Last updated: January 20, 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. 

1. Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.

Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Pathtide Capital Group, Riverview Florida.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country refers to: Florida, United States

Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

Personal Data is any information that relates to an identified or identifiable individual.

Service refers to the Website.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Website refers to Pathtide’s Platform, accessible from http://pathtidefp.com

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

In this Privacy Policy, a User or You refers to any of the following;

• Registered Users
• Unregistered Users
• Active User

Registered User -Is an individual who creates accounts and may interact with Pathtide by Subscribing to Pathide’s sevices or not. 

Unregistered Users-  Is an individual who is a visitor to Pathtide’s platform, but yet to create an account

Active User- This is an individual or company who creates an account on Pathtide’s Platform, interacts and participate in Pathtide’s services either as an Issuer or Investor or Both.

You acknowledge and consent to our privacy practices as detailed below;

1. Privacy Context

The Privacy Policy applies to the Pathtide’s Platfrom (which includes websites, application and online services and other channels which includes, but not limited to the help center service.

Pathtide’s interaction with You will determine the applicability of this Privacy Policy to you and the information you share through Pathtide’s Platform.  In a nutshell, either you engage Pathtide directly, independently of a third-party and/or through a third-party whose services are directly accessible on Pathtide’s platform, this Privacy Policy would apply.

Any information that is processed by third-party which includes but not limited to;

Background Checks -This is a bad actor checks for a prospective issuer. 

Identity Verification (Know your customer)- This is an independent verification of an investor’s identity. 

Is the responsibility of that third-party service provider to protect your information. 

In case you have any questions on who is responsible to protect your information, please contact Us at Invest@ptcapgroup.com

1. Collecting and Using Your Personal Data

Types of Data CollectedPersonal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to;

Registered and Active Users- These are individuals who sign-up, create user account and then participate in the services of Pathtide’s information that may be provided includes.

• First name
• last name
• Email address
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Optional Demographic Information Including but not limited to; Gender, Race, Age, 
• Usage Data 

US and Non US Based Investors- These are Registered and Active users who have created account to participate in accessing investment opportunities while using Pathtide’s Platform . Pathtide may collect.

• Legal Name as written on the user’s valid means of ID. 
• Physical Address
• Email Address
• Phone Number
• Emergency Contact- Optional
• Tax ID or Social Security Number
• International Passport- This is to verify Non-US Based Investor’s Identity
• Means of ID to validate your Identity. This includes Permanent Residency Card (Green Card), US passport, Driver’s License, State of resident ID, 

Other Information includes but not limited to;

• Annual Income
• Net worth
• Questionnaire- Responses to questions to assess their risk appetite. This for informational purposes only and not to be construed as a means to 

Issuers – These are both Registered and Active users who have applied and intend to participate in the raising of capital.  Depending on the Pathtide service subscribes for, we may collect some information as follows;

• Key financial data
• Company formation Info
• Offering Info
• Questionnaire. Responses to questions before creating profile to guaage an Issuers readiness to raise capital on the Platform

1. Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

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2. Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
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4. Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, 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 a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies on the Free Privacy Policy website article.

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

• Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

• Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

1. Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.

• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
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• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

• To manage Your requests: To attend and manage Your requests to Us.

For other purposes: We may use data collected for data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our services.  

• Use of Investor and Issuers Information

• Verify and validate your identity and status. 

• Facilitate your payment and any escrow of funds.

• Record your investment with our third-party SEC registered agent.

• Provide you with necessary tax reporting tax reporting information.

• For other purposes such as data analysis, identifying usage trends, determining our effectiveness of our promotional campaigns and to evaluate and improve our services. 
  1. Use of Pathtide Event Attendee Information.

• Communicate the event details to you (Time, Venue, Speaker, Theme of the event)

• Confirmation of your event Registration

• Provide you with post event communication.

1. Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

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2. Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

1. Detailed Information on the Processing of Your Personal Data

Google Places

Google Places is a service that returns information about places using HTTP requests. It is operated by Google

Google Places service may collect information from You and from Your Device for security purposes.

The information gathered by Google Places is held in accordance with the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/

1. California Consumer Privacy Act

Any California resident is subject to the provision of the California Privacy Rights Acts (CPRA) which builds on the Consumer Privacy Act (CCPA), and the amendment of  California . This provision secures the Californian residents the following rights.

Right to Know – You have a right to know about your personal information Pathtide’s collect through our platform and also see what kind of information, how it used

The categories of personal information it has collected about that consumer.

The categories of sources from which the personal information is collected.

The business or commercial purpose for collecting. 

The specific pieces of personal information it has collected about that consumer.

Right to Access and Deletion- You have the right to request that Pathtide delete any personal information about you that Pathtide has collected from you. Moreso, there are exceptions under which we may retain your Personal Information and where we are not required to delete your Personal Information.

Right to Correction – You shall have the right to request  that maintains inaccurate personal information about the consumer correct such inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.

Disclosure not to share Opt-in data– Pathtide Capital Group shall at anytime never sell or share your personal information about you to third parties under any circumstances. Your personal information shall be protected and kept in strict confidence. 

SMS/text messaging opt-in data and consent will not be shared with or sold to any third parties for marketing or messaging purposes under any circumstances. This includes phone numbers and agreement to receive SMS/text messages—Pathtide Capital Group will never transfer this information to any other party.

This includes phone numbers and agreement to receive SMS/text messages—Pathtide will never transfer this information to any other party.

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2. Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

1. Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

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2. Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

1. Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: Invest@ptcapgroup.com