Esmark, Inc. Privacy Policy

Effective Date: January 14, 2026

This Privacy Policy describes the privacy practices of Esmark, Inc. and its affiliates (“Esmark,” “we,” “us,” or “our”) in connection with the information we collect about you (also referred to herein as “consumers”), including through our websites, microsites, mobile versions of these websites, and mobile applications that expressly adopt and display or link to this Privacy Policy (collectively, the “Site”), the official social media pages we operate (“Social Media Pages”), and our other communications with you, including but not limited to our communications with you via phone and email.

If you have any questions about this Privacy Policy, please contact us by using the contact details in the Contact Information section below.

The submission of your personal data and Esmark’s use of your personal data is subject to the terms of this Privacy Policy. Depending on your activities when visiting the Site, you may be required to agree to additional terms and conditions. Your use of our Site is also subject to Esmark’s Terms of Use.

INFORMATION COLLECTED

We may collect the following categories of information about consumers:

Location: We use various technologies to learn your general geographic location, including by collecting your IP address or other device information, which may depend on your device’s settings for location services.

Device Information: When you visit our Site, interact with our Social Media Pages or online ads, or open our emails, we learn about your browser, device type, IP address, internet service provider, and other technical information about your device.

Identifiers: We collect identifiers that include personal information like name, email address, phone number, company name, job title, username and password for any Site accounts, online identifiers, and may also include information such as your social media account information.

Call, Email, and Mail Records: If you call, email, or mail our offices or our representatives, we may keep records of those communications.

Commercial Information: We keep track of inquiries and business interactions related to our products and services, including transaction history and information about your interests in our solutions and investments.

Payment Details: If applicable, we may collect payment information when you purchase any of our products or services or when you make payments in connection with business transactions.

Site Interactions: We collect information about your interactions with our Site. This data may be used to troubleshoot customer service issues, to improve site functionality, to provide advertisements and marketing to you, and to analyze user needs.

Submitted Content: We collect any content you submit to our Site, Social Media Pages, or to us, including comments, photos, reviews, questions, forms, or content submitted in connection with promotions, events, or investor relations inquiries.

Unsubmitted Content: We may collect information that you type into search bars or other text submission areas on the Site, even if you do not click submit.

Demographic Information / Characteristics of protected classifications: We may have access to demographic details about our website visitors such as gender, ZIP code, and other similar details.

Job Applications: If you apply for employment with Esmark, we have access to the content you provide such as your resume, cover letter, and any information contained therein, as well as information you provide via our careers pages or applicant tracking systems.

Inferences: We may use any of the above information to draw inferences such as consumer or business preferences, behavior, and characteristics.

Other Information: We may collect other information that we are able to infer or that you provide when contacting us or through the course of visiting or using our Site or otherwise interacting with us, including engaging with our Social Media Pages.

HOW WE COLLECT YOUR INFORMATION

We may collect the information described above directly from you, from third parties we partner with, or through cookies or other automated means. The categories of sources we collect information from include, but are not limited to:

You: We collect information directly from you whenever you:

  • Visit our Site
  • Contact us with questions or comments
  • Submit a form, product or service inquiry, or investor or media request
  • Register for or attend an event, meeting, or webinar
  • Enter a promotion, sweepstakes, or giveaway we offer or participate in
  • Consent to receive our promotional communications or other updates
  • Create an account on any Esmark Site or portal
  • Respond to a survey or questionnaire, engage in market research, or otherwise communicate or interact with us in any manner

Your Device or Browser: Certain information is automatically collected from your device or browser and analyzed when you visit or use our Site, interact with our Social Media Pages or online advertising, or open our emails.

Third Parties: We work with third parties who provide services to us such as analytics providers, survey providers, data suppliers, advertising companies, event partners, product or service partners, or other service providers. Your information may be collected and processed independently in accordance with the third party’s own privacy notices. These third parties may share information they have collected with us.

Social Media Platforms: Social media platforms share information with us. You can learn more about how social media platforms collect and use your information by reviewing their privacy policies and settings.

