Binary Semantics’ Privacy Assurance

Introduction

Binary Semantics Limited ("BSL"), along with its direct and indirect subsidiaries and foreign branch offices (collectively, "BSL" or "we"), including our product FleetRobo® (hereinafter, "FleetRobo®" and "BSL" together will be referred to as "BSL"), is committed to upholding legal and regulatory standards concerning data protection and privacy across all business operations. This Privacy Policy sets forth the foundational guidelines governing BSL's collection, processing, and usage of personal data, including sensitive personal data, concerning our associates, business contacts, customers, and vendors (collectively referred to as "Individuals").

Scope of Application

Where Binary Semantics Limited exercises control over other corporate entities, such entities are mandated to adhere to the principles enshrined in this Policy.

Key Terms

Personal Data:

Information that can identify an individual, either directly (e.g., name, email address) or indirectly (when combined with other data).

Sensitive Personal Data:

A special category of personal data that requires stricter protection, such as information about race, ethnicity, health, or political opinions.

Data Subject Rights:

Rights granted to individuals under applicable laws to access, rectify, erase, or restrict processing of their personal data.

PRIVACY PRINCIPLES:

Compliance and Accountability

BSL is dedicated to ensuring that personal data is handled with utmost care and in strict compliance with applicable legal and regulatory requirements. We hold our business partners and vendors accountable to these standards through meticulous contractual agreements.

Lawfulness of Processing

BSL commits to collecting, storing, processing, sharing, transferring, analyzing, or otherwise handling ("Processing") personal data in strict alignment with applicable legal requirements. This includes processing for legitimate business purposes, compliance mandates, or with the express consent of the Individuals, in adherence to the prevailing laws and regulations.

Limitation on Collection and Processing

BSL strictly limits the scope and duration of personal data processing to what is essential for the intended purpose. We ensure that unnecessary or excessive data collection and processing practices are avoided.

Transparency and Information Provision

BSL pledges transparency in its data processing activities. In line with applicable legal requirements, we provide clear and concise information to Individuals about the scope, purpose, and methods of data processing. Individuals are also informed about whom to contact for inquiries or clarifications regarding privacy and data protection concerns.

Information We May Collect & Sources of Personal Data

BSL collects personal data in various ways, depending on your interaction with us. This data may include:

• 1. Information you disclose to us: This encompasses personal information you voluntarily provide through our website forms, applications, surveys, or during interactions with customer support. The specific information collected depends on the purpose, such as visiting our website, requesting services, participating in events, or subscribing to marketing communications.


• 2. Information automatically collected: BSL automatically gathers certain information when you visit and navigate our websites. This information does not necessarily reveal your specific identity and may include device and usage data such as IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, location(country), information about how and when you use our websites, and other technical details. This data is essential for maintaining website security and operation, as well as for internal analytics and reporting.


• 3. Information from cookies and similar technologies: Like many businesses, BSL utilizes cookies and similar technologies to gather information about your activity on our websites.

BSL'S COMMITMENT TO DATA INTEGRITY

Precision and Accuracy

BSL prioritizes the accuracy of processed personal data, adhering to applicable laws and regulations. We take proactive measures to ensure data accuracy for its intended purpose. Inaccurate personal data will be promptly rectified or erased. Individuals are encouraged to notify us of any inaccuracies or utilize the options outlined in our Privacy Notices.

Fortified Security and Confidentiality

We are committed to safeguarding the security and confidentiality of individuals' personal data. BSL implements comprehensive physical, technical, and organizational measures to prevent accidental, unlawful, or unauthorized access, alteration, disclosure, loss, or destruction of data. Our security measures are tailored to the risks associated with our data processing activities and the nature of the personal data involved.

Privacy Embedded in Design

BSL integrates Privacy by Design principles into all digital and manual personal data processes. Privacy considerations are inherently built into our standards, protocols, and processes, ensuring data protection is a foundational element across our operations.

Selective Disclosure

BSL only discloses personal data to third parties when required or permitted by law, with the individual's consent, or for specified lawful purposes. Third-party recipients may include public authorities, law enforcement agencies, and similar entities. We disclose personal data exclusively for the purposes outlined in our privacy notices.

