Privacy Notice (Non-EU)

Thank you for visiting the website of Panamint Capital, LLC also referred to as “Panamint”. An important part of our commitment to you is our respect for your privacy as a user of this website (the “Site”). This Privacy Policy seeks to help you understand whether and how we collect information about you when you visit the Site, and how we use such information.

Your visit to the Site is subject to this Privacy Policy. By accessing the Site, you accept and agree to be bound and abide by the data processing practices described in this Privacy Policy, which may be updated at any time by us. If we update our Privacy Policy, we will post the updated Privacy Policy here. Any such changes will be effective upon posting. You should consult the “Privacy Policy” bar on this Site each time you visit the Site. If you do not agree with the Privacy Policy, you must not access or use the Site.

This Privacy Policy concerns only the Site and does not concern any website to which the Site may link. Should you choose to visit these third-party sites, you should review their privacy policies to ensure that you understand and are comfortable with their practices concerning your personally identifiable information. Similarly, this Privacy Policy does not concern your interaction with Panamint in any matter other than your use of the Site. Finally, this Privacy Policy does not address our privacy practices with respect to any nonpublic personal information we may collect from you as a prospective employee or contractor, or as an investor in us or in funds that we sponsor or manage. We address these practices in separate notices.

If you have any questions or comments about this Privacy Policy, you can email us at info@panamintcapital.com, or send your request via mail to Panamint Capital LLC 917 Tahoe Blvd, Ste 202, Incline Village, NV 89451.

1. The Types of Information We Collect About You

When you enter and browse the Site, we may collect two different types of information about you: information you provide to us, and information we collect through technology.

Information You Provide to Us

In order to obtain access to certain information or materials provided via the Site, including when you sign up to receive our newsletters, you may have to provide information that we collect and store in a way that allows us to relate it to you personally, including but not limited to your name, e-mail address, mailing address, phone number, facsimile number and the type of investor you are (e.g., individual, analyst, broker). We refer to such information as personally identifiable information. Additionally, we may collect and retain a record of all communications with you.

Information We Collect Through Technology

We may collect information about you through technology. For example, we may collect your IP address each time you request a page during a visit to the Site. (An IP address is often associated with the portal through which you enter the Internet.) At times, we may also use IP addresses to collect information regarding the frequency with which users browse various parts of the Site.

The Site may also use other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which our users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send our Site users and individuals who subscribe to our newsletters to determine whether such recipients have opened those e-mails and/or clicked on links in those e-mails. We may collect the information from use of these technical methods in a form that is personally identifiable.

During some visits we may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse overs), and methods used to browse away from the page. We may use this information to measure Site activity, to develop ideas for improving the Site, and for any other purpose to the extent permitted by applicable law.

Cookies

Panamint and its third party partners collect certain information, including Personal Data, by automated means, such as cookies, web beacons (including pixels and tags), web server logs, analytics and other technologies (collectively “Cookies”).  We use these Cookies for several purposes, including to ensure our services are functioning correctly and to provide and measure advertisements. 

What are Cookies?

A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser.  A “web beacon”, also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and may be used to transmit information collected through cookies back to a web server.  We refer to all of these and similar technologies as “Cookies” for purposes of this Cookie Notice.

What Information can We Obtain through Cookies?

The information we may obtain through Cookies includes your traffic data, IP address, logs, identifiers associated with your devices, types of devices connected to the Site, operating system, error reports, browser type, web browser characteristics, device characteristics, and language and country preferences,  referring/exit pages, clickstream data, error information, and dates and times of WebsiteSite visits. 

What Cookies do we Use?

We use Cookies on the Site that fall into the following categories: 

Strictly Necessary

These cookies are necessary for the Site to function and cannot be switched off. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personal data.

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of the Site. They help us to know which pages are the most and least popular and see how visitors move around the sites. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance. 

Functional Cookies

These Cookies enable the WebsiteSite to provide enhanced functionality and user experience. These Cookies collect information about your choices and remember your preferences so we can show you relevant content and personalizse the Site. They may be set by us or by third party providers whose services we have added to our pages.  Functional Cookies are deleted when you end your browsing session or within a short period of time thereafter. If you do not allow these Cookies then some or all of these services may not function properly.

