PRIVACY NOTICE

Last updated on August 4, 2026

This Privacy Notice describes the information collection, use, retention, and sharing practices of Pennsylvania Steel Company, Inc. (“PA Steel”, “we”, “us”, “our”) when you interact with us through our website, www.pasteel.com (the “Website”), and when you interact with us offline, such as when you contact us via telephone or by other offline means (collectively, the “Services”). It also applies to the personal information we collect, use, retain, and share for individuals applying to jobs at PA Steel (“Applicants”).

As used in this Privacy Notice, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person.

PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG

Website Visitors

We collect personal information as you engage with our Services, including when you:

▪         Contact us. When you contact us, we collect, from you, your personal identifiers (name, email address, and phone number), your professional or employment-related information (dealership or company name, job title), and any additional information you choose to include in your message. We use this information to respond to your questions or inquiries, such as a product demo request, and to troubleshoot where necessary.

▪         Request a quote. When you request a quote, we collect, from you, your personal identifiers (name), your professional or employment-related information (company name, address, business email, and business phone number) along with any other information you choose to include in your request. We use this information to assess, generate, and communicate with you about a quote for our goods and services.

▪         Log in to your account. When you log in to your account, we collect, from you, your personal identifiers (PA Steel-issued username) and password (which we store in secure form). We use this information to authenticate access to your account.

▪         Subscribe to our newsletter. When you subscribe to our newsletter, we collect, from you, your personal identifiers (email address). We use this data to send you information about our services, products, events, and more. You may revoke your consent at any time with effect moving forward by clicking the “unsubscribe” link included within each email we send to you. However, we will continue to send you service-related messages. We, through our service provider, use tracking pixels (internet or other electronic network activity information) to determine whether you open emails, the time of opening, information about the device you use (including IP address), source URL, whether you interacted with the email, the topic of the email, whether it was delivered, sender and recipient addresses. We use this information to:

1)      measure the effectiveness of our communications and make them more attractive, particularly by improving email subject lines;

2)      limit the frequency of sending or stop it, ensuring emails continue to reach their recipients;

3)      detect and analyze suspected fraud;

4)      personalize communications based on your interest in received emails and interaction with them. This personalization includes: adapting message content / adjusting sending frequency or communication channel / optimizing campaigns based on reactions (e.g., adjusting email subject lines); and 

5)      offer tailored or personalized communication by type of stakeholder and audience

You can avoid downloading the pixel by rejecting the download of images in the email.

▪         Complete a credit application. When you complete a credit application, we collect, from you, your personal identifiers (name), your professional or employment-related information (job title, business contact information, company name and address), as well as the personal identifiers (name, business contact information) for the company’s accounts payable and buyer contact, the company owner’s personal identifiers (name) and principles, reference information for major suppliers and services, and the personal identifiers (name and contact information) for a banking reference. We use this information to receive, assess, evaluate, and extend credit for businesses that apply for financing. We use contact information for major suppliers and services and the bank to contact such references to assess your businesses’ creditworthiness. Before you provide us with the names and contact information for your references, you must first obtain their consent.

▪         Interact with us on social media. When you interact with our social media pages on social networking websites, such as LinkedIn, Instagram, Facebook, and YouTube (each a “Social Media Page” and collectively, “Social Media Pages”), we collect basic engagement metrics and use it to tailor content and marketing and use it to improve user experience as set forth in this section. Please note that we do not control the use or storage of the information that you have posted to any social networking websites. This information is collected and processed by social networking websites for their own purposes, including marketing. For more information on how LinkedIn, Instagram, Facebook, and YouTube use your personal information, please see LinkedIn’s Privacy Policy, Instagram’s Privacy Policy, Facebook’s Privacy Policy, and YouTube’s Privacy Policy.

●       Social Media Pages. When interacting with our Social Media Pages, we collect, from you, your personal identifiers (first and last name) and visual information (photograph (i.e., profile picture)), as well as any information that you provide when interacting with our Social Media Pages (e.g., commenting, sharing, and rating). We use this information to advertise our products, for events and invitations, and to communicate with users via the contribution and comment function. Because our Social Media Pages are publicly accessible, when you use them to interact with other users, for example by posting, leaving comments or liking or sharing posts, any personal information that you post in them or provide when registering can be viewed by others or used by them as they see fit. The content posted on our Social Media Pages or other public areas of social networking websites can be deleted in the same way as other content that you have created. If at any time you want content posted to be deleted, please email your request to us at marketing@pasteel.com.

●       Community Management. We collect, from you, your contact, including “likes”, shares, messages and other interactions with the content, in order to analyze and evaluate how our content is perceived, to learn from it, and to improve our public relations efforts.

