Privacy Notice

This Privacy Notice ("Notice") describes how OrbitronAI Agentic-FZCO and its affiliated entities (together "OrbitronAI", "we", "us", or "our") collect, use, manage and protect Information provided to OrbitronAI. This Notice explains how we use your Information, who OrbitronAI may share it with, and the measures OrbitronAI takes to keep it secure.

This Notice applies to all access and use of the OrbitronAI Services, Website, and Platform, regardless of where it is accessed from.

This Notice continues to apply even if your agreement with OrbitronAI for the OrbitronAI Services and other products ends.

This Notice may be updated from time to time. You may access the latest version of this Notice at any time on the Website. You are advised to review this Notice periodically for any changes. Updates will take effect when they are published, and OrbitronAI may notify you of material changes where required by Applicable Law.

If OrbitronAI has provided you with additional terms about how OrbitronAI collects and uses your Personal Information specific to a particular product, service, or context, those terms shall prevail in the event of a conflict with this Notice.

In this Notice, the following capitalised terms have the meaning assigned to them below, unless expressly stated otherwise:

OrbitronAI may collect the following Information to verify your identity. This may include:

• (a)your name, date of birth, and place of birth;
• (b)contact details, such as your home address, work address, email and phone number;
• (c)details about your employment, your role with the Client, the Client's company incorporation details, group structure, and ultimate beneficial ownership details of the Client;
• (d)proof of identity, such as a copy of a valid passport or national ID; and
• (e)any details that you provide OrbitronAI through the OrbitronAI chat feature on the Website, during the integration process, or Information OrbitronAI collect or generate about you when you get in touch with OrbitronAI.

OrbitronAI may also get Information about you and the Client from external sources to help OrbitronAI verify your identity and manage OrbitronAI's business risk. This may include engaging with credit reference or fraud prevention agencies and Know Your Customer (KYC) and Anti-Money Laundering (AML) service providers to fulfil OrbitronAI's legal duties.

When you use the OrbitronAI Services as an End User, OrbitronAI may collect the following Information about you:

• (a)your name and credentials required to access your service provider account;
• (b)Information from account(s) held by you with a service provider — including account details, balance details, and transaction history — to which you have provided consent;
• (c)your contact details, such as your address, email and/or phone number;
• (d)details about your employment;
• (e)proof of identity, such as a copy of a valid passport or national ID; and
• (f)any details that you provide through OrbitronAI's chat feature on the Website.

By choosing to use the OrbitronAI Services or as a result of your access to the Website, OrbitronAI may also collect Information concerning:

• (a)your interactions and usage of the OrbitronAI Services;
• (b)information about your preferences and interactions with the OrbitronAI Services to personalise your experience, with your consent;
• (c)details about how you use and interact with the Website or the OrbitronAI Services;
• (d)the mobile network, device and operating system that you use so that OrbitronAI can analyse how the Website and the OrbitronAI Services work and fix any issues; and
• (e)your location if you've authorised tracking, so OrbitronAI can help protect you against fraud.

OrbitronAI collects and uses your Information for various purposes and will always have a lawful basis for doing so. OrbitronAI may need to process your Personal Information for the performance of an agreement OrbitronAI has with you, to enter into an agreement with you, to enable OrbitronAI to comply with the law, or OrbitronAI may use your Personal Information for its legitimate interests, or those of a third party (for example, to help product development, to manage OrbitronAI's business risk, financial affairs and to protect OrbitronAI's staff/personnel, or for security and maintenance).

OrbitronAI may also use your Information to:

• (a)develop, operate, provide, maintain, and improve the OrbitronAI Services, now and in the future;
• (b)communicate with you about your use of the OrbitronAI Services, including updates and support, where permitted by Applicable Law;
• (c)provide and receive information, support, feedback and assistance related to the OrbitronAI Services;
• (d)enable you to create a personal profile, access the application dashboard and view protected content;
• (e)analyse usage trends and the preferences of the User and to conduct questionnaires and surveys, in order to improve the OrbitronAI Services;
• (f)where you are a Client, or work for a Client: contact you for administrative purposes, send communications relating to products and services offered by us, personalise content to your preferences, and protect, investigate, and deter against fraudulent, unauthorised, or illegal activity;
• (g)where you are an End User, with your consent, OrbitronAI will create and maintain a profile to remember your identity, preferences, and account details across different Clients;
• (h)with your consent, personalize your experience by remembering your preferences and interactions across OrbitronAI Services.

