PRIVACY POLICY

Last Updated: [●] [●], 2025  

INTRODUCTION

POBCO, Inc. (“POBCO”, “Us”, “Our”, or “We”) respects the privacy of Our current, former and prospective customers (“Customers”) who engage Our services (the “POBCO Services”) and visitors (“Visitors” and together with Customers, “Users”,  “Your”, or “You”) of Our Website (“Website”). We are committed to protecting Your privacy through compliance with Our privacy policy (“Privacy Policy”). This Privacy Policy is being provided to You to inform You of, among other things: (i) the types of information We collect about You; (ii) Your choices on how We may use Your information; and (iii) how We use, secure, process, share, update and/or retain Your information as We operate Our business, particularly in relation to POBCO Services and Our marketing and business development efforts. This Privacy Policy applies to all information that We may collect from You or that You may provide to Us through (i) Our Website; (ii) Our mobile/tablet sites; (iii) Our official social media accounts (e.g., LinkedIn, Facebook, Instagram, X (f/k/a Twitter), YouTube) (the “POBCO Social Accounts”); (iv) Our messaging platforms, including those contained in the POBCO Social Accounts; (v) e-mails from Us that You have expressly opted in to receive; or (vi) any other instance when You contact Us ((ii) through (vi) are collectively referred to herein as “Channels”).

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY to understand Our policies and practices regarding Your Personal Information (as defined in this Privacy Policy) and how We will treat it. If You DO NOT AGREE with Our policies and practices as stated in this Privacy Policy, Your choice is to not use Our Website.

If You do not provide Us with Your Personal Information as We reasonably require, We may be unable to provide You with information or services that You have requested from Us. By accessing and/or using Our Website or Channels, You are agreeing to the terms of this Privacy Policy. POBCO may, from time to time, modify this Privacy Policy as set forth in Changes To Our Privacy Policy below. Your continued use of Our Website, Channels, and the POBCO Services, constitutes Your acceptance of this Privacy Policy.

YOU CAN WITHDRAW YOUR CONSENT AT ANY TIME.

IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, OUR TERMS OF USE, OUR TERMS AND CONDITIONS, OR IF YOU DO NOT CONSENT TO PROVIDE US YOUR PERSONAL INFORMATION FOR PROCESSING AS DESCRIBED IN THIS PRIVACY POLICY, THEN PLEASE DO NOT ENGAGE THE POBCO SERVICES, AND PLEASE DO NOT VISIT OUR WEBSITE OR ACCESS OUR CHANNELS.

INFORMATION WE COLLECT ABOUT YOU

POBCO only collects information You provide to Us or permit Us access to when You use Our Website or Channels. We may collect or receive information, including sensitive information (“Sensitive Information”), that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular User, household, or device (“Personal Information”). Sensitive Information is a subset of Personal Information, which is denoted with an Asterix (“*”), below. Personal Information does not include de-identified data or publicly available data. The chart below sets forth the categories of Personal Information that We may collect from Customers and/or Visitors of Our Website or Channels:

SOURCES OF WHICH WE COLLECT INFORMATION

The Personal Information We collect about You varies based on how You interact with Us, as outlined below: 

INFORMATION YOU PROVIDE TO US

Visitors of Our Website or Channels are not required to provide any information to access or use Our Website and may not be required to provide information to us to access Our Channels. Any information We collect, including Personal Information, is entirely based on what You choose to share with Us. We collect Personal Information that You provide to Us when You engage in the following activities:

• Access Our Website.

• Access Our Channels.

• Search queries on Our Channels.

• Request or obtain POBCO Services or information regarding POBCO Services from Us.

• Apply for a job or internship at POBCO or when You become an employee of POBCO. 

• Interact with the POBCO Social Accounts (e.g., commenting, following, reposting, etc.).

• Provide Us unsolicited information about You.

• Request or agree to receive Our marketing materials.

• By contacting Us for any purpose, including, but not limited to providing feedback on Our Website.

• Visit Our offices.

• Propose or deliver services to Us as a vendor.

• Subscribe to Our blogs.

• Interact with us at trade shows, conferences, or similar events.

You also may provide information to be published or displayed (“posted”) on public areas of the POBCO Social Accounts (“User Contributions”). Before providing Sensitive Information on the POBCO Social Accounts, We urge You to carefully consider whether to disclose such Sensitive Information as part of Your User Contributions. If You provide Sensitive Information, You consent to its use and disclosure as described in this Privacy Policy. Your User Contributions are posted on and transmitted to others at Your own risk. Additionally, We cannot control the actions of other users of the POBCO Social Accounts with whom You may choose to share Your User Contributions. Therefore, We cannot and do not guarantee that Your User Contributions will not be viewed by unauthorized persons.

