We will not disclose or delete any information until the individual’s identity is verified. If an agent makes a request on your behalf, they will be required to verify the request by submitting your written authorization, and we may still ask that you verify your identity with us before we can proceed with the request. We will not honor any requests from agents until authorization is verified. We will maintain records of consumer requests made under CCPA and how we responded to those requests in accordance with the CCPA.

California Shine the Light Disclosure: Under California Civil law, Californians are also entitled to request information relating to whether a business has disclosed Personal Data to any third parties for the third parties’ direct marketing purposes. If you are making a request for access, we may not be able to provide specific pieces of Personal Data if the disclosure creates a substantial, articulable and unreasonable risk to the security of your Personal Data, your account with us or our systems or networks. If you are making a request for erasure, we will ask that you confirm that you would like us to delete your Personal Data again before your request is submitted. To make a request, please contact us at the contact information below.

11.4 Retaining your personal data
Where we process your Personal Data in connection with the Internet Services, we keep the Personal Data to comply with our legal obligations or to communicate with you because you still have another connection with Karlon Group. Where we process your Personal Data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after that (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your Personal Data so that we can respect your request in future. We maintain administrative and financial records and use multiple methods to back up our data and systems to ensure reliable data recovery in the event of a significant business disruption, and we retain this information in accordance with our Personal Data Retention and Destruction Policy.  We retain all other Personal Data for the time necessary to achieve the purposes outline in this Privacy Policy, taking into account the statute of limitations period and record retention requirements under applicable law.

11.5 Links
The Sites may contain links to other websites. We are not responsible for the privacy practices of any such other website (whether accessed through an advertisement, service or content link) and urge you to review such practices prior to submitting any information or Personal Data to such websites.

11.6 Changes
We may update this Privacy Policy from time to time in our sole discretion and encourage visitors to review this page frequently for any changes. Any updated version of this Privacy Policy will be effective as of the date set forth therein. If you are located in the United States of America or otherwise outside the EU or the UK, by continuing to use the Internet Services after such updates, you expressly agree to the terms of the updated Privacy Policy.

11.7 Questions
If you have any questions about this Privacy Policy, please feel free to contact us by email at info@karlongroup.com.