Website and Mobile Privacy Notice

Nightwing Group, LLC, otherwise described as “Nightwing” is responsible for this website, including its mobile versions, and we are committed to respecting the privacy of visitors. Nightwing has implemented technical, administrative and physical measures to safeguard any personal information that we may collect.

This Privacy Notice describes our practices related to personal information collected through Nightwing websites, including mobile versions, unless there is a separate privacy notice for the website or mobile version.

Nightwing has three other privacy notices:

• The General Privacy Notice covers personal information that Nightwing may collect and process separate and apart from its websites and mobile versions. This covers contractors, dependents of employees, and others whose data we may collect or receive outside of this website.

• The Employee Privacy Notice covers personal information that Nightwing may collect and process of its employees.

• The Job Applicant Privacy Notice If you apply for a job through our Careers section, Nightwing's use of the personal information you provide is governed by Nightwing Job Applicant Privacy Notice.

For this privacy notice, Nightwing defines personal information as any data that relates to an identified or identifiable person.

Does this Notice apply to all Nightwing Websites?

This Privacy Notice applies to visitors of Nightwing websites that link to this specific Privacy Notice. Individual websites for Nightwing entities, services and products may adopt different privacy notices because the transactions taking place on those websites may be different. If an Nightwing website has its own privacy notice, the provisions of that notice apply to that website.

What personal information does Nightwing collect?

Information collected through our website analytics in the US only: Nightwing monitors user traffic patterns throughout the website according to a user’s domain name, browser type, date and time of access, and pages viewed. This information is collected in order to measure the number of visitors to our website and to determine which areas users find useful based upon the traffic to particular areas. Nightwing uses this information to enhance visitors’ experience and to better prepare future content based on the interests of visitors. Note that these analytics are only used for visitors from US locations.

Information collected directly from you: A visitor to our website may be asked to provide personal information to receive a response or some other service from Nightwing. The personal information that you may be requested to provide includes your name, email address and any information that you choose to provide. The collection of information will be transparent to you – you will be asked for it and will have the opportunity to decide whether or not to provide it. If you choose not to provide any of the personal information requested, Nightwing may be unable to complete the transaction you have requested.

Your mobile provider may have a conflicting privacy position that captures personal information when you visit our website. Nightwing is not responsible for and does not control how other parties may collect your information when you access our website(s).

How does Nightwing use the personal information it collects?

We may use your personal information for the following purposes, as well as for any other purpose to which you consent or is required by law:

• conduct basic business operations, such as communicate with customers and business planning;

• provide investor services;

• provide the information, item or service you have requested;

• communicate with you about products, services and events relating to Nightwing, to the extent that you have requested such communications and with the opportunity to opt-out;

• improve our products, services and websites;

• verify your identity to ensure security for one of the other purposes listed here;

• respond to a legitimate legal request from law enforcement authorities or other government regulators;

• investigate suspected or actual illegal activity;

• support the sale or transfer of all or a portion of our business or assets (including through bankruptcy); and/or

• conduct investigations to ensure compliance with, and comply with, legal obligations.

Information that individuals submit to express interest in, or be considered for, an employment opportunity with Nightwing is covered by the applicable Job Applicant Privacy Notice (see above for more information).

Your personal information will be used with your consent or to fulfill a legal obligation, and, in locations that permit it, for a legitimate interest.

Where does Nightwing store your information?

Nightwing may transfer your information from one legal entity to another or from one country to another in order to accomplish the purposes listed above. We will transfer your personal information consistent with applicable legal requirements and only to the extent necessary for the purposes set forth above.

Nightwing relies on available legal mechanisms to enable the legal transfer of personal information across borders and ensure an adequate level of protection, as required by law. To the extent that Nightwing relies on the standard contractual clauses (also called the model clauses) to authorize transfer, Nightwing will comply with those requirements, including where there may be a conflict between those requirements and this Notice.

Does Nightwing use your personal information to contact you?

Nightwing does not use the personal information collected on this website to contact you except in response to a direct inquiry or if you register for communications on this site.

Does Nightwing share the information it collects with any third parties?

Nightwing may share your Personal Information with our subsidiaries and affiliated companies. When Nightwing transfers your Personal Information, it will do so consistent with applicable law.

In addition, Nightwing may provide access to or share Personal Information on an as-needed basis with third parties, such as trusted service providers, consultants and contractors who are granted access to Nightwing facilities or systems, and with government agencies and others as required by law. Nightwing will only share your information to:

• allow service providers Nightwing has retained to perform services on our behalf. In those cases, Nightwing will only share the information with service providers for the purposes outlined above. The categories of service providers with which Nightwing may share your Personal Information include (and only where applicable): companies that may provide you with requested information (such as a public filing); outsourced digital technology providers; and service providers offering software as a service. These service providers are contractually restricted from using or disclosing the information except when it is necessary to perform services on our behalf or to comply with legal requirements;

• comply with legal obligations, including but not limited, to complying with tax and regulatory obligations, sharing data with labor/trade unions and works councils, and responding to a court proceeding or a legitimate legal request from law enforcement authorities or other government regulators;

• investigate suspected or actual policy, ethics, or compliance violations or illegal activity;

• prevent physical harm and protect human safety; or

• support the sale or transfer of all or a portion of our business or assets, including through bankruptcy.

