Form ADV Report: Key Updates in Pagaya US Holding

Last Updated: May 8th, 2023

Risk Advisors Inc. ("Risk Advisors", "we", "our") is committed to protecting and respecting your privacy. This Privacy Policy describes how we collect, use, and protect your Personal Information and other data that Risk Advisors gathers when you are accessing our website (the “Site”). The Site may contain links to third-party sites, which are not subject to this Privacy Policy. We recommend that you read the privacy policy of any such sites that you visit. By using our Site or registering to use the Site, you are consenting to the personal information collection, use, andxz sharing practices described in this Privacy Policy.

What Information Do We Collect?

Personal Information means any information that may be used to identify an individual which because of name, personal profile, contact information, number, symbol, mark, email address, home or other physical address, or other identifier, can be used to identify that individual.

When you visit our Site, you may provide us with personal information you knowingly choose to disclose that is collected on an individual basis and information that is aggregated or anonymized as you and others use our Site. We collect IP addresses for Site security and to help us understand how people use the Site so that we can improve the Site and our users' respective experiences. For similar quality reasons, we use a feature known as a "cookie." Cookies contain bits of information that websites transfer to your computer's hard drive for record-keeping purposes. Cookies can make the Web more convenient by storing information about your preferences on a site.

Although we may assign your browser a cookie, the cookie does not tell us who you are. Only you can tell us that. Besides cookies, we may also use tiny electronic images (called "single-pixel GIFs" or "Web beacons"), which allow us to count users who have visited specific pages or access certain cookies. We may use single-pixel GIFs in the following ways:

To count and recognize users

To conduct research and for auditing purposes.

To determine aggregate information about users, including demographic and usage information.

Third parties may also use single-pixel GIFs as part of their publications available on our Site. In general, any electronic image viewed as part of a Web page can act as a Web beacon.

We also use server logs and Web traffic analytic services to collect information about how our Site is used. The information collected may include the time, date, and page views. We collect specific data about your use of our publications, including the pages accessed by your username and when you accessed them. This information is used to confirm compliance both with your specific subscription plan and with our third party data providers. The usage information also allows us to ensure that the information we are providing is what our users want.

We record user submitted information in the in-line email system in order to handle with any issues in the data submitted by you. We have a record of your responses in a database. That information may include: first and last name, phone number, email address, and any comment you have entered into the form.

If you become a registered User, we need to collect registration and billing information. To register for an account, we collect information such as your username, password, and email address. If you provide us with a billing address, we may infer that it may be your residence. If you register using a third party account such as LinkedIn, Facebook, or Google, then we will collect data and information from such parties if you give permission to those third parties to share your information with us.

We or a third-party billing service may collect billing information for you such as your name, address, email address, and the financial information needed to process your method of payment (e.g., credit card, wire, or check).

If you send us email, we may retain the content of your messages together with your email address and our responses. These will be subject to our normal email retention policies for such communications.

We collect data from the applications and devices that you are using to access our site. This may include your IP address and browser which may also allow us to infer your geographic location. If you use a third party source that refers you to our site through an email or a link on another website, we may record information about the third party source that referred you.

How Do We Protect Children?

We operate our sites in compliance with the Children's Online Privacy Protection Act and it is our policy not to knowingly collect or use personally identifiable information from anyone under 13. However, you should be aware that we assume that any communications submitted through email or an online transaction are from an adult.

How Do We Use Your Information?

We use the Personal Information that you provide to us in different ways. You agree that we may use your Personal Information to:

1.provide the services and customer support you request;

2.process, confirm, and provide you access to the subscriptions that you have registered for;

3.facilitate account creation and the logon process;

4.resolve disputes, collect fees, contact you about your service or account, and troubleshoot problems;

5.prevent potentially prohibited or illegal activities, and enforce our Site policies;

6.notify you of important changes to our Site;

7.customize, measure, and improve our services, content, and third-party publications;

8.tell you about targeted marketing, service updates, and promotional offers based on your specific preferences (if you would prefer not to receive such communications you can use our Opt-Out email address: info@radientanalytics.com along with “Unsubscribe” in the subject line;

9.comply with applicable laws including, but not limited to, responding to legal requests;

10.compare your information for accuracy, and verify it with third parties;

11.create new services, features, and content; and

12.create analytics from aggregated or anonymized use of the Site.

