Pattons Privacy Policy

We at Pattons Inc. (“Pattons”/“we”/“us”) respect the privacy of every person and company and we place great importance towards the protection of your data which is collected by us. We want you to feel secure while we have your data with us.

We implement reasonable administrative, technical, and physical safeguards to protect your personal information from unauthorized access, disclosure, or misuse. We ensure, as far as practicable, that the data is not subject to unauthorised access and unlawful disclosures.

By using this site or our services, you acknowledge that you have read and agree to this Privacy Policy.

This privacy policy is adopted by Pattons Inc. and applies to all personal information collected in the United States and globally.

This policy will enable you to understand:-

1. What is Personal Data/Information & Sensitive Personal Data/Information?

2. How do we process your information

3. What type of data do we collect?

4. For what purpose do we collect/process data?

5. How do Pattons Inc and its subsidiaries secure your data?

6. Where can your data be processed?

7. Will your data be disclosed/shared with any third parties?

8. How long will we preserve your data?

9. What rights do you have with regard to data processing?

10. Is your information is transferred internationally?

11. How can you deal with any issues?

12. How do we manage a data breach?

13. How are disputes resolved?

14. What kind of internet privacy do we provide?

15. How can this policy be changed?

16. How to contact us.

17. When was this policy last updated?

1. What is Personal Data/Information & Sensitive Personal Data/Information?

“Personal Data” or “Personal Information” means any data/information relating to an identified or identifiable natural person that can directly or indirectly identify that person, either alone or in combination with other data held by Pattons Inc.

2. How do we process your information

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

3. What type of data we collect?

The categories of your data including Personal Data/Information, and/or Sensitive Personal Data/Information that Pattons Inc processes for the purposes of operating its business are outlined below:

a) Personal Data/Information collected directly from you

Pattons Inc generally collects Personal Data/Information, and/or Sensitive Personal Data/Information directly from you (electronically, in writing) by way of, among other things, agreement, website forms and messages addressed to us. You may also occasionally provide new, or updated or corrected Personal Data/Information and/or Sensitive Personal Data/Information to Pattons Inc from time to time. Personal Data/Information, and/or Sensitive Personal Data/Information we process will include the following:

i. Personal details, such as name, contact details including address, mobile/telephone number, company/employer/previous employer, as relevant, e-mail address;
ii. In respect of Customers & Suppliers-Other customer/supplier details, such as username, password, fax number, job title/function, contact person, Pattons Inc account number;
iii. Other supplier, customer or partner details, such as invoice data, including invoice mailing address, contact name, bank account details, description of work or scope of services and associated information made available for the payment of invoices;
iv. Customer preferences, such as product preferences or interest, purchase history, distribution channel used, financial information;
v. Your enquiries and our responses, which may contain Personal Data/Information, and/or, Sensitive Personal Data/Information;
vi. Transaction data, such as when you purchase a product or service from us; and
vii. Customer service, warranty or other claims.

b) Personal Data/Information automatically collected from your device

Pattons Inc collects certain Personal Data/Information directly from your device, when you visit our website:

i. Device and browser information: We may collect information about your computer and/or device, including device type, IP addresses, Internet Service Provider, device identifier, and operating system.
ii. Location data: If you have enabled access to your location on your mobile device, we may collect location information, including precise and imprecise location derived from your IP address.
iii. Information and statistics on site usage: We use cookies to collect information about your use of our website, including content viewed or downloaded, time spent on pages, links clicked, features used, and dates and times of interactions.
For further details concerning the above, including how to disable these technologies, please see the cookie policy available in our website.

c) Personal Data/Information Pattons Inc collects from third parties

i. Pattons Inc collects certain Personal Data/Information directly from third parties who provide services to Pattons Inc or carry them out on our behalf, such as payment services providers or website management providers.
ii. In certain cases, Pattons Inc receives Personal Data/Information from third parties who provide services to Pattons Inc for the purposes described below. Such parties include social networks that you use to connect with us, such as LinkedIn. We may also receive data from third party service providers such as recruiters who may send us candidates’ profiles and data, or providers who perform personality tests on candidates.