INFORMATION WE RECEIVE FROM THIRD PARTIES

In specific situations, We may obtain various categories of Personal Information about You from third parties and public sources, such as Our Customers, representatives and professional advisors, recruitment agencies, marketing partners, third-party service providers (including those who provide Us feedback about Our Website and analytics and general information about browsing patterns to improve Our Website), or those seeking to do business with Us. Additionally, We may access information You have shared on Your social media accounts when You connect or interact with Us via the POBCO Social Accounts, and, depending on Your privacy settings, We may utilize or disclose this information in accordance with the terms outlined in this Privacy Policy.

AUTOMATICALLY COLLECTED INFORMATION

As You navigate through and interact with Our Website and Channels through Your device(s), We (and Our service providers) use automatic data collection technologies, to collect and record certain information about Your equipment, browsing actions, and patterns, including but not limited to the following (collectively referred to as “User Activity Data”):

• Details of Your visit(s) to Our Website or Channels, including Your location data, logs, traffic data, and other communication data and the resources that You access and use on Our Website.

• Information about Your computer and internet connection, including Your IP Addresses, device characteristics (such as connection type, operating system, browser type, screen resolution).

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  If You are accessing the Website or Channels using a mobile device, information about Your mobile device, including device model, operating system, and network information.

The User Activity Data We collect automatically consists solely of statistical data and does not include Personal Information. We do not automatically collect Personal Information, nor do We permit Our service providers to use or share any analytical data derived from User Activity Data. User Activity Data helps Us improve Our Website and Channels and deliver a better and more personalized experience to You.

Automatic data collection technologies used by Us (or Our service providers) may include the following (collectively “Data Technologies”):

• Cookies (or browser cookies): Cookies are small text files or pieces of information that are stored on the hard drive of Your computer, tablet, or mobile device that contain information about Your device, user setting, browsing history, and online activity when using Our Website or Channels. The information produced by a cookie often consists of a string of numbers and letters that uniquely identifies Your device. Unless You have adjusted Your browser setting so that it will refuse cookies, Our Website or Channels will issue cookies when You direct Your browser to Our Website or Channels.

• Web Beacons: Pages of Our Website, Channels, and Our e-mails may contain small electronic files known as web beacons (also referred to as tracking pixels, clear gifs, pixel tags, and single-pixel gifs) that permit POBCO, for example, to count users who have visited those pages or opened an e-mail and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity). Web beacons may also be used to help inform advertisements on third-party platforms based on the activity tracked from Your browser or device, to identify return traffic from third-party platforms such as social media applications, and for third-party web analytics.

• Website Analytics: We use third-party Website analytics services in connection with Our Website, including, for example, to register mouse clicks, mouse movements, scrolling activity and text that You type into Our Website. These Website analytics services generally do not collect Personal Information unless You voluntarily provide it and generally do not track Your browsing habits across Websites that do not use their services.

• Log Files: Like many standard Website servers, Our Website servers use log files. Log files include IP Addresses, browser type, internet service provider, referring/exit pages, platform type, date/time stamp and number of clicks. Log files are used to analyze trends, administer the site, track aggregated users’ movement and gather broad demographic information.

For more detailed information about the types of Data Technologies We use and the purposes for which We use them, please see Our Cookie Policy. For information about managing Your privacy and security settings for Data Technologies, see Your Choices below.

USE OF INFORMATION COLLECTED

We use information that We collect about You or that You provide to Us, including any information that is classified as Personal Information under appliable laws for legitimate business purposes, except as restricted by applicable law, for the following purposes:

• To present Our Website and/or Channels and their contents to You.
• To provide, enhance, personalize and customize User experience.
• To manage, resolve issues, and enhance Our Website.
• To conduct research and analysis in order to enhance Our understanding of industry trends and Client needs, while also expanding and maintaining Our list of contacts for effective communication and outreach.
• To send You marketing materials and other materials that You have expressly consented to or opted in to receive.
• To examine, prevent, or address illegal activities, suspected fraud, or breaches of Our Terms Of Use, Our Terms And Conditions as well as to meet Our legal obligations arising from any contracts entered into between You and Us, including for billing and collection.
• To allow Us to better service You and respond to Your inquiries or communications.
• To provide You with information about the POBCO Services that You have requested from Us.
• To protect the security and integrity of Our Website and/or Channels and overall business practices.
• To manage and support Our relationship with Customers, including providing additional services to enhance Our engagement.
• In any other way We may describe when You provide the information.
• Monitor adherence to and enforce this Privacy Policy, along with any other relevant policies.
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• To notify You about changes to Our Website or the POBCO Services.
• To fulfill, as We reasonably deem necessary and appropriate, Our legal obligations which We are subject.
• To fulfill any other purpose for which You provided the information or for which You have expressly consented to.

