VICOTECH B2B PRIVACY POLICY

Effective Date: March 30, 2025

INTRODUCTION

This Privacy Policy applies to the information that VICO TECH PTE. LTD. and its subsidiaries and affiliates (collectively, "VicoTech," "we," "our," or "us") collect from our business partners, including but not limited to OEMs, ODMs, technology partners, distributors, and solution partners (collectively, "Partners") in connection with our Platform-as-a-Service (PaaS) and Software-as-a-Service (SaaS) offerings for vision-based IoT devices (the "VicoTech Platform").

This Privacy Policy describes how we collect, use, disclose, and protect Partner information, as well as choices available to Partners regarding our use of their information. This Privacy Policy does not apply to information collected from end users of Partner products that integrate with the VicoTech Platform; Partners are responsible for providing appropriate privacy notices to their end users.

BY ACCESSING OR USING THE VICOTECH PLATFORM, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, DO NOT USE THE VICOTECH PLATFORM.

1. INFORMATION WE COLLECT

1.1 Information You Provide to Us

We collect information that you provide directly to us, including:

• Account Information: When you register for the VicoTech Platform, we collect information such as your name, email address, phone number, company name, job title, and login credentials.
• Business Information: We collect information about your business, including address, tax identification numbers, bank account information, and other information necessary for our business relationship.
• Communications: We collect information you provide when you communicate with us, such as when you request support, provide feedback, or participate in surveys or events.
• Partner Product Information: We collect information about the products you develop that integrate with the VicoTech Platform, including technical specifications, integration details, and sales data.

1.2 Information We Collect Automatically

When you access or use the VicoTech Platform, we may automatically collect certain information, including:

• Usage Data: We collect data about your use of the VicoTech Platform, including log files, IP address, device information, browser type, referring/exit pages, operating system, date/time stamps, and clickstream data.
• Integration Data: We collect technical data related to the integration between your products and the VicoTech Platform, including API calls, error logs, and performance metrics.
• Device Data: For Partners using our hardware reference designs or OEM/ODM services, we may collect information about the manufactured devices, including serial numbers, firmware versions, and activation status.

2. HOW WE USE YOUR INFORMATION

We use the information we collect for various business and commercial purposes, including:

2.1 Providing and Improving the VicoTech Platform

• To provide, maintain, and improve the VicoTech Platform
• To develop new products, services, features, and functionality
• To process and complete transactions
• To respond to your comments, questions, and requests
• To provide technical support and customer service

2.2 Business Operations

• To manage our business relationship with you
• To send you technical notices, updates, security alerts, and administrative messages
• To facilitate collaboration between Partners where appropriate
• To monitor and analyze trends, usage, and activities in connection with the VicoTech Platform
• To detect, prevent, and address technical issues, security breaches, and fraudulent or illegal activity

2.3 Marketing and Communications

• To communicate with you about products, services, offers, promotions, and events
• To provide news and information that we believe may be of interest to you
• To personalize marketing communications and website experiences based on your preferences

2.4 Legal Compliance

• To comply with applicable laws, regulations, and legal processes
• To protect our rights, privacy, safety, or property, and that of our Partners and others
• To enforce our agreements, policies, and terms of service

3. HOW WE SHARE YOUR INFORMATION

We may share your information in the following circumstances:

3.1 With Your Consent

We may share your information when you direct us to do so or otherwise provide consent.

3.2 With Service Providers

We may share your information with third-party service providers who perform services on our behalf, such as hosting, data analysis, payment processing, order fulfillment, customer service, and marketing assistance.

3.3 For Business Transfers

We may share your information in connection with a merger, acquisition, reorganization, sale of assets, or similar transaction, or in the event of insolvency or bankruptcy.

3.4 For Legal Purposes

We may share your information if we believe disclosure is necessary or appropriate to comply with laws, regulations, legal processes, or governmental requests, or to protect the rights, property, or safety of VicoTech, our Partners, or others.

3.5 Within the VicoTech Corporate Family

We may share your information with our subsidiaries and affiliates for purposes consistent with this Privacy Policy.

3.6 With Other Partners

Where appropriate and with your consent, we may share limited Partner information with other Partners for collaboration opportunities.