Providing your Personal Data/Information or Sensitive Personal Data/Information, as relevant, is voluntary and while there is no obligation for you to do so, we will be required under law to request certain types of data. If you are not able to provide certain data, then you may not be able to use some systems which require such data. You will remain solely responsible for the content of any submissions made to this site by way of comments/suggestions or otherwise and such submissions will become the exclusive property of Pattons Inc.

In the event you are giving us data of any other person/s as reference, then it is your responsibility to make that person aware of the provision of their information to Pattons Inc and its subsidiaries.

4. For what purpose do we collect/process data?

a) Pattons Inc. processes your Personal Data/Information, and/or Sensitive Personal Data/Information, in accordance with applicable law, for the following purposes:

i. Performing our contract with you, for instance, by providing our goods and services to you or in connection with your employment with us;
ii. Enabling our distributors, suppliers, and service providers to perform certain functions on our behalf, including payment processing, logistical or other functions, as may be necessary to fulfill your orders;
iii. Sending you newsletters or marketing communications to inform you of our products and services, which we consider may be of interest to you;
iv. Responding to your questions and communications with you, for example if you have left your contact details on our website, so that we can contact you;
v. Ensuring the security of our website, systems, and networks, including by preventing or detecting fraud or abuses, which includes the protection of intellectual property, trade, or business secrets;
vi. Improving our goods and services, for example, by reviewing visits to our website and monitoring the demand for specific goods and services;
vii. Carrying out other business operations, including invoicing, accounting, business networking, auditing transactions; and
viii. Complying with applicable laws, for example, in response to a request from a court or regulatory authority, where such request is made in accordance with the law.

b) The basis for processing your Personal Data/Information, and/or Sensitive Personal Data/Information for the purposes described above will include:

i. To perform a contract that we have in place with you or the company you represent;
ii. To protect and promote Pattons Inc.’s legitimate business interests, as outlined above;
iii. Because you provided us with your consent;
iv. For the establishment, exercise, or defense of a legal claim; or
v. For compliance with a legal or statutory obligation to which Pattons Inc. is subject.

c) Your rights under applicable privacy laws:

You may have rights, depending on your location and applicable law, including but not limited to:

i. The right to access the Personal Data/Information we hold about you;
ii. The right to correct inaccurate or incomplete Personal Data/Information;
iii. The right to request deletion of your Personal Data/Information, subject to certain exceptions;
The right to opt out of the sale or sharing of your Personal Data/Information (where applicable);
The right to restrict or object to certain data processing activities;
iv. The right to data portability; and
v. The right to withdraw consent at any time where processing is based on consent.

To exercise these rights or for more information, please see the “How can you deal with any issues?” section or contact us as described in this policy.

d) Means of collection

i. Pattons Inc. will collect Personal Data/Information, and/or Sensitive Personal Data/Information only by lawful and fair means.
ii. Pattons Inc. will collect Personal Data/Information, and/or Sensitive Personal Data/Information about an individual only from the individual unless:

A. the individual consents to the collection of the data/information from someone other than the individual; or

B. Pattons Inc. is required by or under a law, or court/tribunal order, to collect the information from someone other than the individual; or

C. it is unreasonable or impractical to do so.

e) Dealing with unsolicited Personal Data/Information

If Pattons Inc. receives Personal Data/Information, and/or Sensitive Personal Data/Information and it determines in accordance with applicable laws, that the data/information was not solicited correctly, it will destroy the data/information or ensure that the data/information is de-identified, if reasonable to do so.

5. How do Pattons Inc. and its group companies secure your data?

a) Pattons Inc. and its group companies aim to provide strong security mechanisms to protect your Personal Data/Information, including Sensitive Personal Data/Information. We have implemented reasonable administrative, technical, and physical safeguards designed to protect your data from loss, misuse, unauthorized access, alteration, and unlawful disclosure, in compliance with applicable U.S. laws and industry standards.

b) We regularly conduct internal audits on our data protection systems and also conduct external audits through independent third-party audit agencies to ensure effectiveness of our security controls.

c) Pattons Inc. and its subsidiaries have a dedicated technical and compliance team to maintain the security of data, and we regularly update our security systems to address emerging threats and vulnerabilities.

d) We also review our privacy policy regularly, and maintain various procedures, employee training programs, and internal policies to ensure our employees and contractors secure your data responsibly.

e) Pattons Inc. will take reasonable steps to ensure that Personal Data/Information, and/or Sensitive Personal Data/Information it collects is accurate, up to date, and complete. We also ensure that the data used or disclosed for the purposes it was collected for, is accurate, up to date, complete, and relevant.