Occasionally, we may conduct user surveys to learn how we can better serve you. These surveys are optional and if you choose to respond, your responses will be kept anonymous. The demographic information we collect in the registration process and through surveys is used to help us improve our services.

To Whom May We Disclose Your Information?

We disclose your Personal Information to third parties for many reasons. Most commonly, we share your Personal Information to third parties so that they can provide services to you. We have in place reasonable contractual protections to ensure the confidentiality of your Personal Information to such entities. For example, we may disclose your Personal Information to our billing service providers so they may contact you when your subscription is due for renewal or in case you need to communicate with them regarding any issues with your account. By using the service, you are consenting to the disclosure of your Personal Information to such service providers.

We also provide your Personal Information when we have your consent for a specific reason such as processing a credit card payment with a credit card service company for your subscription registration. We may choose to make certain offers or services available to our users from third parties. If we do, during the registration process and at certain points thereafter in connection with specific offers we may ask you whether your Personal Information may be sent to third parties who have products, services and opportunities which may be useful to you. If you give your permission to allow third parties to contact you, your Personal Information (such as your contact information and other information collected during your visit to our Site) may be shared with data aggregators, marketers (possibly in the form of list rental), and other organizations. If you agree to allow a third-party to contact you for marketing purposes through our Site, you may later revoke such permission; however, if you want the third party to stop sending you marketing communications, you will need to contact the third party directly.

We may share aggregated or anonymized Personal Information with third parties to (i) improve our services, (ii) promote our services, or (iii) offer new services, analytical tools, or data. We may also share broad aggregate demographic data and related usage information with our business partners. This aggregate information does not contain any Personal Information that can identify an individual user.

Although advertisers may display advertisements of our services on other websites and we may request that they deliver those advertisements based on the presence of a cookie, we will not share any other information with the advertiser.

If your employer has subscribed on your behalf, your employer may provide us with limited Personal Information to enable your access. Your employer may also require us to provide information about your use of the services, for example how often you use the subscription that they have purchased for you. Under such circumstances, we may provide your employer with such personally identifiable information. We may also contact your employer if we have any issues with your compliance with the Terms of Use.

Risk Advisors may share your information if all or substantially all of our assets are acquired by or merged with another company, our company is reorganized, or our business changes. Under such circumstances, you expressly consent to Risk Advisors transferring your Personal Information to the new owner or successor entity so that it may continue to provide you with services. Where applicable, Risk Advisors will notify the appropriate agencies of such a transfer to comply with applicable data protection and privacy laws.

Risk Advisors does not intend to transfer Personal Information without your consent to third parties who are not bound to act on Risk Advisors' behalf unless such transfer is legally required We may disclose your Personal Information if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to (i) comply with any applicable law, regulation, legal process or governmental request, (ii) enforce our Terms of Use including investigations of potential violations thereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, or (iv) protect against harm to the rights, property or safety of Risk Advisors, its users, yourself or the public.

How Secure Is The Information We Collect?

Risk Advisors is committed to preventing the loss, misuse, and alteration of the personal information in our possession. However, as you know, third parties may unlawfully intercept or access transmissions or private communications, and other users may abuse or misuse Personal Information that they collect from the Site. Therefore, although we work very hard to protect your privacy, we do not promise, and you should not expect, that your Personal Information or private communications will always remain private.

If you are paying with a credit card, payment transactions are conducted in a Secure Socket Layer (SSL) session, which encrypts all transaction data for transmittal in a format that helps reduce the chance of theft of the information. The website securely transmits your payment information to Stripe (stripe.com) which manages and provides approval for the transaction. While on a secure page, most modern browsers will let you know that you are in a secured session. Our servers are located in a secure, supervised environment.

