www.jpgaldaco.com (the “Website”) is a website operated by J.P. Galda & Co., LLC (“J.P. Galda & Co.,” “Company,” “we,” “us,” or “our”), a Pennsylvania limited liability company. J.P. Galda & Co. is a corporate securities and finance law firm providing legal services to public and private companies, including in connection with capital markets transactions, SEC compliance, and related corporate matters. As such, we are committed to protecting your privacy and handling your personal information transparently and securely.

This Privacy Policy describes how we collect, use, share, and protect personal information in connection with our Website and related services (collectively, the “Services”). This policy is incorporated into the J.P. Galda & Co. Terms of Use and complies with all applicable state and federal regulations.

By using our Website, you are consenting to be bound by this Privacy Policy. This policy sets out:

• What information we collect and why we collect it;

• How we use that information;

• Choices you have regarding the use of your personal information

A. Information We Collect

1. Categories of Personal Information

We may collect the following categories of personal information:

• a) Personal identifiers including legal name, business name, and entity information; email addresses and telephone numbers; physical and mailing addresses; government-issued identification numbers (SSN, tax ID, EIN, driver’s license number, passport number); account usernames and passwords; device identifiers and IP addresses; and customer and account numbers.

• b) Commercial information including records of services requested or considered, service transaction history, payment information (card numbers, bank account details, routing numbers), and credit and financial account information.

• c) Financial information including banking and payment account details, AML and KYC documentation (where applicable), website usage analytics and browsing behavior, search history and interaction data, log files and system access records, device and browser information, and cookies and similar tracking technologies.

• d) Geolocation data including general location derived from IP addresses and mailing addresses.

• e) Audio, visual, or similar information including recordings of phone calls (where legally permitted), video conference recordings, and photographs for identity verification.

• f) Inferences including client preferences, risk assessment profiles, fraud detection and security risk profiles.

2. Sensitive Personal Information

We may collect the following categories of sensitive personal information:

• a) Government identifiers, including Social Security numbers, driver’s license numbers, passport numbers, and tax identification numbers.

• b) Financial account access, including account log-in credentials combined with passwords or access codes.

• c) Communications contents, including contents of email, mail, and text messages (only when we are the intended recipient).

• d) Health information, including medical information related to account accommodations.

We limit the use and disclosure of sensitive personal information to specific business purposes described in Section B, below, unless you provide separate consent for additional uses.

3. Sources of Information

We collect personal information via:

• a) Direct collection such as through contact form submissions and inquiries, client service communications via phone, email, chat, or mail; surveys, feedback forms, and marketing preferences; document uploads for identity verification and compliance; and event registrations and newsletter subscriptions.

• b) Automatic collection such as through website and application usage via analytics tools, security monitoring and fraud detection systems, and marketing attribution tools; and cookies, web beacons, and similar tracking technologies.

• c) Third-party sources such as identity verification and background check services, credit reporting agencies and financial institutions, regulatory databases and government watchlists, business partners and referral sources, and social media platforms and public databases.

B. How We Use Your Personal Information

1.  We may use the information set out above to:

• a)  Create and manage your account or matter profile with us;

• b)  Verify your identity and protect against, identify, and prevent fraud and other unlawful activity, claims, and other liabilities;

• c)  Assist us in responding to your inquiries;

• d)  Provide J.P. Galda & Co. legal services and information to you;

• e)  Process your payments;

• f)  Communicate with you about, and administer your participation in, special events, programs, offers, surveys, and market research;

• g)  Operate, evaluate, and improve our business, including developing new services;

• h)  Comply with and enforce applicable legal requirements, relevant professional conduct rules, contractual obligations, and our policies; and

• i)  Other purposes in respect of which you will be notified at the time of collection.

When you contact J.P. Galda & Co., we may keep a record of your communication to assist us in ensuring that you get the best from our services.

C. How We Share Your Personal Information

1. From time to time, we engage unaffiliated third parties and their affiliates, agents, and subcontractors, including social media platforms (“Service Providers”), to perform certain technological or administrative services. In some cases, a Service Provider will be collecting your personal information from other sources on our behalf to fulfill the purposes set out in Section B. We may also use a Service Provider to host and administer the Website, process and store data, and fulfill similar technology-related functions on our behalf. The personal information a Service Provider receives is limited to what is needed to render their service to us.