6. Where can your data be processed?

Pattons Inc. is a global company with operations spread across the globe. Processing of data is always done in a systematic and secure manner.

a) Mostly, processing happens in the respective country or city itself, but some circumstances or legal provisions require transfer of your Personal Data/Information, and/or Sensitive Personal Data/Information to a third party in countries outside the country in which it was originally collected for further processing.

b) In particular, only when required, your Personal Data/Information, and/or Sensitive Personal Data/Information may be transferred throughout the Pattons Inc. group of companies located abroad. You can find locations of our global affiliates in our annual report available on our website. Intra-group transfers of Personal Data/Information, and/or Sensitive Personal Data/Information to recipients in countries that do not have the same level of protection as your home jurisdiction are governed by legally recognized safeguards such as Standard Contractual Clauses (SCCs), or other applicable lawful mechanisms.

c) In rare circumstances where your Personal Data/Information and/or Sensitive Personal Data/Information is transferred to our outsourced service providers located outside the country in which you reside , we will, where required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organizational, contractual, or other lawful means. In particular, we take measures to help protect your Personal Data/Information and/or Sensitive Personal Data/Information when it is transferred internationally.We rely on European Commission adequacy decisions about certain countries, as applicable (see here).Other measures include having standard clauses approved by the European Commission (see here) in our contracts with third parties that receive information outside the EEA or using other acceptable data transfer mechanisms This may include compliance with laws such as The Indian Information Technology Act, 2000 and The Information Technology Rules, 2011 of India, The Australian Privacy Act, 1988, Data Privacy Framework (EU-U.S. DPF) (see here) , Binding Corporate Rules (see here), approved Codes of Conduct and Certifications or, in exceptional circumstances, based on permissible statutory derogations.

d) Please contact Pattons Inc. at [email protected] for a copy of the safeguards we have put in place to protect your Personal Data/Information, and/or Sensitive Personal Data/Information and your privacy rights in these circumstances.

7. Will your data be disclosed/shared with any third parties?

Except as stated above, we do not share any data, including Personal Data/Information and/or Sensitive Personal Data/Information, with any third parties unless you have given explicit consent for such third parties to process your data and you have permitted us to disclose it to them. In certain circumstances, we may wish to disclose or may be compelled to disclose your Personal Data/Information, and/or Sensitive Personal Data/Information to third parties for the purposes described in this Privacy Policy. Such disclosure will only take place in accordance with applicable laws and for the purposes listed above. These scenarios may include disclosures:

a) to our affiliates or associated offices (for more information about Pattons Inc.’s affiliates and subsidiaries, please contact us at the address provided in Section 13 below);

b) to our outsourced service providers or suppliers to facilitate the provision of our goods or services, such as hosting service providers, IT system administrators and support services, online payment services, and customer services providers;

c) to third-party service providers and consultants, in particular providers of IT and server security services, in order to protect the security or integrity of our business, including our databases and systems, and for business continuity purposes;

d) to another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganization, change of legal form, dissolution, or similar event. In the case of a merger or sale, your personal data will be permanently transferred to a successor company;

e) to public authorities where we are required by law to do so, or to defend or enforce our rights, protect our property, assets, or ensure the safety of others;

f) Some links on our website may take you to Pattons Inc.’s social media pages located on platforms such as LinkedIn or others. These pages are governed by the privacy policies of the respective third-party platforms.

In compliance with applicable U.S. privacy laws, Pattons Inc. does not “sell” your Personal Data/Information as defined under the California Consumer Privacy Act (CCPA), nor do we share it with third parties for cross-context behavioural advertising without providing you the opportunity to opt out.