If You have opted in or consented to receive marketing communication from Us, and no longer wish to receive such communications, You may OPT OUT from receiving any informational or marketing materials, at any time, (i) by clicking “unsubscribe” in any marketing e-mail sent by Us to You; or (ii) by any method stated in Contact Us below. For more information, see Choices About How We Use and/or Disclose Your Information below.

DISCLOSURE OF INFORMATION

POBCO does not sell aggregated information, including information that is defined as Personal Information, about Our Users. In addition, POBCO does not share Your Personal Information with any unaffiliated entity unless You have explicitly consented or directed Us to do so. We may disclose or share Personal Information We have collected about You, or that You or a third-party have provided on Your behalf, as outlined in this Privacy Policy, for the following legitimate business purposes:

• To provide, support, personalize, and develop the POBCO Services, Our Website, or Channels.
• To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve Our responses.
• To Our subsidiaries and affiliates for any of the purposes listed in Use of Information Collected
• To help maintain the safety, security, and integrity of Our Website, products, services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve Our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• In connection with, any legal proceeding or prospective legal proceeding as We reasonably deem necessary and appropriate.
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• To enforce or apply Our Terms Of Use, Our Terms And Conditions and other agreements, including for billing and collection purposes.
• To any current or future office of POBCO.
• To fulfill the purpose for which You provide it. For example, if You share Your name and contact information to request POBCO Services as part of Our standard Client intake process or ask a question about POBCO Services, We will use that Personal Information to respond to Your inquiry.
• To service providers, advisors, potential transactional partners, or other third parties in the event of a merger, divestiture, restructuring, reorganization, dissolution, or any sale or transfer of some or all of POBCO’s assets—whether as an ongoing business or as part of bankruptcy, liquidation, or similar proceedings—where Personal Information held by POBCO about Our Website and/or Channel users is included among the assets being transferred.
• To third parties that provide services on Our behalf to support Our business, including Our Website administrators, mailing vendors, and analytical service providers.
• If We believe disclosure is necessary or appropriate to protect the rights, property, or safety of POBCO, Our Customers, employees, or others.
• For any other purpose disclosed by Us when You provide the information.
• With Your express consent or direction.

Residents of certain states may have additional Personal Information rights and choices. Please see Your U.S. State Privacy Rights below for more information regarding these rights. Consistent with applicable laws, You may exercise certain rights in regard to how Your information is used. For more information regarding Your rights, see Choices About How We Use and/or Disclose Your Information below.

ACCESSING, CORRECTING, AND UPDATING YOUR INFORMATION

It is important to Us that You are able to access and review the Personal Information We have about You and make corrections to it or delete it, as necessary, consistent with the law. To review, correct, update Your information and/or communication preferences or request We delete Your Personal Information, You can contact Us directly by any method stated in Contact Us below. Please note: (i) We

reserve the right to refuse a request to change or delete information about You if We believe that such change or deletion would violate any law or legal requirement or cause the information to be incorrect; (ii) We may refuse requests if We determine that such requests are unreasonably repetitive, require significant technical efforts, are impracticable or risk the privacy of others; (iii)  if You delete Your User Contributions from Our Channels, copies of Your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Channel users. Proper access and use of information provided on Our Website and/or Channels, including User Contributions, is governed by Our Terms Of Use.

In addition, as discussed in Your U.S. State Privacy Rights below, based on the location where You reside and/or work when Your Personal Information is collected by, or provided to, Us, You may have additional Personal Information rights and choices. For more information regarding these rights and choices, please refer to Your U.S. State Privacy Rights below. We will comply with all specific applicable laws and regulations as regards Your rights covering Personal Information.

DATA SECURITY

We take commercially reasonable security precautions on-line and off-line designed to comply with applicable legal requirements and to protect the security of the information You submit, or We collect, including Your Personal Information. All information You provide to Us is stored on Our secure servers behind firewalls and in locked offices. The computers/servers on which We store Personal Information are kept in a secure environment and access is restricted to those within POBCO who need to know. All accesses on-line and off-line are controlled and monitored.

The security of Your Personal Information is important to Us but be aware that no method of transmission over the internet, or method of electronic storage, or method of off-line storage is one hundred (100.00%) secure. While We strive to use commercially acceptable means to protect Your Personal Information, We cannot guarantee its absolute security. Any transmission of Personal Information is at Your own risk. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. 