Cookies, Device Identifiers, and Similar Technologies:

We use cookies (small data files stored on your device or browser), web beacons (tiny graphic images embedded in a website or email, also known as clear gifs, one pixel gifs, Internet tags or pixel tags), and other similar technologies to automatically collect information when you visit our Site or interact with our emails or advertisements.

We use these technologies to store users’ preferences and to record information about your visit to our Site. We may transmit that information to third party partners to assist us with advertising and marketing. We also use these technologies to customize advertising, web page content, and other offers or services based on user profile information.

Third parties may use third party cookies or other technologies, including pixel trackers, to collect your information. These third parties may use the information that they collect to deliver advertisements about our products and services and those of third parties that are customized to your preferences. These third parties may be online advertising networks or other similar online intermediaries that collect information through cookies and similar tools over time and across different websites. See the section titled Your Privacy Choices for information on choices available relating to our cookie usage and marketing activities.

HOW WE USE YOUR INFORMATION

We may use the information we collect for the following purposes:

  • Providing and improving our products and services, including:
    • Delivering and supporting our products, services, and solutions
    • Fulfilling orders, processing transactions, and managing business relationships
    • Responding to your communications, inquiries, and feedback
    • Processing your requests, purchases, transactions, and payments and preventing transactional fraud
    • Improving your experience on our Site
    • Supporting events, meetings, and industry engagements
    • Understanding how people use our Site and services
  • Communicating with you about products, services, investments, and promotions, including:
    • Sending marketing communications and promotional information
    • Providing information about our companies, portfolio investments, and industry activities
    • Sharing information about events and other opportunities that may be of interest to you
  • Serving content on our Site and Social Media Pages, developing and analyzing our services, and improving user experience, including:
    • Troubleshooting customer service issues
    • Improving Site functionality and effectiveness
  • Presenting advertising, including:
    • Presenting advertising online and via email or other communication channels
    • Working with social media platforms, search engines, and other partners to reach relevant audiences
  • Analyzing your activity with us, including:
    • Evaluating your interactions with our Site, Social Media Pages, and emails or other forms of communication
    • Monitoring the effectiveness of our advertising and communications
  • Personalizing our relationship with you, including:
    • Presenting customized communications, advertising, and experiences on our Site, emails, and ads on social media or third party platforms
    • Providing interactive or personalized elements, services, and offers
  • Providing support and responding to your inquiries, including:
    • Investigating and addressing concerns
    • Monitoring and improving our responses
  • Pursuing our business purposes, including:
    • Conducting data analysis
    • Detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement
  • Maintaining the safety, security, and integrity of our Site, products and services, databases, and other technology assets and business operations.
  • Conducting testing, research, analysis, and product development, including:
    • Developing and improving our Site, products, services, and business activities
  • Protecting legal interests, including:
    • Complying with our legal obligations
    • Responding to legal process or requests for information from government authorities or other third parties
    • Protecting your, our, or others’ rights
  • Evaluating business transactions, including:
    • Conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by Esmark about you is among the assets transferred

We may combine the information that we collect to advance any of these purposes.

HOW WE SHARE YOUR INFORMATION

We may share information with third parties for certain business purposes. We may share the above categories of information:

  • With our service providers that provide services to us in connection with our business, such as:
    • Operational support and customer support
    • Payment processing services
    • Processing employment applications
    • Delivering marketing communications or advertisements
    • Providing data supplementation or market segmentation services
    • Providing web hosting and other IT services
    • Conducting surveys, focus groups, research, and analytics
  • With our business partners, including:
    • Strategic partners, suppliers, and other companies with whom we collaborate in connection with products, services, or events
    • Partners that assist us with analytics, marketing, and industry activities
  • With our affiliates for their own business or commercial purposes consistent with this Privacy Policy.
  • As required by law, such as to:
    • Comply with a subpoena or other legal process
    • Comply with government reporting or regulatory obligations
  • For security purposes, such as:
    • To protect our rights, the integrity of our business, or your safety or the safety of others
    • To detect, prevent, or respond to actual or possible fraud, intellectual property infringement, violations of law, or other misuse of our services
  • In connection with a potential corporate transaction to:
    • Service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets
  • Otherwise with your consent.

