This Privacy Policy describes KTGY Group, Inc. (“KTGY”)’s policies and procedures on the collection, use and disclosure of your information when you use the KTGY’s websites and subdomains on ktgy.com (the “Website”) and tells you about your privacy rights and how the law protects you. We may collect your information when you become a Customer or when you contact us to obtain information (“Services”). As used herein the terms “you” or “your” shall apply to individual users of KTGY’s Website, while a reference to “we,” “us,” or the “Company” is a reference to KTGY and its relevant affiliates involved in the collection, use, sharing, or other processing of personal information.

1. Whose Personal Information We Collect

KTGY obtains information from various entities. These entities are defined below by what they are referred to in this Privacy Policy and when information is collected. Entities may overlap and are not exclusive categories.

• Website Visitors: When you visit our Website or contact us directly for information.
• Customers: When you contact us or engage in any version of our services.
• Vendors: When you contract with us to provide services on our behalf.

This Privacy Policy does not apply to the way we process information on behalf of our Customers. We process and safeguard information on behalf of our Customers in accordance with our agreements with our Customers. Our Customers may request more information about our processes and safeguards by emailing us at: contracts@ktgy.com.

Third Party Links and Websites. KTGY’s Website may link to third party websites. Please be aware KTGY is not responsible for the privacy practices of third-party websites you choose to visit. If you provide any information directly to parties other than KTGY, different rules may apply to the use or disclosure of that information. KTGY recommends you review the privacy policies of those third parties.

2. Personal Information We Collect

Information You Give Us. KTGY will collect and store your personal information when you interact with KTGY’s Website or Services. We collect information, some of which may contain personal information, by online applications as follows: you may voluntarily provide information, including personal information, to us by: (a) inputting information through KTGY’s Website; (b) emailing or calling KTGY about our Services, employment or internship opportunities, marketing, media requests, and other business matters; or (c) inputting information through our job postings hosted by third party software provider ADP.

The categories of information include:

• Identifiers, such as real name, postal address, unique personal identifier, online identifier, Internet Protocol (“IP”) address, email address, account name, or other similar identifiers.
• Categories of personal information described in Section 1798.80(e) of the California Civil Code, such as name, address, telephone number, education, employment, employment history.
• Commercial information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other electronic network activity information, such information regarding a consumer’s interaction with KTGY’s websites.
• Professional or employment-related information.
• Education information.

Information We Automatically Collect

• Website: Like many website operators, we collect information that your browsers sends whenever you visit our Website. This includes log data, such as your computer’s IP address, browser types, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, areas scrolled or clicked, and other statistics, and whether you reached our Website through a social media or email campaign. This information may be collected via several technologies, including cookies, web beacons, clear GIFs, canvas fingerprinting and other means, such as Google Remarketing. You can control cookies in your browser to enable or disable them. Learn more in our Cookie Policy.
• Services: Some of our Services will collect IP addresses, login credentials, connectivity details and locations. This is used for access control and management.

Information We Collect from Third Parties.  If you access our Website through third parties (e.g. Facebook or Google), or if you share content from our Website to a third-party social media service, the third-party service will send us certain information about you if the third-party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third-party service.

Information We Collect From the Public. We may also collect publicly available information concerning our clients through Internet searches, such as a LinkedIn or Google search.

3. How We Use Your Information

We do not sell personal information to others. We may use your personal information for the following purposes:

• To provide you with the services on our Website, which includes:
  • Providing customer service; and
  • Providing advertising or marketing services to you.
• To conduct market research.
• To detect security incidents, protect against fraud or criminal activity, debug and repair errors, and maintain the overall quality and safety of our Website.
• To share your website visitor activity, through website cookies, with third-party partners to market our Services on our Website and other websites that you may visit.
• To fulfill our legal and financial obligations.
• To provide you with employment opportunities.

KTGY uses this information to address your comments, questions, or KTGY may send you commercial or transactional emails as a result of your inputs. We may use your personal information to contact you with newsletters, marketing, or promotional material and other information that may be of interest to you.

You can opt-out of any or all marketing emails you receive from KTGY by using the unsubscribe information in the footer of any marketing email you receive, or you can contact us by using the “Contact Information” section below. Please note that even if you opt out of receiving the foregoing emails, KTGY may still send you a response to any requests you voluntarily input to KTGY’s Website or directly emailing KTGY, such as service-related messages otherwise concerning products and Services you have purchased (unless indicated otherwise).

4. How We Share Your Information

We may share your information with our third-party service providers that perform services on our behalf, in connection with a merger, sale, or other business transfer, or if required by law or to protect KTGY’s rights, or for other reasons.