Your Choices

You may also stop Cookies from being downloaded on your device by selecting the appropriate settings on your web browser. Most web browsers will tell you how to stop accepting new Cookies, how to be notified when you receive a new Cookies and how to disable existing Cookies.  Please note, however, that without Cookies you may not be able to take full advantage of all the features of the Site. 

2. Our Use and Disclosure of Your Personally Identifiable Information

Panamint does not disclose any nonpublic personally identifiable information about its Site users to any nonaffiliated third party, except as set forth below.

We may use or disclose certain personally identifiable information we collect about you when you visit and browse the Site to support our normal business operations, or to send you administrative communications either about your interactions with us or about features of the Site, including any future changes to this Privacy Policy. If you have signed up to receive our newsletter, we will use or disclose certain personally identifiable information in order to provide, maintain, and improve our newsletter service, which includes distributing our newsletter and sharing other information that may be of interest to you and individuals that subscribe.

We may store and use your information for marketing, research and other business purposes, and we may share or disclose this information to our affiliates and third-party partners for these purposes.  We may associate your personally identifiable information with other information we collect about you, such as details about your usage patterns and interests, for these purposes, but we will not sell this combined information or disclose it to third parties. We may also use your contact details and metadata relating to your communications with Panamint representatives for business development purposes.

We may also use service providers to facilitate our services or platform functions on our behalf. These companies and individuals may have access to your personally identifiable information, as needed to perform their functions, but may not use it for another purpose.

We will use or disclose personally identifiable information when we believe that such disclosures are required by law, regulation, legal process, subpoena, document request or governmental request. For example it may be necessary, under anti-money laundering and similar laws, to disclose information about investors in order to accept subscriptions from them. We may also do so to help enforce our Terms of Use, protect your safety or security, including the safety and security of property that belongs to you, or protect the safety and security of the Site, databases or third parties, including the safety and security of tangible or intangible property that belongs to us or to third parties. Also, in the event that Panamint, or substantially all of the assets of Panamint or one or more of its businesses, are acquired or merged with another entity, whether an affiliate or a third party, user information may be one of the transferred assets. We may transfer all user information (which may include personally identifiable information) to our acquirers or successors. 

3. How We Use Your Non-Personally Identifiable Information

Non-personally identifiable information is information that does not personally identify you, including anonymous information and aggregate data. We may use this information to understand better how our visitors use the Site, research our visitors’ demographics, interests, and behavior, improve the Site, provide visitors with customized services and information, and for other similar purposes. We may combine this information with personally identifiable information. We may share this information with others, such as investors, for information or promotional purposes, and may use this information in any manner permitted by law, but any disclosure that identifies you personally will be governed by Section 2.

4. Protection of Information

We endeavor to protect your personally identifiable information. We use reasonable technical, administrative and physical methods to maintain the integrity and security of our databases, including firewalls. Please be aware, though, that there is no such thing as “perfect security” on the Internet, and third parties may unlawfully intercept or access transmissions or private communications. 

5. Do Not Track

Panamint does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (“DNT”) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You should consult the help pages of your browser to learn how to set your preferences so that websites do not track you.

6. Children

Although this Site is not targeted toward children, we are concerned about the safety and privacy of children who use the Internet. If a child under 13 has provided personally identifiable information to us through the Site, a parent or guardian may inform us at the address for legal notices above, and we will use commercially reasonable efforts to delete it from our database, subject to applicable law and this Privacy Policy.

7. International Use

Panamint makes no claims that materials on the Site are appropriate or may be downloaded for use in locations outside the United States. Access to the Site from countries or territories where such access is illegal is prohibited. Furthermore, our databases are located in the United States. If you access this website from outside the United States, you do so at your own risk. By sending us your data, you consent to its transfer to and storage within the United States. Those who access the Site from outside the United States do so on their own initiative and are responsible for compliance with local laws, rules and regulations.

Last updated: October 2025