RETENTION OF INFORMATION

In general, We will retain information, including Your Personal Information for as long as necessary to (i) fulfil the purposes for which it has been collected; (ii) to meet Our current and future legal obligations; (iii) to meet Our legitimate business interests; and (iv) in accordance with the time frame agreed to in an agreement, if applicable. We do not retain Personal Information longer than is necessary for Us to achieve the purposes for which We collected it. When We destroy Your Personal Information, We do so in a way that prevents that information from being restored or reconstructed.

PRIVACY FOR CHILDREN UNDER THE AGE OF 13

Our Website is designed for a “general audience” and is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13 unless such information has been obtained in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”) or provided in conjunction with POBCO Services. For the purposes of this Section of this Privacy Policy, the term “Personal Information” shall have the meaning ascribed to it under COPPA. If You are under 13 years of age, DO NOT USE Our Website or Channels or provide any information about yourself to Us, including Your name, address, telephone number, e-mail address, or any screen name or user name You may use, unless you do so related to POBCO Services.

If We learn We have collected or received information from a child under the age of 13 in a manner not permitted by COPPA, such information will be deleted in accordance with COPPA. If You believe We might have any information from or about a child under 13 years of age, please contact at Us at any method stated in Contact Us below. Residents of certain states under the ages of 13, 16, or 18 years may have additional rights regarding the collection of their personal information. Please see Your U.S. State Privacy Rights below for more information regarding these rights.

CHOICES ABOUT HOW WE USE AND/OR DISCLOSE YOUR INFORMATION

E-mail Opt-Out. We will only send You marketing communications that You have opted in for or expressly consented to receive. If You no longer wish to receive such communications from Us You may OPT-OUT at any time, (i) by clicking “unsubscribe” in any marketing e-mail sent by Us to You; or (ii) by any method stated in Contact Us below. Your decision to OPT-OUT of future marketing communications does not apply to all communications by Us to You (e.g., responding to Your request regarding the POBCO Services or information regarding the POBCO Services; responding to a job application at POBCO which You or a third-party on Your behalf has submitted Your Personal Information; etc.).

Automatic Data Collection and Tracking Technologies and Advertising. Most browsers today automatically accept cookies, however, You have choices relating to how Your device interacts with Our Website and/or Channels, as appliable. If You wish to OPT-OUT or modify certain cookies, You may do so by accessing Your browser settings or consulting the “Help” feature on most browsers. Your browser settings may allow You to limit, turn off cookies and other collection tools, or prevent Your browser from accepting new cookies. If You turn off certain permitted cookies or collection tools, You may not have access to many features that make Your experience more efficient and some of Our Website and/or Channel based services and features may not function properly.

Interest-Based Advertising by Third Parties. Some of Our advertising and technology partners and/or third parties (e.g., Google) may collect Personal Information and/or User Activity Data from You in connection with Your use of Our Website and Channels. These parties may offer You choices relating to their tracking technologies and as such You should consult with the applicable third-party’s policies regarding its tracking technology practices. Certain third-party Data Technology operators that may be associated with Our Website or Channels may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how You can exercise certain choices regarding OPT OUTS of interest-based advertising and other applicable uses of Web-viewing data, please visit DAA’s WebChoices Tool (for desktops) or download the AppChoices mobile application on Your mobile device. In addition, certain third-party Data Technology operators that may be associated with Our Website or Channels may be members of the Network Advertising Initiative (“NAI”). To learn more about how You can exercise certain choices regarding opt outs of interest-based advertising please visit NAI’s Opt Out of Interest-Based Advertising. Do note that the information provided is third-party information, and as such, We are not responsible for the completeness or accuracy of such information. Further note, OPTING OUT of interest-based advertising from those items listed herein only apply to those parties offering You choices relating to their tracking technologies or who are participants of DAA and/or NAI. As such, You may still receive interest-based advertisements from other third parties.

Do Not Track (“DNT”). POBCO does not track Your behavior across third-party Websites. DNT is a feature available in most browser settings that automatically transmits a DNT signal to Websites and online services that You do not wish to be tracked for advertising or analytics purposes. Note, most browsers turn off DNT by default, and require You to manually turn on DNT. You can turn on DNT by accessing Your browser settings or consulting the “Help” feature on most browsers. Further note, there is no standard interpretation, legal standard or practice for recognizing, responding and/or honoring DNT signals, and We, like many related service providers, do not alter Our practices when We receive a DNT signal from a visitor’s browser. To learn more about DNT see https://allaboutdnt.com/ for more information. This information is being provided to You for informational purposes only, and, as third-party information, and as such, We are not responsible for the completeness or accuracy of such information. Residents of certain states may have additional rights regarding DNT signals, with which We comply. Please see Your U.S. State Privacy Rights below for more information regarding these rights.