Affiliates and Service Providers. We share your information with our third-party service providers and any subcontractors as required to offer you our Services. These service providers help us:

• Run, operate, and maintain our Website through third-party platforms and software tools;
• Perform content moderation and crash analytics;
• Run email campaigns;
• Perform marketing analytics;
• Provide measurement services and targeted ads (you can opt out of these services at websites such as http://www.aboutads.info/choices and http://www.youronlinechoices.eu); and
• Provide technical and customer support.

Some external service providers may also collect information directly from you in accordance with their own privacy policy.

Aggregated Data. We may also aggregate or otherwise strip information of all personally identifying characteristics and may share that aggregated, anonymized data with third parties or publish it. We reserve the right to make use of any such aggregated data as we see fit.

Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your personal information to comply with any legal obligation or to enforce or apply our terms and conditions and other agreements, to protect our rights, property, or safety, or to protect the rights, property or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

5. How We Respond to ‘Do Not Track’ Signals

Some browsers provide you with a way to signal that you do not want your browsing activity to be tracked. The Services may not currently respond to all Do Not Track (“DNT”) or similar signals, as we are awaiting consensus from the Internet policy and legal community on the meaning of DNT and the best way to respond to these signals.

6. Cookies

To make our Website and Services work properly, we sometimes place small data files called cookies on your device. Cookies are text files placed on your computer to collect standard internet log information and visitor behavior information. When you visit KTGY’s Website, KTGY may collect information from you automatically through cookies or similar technology. KTGY’s third party software linked to KTGY’s Website uses cookies to collect data about how you interact with KTGY’s Website.

Google Analytics and Lucky Orange. We may use Google Analytics and Lucky Orange analytics. We use the information we get from Google Analytics or Lucky Orange analytics only to improve the Website. We do not combine information collected through the use of Google Analytics or Lucky Orange Analytics with personally identifiable information. Please refer to Google’s Privacy Policy and Lucky Orange’s Privacy Policy for more information. You may also choose to download the Google Analytics opt-out browser add-on.

You may wish to restrict the use of cookies. Please be aware that some of the features of our Website may not function correctly if you disable cookies. Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful:

• Cookie settings in Chrome
• Cookie settings in Firefox
• Cookie settings in Microsoft Edge
• Cookie settings in Safari web and iOS

7. Privacy Rights & Additional Disclosures for Certain US Residents

Several jurisdictions grant state residents certain rights and disclosures. We provide the following information to further help you understand your potential privacy rights.

Right for Information or Deletion. Residents of certain U.S. states have the right to request details about the personal information we collect, use, and share. This may include whether we are processing personal information, and in some instances, you have the right to request that we disclose to you the categories listed below for the preceding 12 months. In responding to this right, we shall provide to you:

• The categories of personal information we collect about you.
• The categories of sources from which your personal information is collected.
• The business or commercial purpose(s) for collecting, selling, sharing, or disclosing your personal information, and the categories of personal information disclosed for such purpose(s).
• The categories of third parties with whom we share your personal information.
• The categories of personal information we have sold, if any, about you and the categories of third parties to whom your personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
• The specific pieces of personal information we have collected about you.

KTGY does not sell personal information.

Request for Correction. Residents of certain U.S. states have the right to request the correction or rectification of inaccurate information in the resident’s personal information.

Request for Portable Data. Residents of certain U.S. states have the right to receive, in certain circumstances, a portable format of their personal information that allows the data to be transmitted to another entity.

Opting Out of Cookies and Sale/Sharing Using Online Tracking Technologies. Residents of certain U.S. states may opt out by broadcasting an opt-out preference signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). To download and use the browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Do Not Sell or Share My Personal Information. Residents of certain U.S. states have the right to opt out of the sale or sharing of the consumer’s personal information. However, we do not sell your personal data, nor do we share your personal information to provide personalized or targeted advertising. If you have any questions or further comments on the matter, please reach out to us via the contact information at the bottom of this Privacy Policy.

Limiting the Use of Sensitive Personal Information. Residents of California have the right to direct us to use or disclose sensitive personal information only for providing goods or services, or as otherwise minimally permitted under applicable law. However, we do not use or disclose sensitive personal information for any purpose other than providing our goods and services to you, or as otherwise minimally permitted under applicable law.

Third Party’s Direct Marketing. If you are one of our Customers, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes. We do not disclose your personal information to third parties for third parties’ direct marketing purposes.