YOUR PRIVACY CHOICES

You can control the information we collect and use in the following ways:

Location Information: You can disable location based services on your mobile device or web browser by adjusting the settings on your device or browser. This will prevent our Site from accessing your location information. Some services may not be available if you disable location based services.

User Accounts: If we offer user accounts and you have one, you can deactivate your account at any time by contacting Esmark. When you deactivate your account, your account may be disabled, but your public comments or submissions may remain on the Site. The Site has no responsibility to take down, remove, or edit any of your public activities or any submissions that are a result of your public activities, except as required by law.

Cookies: Web browsers often allow you to erase cookies, notify you when you receive a new cookie, or block cookies altogether. If you would like to control our collection of information via cookies, please use the Help function in your browser to find instructions on how to set your browser’s cookie preferences. If you elect to block cookies from our Site you may be unable to take advantage of many of the opportunities and online features offered by our Site.

Third Party Cookies: To limit the collection of your information via third party cookies and other types of online behavioral advertising, you may visit the Network Advertising Initiative (NAI) opt out website and the Digital Advertising Alliance (DAA) Your Ad Choices website. The NAI and DAA enable you to opt out of participating third party online advertising networks. You may need to have cookies enabled to opt out using the NAI and DAA tools.

Google Analytics: We may use Google Analytics or similar analytics tools to measure the use of our Site and our Site traffic. Google uses the data collected to track and monitor the use of our Site. This data may be shared with other Google services, and Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt out of Google’s tracking by installing the Google Analytics opt out browser add on. For more information on the privacy practices of Google, please visit the Google Privacy and Terms web page.

Promotional Email: To indicate that you do not want to receive promotional emails from Esmark, you may click on the unsubscribe link at the bottom of any promotional email that you receive from us or contact us at katie.regan@esmark.com.

Direct Mail: To indicate that you do not want to receive mail advertisements from Esmark, you may email us at katie.regan@esmark.com.

Account Information: If you have an online account with us, you may update, review, or correct your account information by accessing your online account.

USER GENERATED CONTENT

The Site may enable users to submit their own content for blogs, chat areas, news groups, forums, communities, personal web pages, calendars, and other message or communication facilities (collectively, “Communication Services”) that allow you to communicate with the public at large or with a group.

Any information you disclose through a Communication Service becomes public information and you should exercise caution when deciding to disclose your personal, financial, or other information. Esmark cannot prevent such information from being used in a manner that may violate the law or your personal privacy and safety, and Esmark is not responsible for the results of any such posting.

PROCEDURES USED BY ESMARK TO PROTECT YOUR PRIVACY

We maintain reasonable administrative, technical, and physical safeguards to protect the information we collect, maintain data accuracy, and use information as authorized. However, no information system can be guaranteed to be completely secure.

When you create an account with us you may choose a password to help protect your account information. A password is only as strong as you make it. You should select a unique password and keep it safe.

DATA RETENTION

We will retain your information for as long as is necessary to fulfill the purpose for which your information was collected and in accordance with our internal retention procedures, or as otherwise necessary to satisfy our legal obligations.

To determine the appropriate retention period for personal information, we consider:

  • The amount, nature, and sensitivity of the personal information
  • The potential risk of harm from unauthorized use or disclosure of your personal information
  • The purposes for which we process your personal information and whether we can achieve those purposes through other means
  • The applicable legal requirements

LINKS TO OTHER SITES

The Site may contain a link to another website operated by a third party (a “Linked Site”). Esmark is not responsible for the content of a Linked Site or your use of a Linked Site. A Linked Site may have its own privacy policy in place, which we recommend you review if you visit a Linked Site. Esmark does not control and is not responsible for what third parties do in connection with their websites or how they handle your personally identifiable information.

The Site may include functionality that allows integration with third party sites, including, but not limited to, X, Facebook, LinkedIn, and other social network sites. Esmark may allow you to share selected information with those third party sites, and you may be permitted to export information concerning your use of the Site to such third party sites. Some of those third party services may provide Esmark with information to enhance and personalize your use of the Site. If you submit credentials for a third party website or service during your registration for the Site or in connection with updating your user profile, Esmark may receive your information from such third party website or service.

