Pairing Party Privacy Policy

The information we collect depends on how you use Pairing Party.

Account Information

We may collect:

• name;
• email address;
• account credentials;
• account identifiers;
• community membership or originating community;
• account creation date; and
• account status.

Profile Information

You may provide:

• first and last name;
• display name;
• headshot or profile photograph;
• city and state;
• biography;
• website;
• Blink card URL;
• LinkedIn URL;
• community/program memberships;
• time in a program;
• professional experience;
• strengths;
• skills;
• asset-type familiarity;
• business interests; and
• other profile information.

Some profile information is intended to be visible to other eligible Pairing Party participants.

Buyer Information

If you apply or participate as a Buyer, we may collect:

• markets in which you operate;
• asset types;
• areas of proficiency;
• business strengths;
• buy box information;
• work you want Members to perform;
• teammate preferences;
• experience requirements;
• team capacity;
• weekly availability;
• participation preferences;
• compensation information you choose to describe;
• preferred contact method;
• phone number and/or email address;
• consent regarding contact-information sharing;
• Buyer application and approval status; and
• Buyer Commitment acknowledgements.

Pairing Party Registration Information

When you join a Pairing Party, we may collect:

• the Pairing Party joined;
• participant role;
• eligibility information;
• registration responses;
• experience preferences;
• teammate preferences;
• Buyer selections;
• selection changes;
• pairing status;
• team assignment; and
• registration timestamps.

Training Attestations

We may collect records showing that you attested to completing required training, such as:

• Safety Training; and
• Module Zero where applicable.

These records may include the applicable requirement, text acknowledged, date, time, and associated Pairing Party.

Communications

If you use Platform messaging or other communication features, we may collect:

• messages;
• sender and recipient information;
• team information;
• timestamps;
• read/unread status;
• reports or moderation information; and
• related communication metadata.

Authorized administrators may access Platform communications where reasonably necessary for moderation, safety, support, dispute resolution, or Platform administration.

Contact Information Shared Through Pairings

Buyers may provide contact information to be shared with Members after a pairing is finalized.

We may collect and process the Buyer's consent regarding that sharing.

Private contact information is not intended to be displayed publicly in the Buyer marketplace.

Technical and Usage Information

When you use Pairing Party, we may automatically collect information such as:

• IP address;
• browser type;
• device type;
• operating system;
• pages or screens viewed;
• timestamps;
• referring or originating community;
• authentication activity;
• interactions with Platform features;
• error and diagnostic information; and
• security-related activity.

We may use cookies, local storage, or similar technologies as necessary to operate, secure, and improve the Platform.

We may use personal information to:

• create and manage accounts;
• identify community membership;
• determine eligibility for Pairing Parties;
• display appropriate Pairing Parties;
• create and maintain profiles;
• administer Buyer applications and approvals;
• administer Pairing Party registrations;
• operate the Buyer marketplace;
• enforce Buyer capacity;
• process Member selections;
• recommend or create pairings;
• administer teams;
• facilitate communication;
• share permitted contact information with paired participants;
• provide notifications;
• provide customer support;
• moderate the Platform;
• investigate misuse or safety concerns;
• prevent fraud and unauthorized access;
• maintain Platform security;
• troubleshoot technical problems;
• analyze and improve Platform functionality;
• maintain administrative and audit records;
• comply with legal obligations; and
• enforce our Terms of Service.

Pairing Party may use automated technology to recommend or create pairings between participants.

Depending on the applicable Pairing Party, matching may consider factors such as:

• geographic proximity;
• participating community;
• experience;
• strengths;
• skills;
• asset-type familiarity;
• stated business needs;
• work preferences;
• teammate preferences;
• Buyer requirements;
• Buyer capacity; and
• Member selections.

Automated matching is used to help organize participants and identify potentially appropriate pairings.

Administrators may review, modify, override, or manually create pairings.

We do not use automated matching to determine eligibility for employment, credit, housing, insurance, or another legally protected high-impact decision through Pairing Party.

Pairing Party is a networking and collaboration platform. Some information is therefore intended to be shared with other eligible participants.

Depending on your role and the applicable Pairing Party, other participants may see information such as:

• your name;
• headshot;
• city and state;
• community affiliation;
• biography;
• strengths;
• skills;
• experience;
• asset types;
• professional links;
• business interests;
• Buyer needs;
• buy box;
• teammate preferences; and
• other information designated for participant visibility.

The Platform is designed so private Buyer phone numbers and email addresses are not publicly displayed in the marketplace.

When pairings are finalized, Members and Buyers assigned to the same team may receive additional information necessary to collaborate.

This may include:

• team roster;
• work instructions;
• resources;
• business information;
• Buyer contact information where sharing was authorized; and
• other team-specific information.

Please use information received through Pairing Party only for legitimate community and collaboration purposes.

We may disclose personal information as described below.

To Other Pairing Party Participants

We disclose information necessary to provide profiles, marketplace functionality, pairings, teams, and communications as described in this Privacy Policy.