Automated Processing & Profiling. Residents of certain U.S. states have the right to opt out of the processing of personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.

Right to Equal Service & Price. You have the right to receive equal service and price, even if you exercise a privacy right.

Verification Process for Exercising Rights. To protect our consumers’ privacy, we verify privacy rights requests to ensure that only you (or your authorized agent) can exercise rights pertaining to your personal information. As part of our verification process, we may request you to submit additional information.

If you are an authorized agent wishing to exercise rights on behalf of a state resident, please contact us using the information at the bottom of this Privacy Policy and provide us with a copy of the consumer’s written authorization designating you as their agent. We may need to verify your identity and place of residence before completing your rights request.

Appeal Process. In certain cases, we may decline to take action on your request as permitted by law. Should we decline your request, we may provide you with a written explanation of the reasons for our decision and an opportunity to appeal the decision.

If we deny your appeal, we may provide a written explanation of our decision with instructions on how to contact your local Attorney General or Department of Justice for further review, where permitted under certain U.S. state privacy laws.

To exercise your rights, please contact us by emailing: contracts@ktgy.com, and specifying your request.

8. Privacy Rights & Additional Disclosures for EEA, UK, and Swiss Individuals

If you are from the European Economic Area (EEA), the United Kingdom (UK) or Switzerland, our legal bases for collecting and using your personal information is as follows:

• The performance of your contract, or to enter into the contract and take action on your requests. For example, to process your account information.
• Our legitimate business interests. For example, fraud prevention, maintaining the security of our network and Services, direct marketing to you, and improvement of our Services.
• Compliance with mandatory legal obligations. For example, accounting and tax requirements, which are subject to mandatory retention periods. We may also collect your personal information to record your requests to exercise your rights and to verify your identity for such requests.
• Consent you provide where we do not rely on another legal basis. Consent may be withdrawn at any time.
• In some limited cases, we may also have a legal obligation to collect personal information from you in response to lawful requests by public authorities, including to meet law enforcement requirements, as described above in the “How We Share Your Information” section.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided at the end of this Privacy Policy.

EEA, UK, or Swiss Individuals’ Rights. If you are from the EEA, UK, or Switzerland you have the right, under certain circumstances, to:

• Access your personal information;
• Correct inaccurate information in your personal information;
• Request erasure of your personal information without undue delay;
• Request restriction of, in certain circumstances, the processing of your personal information;
• Request receiving a portable copy of your personal information held by us, and to have that portable copy transmitted to another controller; and
• To object to the processing of your personal information.

To exercise any of these rights, contact us using the contact details provided at the end of this Privacy Policy, and please specify which privacy right(s) you wish to exercise. We may need to verify your identity to honor your request.

Right to Lodge a Complaint. If you have any issues with our compliance, you have the right to lodge a complaint with the appropriate supervisory authorities. We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry to us via the information in the Contact Information section at the bottom of this Privacy Policy.

9. Children’s Privacy

The Website is not directed at individuals under the age of 16. KTGY does not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If KTGY becomes aware that KTGY has collected personal information from anyone under the age of 16, KTGY will take steps to remove that information from KTGY’s servers.

10. Data Security and Retention

KTGY implements appropriate technical and organizational measures to protect your personal information against unauthorized access, loss, or destruction. However, no website, application, or transmission can guarantee security. Thus, while we have established and maintain what we believe to be appropriate technical and organizational measures to protect the confidentiality, security, and integrity of personal information obtained through our Website, we cannot ensure or warrant the security of any information you transmit to us.

We will retain your personal information for as long as we need it to provide you with our products and Services as outlined in this Privacy Policy. When the information is no longer necessary for these purposes, we delete it or keep it in a form that does not identify you. Because the length of your use of our Services are not foreseeable, we cannot provide you with an exact timeframe for how long we retain your information. Our legal obligations may also require us to maintain your personal information for longer periods of time.  When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

11. Changes to the Privacy Policy

KTGY may revise and update this Privacy Policy at any time and will post the updated Privacy Policy to the KTGY Website. We encourage you to periodically review this Privacy Policy to ensure you are familiar with the most current version. Please review carefully before submitting Personal Data to our Website. The date the Privacy Policy was last updated is indicated at the top of this page.

12. Contact Information

If there are any questions, concerns, or complaints regarding this Privacy Policy you may contact KTGY using the information below:

Web form: Contact Us – KTGY

Email: contracts@ktgy.com

Mail:

KTGY

Attn: Legal

17911 Von Karman Ave., Suite 200

Irvine, CA 92614 USA

Last updated: June 11, 2025