YOUR U.S. STATE PRIVACY RIGHTS

Certain U.S. states afford residents rights with respect to their Personal Data. The rights described in this section are subject to exemptions under applicable law. For purposes of this section, the term “Personal Data” includes both “Personal Information” and “Personal Data” as defined by applicable law.

If your Personal Data is subject to a privacy law in your state, you may have certain privacy rights with regard to that information. You may have the right to:

  • Know, access, and confirm your Personal Data
  • Delete the Personal Data we have about you, subject to exceptions under applicable law
  • Correct inaccuracies in your Personal Data
  • Obtain your Personal Data in a portable and readily usable format
  • Opt out of the use or processing of your Personal Data for profiling or targeted advertising
  • Opt out of the sale or sharing of your Personal Data

Under certain state laws, you may also have the right not to receive discriminatory treatment for the exercise of any of these privacy rights. We will not discriminate against you because you have exercised any of your rights.

Certain state laws may also provide you with the right to appeal our decisions regarding your rights requests if we do not timely respond to your requests or do not take action regarding your requests. To appeal our decision with respect to your request, please contact us at katie.regan@esmark.com. Additionally, if you are a resident of the state of California, you may have a right to pursue legal action for improper handling of your Personal Data.

Submitting a Rights Request

If you wish to exercise the rights listed above, and are a resident of a state that provides such privacy rights, you may submit a request by emailing katie.regan@esmark.com by calling us at (412) 259-8868 , or by using any Privacy Request Form we may make available on the Site.

We will provide your Personal Data to you in writing in a readily usable format. If you choose to submit your request via email, you should include “Privacy Rights Request” in the subject line and clearly provide us with the following information: what type of request you are making, your full name, email address, and mailing address. You may only make the number of requests permitted under applicable law in a 12-month period.

We are required to provide you with access to your Personal Data or delete Personal Data only in response to verifiable or authenticated requests. We will compare the information you provide in your request with any information we may have in our possession in order to verify your request. We may contact you to request additional information in relation to your request. The information you provide must match the information we have in our possession. This measure is in place to help ensure that Personal Data is not disclosed to any person who does not have the right to receive it. The information collected through this process will be used for verification purposes only.

Authorized Agent

You may authorize an agent to exercise any of these rights on your behalf by contacting us by email at katie.regan@esmark.com. If you use an agent, we will take measures to verify your agent’s authorization similar to the verification described above for fulfilling any access or deletion requests. We may require more information to ensure proper verification of you and your agent’s identity and authorization.

Categories of Personal Data Shared for Cross Context Behavioral Advertising, Profiling, or Targeted Advertising

We may use any of the categories of Personal Data listed under Information Collected for purposes of cross context behavioral advertising, profiling, or targeted advertising, to the extent permitted by applicable law.

Deletion Rights

You may request that we delete your Personal Data that we have collected directly from you. Under applicable law, we may decline to delete your Personal Data under certain circumstances, for example, if we need the Personal Data to complete transactions or provide services you have requested or that are reasonably anticipated, for security purposes, for internal business purposes including maintaining business records, to comply with law, or to exercise or defend legal claims. We are not required to delete your Personal Data that we did not collect directly from you.

We require a reasonable or high degree of certainty that the requester is the consumer for which a deletion request is applicable, depending on the sensitivity of the Personal Data.

Sensitive Data and Sensitive Personal Information

We will not process your Sensitive Data or Sensitive Personal Information, as those terms are defined under applicable privacy law, without your prior consent where such consent is required. We do not sell your Sensitive Data or Sensitive Personal Information. We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under applicable privacy laws.

California’s Shine the Light Law

We do not share Personal Information as defined by California Civil Code Section 1798.83 (“Shine the Light Law”) with third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light Law by contacting us using the Contact Information at Contact Information below. Any such request should include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. We are only required to respond to one request per individual each year.

CHILDREN’S ONLINE PRIVACY

The Site is a general audience site and does not knowingly collect or store information about Site visitors under the age of 16. If you are a parent or guardian of a child under the age of 16 and believe he or she has disclosed information to Esmark, please contact Esmark in writing at the email address listed under the Contact Information section below. A parent or guardian of a child under the age of 16 may review and request deletion of such child’s personally identifiable information as well as prohibit the use thereof. We will take measures to verify any parent or guardian of a child for fulfilling any access or deletion requests. We may require more information to ensure proper verification of any such parent or guardian of a child’s identity and authorization.