Personalized areas of the Site are password-protected. Only you have access to these password-protected areas. Do not share your passwords with anyone. Risk Advisors will never ask you for your password in an unsolicited phone call or email. If you are using a computer that others have access to, always remember to log out, clear the cache, and close your browser window when leaving the Site.

How Do We Use Cookies?

› IP ADDRESSES

Your Web browser or email application automatically provides your Internet Protocol address ("IP address") to other computers with which you communicate over the Internet, so that they know where to send you information. We receive an IP address each time you view one of our Web pages, because the browser automatically reports it to us. If you are a Registered User, we also may store the IP address when you register with Risk Advisors or utilize the Site to advertise your products.

We may use IP addresses for various purposes, including:

Diagnosing service or technology problems.

Assessing and maintaining system security.

Displaying the most appropriate advertising or content.

Studying how people use the Site and how we can improve it.

Reporting to advertisers about aggregate, but not individual, information derived from IP addresses.

› COOKIES

Cookies may be used on the Site in the following ways:

If you are a user, we may use cookies to access your stored account information automatically when you log on to the Site, in order to deliver a better and more personalized service. For instance, we may use cookies to allow you to access your account information automatically, as well as make changes to your Personal Information. Also, our search engines may use cookies to expedite your search for content or products.

We may use cookies to improve our services by making them more relevant to our users. The unique cookie that is given to each browser accessing Risk Advisors is used to determine your usage patterns and help us target content and ads based upon user interests.

We may use cookies to authenticate user identity and confirming where and whether you are currently logged in thereby making our Site more secure. Some of our advertisers use third-party networks to serve their advertisements on the Site. Often, these third-party advertising companies use cookies, Web beacons, and similar technologies to measure advertisement effectiveness. We do not control, nor do we have access to, their cookies or the information they obtain. Use of their tracking technology is subject to their own privacy policies. If you would like more information about the privacy policies of third-party advertising networks, including information on how to opt out of their tracking methods, check out http://www.networkadvertising.org/optout_nonppii.asp.

Most browsers are set up to accept cookies, but you can configure yours to refuse cookies or notify you when you've received one. Browsers differ, so check your "Help" menu to learn how to change your cookie preferences. If you reject cookies on the Site, though, you may not be able to access some areas of the Site or use some of its features.

How We Respond To "Do Not Track" Signals?

We do not respond to DNT signals.

How Can You Protect Your Account?

While we do our best to protect Personal Information, Risk Advisors cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. You are responsible for maintaining the secrecy of any password and/or account information. If your password has been compromised for any reason, you should immediately notify us and change your password. Please be careful and responsible whenever you are online, especially when using a computer that other people can use also.

Blogs And Other Areas For Community Comments

Risk Advisors may offer you access to blog or other areas where you can comment with other users in a controlled environment within your entity. You acknowledge that any information you submit may be read, used, and collected by other users who access such areas. Risk Advisors does not make any representations or warranties as to the accuracy of such information. We are not responsible for any Personal Information you share in such areas of our Site.

Retention, Transfer, And Storage Of Your Personal Information To The U.S. And Other Countries

Your Personal Information may be stored in or transferred to any country where Risk Advisors or its partners or affiliates has offices, employees, or sub-contractors. By subscribing to our Site, you consent to the storage or transfer of your Personal Information outside your country of residence. Personal Information that you submit or that we collect through our Site is retained in accordance with Risk Advisors’ records retention and disposition policies. If you would like more information regarding this, you may contact the privacy policy contact listed in this policy.

General

We may amend this policy from time to time. If we decide to change our privacy policy, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If you continue to use the subscription after the changes, you are deemed to have consented to such changes.

If we determine that the changes are material to this policy, we will notify you here, by e-mail, or by means of a notice on our homepage and if they require your express consent, we will provide you a reasonable period of notice to consent to such changes before they are effective. If you continue to use your subscription after any notice period of material changes, you will be deemed to have expressly consented to the privacy policy changes.

If you have any questions that are not answered online, you may write to us at:

Radient

369 Lexington Avenue #3136, 3rd Floor

New York, NY 10017

or email us: support@radientanalytics.com