Within NRE 2 and Participating Programs

Authorized personnel may access information where reasonably necessary to administer Pairing Party, participating communities, member support, safety, or related programs.

To Service Providers

We may use vendors that provide services such as:

• cloud hosting;
• database infrastructure;
• authentication;
• file storage;
• application development;
• analytics;
• security;
• communications; and
• technical support.

These providers may process information on our behalf to provide their services.

For Legal and Safety Reasons

We may disclose information when reasonably necessary to:

• comply with applicable law or legal process;
• respond to lawful governmental requests;
• protect rights or property;
• investigate fraud or misuse;
• enforce agreements; or
• protect the safety of users or others.

Business Transactions

If NRE 2 is involved in a merger, acquisition, financing, reorganization, sale of assets, or similar transaction, information may be transferred as part of that transaction subject to applicable law.

NRE 2 does not sell Pairing Party participants' personal information for money.

Pairing Party is designed primarily as a member collaboration platform, not an advertising marketplace.

If our practices change or applicable law requires additional disclosures or choices regarding the sale or sharing of personal information, we will update this Privacy Policy and provide any legally required choices.

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• maintain accounts;
• operate current and historical Pairing Parties;
• preserve pairing and team history;
• provide support;
• maintain security;
• resolve disputes;
• maintain appropriate business records; and
• comply with legal obligations.

Retention periods may differ depending on the type of information and purpose for which it is maintained.

When information is no longer reasonably necessary, we may delete, anonymize, or otherwise dispose of it consistent with applicable law and our operational requirements.

We use administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

These safeguards may include authentication, database permissions, row-level security, access controls, and other security measures appropriate to the nature of the information processed.

No internet-based service can guarantee absolute security.

You are responsible for maintaining the confidentiality of your account credentials and promptly reporting suspected unauthorized account access.

Profile Information

You may be able to review and update certain profile information through your account.

Information intentionally included in your participant or Buyer profile may be visible to other eligible users as described in this Privacy Policy.

Buyer Contact Sharing

Buyers may control whether designated private contact information is shared with paired Members as provided through the Platform.

Pairing Party Participation

Participation in individual Pairing Parties is voluntary, subject to applicable community and Party requirements.

Communications

You may be able to manage certain Platform notification preferences.

Transactional, administrative, safety, pairing, team, and account-related communications may still be sent where reasonably necessary to provide the Platform.

California residents may have rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA"), if the law applies to NRE 2 and the applicable processing.

Depending on applicability and subject to legal exceptions, these rights may include the right to:

• know the categories and specific pieces of personal information collected;
• know the sources and purposes for collecting personal information;
• know the categories of third parties to whom personal information is disclosed;
• request deletion of personal information;
• request correction of inaccurate personal information;
• opt out of the sale or sharing of personal information where applicable;
• limit certain uses and disclosures of sensitive personal information where applicable; and
• exercise applicable privacy rights without unlawful discrimination.

To submit an applicable privacy request, contact: support@subto.com

Please include enough information for us to understand the nature of your request.

We may need to verify your identity before completing certain requests.

An authorized agent may submit a request where permitted by California law and subject to applicable verification requirements.

If NRE 2 does not currently meet the legal requirements that make a particular CCPA obligation applicable, we may nevertheless choose to honor certain privacy requests voluntarily.

Depending on how you use Pairing Party, we may collect the following categories of personal information:

Identifiers: such as name, email address, account identifiers, IP address, and potentially phone number.

Customer Records / Contact Information: such as contact details and account information.

Internet or Electronic Network Activity: such as Platform interactions, browser/device information, and authentication activity.

Geolocation Information: such as city and state provided by you and approximate location information that may be inferred from technical information.

Professional or Employment-Related Information: such as professional experience, skills, business information, markets, and areas of proficiency.

User-Generated Content: such as profile information, messages, instructions, registration responses, and resources.

Inferences: such as compatibility or matching assessments generated from information provided for Pairing Party matching.

We use these categories for the business and operational purposes described in this Privacy Policy.

Pairing Party is intended only for individuals who are 18 years of age or older.

We do not knowingly permit children under 18 to create Pairing Party accounts or participate in Pairing Parties.

If we learn that an ineligible minor has created an account, we may take steps to remove the account and associated information.

Pairing Party may contain links to websites, LinkedIn profiles, Blink cards, community platforms, or other third-party services.

Third-party services operate under their own privacy practices.

This Privacy Policy does not govern information independently collected by those third parties.

Pairing Party is operated from the United States.

If you access Pairing Party from outside the United States, your information may be processed and stored in the United States or other jurisdictions where our service providers operate, subject to applicable law.

We may update this Privacy Policy as Pairing Party evolves.

If we make material changes, we may provide notice through the Platform, email, or another reasonable method.

We will update the "Last Updated" date when this Privacy Policy changes.

Where required by law, we will obtain consent before using personal information for materially different purposes.

For questions about this Privacy Policy, Pairing Party's privacy practices, or to submit a privacy-related request, contact:

NRE 2, LLC

Email: support@subto.com