However, your Sensitive Personal Data/Information may be disclosed/divulged only with your prior explicit written consent, except in the scenario (e) stated above.

8. How long will we preserve your data?

We will preserve your data for as long as necessary to fulfil the purposes for which it was collected, including to comply with legal, accounting, or reporting requirements. We have management procedures in place for the maintenance of data, and after a reasonable period of time, the data will be deleted or securely anonymized, in compliance with applicable U.S. laws and internal retention policies.

a) We will delete your data once the business or employment relationship has ended, unless retention is required to comply with legal obligations, resolve disputes, enforce our agreements, or for other legitimate business purposes; and

b) We will retain the data if required to do so in accordance with our contractual or legal obligations, such as under tax, employment, or regulatory laws.

We may also retain minimal data for archival, audit, or legal defense purposes as permitted under applicable data protection laws.

9. What rights do you have with regard to data processing?

As a data subject, you have the following rights regarding the processing of your Personal Data/Information, and/or Sensitive Personal Data/Information:

a) The right to know and access Personal Data/Information: You can request access to the categories and specific pieces of Personal Data/Information that Pattons Inc. has collected about you, the purpose of collection, and the categories of recipients to whom such data is disclosed. You can also request basic information about third-party recipients by contacting [email protected].

b) The right to data accuracy: You have the right to review whether your data is accurate and request that we correct it if it’s incomplete or outdated.

c) The right to rectification: You can verify the correctness of the information and notify us of any errors so it can be updated or corrected.

d) The right to object to processing: You may object to the processing of your Personal Data/Information for specific purposes, particularly where we rely on a legitimate business interest or process your data for direct marketing.

e) The right to request deletion: You may request the deletion of your Personal Data/Information when it is no longer necessary for the purposes for which it was collected, subject to certain legal exceptions (e.g., regulatory compliance, fraud prevention).

f) The right to withdraw consent: You can withdraw any consent you previously provided at any time. This will not affect the lawfulness of data processing carried out prior to withdrawal.

g) The right to data portability: You can request a copy of your data in a structured, commonly used, and machine-readable format, and have the right to request transfer to another service provider or data controller, where technically feasible.

h) The right to restrict processing: You can request that Pattons Inc. limit or suspend processing of your Personal Data/Information in specific situations, such as pending a correction request or contesting the legality of processing.

i) The right to non-discrimination: Pattons Inc. will not discriminate against you for exercising your rights under applicable law or this Privacy Policy. However, if certain services rely on the use of your Personal Data/Information, restricting its use may affect functionality or availability.

To exercise any of the above rights, or for additional questions, please contact us at [email protected]. For California residents, you may also designate an authorized agent to make a request on your behalf in accordance with the CCPA.

10. How can you deal with issues?

In the event you have any concerns or issues regarding the processing or protection of your data, we encourage you to contact us so that we can address and resolve the issue promptly.

You can file a complaint with us at [email protected].

If you are a resident of certain U.S. states, such as California, Virginia, or Colorado, and are unsatisfied with our response, you may have the right to appeal our decision or file a complaint with your state Attorney General’s office.

11. Is your Information transferred Internationally?

We may transfer, store, and process your information in countries other than your own.

Our servers are located in with cloud service provider which may store your information in different countries. If you are accessing our Services from outside, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information.

If you are a resident in the US, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

12. How we manage a data breach

We are responsible for protecting the data we hold and we employ robust data protection systems, ongoing surveillance, employee training, and periodic audits of our information security practices. All personnel who collect, use, or manage Personal Data/Information at Pattons Inc. are expected to follow strict data protection procedures and are held accountable for protecting that data.

a) How can a data breach happen?

i. Hard copy files or records are left unattended, lost, or stolen;
ii. Laptops, tablets, phones, USB drives, or any portable devices containing personal or sensitive data are lost or stolen;
iii. Databases or systems are accessed by unauthorized users—either accidentally due to weak access controls or intentionally due to a cyberattack;
iv. Equipment or server failure;
v. Sensitive information is inadvertently sent or disclosed to the wrong person (e.g., via email, fax, or post);
vi. Physical damage to storage or IT infrastructure due to unforeseen events like fire, flood, or theft;
vii. Data is exposed through unauthorized viewing of phone screens or computer displays in public places.