Third Party Use of Cookies and Other Tracking Technologies. Our Website and/or Channels may include links to content provided by third parties. A link to a third-party Website does not mean that We endorse it, or the quality or accuracy of information presented on it. If You decide to click on such link, You may be directed to a Website hosted by that third-party. We encourage You to review the legal and privacy notices of all third-party Websites and digital services You visit. Any Personal Information You provide through a third-party Website is at Your own risk and will be collected by that third-party, not by or on behalf of POBCO, and will be governed by the third-party’s privacy policy rather than this Privacy Policy. This Privacy Policy DOES NOT apply to information collected by

third parties or through their webpages that You access via Our Website or Channels. POBCO has no control over and is not responsible for how third parties use the information they collect.

YOUR U.S. STATE PRIVACY RIGHTS

Residents of California.

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act provides certain visitors, users, and others (e.g., employees, customers, prospects) who reside in the State of California additional privacy rights. For more information on these additional rights, please see Our California Consumer Privacy Act Notice.

Residents of Texas.

The Texas Data Privacy and Security Act provides consumers who reside in the State of Texas additional privacy rights. For more information on these additional rights, please see Our Texas Data Privacy and Security Act Notice.

Residents of Nebraska.

The Nebraska Data Privacy Act provides residents of the State of Nebraska additional privacy rights. For more information on these additional rights, please see Our Nebraska Data Privacy Act Notice.

CHANGES TO OUR PRIVACY POLICY

NOTIFICATION OF CHANGES

This Privacy Policy is effective as of the Last Updated Date set forth at the top of this Privacy Policy. By accessing Our Website and Our Channels, You agree to this Privacy Policy. We reserve the right to update, revise, and/or modify this Privacy Policy at any time and at Our sole discretion. In the event We make a material change to this Privacy Policy, and such change would materially and adversely affect Your rights hereunder, We will provide You advance notice by posting a notice of material changes to this Privacy Policy on Our Website. Upon the effective date of the Last Updated Date set forth at the top of this Privacy Policy, Your continued use or access to Our Website or Channels shall constitute Your acceptance of any amended Privacy Policy. The amended Privacy Policy

supersedes all previous versions. If You do not agree with the amended Privacy Policy or if You do not wish to be bound by such amended Privacy Policy, You should cease using Our Website and/or Channels immediately.   

OTHER PROVISIONS AS REQUIRED BY LAW

We continuously look for changes in laws and regulations that may impact the personal and corporate information We collect and maintain. We will adjust this Privacy Policy accordingly to ensure We are meeting the laws within the states where We operate and where We support individual and business operations.

GEOGRAPHIC RESTRICTIONS

Our Website and Channels are offered to and exclusively available to users who are over 18 years of age, who reside and are physically located in the United States or any of its territories or possessions (“Authorized Users”). By using Our Website or Channels, You represent and warrant that You are of legal age to form a binding contract with POBCO and meet all of the foregoing eligibility requirements. If You do not meet all of these requirements, You must not access or use Our Website or Channels.

POBCO, the owner of the Website, is based in the Commonwealth of Massachusetts, located in the United States. We provide this Website for use only by Authorized Users. We make no claims that Our Website or any of its content, including Channels and User Contribution, is accessible or appropriate outside of the United States or any of its territories or possessions. Our Website and Channels are not intended to subject Us to the laws or jurisdiction of any state, country or territory other than those of the United States.

Access to Our Website or Channels may not be legal by certain persons or in certain countries. If You access Our Website or Channels from outside the United States, You do so on Your own initiative and You are solely responsible for compliance with local laws, including General Data Protection Regulation or any other foreign privacy law. Any information, including Personal Information, You provide through use of Our Website and/or Our Channels may be stored and processed, transferred between and accessed from the United States and other countries which may not guarantee the same level of protection of Personal Information as the one in which You reside. However, We will handle Your Personal Information in accordance with this Privacy Policy regardless of where Your Personal Information is stored or accessed.

TERMS OF USE

By using Our Website and/or Our Channels You are agreeing to Our Terms Of Use governing the use of Our Website and/or Our Channels. If You do not AGREE to Our Terms Of Use, do not use Our Website and/or Our Channels.

CONTACT US

If You have any questions, comments, or concerns about this Privacy Policy, the ways in which POBCO collects and uses the information described herein, Your choices and rights regarding such use, would like a copy of Your information You have previously sent Us, need to access this Privacy Policy in an alternative format due to having a disability, or about any other matter, please do not hesitate to contact Us at one of the following methods: