PATHFACTORY Data Privacy Framework Notice

LAST UPDATED AS OF March 11, 2025

PathFactory  Corp. (“PathFactory ”, “we”, “our” or “us”) has self-certified its compliance with the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce (collectively, the “Data Privacy Framework”). We have certified that we adhere to the Data Privacy Framework Principles regarding the collection, use, and retention of personal information transferred from the European Union, United Kingdom, and Switzerland to the United States in reliance on the Data Privacy Framework. Additional information, along with details of PathFactory’s self-certification, can be found at https://www.dataprivacyframework.gov.

1. Scope

PathFactory provides a software-as-a-service (“SaaS”) offering (the “Services”). PathFactory’s Data Privacy Framework certification applies to personal information that we collect and process in the provision of our Services or “Customer Personal Data” (as defined in the PathFactory Software-as-a-Service Terms of Service and/or the PathFactory Data Processing Addendum) originating from the European Union, the United Kingdom, and Switzerland, where the agreement with the customer stipulates a different transfer mechanism recognized by the relevant authorities (e.g., standard contractual clauses). The types of personal information that our customers upload and store in the Service is at their discretion (subject to any limitations in the applicable agreement) and we only process such information in accordance with the customer’s instructions, as set forth in the applicable agreement.

2. Inquiries & Complaints

You may direct any inquiries or complaints concerning our Data Privacy Framework compliance to privacy@pathfactory.com. PathFactory will investigate and attempt to resolve complaints within 45 days. If your inquiry or complaint is not resolved as it relates to PathFactory ’s compliance with the Data Privacy Framework, you may contact as applicable, the relevant EU Data Protection Authorities (DPAs), the UK Information Commissioner’s Office (ICO), or the Swiss Federal Data Protection Information Commissioner (FDPIC). PathFactory commits to cooperate and comply with the advice of the respective panel established by the EU DPAs, the ICO or the FDPIC with regard to unresolved complaints concerning our handling of personal information received in reliance on the Data Privacy Framework.

3. Disclosure Requests

PathFactory may be required to disclose personal information in response to lawful requests by public authorities, including national security or law enforcement requirements.

5. Onward Transfers

PathFactory is responsible for any of its third party agents to which we disclose personal information received under the Data Privacy Framework.

6. Enforcement

PathFactory’s compliance with the Data Privacy Framework is subject to the investigative and enforcement powers of the U.S. Federal Trade Commission.

7. Changes to this Notice

We may change this Notice from time to time. If we make any changes to this Notice, we will change the Last Updated date above. Please ensure you check this page from time-to-time for any updates.

8. How to Contact Us

If you have any questions about this Notice or our Data Privacy Framework certification, please contact us at privacy@pathfactory.com, by phone call to 416-304-9400 or mail to 1775 I St. NW, Suite 1150, Washington, DC 20006.