Privacy Statement

Last modified: August 28, 2024

Introduction

The PFM group of companies (“PFM” and referred to hereina er as the “Organization”, “we”, “us”, or “our”) respects your privacy and is committed to protecting it through compliance with this privacy statement. For further details regarding the legal entities making up PFM, see www.pfm.com/disclosures.

This privacy statement describes the types of information we may collect from you or that you may provide when you visit the website www.pfm.com (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This privacy statement applies to information we collect:

On this Website.

In email, text, and other electronic messages between you and this Website.

It does not apply to information collected by:

us oﬄine or through any other means, including on any other website operated by The Organization or any third party (including our affiliates and subsidiaries); or

any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this statement carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy statement. This privacy statement may change from time to time (see section titled Changes to Our Privacy Statement below). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the privacy statement periodically for updates.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

by which you may be personally identified, such as name, postal address, e-mail address, telephone number or any other identifier by which you may be contacted online or oﬄine ("personal information");

that is about you but individually does not identify you; and/or

about your internet connection, the equipment you use to access our Website and usage details.

We collect this information:

Directly from you when you provide it to us.

Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.

Information You Provide to Us. The information we collect on or through our Website may include:

Information that you provide by filling in forms on our Website. This includes information provided at the time of requesting further services. We may also ask you for information when you report a problem with our Website.

Records and copies of your correspondence (including email addresses), if you contact us.

Your responses to surveys that we might ask you to complete for research purposes.

If applicable, you also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website 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 Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information or we may maintain it or associate it with personal information we collect in other ways. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.

Store information about your preferences, allowing us to customize our Website according to your individual interests.

Speed up your searches.

Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see the section below titled Choices about How We Use and Disclose Your Information.

Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Organization, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

To present our Website and its contents to you.

To provide you with information, products, or services that you request from us.

To fulfill any other purpose for which you provide it.

To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

To notify you about changes to our Website or any products or services we offer or provide though it.

To allow you to participate in interactive features on our Website.

In any other way we may describe when you provide the information.

For any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you. For more information, see section titled Choices about How We Use and Disclose Your Information below.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy statement:

To our subsidiaries and affiliates, successor and assigns.

To contractors, service providers, and other third parties we use to support our business.

To fulfill the purpose for which you provide it.

For any other purpose disclosed by us when you provide the information.

With your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

To enforce or apply our terms of use and other agreements, including for billing and collection purposes.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Organization, our customers, or others.

Choices about How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Promotional Offers from the Organization. If you do not wish to have your contact information used by a particular entity of the Organization to promote its or a third party’s products or services, you can opt-out by following instructions provided to you electronically at the time of distribution or at any other time by sending us an email stating your request to websiteterms @pfm.com. This opt out does not apply to information provided to the Organization as a result of a service or product purchase, service experience, or other transactions.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Statement

It is our policy to post any changes we make to our privacy statement on this page. The date the privacy statement was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this privacy statement to check for any changes. We also reserve the right to notify you in other ways from time to time about the processing of your personal information, as necessary.

Contact Information

To ask questions or comment about this privacy statement and our privacy practices, contact us at:

websiteterms @p fm.com

(215) 567-6100

The below only applies for Personal Information subject to the GDPR:

Personal Information / Data Protection and the GDPR

We are committed to protecting the privacy and security of your Personal Information.

We abide by all applicable national and international data protection laws and regulations relevant to our business.

Regulation (Regulation (EU) 2016/679 (“GDPR”) ’.

The legal bases for which we may collect and process your personal information under the GDPR (where you are an EU resident) are set out and referred to in the section headed “How we use your information” above.

Will your personal information be subjected to automated decision-making?

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making under the following circumstances:

Where it is authorized by law

Where it is necessary to perform the contract with you and appropriate means are in place to safeguard your rights

With your explicit written consent and where appropriate means are in place to safeguard your rights.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes and request your express consent.

Data-sharing / Third Parties

We may share your Personal Information with third parties where it is required by law, where it is necessary in order to administer the working relationship with you or when we have another legitimate interest in doing so. Third parties include third-party service providers (including contractors and designated agents) and other entities within our group.

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our practices. We do not allow any third party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes in accordance with our instructions.

Where you are an EU resident please note that we may transfer the personal information we collect about you to countries outside the EEA. There is not an adequacy decision by the European Commission in respect of those countries which means they are not automatically deemed to provide an adequate level of protection for your personal information.

To ensure your personal information does receive an adequate level of protection we have accordingly put in place relevant appropriate measures to require those third parties to treat your personal information in a way that is consistent with and which respects the relevant laws on data protection.

The period for which data is stored

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for including for the purposes of satisfying any legal, accounting, regulatory or other reporting requirements.

The data protection principles

When we process your personal information we will apply the core principles of the GDPR to ensure it is:

Used lawfully, fairly and in a transparent way

Collected only for valid purposes that we have explained to you and not used in any way that is incompatible with those purposes

Relevant to the purposes we have told you about and limited only to those purposes

Accurate and kept up to date

Kept only as long as is necessary for the purposes we have told you about

Kept securely.

Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or wrongly disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a legitimate business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and we will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Your Rights

Under certain circumstances you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you (but only in certain circumstances) to ask us to delete or remove personal information where there is no good reason for us continuing to process it.

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

Request that we transfer your personal information to a third party.

If you want to seek to review, verify, correct or request erasure of your personal information, object to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact websiteterms@pfm.com.

Where processing of your personal information is based not on a legal basis but on you having provided for consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time by contacting websiteterms@pfm.com.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the

information (or to exercise any of your other rights).

Raising a complaint

If you are unhappy with the way in which your personal information has been processed you may wish in the first instance to

If having contacted us you remain dissatisfied you have the right to address your concern directly to the UK Data Protection

Authority, as follows:

The Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel. (0303) 123 1113