b) In case of any data breach:

i. The employee or IT staff member who identifies the breach must immediately notify the Information Security Officer (ISO) and relevant department heads;
ii. The ISO will assess the breach and notify senior management, the data privacy officer, and, if required, law enforcement or regulatory authorities in accordance with applicable U.S. state or federal laws;
iii. We will also notify affected individuals without undue delay, if the breach is likely to result in harm, in accordance with breach notification laws (e.g., CCPA, state breach laws);
iv. A risk assessment will be conducted to determine the nature and impact of the breach, including the type and amount of data affected, whose data was involved, and whether it was a partial or full exposure;
v. We will attempt to recover lost data or remotely disable access to stolen devices where possible and take immediate steps to prevent a recurrence;
vi. If the breach is material or affects a large number of individuals, a public statement or press release may be issued;
vii. We will take any additional remediation steps necessary to reduce potential harm and document the entire breach investigation in accordance with applicable legal requirements.

13. How are disputes resolved?

Any queries or clarifications regarding Pattons Inc.’s compliance with this Privacy Policy should be directed to the address provided in Section 14. Pattons Inc. will make reasonable efforts to investigate and resolve any complaints or disputes regarding the use and disclosure of your Personal Data/Information and/or Sensitive Personal Data/Information in accordance with this Privacy Policy.

If a concern remains unresolved after direct engagement, Pattons Inc. agrees to participate in appropriate dispute resolution procedures under the laws of the United States or the relevant U.S. state in which the dispute arises. Where applicable, we will cooperate with state or federal data protection authorities, such as the California Privacy Protection Agency (CPPA) or the Federal Trade Commission (FTC), in resolving complaints.

Binding arbitration or mediation may be pursued only after exhausting other internal and administrative resolution channels. Any such process will be conducted in accordance with applicable laws and will be free of charge to you to the extent required by law.

14. What kind of Internet Privacy do we provide?

Pattons Inc. operates its websites to provide information concerning its products and services to the general public. We understand the importance of protecting the privacy of Personal Data/Information, and/or Sensitive Personal Data/Information collected through its websites. There is no legal requirement for the visitors to provide any data on our website. However, our website may not work without routing the required information essential for its functionality.Pattons Inc. collects Personal Data/Information, or Sensitive Personal Data/Information of visitors who voluntarily provide them by submitting online queries, feedback, requesting product/service information, or seeking job opportunities. Pattons Inc.may also collect technical dataabout your visit through the use of “cookies” or similar tracking technologies to improve your browsing experience and enhance site functionality. For more information about our use of cookies and your options to manage them, please refer to our Cookie policy on our website)

We may also collect data about your visit through the use of “cookies” or similar tracking technologies to improve your browsing experience and enhance site functionality. For more information about our use of cookies and your options to manage them, please refer to our Cookie Policy available on our website.

We do not sell your Personal Data/Information to third parties and comply with “Do Not Track” signals and other consumer choice mechanisms to the extent required under applicable U.S. law.

15. How can this policy be changed?

Pattons Inc. reserves the right to change, modify, or update this Privacy Policy at any time in accordance with applicable U.S. federal and state laws. Any material changes will be communicated by updating the “Last Updated” date below and, where required, by providing prominent notice on our website homepage or via email notification.

Please review our website periodically to stay informed of any updates to this Privacy Policy.

16. How to contact us

If you have any questions, comments, or requests regarding this Privacy Policy, please direct your request to: [email protected]

In accordance with applicable laws, individuals may have the option to remain anonymous or use a pseudonym when interacting with Pattons Inc., where lawful and practical. However, in most cases, we may require your full name and identifying details to process your inquiry, complaint, or request efficiently and appropriately.

17. When was this policy last updated?

This Privacy Policy is current as of [ September 01, 2025]. We may revise this policy from time to time. When we do, we will update this section with the new effective date and provide at least 14 days’ notice of material changes