Website Privacy Notice

UPDATED ON NOVEMBER 02, 2023

Pantheon Mining (collectively referred to us “We” or the ‘’Company’’) is the controller and responsible for your personal data. We respect your privacy and commit to protecting it through our compliance with the practices described in this notice.

This notice describes our practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you
visit our website (our “Website”).

The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We do not control these third-party websites, and we encourage you to read the privacy notice of every website you visit.

This website is not intended for children and we do not knowingly collect data relating to children.

Please read this notice carefully to understand our policies and practices for processing and storing your personal data. By engaging with our Website, you accept and consent to the practices described in this notice. This notice may change from time to time. Your continued engagement with our Website after any such revisions indicates that you accept and consent to them, so please check the notice periodically for updates.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

DATA WE MAY COLLECT ABOUT YOU

We collect and use different types of data from and about you including:

• Personal and contact data that we could reasonably use to directly or indirectly identify you, such as your name, date of birth, gender, postal address, email address, billing address, telephone number, Telegram user name or other similar identifier (”personal data”).
• Financial and Transaction Data includes bank account and payment card details, details about payments to and from you and other details of products and services you have purchased from us.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, or operating system and platform.
• Non-personal data that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, statistics, or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Website feature.
• Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream information to, through, and from our Website (including date and time), products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from the page.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

HOW WE COLLECT DATA ABOUT YOU

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us information about you by filling in forms or by corresponding with us by phone, email or otherwise. This includes information you provide when you create an account, subscribe to our service, search for a product, place an order or participate in discussion boards or other social media functions on our Website, enter a competition, promotion or survey and when you report a problem with our Website.
• Automated technologies or interactions. As you interact with our Website, we may automatically collect technical data about your equipment, browsing actions and patterns as specified above. We collect this information by using cookies, and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We may receive information about you from third parties including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, data brokers, or aggregators.
• User contributions. You also may provide information for us to publish or display (”post”) on public Website areas or transmit to other Website users or third parties (collectively, “User Contributions”). You submit User Contributions for posting and transmission to others at your own risk. Although, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of any Website users with whom you choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.

Cookies and Automatic Data Collection Technologies

Our Website uses cookies (small files placed on your device) or other automatic data collection technologies to distinguish you from other Website users. This helps us deliver a better and more personalized service when you browse our Website. It also allows us to improve our Website by enabling us to:

• Estimate our audience size and usage patterns.
• Store your preferences so we may customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, certain parts of our Website may become inaccessible and certain features may not work correctly. Unless you adjust your browser settings to refuse cookies, our system will issue them. For detailed information on the cookies we use and the purposes for which we use them, see our cookie policy

Our Website pages and emails may contain web beacons (small transparent embedded images or objects, also known as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or email readers, or to compile other similar statistics such as recording Website content popularity or verifying system and server integrity.

HOW WE USE YOUR PERSONAL DATA

We use your personal data to provide you with products, offer you services, communicate with you, deliver advertising and marketing, or to conduct other business operations, such as using data to improve and personalize your experiences. Examples of how we may use the personal data we collect include to:

• Present our Website and provide you with the information, products, services, and support that you request from us.
• Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or comply with legal requirements.
• Fulfil the purposes for which you provided the data or that were described when it was collected.
• Notify you about changes to our Website, products, or services.
• Ensure that we present our Website content in the most effective manner for you and for your computer.
• Administer our Website and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
• Improve our Website, products or services, marketing, or customer relationships and experiences.
• Enable your participation in our Website’s interactive, social media, or other similar features.
• Protect our Website, employees, or operations.
• Measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you;
• Make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.

We may also use personal data to contact you about goods and services that may be of interest to you. If you do not want us to use your data in this way, please check the relevant box located on the form where we collect your data.

We may use personal data to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal data for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may use non-personal data for any business purpose.

DISCLOSURE OF YOUR PERSONAL DATA

We may share your personal data with:

• Any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, and our affiliates.
• Business partners, suppliers, service providers, sub-contractors, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization).
• Third parties to market their products or services to you if you have consented to these disclosures.
• Advertisers and advertising networks that require the data to select and serve relevant ads to you and others. We do not disclose data about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in a specific location). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
• Credit reference agencies when required to assess your credit score before entering into a contract with you.
• To fulfil the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website, we will transmit the contents of that email and your email address to the recipients.
• For any other purposes that we disclose when you provide the data.
• With your consent.With your consent.

We may also disclose your personal data to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• To a buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the personal data we hold.
• To comply with any court order, law, or legal process, including responding to any government or regulatory request.To comply with any court order, law, or legal process, including responding to any government or regulatory request.
• To enforce or apply our terms of use and other agreements.
• To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.

We may share non-personal data without restriction.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

CONSENT TO PERSONAL DATA TRANSFER

We are based in the Netherlands. We may process, store, and transfer the personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own.

Whenever we transfer your personal data out of the Netherlands, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the Netherlands which give personal data the same protection it has in the Netherlands.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the Netherlands.

By submitting your personal data or engaging with our Websites, you consent to this transfer, storing, or processing.

YOUR PERSONAL DATA USE CHOICES

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

• Promotional Offers from the Company. If you do not want us to use your email address or other contact information to promote our own products and services, or third parties’ products or services, you can opt-out by checking the relevant box located on the form where we collect your data or at any other time by logging into the Website and checking or unchecking the relevant boxes to adjust your account profile’s user preferences, or by sending us an email with your request to info@pantheonmining.com. You may also opt-out of further marketing communications by replying to any promotional email we have sent you or following the opt-out links on that message.
• Third-Party Advertising. If you do not want us to share your personal data with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form where we collect your data. You can also always opt-out by logging into the Website and checking or unchecking the relevant boxes to adjust your account profile’s user preferences, or by sending us an email stating your request to info@pantheonmining.com.
• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by checking the relevant box located on the form where we collect your data. You can also always adjust your user advertising preferences in your account profile by checking or unchecking the relevant boxes, or by sending us an email stating your request to info@pantheonmining.com.

Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates, or include plug-ins enabling third-party features. If you follow a link to any third-party website or engage a third-party plug-in, please note that these third parties have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these third parties.

ACCESSING AND CORRECTING YOUR PERSONAL DATA

You can access, review, and change your personal data by logging into the Website and visiting your account profile page.

You may also send us an email at info@pantheonmining.com to request access to, correct, or delete personal data that you have provided to us. We may not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or negatively impact the information’s accuracy.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or because other Website users may have copied or stored them.

DATA SECURITY

The security of your personal data is very important to us. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to take care when providing information in public areas of the Website like message boards, which any Website visitor can view.

DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
‍
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Your rights include:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact vie email: info@pantheonmining.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

CHILDREN’S ONLINE PRIVACY

We do not direct our Website to minors and we do notknowingly collect personal data from children under 18or as defined by local legal requirements. If we learn we have mistakenly orunintentionally collected or received personal data from a child withoutappropriate consent, we will delete it. If you believe we mistakenly orunintentionally collected any information from or about a child, please contactus at info@pantheonmining.com.

CHANGES TO OUR PRIVACY NOTICE

We will post any changes we may make to our privacy notice on this page. If the changes materially alter how we use or treat your personal data we will notify you by email to the primary email address specified in your account or through a notice on the Website home page. Please check back frequently to see any updates or changes to our privacy notice.

CONTACT INFORMATION

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Email address: info@pantheonmining.com