If you participate in an OrbitronAI activity or forum on the Website, the Information that you provide will be made visible to others.

You are responsible for making sure the Information that you give OrbitronAI is accurate and up to date. You must also tell OrbitronAI if anything changes, as soon as possible. If OrbitronAI asks you for any Information and you do not provide it, OrbitronAI may stop providing the OrbitronAI Services to you.

If you give OrbitronAI any information about another person connected to your account, you must tell them what Personal Information you have given OrbitronAI, and make sure that they are informed of the contents of this Notice and agree that OrbitronAI can use their information as set out in this Notice.

Strictly with your permission, OrbitronAI may use your Information for marketing purposes. Each promotional email you receive from OrbitronAI or any of its affiliated third parties will include instructions on how you can unsubscribe from that category of mailing or from receiving emails from that third party. You may also unsubscribe from OrbitronAI's promotional emails by sending an email, including your name and email address, to privacy@orbitronai.com.

OrbitronAI may analyse and evaluate your Information in an automated manner so as to identify significant characteristics or to predict insights and to create profiles. These may be used for business-related checks, product development and management.

When providing you with the OrbitronAI Services, OrbitronAI may make decisions about you by automated means. For example, OrbitronAI uses technology that helps OrbitronAI to identify the level of risk involved in User account activity (i.e. for credit, fraud and financial crime reasons).

You have a right to certain information about how OrbitronAI makes these decisions. OrbitronAI ensures that a suitable contact person is available if you wish to express a view on any automated individual decision, where such opportunity to express a view is required by law. Please contact OrbitronAI using the contact details in Section 17 for more information.

In some instances, OrbitronAI may collect non-personal (aggregate or demographic) data through cookies, web logs, and web beacons. This Information may include, but is not limited to, your device's Internet Protocol address, browser type, browser version, the pages of the Website that you visit, the time and date of your visit, and unique device identifiers.

When you access the Website with a device, the Information may also include the type of device you use, your device unique ID, the IP address of your device, your device operating system, the type of internet browser you use, and other diagnostic data.

This information allows OrbitronAI to better understand and improve the usability, performance, and effectiveness of the Website and to correct any problems that may occur. OrbitronAI may also collect and store your location data when you access the Website via a mobile device or computer. You can enable or disable location services when you use the Website at any time through your device settings.

OrbitronAI may share and transfer your Personal Information within the OrbitronAI group and with OrbitronAI's affiliated companies, Service Providers and any third parties engaged by OrbitronAI where:

OrbitronAI may need to share your Personal Information with OrbitronAI's affiliated companies, Service Providers, and other third parties to provide the OrbitronAI Services. These parties are authorised to use your Personal Information only to the extent necessary to perform their functions related to the OrbitronAI Services and are contractually prohibited from using it for any other purposes.

On occasion OrbitronAI may transfer and disclose your Information in other cases including:

• (a)in response to subpoenas, court orders, legal process or according to the requirements of Applicable Laws;
• (b)to establish or exercise OrbitronAI's legal rights or defend against legal claims;
• (c)to investigate, prevent, or take action against illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person;
• (d)when there is a sale or transfer of all or part of OrbitronAI's business or assets; or
• (e)OrbitronAI may share aggregated and/or anonymised data with others — you will not be able to be individually identified from this information.

The Website is hosted in the United Arab Emirates but can be accessed worldwide. Accordingly, any Information collected through the Website may be transferred to, and stored at, a destination outside of the country or jurisdiction in which it was collected, including locations which may not have the same level of protection for your Personal Information.

All Personal Information is stored in an encrypted and segregated manner and access is strictly limited to such OrbitronAI employees who need to access it to fulfil a service or instruction to you.

In some cases, OrbitronAI may need to transfer your Information outside of the country or jurisdiction in which it was collected. OrbitronAI may need to transfer your Information in this way to perform its agreement with you, to fulfil a legal obligation, to protect the public interest and/or for OrbitronAI's legitimate business interests.