2. In certain cases, we may share some of the personal information we collect with carefully selected business partners, who are first required to sign an agreement obligating them to keep the information confidential and secure and prohibiting them from using it for unauthorized purposes.

3. We may disclose personal information without notice to you if a law, regulation, search warrant, subpoena, court order, or regulatory notice permits or requires us to do so. We may also disclose personal information without notice to you to prevent fraud or abuse, or to protect the rights, property, or personal safety of J.P. Galda & Co., its clients, employees, service providers, or the public.

4. J.P. Galda & Co. will treat as confidential all information it holds in relation to a client where that information is not in the public domain. Subject to this clause, J.P. Galda & Co. will not disclose such confidential information to third parties.

5. We will share your personal information with third parties only in the ways described in this Privacy Policy. We will not sell, rent, loan, trade, or lease any personal information collected, including application forms, financial data, or email addresses.

6. We may provide your personal information to companies that deliver services to help us with our business activities such as sending newsletters, social media advertising, or providing client service. These companies are authorized to use your personal information only as necessary to provide these services to us.

7. We will disclose otherwise confidential personal data and confidential information if we are compelled to do so by laws and regulations applicable to us and/or our agents, whether in the U.S. or elsewhere.

D. How We Communicate With You

1. Communications between you and J.P. Galda & Co. may be conducted via live chat, email, mail, phone, fax, text message, or by other online or electronic means. Any instructions that you give to us in any such manner will have the same legal effect as if you gave them to us in original written form. You agree that all telephone calls and electronic communications may be recorded and retained by us as a record of your instructions. You also agree that we may contact you electronically in response to a request, inquiry, or complaint, as otherwise solicited by you, or as permitted or required by law.

2. We may also communicate with you from time to time electronically about news, updates, and other information regarding J.P. Galda & Co. or its selected partners. If you wish to unsubscribe from marketing emails from J.P. Galda & Co., please contact info@jpgaldaco.com. We will strive to honor your request within 10 business days. Please note that this request will apply only to marketing emails and not to certain account-based or matter-related communications, which will continue to be sent as necessary.

E. Information Storage and Retention

1. We may process your personal information on servers located outside the country where you live. Wherever we process or store your personal information, we will, in addition to complying with all applicable laws and regulations in that jurisdiction, comply with this Privacy Policy.

2. Your information may also be processed by employees or consultants of the Firm who are located outside of the European Economic Area (“EEA”). By submitting your personal data, you agree to this processing, storing, and transfer.

3. We retain personal information only for as long as reasonably necessary to fulfill the purposes described in this policy, to comply with applicable professional conduct rules and record retention requirements, or as otherwise required by law.

4. If you have questions or comments about this Privacy Policy, please email us at info@jpgaldaco.com.

F. Cookies and Other Tracking Technologies

Log Files

1. As is true of most websites, but subject to your browser settings, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

2. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site, and to gather demographic information about our user base as a whole.

3. We do not link this automatically collected data to personally identifiable information.

4. We reserve the right to use a third-party tracking service, such as Google Analytics, which uses cookies to track aggregate, non-personally identifiable information about visitors to our site—such as number of visits, pages searched, and browser type—to improve our website and client experience.

Cookies

1. Cookies are small pieces of information placed in your computer’s memory when you visit a website. J.P. Galda & Co. uses cookies to recognize you as a repeat visitor, to identify your browser type, to track online patterns and preferences in order to better understand you as a visitor, and to improve the quality of the Website and our services.

2. It is always open to you to modify your web browser settings to prevent the placement of cookies or to notify you each time a cookie is set. The website www.allaboutcookies.org contains additional useful information on how to block or control cookies using different browsers. However, by blocking or deleting cookies, you may not be able to take full advantage of J.P. Galda & Co.’s services.

3. The Website may allow you to interact with plugins from social media sites such as Facebook, X (formerly Twitter), YouTube, Instagram, or other similar sites. In such cases, there may be a flow of your personal information between J.P. Galda & Co. and such social media sites. Your use of these plugins will be governed by each site’s privacy policy and not this Privacy Policy. We encourage you to become familiar with each site’s privacy and security practices before enabling such plugins.

4. Our website recognizes Global Privacy Control (GPC) signals. If your browser sends a GPC signal, we will automatically opt you out of non-essential tracking cookies where required by applicable law.