Your Rights as a Data Subject

In compliance with applicable legal frameworks, BSL facilitates the exercise of data subject rights available to individuals engaged with us. These rights may encompass:

1. Accessing your personal data
2. Correcting inaccuracies
3. Objecting to processing in certain situations
4. Requesting erasure of your data (under certain conditions)
5. Withdrawing your consent (where processing is based on consent)
6. Receiving your data in a portable format (where applicable)

Each Data Subject Request is meticulously validated and monitored to ensure closure. Depending on the jurisdiction and the nature of engagement, additional rights may also be available. BSL is committed to assisting data subjects in exercising these rights effectively.

International Data Transfers

Given BSL's global operations, we may occasionally transfer personal data across borders. We recognize the importance of protecting data during such transfers, particularly to countries with differing data protection standards. When transferring personal data to such jurisdictions, BSL ensures compliance with this Policy and applicable legal requirements, maintaining the highest standards of data protection. We may use standard contractual clauses or other approved transfer mechanisms to ensure adequate data protection.

Data Retention and Disposal

BSL adheres to structured data retention policies, deleting personal data once it's no longer necessary for its intended purposes or as mandated by law. Exceptions may apply when data retention is required indefinitely for specific purposes or by legal obligations. Upon concluding the data's utility, we promptly delete it in a secure manner. This may involve secure deletion of electronic files or physical destruction of paper records.

Jurisdiction-Specific Compliance and Adaptation

BSL recognizes that national data protection and privacy laws may impose additional requirements on the processing of personal data. We are committed to establishing supplementary procedures and guidelines when necessary, ensuring compliance with local regulations. BSL engages proactively with relevant regulatory and supervisory authorities to uphold the principles of this Policy.

Global Privacy Governance and Contacts

BSL's Global Privacy Function, led by the Data Protection Officer (DPO), is responsible for overseeing and implementing privacy and data protection standards across our global operations. We may appoint specific data protection roles tailored to individual countries or regions. Data Protection Officers are also designated where mandated by applicable laws. This function orchestrates training and awareness initiatives and integrates privacy principles into BSL's business operations.

For inquiries regarding this Policy, how to exercise your data subject rights, or to report a privacy concern, please contact our Data Protection Officer (DPO) at dpo@binarysemantics.com You can also find more information and details on exercising your rights in our privacy notice available at www.binarysemantics.com

Data Breach Management

BSL mandates immediate reporting of all known or suspected incidents involving personal data. This encompasses incidents reported by BSL associates, clients, third-party service providers, or other business partners. We prioritize education and awareness among our workforce, ensuring they understand the procedures for reporting suspected or confirmed data breaches. Each incident undergoes a comprehensive investigation, and its progress is tracked until resolution. In the event of a data breach that poses a high risk to individuals' rights and freedoms, we will notify affected individuals without undue delay and provide information and support as required by law.

Policy Implementation and Compliance

BSL maintains internal mechanisms to ensure Policy compliance, facilitate the effective exercise of individuals' rights under this Policy and applicable laws, and address any concerns regarding potential non-compliance. Individuals can access these mechanisms or exercise their rights by contacting our Data Protection Officer (DPO) as mentioned above.

Job Applicants

If you submit an application for a job opening at BSL, we may collect and process personal data relevant to your candidacy, such as:
1. Resume and cover letter
2. Contact information (name, email, phone number)
3. Educational background and work experience
4. Educational background and work experience
5. References (with your consent)
6. Information from skills assessments or interviews
We use this information solely for the purpose of evaluating your application and managing the recruitment process. All applicant data is treated confidentially in accordance with this Policy.

Children and Minors

Our websites and services are not directed towards children. BSL does not knowingly collect personal data from individuals under the age of 18. If you are a parent or guardian and believe that your child has provided personal data to us, please contact us using the methods outlined in the "Contact Us" section below. We will take appropriate steps to investigate and address the situation.

Third-Party Sites

Our websites may contain links to third-party websites. We are not responsible for the privacy practices of these third-party sites. When you click on a link to a third-party site, you should review their privacy policy, which will govern the use of your personal data on that site.

Policy Updates

BSL reserves the right to update this Privacy Policy periodically to reflect changes in laws or our privacy practices. We will post any updates on our website at www.binarysemantics.com.

Contact us: dpo@binarysemantics.com, info@fleetrobo.com

Thank you for your interest in BSL's Privacy Practices!