Whenever OrbitronAI transfers your Information outside of the country or jurisdiction in which it was collected, OrbitronAI will ensure that it is protected in a manner that is consistent and permissible under applicable data protection rules.

Depending on the kind of product or OrbitronAI Service that is used, your Personal Information may also be disclosed to third parties domiciled in jurisdictions which are deemed not to have an appropriate level of data protection. If data is transferred to such a country, OrbitronAI takes appropriate measures (for example, relying on contractual arrangements such as Standard Contractual Clauses or other precautions or justifications, as may be applicable) so that your Personal Information continues to receive the appropriate protection.

OrbitronAI is committed to protecting the Personal Information you share with OrbitronAI. OrbitronAI relies on a combination of industry-standard security technologies, procedures, and organisational measures to help protect your Personal Information from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your Personal Information transmitted, stored or otherwise processed by OrbitronAI.

OrbitronAI advises that you take every precaution to protect your Personal Information when you are accessing the Website, Platform and using the OrbitronAI Services. For example, OrbitronAI recommends that you change your passwords regularly, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser.

OrbitronAI uses technologies such as Cookies and web beacons, which allow OrbitronAI to make your visit to the Platform easier, more efficient and more valuable by providing you with a customised experience and recognising you when you return.

A Cookie cannot read Personal Information off your hard disk or read Cookie files created by other websites. The only Personal Information a Cookie can contain is information you supply yourself. Accepting the Cookies used on the Platform may give OrbitronAI access to Usage Information about your browsing behaviour, which OrbitronAI may use to personalise your experience and track your User traffic patterns.

In addition, OrbitronAI uses web beacons in conjunction with Cookies to understand User behaviour. Web beacons are simply a convenient way of gathering basic statistics and managing Cookies and do not give away any extra information from your computer.

If you prefer not to receive Cookies while browsing the Platform, you can set your browser to warn you before it accepts Cookies or refuse the Cookie when your browser alerts you to its presence. You may browse most of the Platform without accepting Cookies, however some functionality may be lost by disabling Cookies on your computer.

If you consent, OrbitronAI may use cookies or similar technologies to recognise you when you return to the OrbitronAI Services through different platforms, enabling OrbitronAI to provide a seamless experience.

The Website, Platform and/or the OrbitronAI Services may contain links or directly connect with third-party websites, applications and/or services not managed or controlled by OrbitronAI. In such cases, the privacy notice of the respective third party will apply, and OrbitronAI bears no responsibility for the information collected or used by any third-party website or application, and you release OrbitronAI from any liability for the conduct of these third parties.

OrbitronAI encourages you to review the privacy policies and notices of any third-party website that you access, including the privacy notice of the application through which you access the OrbitronAI Services.

OrbitronAI may engage third party Service Providers from time to time. These Service Providers may have access to your Personal Information only to the extent necessary to perform the tasks assigned to them by OrbitronAI. All Service Providers engaged by OrbitronAI are legally required to maintain the confidentiality of your Personal Information, have in place systems and controls to protect against any loss or damage to your Personal Information, and must not disclose or use your Personal Information for any other purpose other than as they are instructed.

The Website is not intended for use by individuals under the age of 18 ("Child" or "Children") without parent or guardian supervision. OrbitronAI does not knowingly collect Personal Information from Children. If you become aware that a Child has provided OrbitronAI with Personal Information, please contact OrbitronAI immediately. If OrbitronAI becomes aware that OrbitronAI has collected Personal Information from a Child without parental or guardian consent, OrbitronAI will take steps to remove that Information from our servers.

OrbitronAI will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes OrbitronAI collected it for, including to satisfy any legal, regulatory, tax, accounting or reporting requirements.

On occasion, OrbitronAI may retain your Personal Information for a longer period, and even after you stop using the OrbitronAI Services, in order to:

• (a)respond to enquiries and complaints;
• (b)comply with laws and regulations;
• (c)act in accordance with OrbitronAI's internal policies and procedures; or
• (d)protect OrbitronAI's interests.

If you have consented and subject to any legal or regulatory requirements that may require OrbitronAI to retain certain information, OrbitronAI will retain your End User profile data for as long as your consent remains valid or until you withdraw your consent.

Should you have any privacy-related questions or comments related to this Notice, please send an email to privacy@orbitronai.com or you may contact OrbitronAI at the address below.