Remarketing

1. J.P. Galda & Co. may use remarketing services through its Website to advertise on third-party websites (including Google) to previous visitors to the Website.

2. Any data that we collect will be used in accordance with this Privacy Policy and any applicable third-party website privacy policy.

You can opt out of all third-party cookie advertising by visiting: http://www.networkadvertising.org/choices

G. Your Privacy Rights and Choices

1. You have the following rights regarding your personal information:

• a)  Right to Know (Access) You may request disclosure of personal information categories we have collected about you in the past 12 months; obtain specific pieces of information we have collected; learn about our data collection sources, business purposes, and sharing practices; and receive information about third parties with whom we share your personal information.

• b)  Right to Delete You may request deletion of personal information we have collected from you and receive confirmation of deletion or an explanation of legal exceptions that prevent deletion, understanding that deletion may result in your inability to access certain services offered by J.P. Galda & Co.

• c)  Right to Correct You may request correction of inaccurate personal information in our records (provided that proper documentation is submitted) and are entitled to confirmation that corrections have been made.

• d)  Right to Opt Out of Sharing You may opt out of the sharing of personal information for cross-context behavioral advertising. You may exercise these opt-out rights via the relevant link on our Website.

• e)  Right to Limit Sensitive Personal Information You may request that we limit our use and disclosure of your sensitive personal information to specific permitted purposes and restrict processing to what is necessary to perform requested services or ensure security.

• f)  Right to Non-Discrimination You are entitled to receive equal service and pricing regardless of your exercise of privacy rights. You shall not be denied goods or services or receive different prices or quality of services for exercising your privacy rights.

• g)  Do Not Track Our Website recognizes Global Privacy Control (GPC) signals and other browser-level opt-out signals to the extent required by applicable law. Please note that we do not otherwise respond to ‘Do Not Track’ signals at this time.

H. Children’s Privacy

Our Website is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If you believe that a child under 13 has provided us with personal information, please contact us immediately at info@jpgaldaco.com so that we may take appropriate steps to remove such information.

I. Security

1. We implement reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. These measures include, among others, encrypted communications, secure server infrastructure, and role-based access controls.

2. Notwithstanding the foregoing, no method of transmission over the Internet or method of electronic storage is 100% secure. Accordingly, you should not submit highly sensitive or confidential information through this Website. We encourage you to use secure and encrypted communication channels when transmitting sensitive materials to our firm.

J. Links to Other Sites

Content within our Website may include links to other sites not operated by us. If we link to an external site, it is a site we trust; however, we are not responsible for the content or privacy practices of any site not managed by our firm. We strongly advise you to review the privacy policies of any external websites you visit. We are not responsible for the privacy practices of third-party websites.

K. Attorney-Client Confidentiality Notice

This Privacy Policy governs the collection and use of personal information submitted through the Website only. It does not describe, alter, or supersede the attorney-client relationship, attorney-client privilege, or any professional duties of confidentiality owed by J.P. Galda & Co. to its clients under applicable rules of professional conduct, including Rule 1.6 of the ABA Model Rules of Professional Conduct and corresponding state rules. Nothing in this Privacy Policy should be construed as creating an attorney-client relationship or as legal advice. Unsolicited information submitted through the Website prior to the establishment of an attorney-client relationship may not be treated as confidential.

L. California Privacy Rights

California residents have the right to request a notice disclosing the categories of personal information we have shared with third parties for their direct marketing purposes during the preceding calendar year. To make such a request, please contact us at info@jpgaldaco.com. In addition, California residents have all the rights described in Section G above pursuant to the CCPA/CPRA.

M. Changes to This Policy

It may become necessary to change the terms of this Privacy Policy from time to time. We reserve the right to change this Privacy Policy as necessary to comply with law or for legitimate business purposes. By continuing to use J.P. Galda & Co.’s Website and services, you agree to be bound by updates to this Privacy Policy. Please check back frequently; you will be able to see if changes have been made by looking at the top of the Privacy Policy for the date it was last updated.

Contact Us

If you have questions, comments, or concerns about this Privacy Policy or our data practices, please contact us at:

J.P. Galda & Co., LLC
Email: info@jpgaldaco.com
Website: www.jpgaldaco.com