●       Page Insights. When you visit our Social Media Page, the applicable Social Network records your IP address and other information about your usage behavior on our Social Media Page. The Social Network collects this information through trackers in the browser of your device or via the advertising ID (IDFA from Apple or GAID from Google), when you open the Social Network app through your mobile device (e.g., smartphone or tablet). The Social Network uses this information to provide us with statistical evaluations of the use of our Social Media Page. We receive this information directly from Social Network, in the form of aggregated data and anonymous statistics regarding certain data points, such as: age; gender; city/country; device; inquiries from fans about other Social Media Pages; region and language settings of the users; proportion of men and women; the number of people reached; clicks on posts, “likes” and reactions; comments, reposts, and shared content; profile views, and total video views. We use this information to analyze and improve the advertising campaigns we conduct through our Social Media Pages. We do not collect or process any other personal information in connection with Social Network “Page Insights” function.

We do not retain this information independently. For information on data protection and the storage period on the Social Network in relation to its Insights function, see the Social Network privacy policy linked above. It has been contractually agreed with the Social Network that the Social Network is responsible for providing you with information about the processing for Page Insights.

●       Information Processed Solely by Social Networks. We do not know how the Social Networks use personal information for their own purposes, how long the personal information is stored on the Social Networks or whether the Social Networks’ data is passed on to third parties. If you are currently logged in to a Social Network as a user, the Social Network automatically collects, through trackers on your device, your Social Network ID or a link between the Social Network ID and the advertising ID (IDFA from Apple or GAID from Google) when you open the Social Network app through your mobile device (e.g., smartphone or tablet). This enables the Social Network to understand that you have visited our Social Media Page along with other social media pages that you have clicked on, whether you clicked on Social Network buttons integrated into websites that partner with the Social Network, and other online interactions that report user data to the Social Network. Based on this data, content or advertising tailored to you can be offered. You can find more information about the personal information collected by Social Networks, how it is used and how long it is stored by visiting the Social Network’s privacy policies, linked above.

▪         Aggregate and anonymize data. We deidentify and/or aggregate the data we collect and use and share it, in deidentified and/or aggregated form, for benchmarking purposes, advertising, and internal analytics. We maintain and use this data in deidentified form. We will not attempt to reidentify the data unless it is necessary to determine whether our deidentification processes satisfy applicable data protection laws.

▪         Interact with the Website. We use essential cookies to ensure the Website functions as intended, prevent fraud, and to maintain the security of the website.

Job Applicants:

• Complete an application. When you apply for a position at PA Steel, we collect, from you, your personal identifiers (name, email address, telephone number, and physical address), your professional or employment-related information (resume/CV, cover letter, certifications or licenses, qualifications, and employment history), and any other information you choose to include with your application. We use this information to review your background and skills, to determine your qualifications for the role you are applying to, and to confirm information related to your employment and education. For equal employment and affirmative action purposes, you also have the option (when it is clearly and specifically requested) to provide us with your protected classifications (gender, age, veteran status, and disabilities) and sensitive protected classifications (race and ethnicity). We use this protected classification and sensitive protected classification information for government reporting purposes, to comply with legal requirements, to analyze requested disability accommodations as applicable, and to document any accommodations we have provided to accommodate your needs. We also use this information, in the aggregate, to conduct internal analytics and benchmarking. 

• Information from references. When you provide references with your application, we will obtain from your references, your professional or employment-related information (companies you worked at, job titles you held, and your work skills), and will draw inferences from your references, such as their thoughts on how your skills might enable you to succeed in the position you have applied for. We use this personal information to assess your suitability for the position for which you have applied.

• Monitor work-related licenses and credentials. When you first join PA Steel and throughout your tenure, we collect from you, as well as from educational institutions, personal and professional references, your personal identifiers (name) and your professional or employment-related information (licenses, credentials, employment history, educational history, and resume/CV). We use this information to manage work-related licenses and credentials.

• Verify your education. When you first join PA Steel and throughout your tenure with us, we collect from you, as well as from background check providers, and education institutions, your non-public education information (verification of education level completed, verification of dates enrolled in educational institutions, certifications obtained, report cards, and transcripts). We use this information to verify your education for employment purposes.

• Conduct a background check. When a background check is requested as part of the candidate review process, we will collect, from you, your personal identifiers (name, date of birth, and physical address) and sensitive identifiers (Social Security number). Social Security numbers are considered sensitive under some privacy laws. We share this information with a background check provider to conduct a background check to verify your identity, credentials, and criminal history, and to facilitate the background check. For positions where a pre-employment drug test is required, we share your personal identifiers (name, date of birth, email address, telephone number, and physical address) with a third-party drug screening provider to facilitate and arrange the screening. We will subsequently collect your health information (drug test results) from this provider. We use this information to confirm you adhere to PA Steel’s drug policy.

PA Steel will also use the personal information we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in HOW WE SHARE YOUR PERSONAL INFORMATION.