EEA / UK PRIVACY RIGHTS

If you are located in the European Economic Area or the United Kingdom, you may have certain rights and protections under applicable laws regarding the processing of your Personal Data, including under the General Data Protection Regulation (EU) 2016/679 (GDPR) or the UK version of the GDPR (UK GDPR) together “European Privacy Laws.”

European Privacy Laws generally afford applicable data subjects the right to:

  • Know whether we are processing your Personal Data
  • Request a copy of the Personal Data we hold about you, subject to exceptions under applicable law
  • Request that we correct inaccurate or incomplete Personal Data we hold about you
  • Request that we erase your Personal Data, subject to exceptions under applicable law
  • Request, in certain circumstances, that we transfer any Personal Data we hold about you to another company
  • Under certain circumstances, restrict certain types of processing
  • Object to having certain decisions made about you by automated processes or profiling
  • Withdraw your consent where we have processed your Personal Data based on your consent
  • Lodge a complaint with the relevant supervisory authority

We do not make decisions about you based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you in a similar way.

In addition to the security measures mentioned above, we will endeavor to ensure that your Personal Data is adequately protected, for example, by entering into contracts that contain appropriate data protection provisions where required.

How to Submit a Request (EEA / UK)

If you are located in the EEA or the UK and wish to exercise any of your rights under European Privacy Laws where applicable, you may submit your request by emailing us at katie.regan@esmark.com.

Please note that these rights are not absolute and we may be entitled to refuse or limit requests, wholly or partly, where exceptions under applicable law apply.

If you would like to make a complaint about how we handle your Personal Data, or make a complaint about a breach of data protection laws, please contact us using the contact information described below. Complaints will be investigated and the outcome of the investigation will be communicated to you in accordance with applicable law. If European Privacy Laws apply, you also have the right to make a complaint with your local data protection authority.

Legal Basis for Processing

We will process your Personal Data only where we have a lawful basis for doing so. These lawful bases for processing are set forth in applicable data protection law and, where European Privacy Laws apply, our processing will be on the basis of one or more of the following where applicable:

  • The performance of a contract to which you are a party or to take steps at your request prior to entering a contract
  • Compliance with our legal obligations
  • Our legitimate interests
  • The establishment, exercise, or defense of legal claims
  • To carry out tasks in the public interest or for reasons of substantial public interest

In some circumstances we may process your information if you have provided your consent for us to do so. You have the right to withdraw any such consent by contacting us using the contact details below, without affecting the lawfulness of processing based on consent before its withdrawal.

Marketing Notice

We may process your Personal Data for marketing purposes, for example, to let you know about news, updates, or events which we think you may be interested in.

If you are a data subject in the UK or the EEA, for email marketing to an individual, that is, a non-corporate email address, we may need your consent to send you unsolicited email marketing. Where you provide consent, you can withdraw your consent at any time.

Your Personal Data may also be collected in our relationship management systems when you register online to receive information or when we otherwise receive your contact details.

You can opt out of direct marketing at any time by contacting us katie.regan@esmark.com or by following the unsubscribe instructions at the bottom of each marketing communication.

Data Protection Authority

If you have a concern about our processing of Personal Data that we are not able to resolve, you have the right to lodge a complaint with the applicable data protection regulator.

PRIVACY REQUEST

You have the right to make choices about how we collect, use, and share your personal information. If you wish to opt out of the sale or sharing of your personal information, delete your data, or submit another type of privacy request, you may contact us at katie.regan@esmark.com, call us at (412) 259-8868 or use any Privacy Request Form we may provide on the Site. We will process your request in accordance with applicable privacy laws.

CONTACT INFORMATION

If you have any questions or comments about this Privacy Policy or the Site, or if you wish to exercise your rights, please contact Esmark by:

Phone:

(412) 259-8868

Address:

Esmark, Inc.
Attn: Privacy
100 Hazel Lane, Suite 300
Sewickley, Pennsylvania 15143

Email: katie.regan@esmark.com