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PRIVACY POLICY — THRESHOLD MEDIA GROUP

Last updated: June 10, 2026

1. Who we are

Threshold Media Group (TMG) is a digital media platform focused on business intelligence, economic analysis and strategic information covering Guinea and West Africa. TMG is operated by Palabre Holding. Data controller: Palabre Holding Contact: privacy@thresholdmediagroup.com Website: thresholdmediagroup.com

2. What data we collect and why

2.1 Account and newsletter registration When you subscribe to our newsletter or create a TMG Pro account, we collect your email address and full name. We use this information to send you editorial content, manage your subscription and communicate with you about your account. The legal basis for this processing is your consent, which you can withdraw at any time. 2.2 Payment information (TMG Pro) When you subscribe to TMG Pro, payment is processed through LengoPay. TMG does not store your card details directly. LengoPay processes and stores payment data on our behalf under their own security and compliance standards. We retain transaction records for accounting and legal purposes. 2.3 Analytics and cookies We use Google Analytics to understand how visitors use our website. This involves the collection of data such as pages visited, time spent on the site, browser type, device type and approximate geographic location. This data is anonymised and aggregated. We use cookies to enable this analytics functionality. You can manage your cookie preferences at any time through our cookie banner or browser settings. 2.4 Data we do not collect We do not collect sensitive personal data such as racial or ethnic origin, political opinions, health data or biometric data.

3. How we use your data

We use the data we collect for the following purposes: - To send you our newsletters and editorial content - To manage your TMG Pro subscription and process payments - To analyse website performance and improve our content - To respond to your inquiries - To comply with our legal obligations We do not sell your personal data to third parties. We do not use your data for automated decision-making or profiling.

4. Who we share your data with

We share data only with the following categories of third parties, strictly necessary for the operation of our services: - LengoPay: payment processing for TMG Pro subscriptions - Mailchimp: newsletter distribution and subscriber management - Google Analytics: website analytics - Hosting and infrastructure providers: for the operation of our website All third parties are required to handle your data in accordance with applicable privacy laws.

5. How long we keep your data

Newsletter subscribers: we retain your email address and name for as long as your subscription is active. You may unsubscribe at any time. TMG Pro accounts: we retain account data for the duration of your subscription and for a period of 3 years thereafter for accounting and legal purposes. Analytics data: Google Analytics data is retained for 14 months by default.

6. Your rights

Depending on your country of residence, you have the following rights regarding your personal data: - Right of access: you can request a copy of the personal data we hold about you - Right to rectification: you can ask us to correct inaccurate data - Right to erasure: you can ask us to delete your data, subject to our legal obligations - Right to withdraw consent: you can unsubscribe from our newsletter or withdraw analytics consent at any time - Right to data portability: you can request your data in a structured, machine-readable format - Right to object: you can object to certain types of processing To exercise any of these rights, contact us at privacy@thresholdmediagroup.com. We will respond within 30 days.

7. Cookies

We use the following types of cookies on our website: - Essential cookies: necessary for the site to function. Cannot be disabled. - Analytics cookies: Google Analytics, used to understand how you use our site. You can opt out via our cookie banner or by installing the Google Analytics opt-out browser add-on. We do not use advertising or targeting cookies.

8. International data transfers

TMG is operated from Guinea and serves an international audience. Some of our third-party providers, including Google and Mailchimp, are based in the United States. Where your data is transferred outside your country of residence, we ensure that appropriate safeguards are in place in accordance with applicable law.

9. Security

We take reasonable technical and organisational measures to protect your personal data against unauthorised access, loss or disclosure. All payment transactions are processed through encrypted channels via LengoPay.

10. Changes to this policy

We may update this policy from time to time. We will notify you of material changes by email or by posting a notice on our website. The date of the last update is indicated at the top of this page.

11. Contact

For any questions about this privacy policy or your personal data, contact us at: privacy@thresholdmediagroup.com