DATA RETENTION

Unless otherwise stated in this Privacy Notice, we retain your personal information as long as reasonably necessary to retain it for the purpose for which it was collected or until we receive a valid request to delete the information, in which case we will delete or anonymize the information (unless there is a reason to retain the information for longer as explained below). This includes maintaining a customer account with us (if applicable) or until the information is no longer needed for a service provider or contractor’s operational purpose(s). Subscription, billing, tax, audit, and transaction-related records may also be retained for longer where reasonably necessary for accounting, dispute resolution, chargeback management, tax, audit, and legal compliance purposes.

We use the following criteria to determine whether it remains reasonably necessary to retain your personal information for such purposes or a service provider or contractor’s operational purpose(s): (i) any retention period required by applicable law or regulation; (ii) actual or threatened litigation requiring preservation of the information; (iii) statutes of limitations for potential legal claims; (iv) responding to legal process or enforceable governmental requests; (v) enforcing our contracts; (vi) keeping our properties and assets secure and preventing fraud; and (vii) showing proof of performance. When we determine that it is no longer reasonably necessary to retain your personal information based on the above criteria, we will delete or anonymize your personal information.

HOW WE SHARE YOUR PERSONAL INFORMATION 

PA Steel shares personal information as described in the PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG section, and generally in the following instances:

▪          Within PA Steel. We share your personal information within PA Steel for the legitimate business purposes of efficiently and effectively providing the Services, such as accounting and customer service support. Access to your personal information is limited to those on a need-to-know basis. For Applicants, we share applicant personal information within PA Steel among our hiring decision-makers (i.e. human resources department, senior management, and hiring managers) to assess applications and make hiring decisions. Access to applicant personal information is limited to those on a need-to-know basis.

▪          In the event of a corporate reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, including without limitation, bankruptcy or liquidation, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction.

▪          For legal purposes. We share personal information where we are legally required to do so, such as in response to court orders, subpoenas, governmental/regulatory bodies, law enforcement or legal process, including for national security purposes. We may share your information with our legal advisors or auditors to establish, protect, or exercise our legal rights or as required to enforce our terms of service or other contracts or to defend against legal claims or demands. We also share this information with third parties as necessary to: detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; to comply with the requirements of any applicable law; or to comply with our legal obligations.

▪          For a business purpose. We have disclosed your personal information to service providers that assist us in providing the Services. These service providers assist us with the following: information technology (“IT”) support; artificial intelligence (AI) services; website hosting; cloud storage; data analysis; customer service; email delivery; marketing; external auditors; payment processing; distribution; shipping providers; and similar services. We have disclosed your internet or other electronic network activity information collected by cookies to our IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair the Services and platform errors. We have disclosed your internet or other electronic network activity information collected by cookies to our IT support to update, improve, and maintain the Website.             

▪          With your consent. Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time with effect moving forward and may do so by contacting us via email at Jodi.Sabara@pasteel.com.

YOUR INFORMATION CHOICES

You have the following choices with respect to your personal information:

▪         Correct or View Your Information. You may access your account to correct or view certain personal information you have provided to us, and which is associated with your account.

▪         Opt Out of Email Tracking. You can disable this tracking by blocking automatic loading of images in your email.

▪         Opt Out of Marketing Communications. You may opt out of receiving marketing emails from us by clicking the “unsubscribe” link provided at the bottom of each email we send. Please note that we will continue to send you notifications necessary to the services.

▪         Applicant Rights. You may be entitled to certain rights under applicable labor laws. For more information, please email us at Jodi.Sabara@pasteel.com and include “Labor Law Inquiry” in the subject line. To exercise your privacy rights as an Applicant, you may submit a request via email to Jodi.Sabara@pasteel.com.

DO NOT TRACK DISCLOSURE

We do not respond to Do Not Track requests. Do Not Track is a preference you can set in your web browser to inform websites and mobile applications that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

INFORMATION SECURITY

We implement appropriate technical and organizational security measures, such as access controls and encryption, to protect the personal information that we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. However, no security measure or modality of data transmission is 100% secure, and we are unable to guarantee the absolute security of the personal information we have collected from you.

CHILDREN’S PRIVACY

The Services are not intended for anyone under the age of eighteen (18). We do not knowingly collect the personal information of anyone under the age of eighteen (18). If we learn that we have collected or received personal information from individuals under the age of eighteen (18), we will delete their personal information. If you believe we have personal information on individuals under the age of eighteen (18), please contact us at the contact information provided below.

CHANGES TO THIS PRIVACY NOTICE

We may amend this Privacy Notice in our sole discretion at any time. If we do, we will post the changes to this page and will indicate the date the changes go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominent posting on the Website and/or via email, and either obtain your opt-in consent (if required) or provide an opportunity to withdraw your consent.

CONTACT US

If you have any questions about this Privacy Notice or need to access this Privacy Notice in an alternative format due to having a disability, please contact us by email at Jodi.Sabara@pasteel.com (and use “Privacy Inquiry” in the subject line).