3.7 Aggregated or De-identified Information

We may share aggregated or de-identified information, which cannot reasonably be used to identify you, with third parties for industry analysis, research, demographic profiling, and other similar purposes.

4. DATA RETENTION

We retain your information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the information, whether we can achieve those purposes through other means, and applicable legal requirements.

5. DATA SECURITY

We implement appropriate technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, access controls, network firewalls, and secure data centers. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

6. INTERNATIONAL DATA TRANSFERS

We may transfer your information to countries other than the country in which you are located, including to countries where VicoTech or its service providers operate. When we transfer personal information across borders, we take steps to ensure that your information receives an adequate level of protection in the jurisdictions in which we process it.

7. YOUR RIGHTS AND CHOICES

Depending on your location, you may have certain rights regarding your information. These may include:

• Access and Portability: You may request access to the information we hold about you and, in some cases, receive it in a structured, commonly used, and machine-readable format.
• Correction: You may request that we correct inaccurate or incomplete information about you.
• Deletion: You may request that we delete certain information about you, subject to legal obligations that may require us to retain some data.
• Restriction and Objection: You may request that we restrict the processing of your information or object to our processing of your information.
• Withdraw Consent: Where we process information based on your consent, you may withdraw that consent at any time.

To exercise these rights, please contact us using the information provided in the "Contact Us" section below. Please note that certain information may be exempt from such requests under applicable law.

8. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on our website and update the "Effective Date" at the top of this Privacy Policy. Your continued use of the VicoTech Platform after the effective date of the revised Privacy Policy constitutes your acceptance of the revised Privacy Policy.

9. CHILDREN'S PRIVACY

The VicoTech Platform is not intended for individuals under the age of 18, and we do not knowingly collect personal information from individuals under 18. If we learn that we have collected personal information from an individual under 18, we will take steps to delete such information as soon as possible.

10. CONTACT US

11. ADDITIONAL INFORMATION FOR SPECIFIC REGIONS

11.1 European Economic Area (EEA), United Kingdom, and Switzerland

If you are located in the EEA, United Kingdom, or Switzerland, the following additional information applies:

• Legal Basis for Processing: We process your information on the following legal bases:
  • Performance of a contract when we provide you with the VicoTech Platform
  • Legitimate interests, which include operating and improving our business and the VicoTech Platform
  • Compliance with legal obligations
  • Your consent, where applicable
• Data Controller: VICO TECH PTE. LTD. is the data controller responsible for your information.
• International Transfers: When we transfer your information outside the EEA, UK, or Switzerland, we implement appropriate safeguards, such as standard contractual clauses approved by the European Commission.
• Data Protection Authority: You have the right to lodge a complaint with your local data protection authority if you believe our processing of your information violates applicable law.

11.2 Asia Pacific Region

If you are located in the Asia Pacific region, the following additional information may apply:

• Singapore: Under the Personal Data Protection Act 2012 (PDPA), you have the right to access and correct your personal data held by us. We will also obtain your consent before collecting, using, or disclosing your personal data, unless an exception under the PDPA applies.
• Australia: Under the Privacy Act 1988, you have the right to access and correct your personal information held by us. If you believe we have breached the Australian Privacy Principles, you may complain to us and we will respond within a reasonable time.
• China: If you are located in the People's Republic of China, we may need to obtain separate consent from you for certain data processing activities in accordance with the Personal Information Protection Law.

11.3 Americas Region

If you are located in the Americas region, the following additional information may apply:

• United States - California: If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including the right to know, delete, correct, and opt-out of the sale or sharing of your personal information.
• Brazil: If you are located in Brazil, you have rights under the Lei Geral de Proteção de Dados (LGPD), including the right to confirm the existence of processing, access your data, correct incomplete or inaccurate data, anonymize or delete unnecessary data, port your data, and revoke consent.

12. BUSINESS PARTNER DATA PROCESSING ADDENDUM

If you process personal data of end users on behalf of VicoTech or if VicoTech processes personal data of end users on your behalf, our business relationship may be subject to a separate Data Processing Addendum that governs such processing activities. Please contact us to request a copy of our standard Data Processing Addendum.