Your personal information may also be maintained and processed by our service providers in countries other than the one in which it was collected.

How long does Nightwing retain personal information?

Nightwing will retain personal information as long as needed to comply with its contractual and legal obligations. If the personal information is not subject to contractual or legal obligations, Nightwing will retain the data for as long as is required for the original purpose for which it was collected.

How does Nightwing use cookies or other tracking technologies?

Nightwing uses cookies on this website. Cookies are small text files sent to and stored on users’ computers that allow websites to recognize repeat users, facilitate users’ access to websites and allow websites to compile aggregate data that will allow content improvements. Cookies do not damage users’ computers or files. If you do not want cookies to be accessible by this or any other Nightwing website, you should adjust the settings on your browser program to deny or disable the use of cookies. The cookies that Nightwing uses on this site do not identify you. The cookies simply provide Nightwing with aggregate, anonymous analytics about the number of people visiting particular pages on this website.

This website may also use web beacons. A web beacon is usually a pixel on a website that can be used to track whether a user has visited a particular website to deliver targeted advertising. Web beacons are used in combination with cookies, which means that, if you turn off your browser’s cookies, the web beacons will not be able to track your activity. The web beacon will still account for a website visit, but your unique information will not be recorded.

Nightwing may also use cookies and similar technology placed by one of our business partners to enable Nightwing to learn which advertisements bring users to our website. For more information about cookies and other tracking technologies, click here.

What should you understand about the third-party links that may appear on this website?

In some instances, Nightwing may provide links to non-Nightwing controlled websites, which Nightwing will make reasonable efforts to identify as such. Nightwing does not control such third-party websites, and cannot be responsible for the content or the privacy practices employed by other websites.

What additional information should specific users know?

Parents, guardians and children: This website is intended for visitors who are at least 18 years of age and the minimum age for legal consent in their jurisdiction of residence. Nightwing does not knowingly solicit information from, or market products or services to, children. If you do not meet the age requirements set out above, please do not enter your personal information on this or any other Nightwing website.

Residents of California:

California Shine the Light Law: California residents may annually request and obtain information that is shared with other businesses for their own direct marketing use within the prior calendar year. Nightwing does not share your personal information with other businesses for their own direct marketing use.

California Consumer Privacy Act: California residents have the right to

• request details about the personal information that we have about you, including the categories of information, the purpose for which we use it, with whom we share it, and specific information about what personal information we have about you;

• request that your data be deleted; and

• direct a company not to sell your data, but, since Nightwing does not sell personal information, this does not apply.

If you are a California resident not covered by the exclusions mentioned above and you would like to exercise your rights, you should contact Nightwing either by calling 1- (833) 840-5111 or visiting nightwing.ethicspoint.com. Please provide your name, a way for Nightwing to contact you (such as an email address or telephone number) so that we can respond to your request, information about the nature of your relationship with us (for example, are you a visitor to our website or a shareowner), and details about the action that you would like us to take. Based on your request, we will investigate to determine if we have any of your personal information. If we do have your personal information (other than that provided in your request), we will seek to verify your identity based on the personal information that we already have; the data we will request will depend on the nature of the personal information we have about you. Once we verify your identity, we will provide you with a response, indicating how we will satisfy your request or why we cannot comply with your request.

Residents of the United States: Nightwing does not collect Social Security Numbers through nightwing.us. Nightwing does, however, collect Social Security Numbers where required by law, such as tax and payroll purposes for its employees. When Nightwing collects and/or uses Social Security Numbers, Nightwing will take proper care by protecting confidentiality, limiting collection, ensuring access on a need-to-know basis, implementing appropriate technical safeguards and ensuring proper disposal.

How might Nightwing change this policy?

As Nightwing expands and improves this website, we may need to update this policy. If we make any significant changes to the policy, we will post a notice on our websites or contact you to inform you when required by law. By continuing to interact with us after the modified version of the policy has been posted, you are accepting the changes to the policy, subject to any additional requirements that may apply. We encourage you to review this policy on a regular basis for any changes. The date of the latest version will be identified at the bottom of the policy.

How can you contact Nightwing?

If you have any comments or questions or suggestions, please call 1- (833) 840-5111. If you wish to access, correct or update your personal information, or if you have questions about Nightwing’s privacy practices in general or a complaint, please call 1- (833) 840-5111.

Last updated: 1 April 2024