Privacy Notice

1. Introduction and Scope

1.1 This Privacy Notice applies to all individuals whose personal data is collected or processed by Neutrinos in connection with any engagement with the Kamios platform or Neutrinos, including:

• users of the Kamios platform, whether on a free trial, paid subscription or other access basis;
• individuals who register for or attend product demonstrations, webinars or events at which Kamios is presented;
• representatives of prospective and existing customers, partners and vendors who communicate or engage with Neutrinos in a business development, commercial or contractual context;
• visitors to Neutrinos' and Kamios' websites and digital properties; and
• any other individuals whose personal data is provided to Neutrinos in connection with the foregoing.

1.2 This Privacy Notice does not apply to the personal data of Neutrinos' own employees, contractors or job applicants, which is subject to separate internal privacy documentation.

1.3 Neutrinos is committed to processing personal data in a lawful, fair and transparent manner, in accordance with applicable data protection legislation including the General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), the Singapore Personal Data Protection Act (PDPA), and other applicable national and state data protection laws.

2. Identity of the Data Controller

The data controller responsible for personal data processed pursuant to this Privacy Notice is:

Where Neutrinos' group affiliates process personal data in their respective jurisdictions, those entities may act as separate controllers or as joint controllers with Neutrinos INC. Details of applicable group entities are available on request by contacting privacy@kamios.ai.

3. Categories of Personal Data Collected

Neutrinos collects the following categories of personal data, depending on the nature of the engagement:

3.1 Identity and contact data: full name, job title, role, work email address, work telephone number, company name, business address and country of location, collected at registration, sign-up, or in the course of business correspondence.

3.2 Account and access data: login credentials (stored in hashed or encrypted form), account identifiers, access permissions, session tokens and authentication data.

3.3 Platform usage data: logs of access to and use of the Platform, including login timestamps, API call records, feature and module usage patterns, Credit consumption, workflow execution records and session metadata.

3.4 Communications data: the content of emails, messages, meeting notes and records of correspondence between you and Neutrinos, including in the context of sales, support, FDE engagement, or business development.

3.5 Event and marketing data: registration information for webinars, conferences and product events; marketing communication preferences and consent records; and records of interactions with Neutrinos' marketing materials.

3.6 Technical and device data: IP addresses, browser type and version, operating system, device identifiers, access times, referring URLs, and similar technical information collected through the use of the Platform or Neutrinos' websites.

3.7 Cookie data: data collected through cookies and similar tracking technologies as further described in Section 10.

3.8 Commercial and contractual data: details of agreements, orders, invoices, purchase history and related commercial information, in respect of customers or partners who have entered into agreements with Neutrinos.

4. Purposes of Processing and Legal Bases

Neutrinos processes personal data for the following purposes:

Where Neutrinos relies on legitimate interests as the lawful basis for processing, it has conducted a balancing assessment to confirm that such processing does not override the rights and freedoms of the individuals concerned.

5. Disclosure of Personal Data

Neutrinos may disclose personal data to the following categories of recipient:

• Neutrinos group companies and affiliates: for the purposes described in this Privacy Notice, subject to intra-group data sharing arrangements.
• Cloud infrastructure and hosting providers: who host the Platform and associated infrastructure on behalf of Neutrinos, subject to data processing agreements.
• Technology and software service providers: including providers of CRM, email, video conferencing, identity verification, customer support and analytics tools, each engaged under appropriate contractual arrangements.
• Professional and legal advisers: including solicitors, barristers, accountants and auditors, bound by applicable duties of confidentiality.
• Financial institutions and payment processors: in connection with commercial transactions with customers and partners.
• Regulators, law enforcement and governmental authorities: where required or authorised by applicable law, court order or regulatory obligation.
• Prospective purchasers or investors: in connection with any proposed or actual merger, acquisition, reorganisation, sale of assets or financing of Neutrinos, subject to appropriate confidentiality obligations.

Neutrinos does not sell personal data to third parties. Neutrinos does not disclose personal data to third-party advertisers for the purpose of serving advertisements.

6. International Transfers of Personal Data

6.1 Neutrinos operates on a global basis. Personal data collected in connection with any engagement may be transferred to, stored in, and processed in countries outside the country in which you are located, including the United States of America, Singapore, India, the United Arab Emirates and South Africa, where Neutrinos' group entities and service providers are situated.

6.2 Where personal data is transferred from the European Economic Area (EEA), the United Kingdom or other jurisdictions with equivalent transfer restrictions, Neutrinos implements appropriate safeguards to ensure an adequate level of protection, including:

• adequacy decisions adopted by the relevant data protection authority or the European Commission, where applicable;
• Standard Contractual Clauses (SCCs) approved by the European Commission, and the International Data Transfer Agreement (IDTA) approved by the UK Information Commissioner's Office, as applicable; and
• supplementary measures where required following a transfer impact assessment.

6.3 Further information regarding the safeguards applicable to specific international transfers may be obtained by contacting privacy@kamios.ai.

7. Retention of Personal Data

7.1 Neutrinos retains personal data for no longer than is necessary for the purposes for which it was collected, having regard to the nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, and applicable legal and regulatory requirements.

7.2 The following indicative retention periods apply:

7.3 Personal data that has been anonymised or irreversibly aggregated and can no longer be attributed to an identifiable individual is not subject to this Privacy Notice and may be retained and used indefinitely for analytical and product development purposes.

8. Rights of Data Subjects

Depending on your location and the applicable data protection law, you may have the following rights in relation to your personal data:

• Right of access: to request a copy of the personal data Neutrinos holds about you and information regarding how it is processed.
• Right to rectification: to request correction of inaccurate or incomplete personal data.
• Right to erasure: to request deletion of your personal data in certain circumstances, including where it is no longer necessary for the purposes for which it was collected.
• Right to restriction of processing: to request that Neutrinos restricts processing of your personal data in defined circumstances.
• Right to data portability: to receive personal data you have provided to Neutrinos in a structured, commonly used and machine-readable format, and to transmit it to another controller, where processing is based on consent or contract performance.
• Right to object: to object at any time to processing of your personal data based on legitimate interests, including for direct marketing purposes.
• Right to withdraw consent: where processing is based on your consent, to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.
• Rights under the CCPA and CPRA (California residents): if you are a California resident, you have rights under the California Consumer Privacy Act and California Privacy Rights Act, including the right to know what personal data is collected, used, shared or sold; the right to request deletion; the right to opt-out of the sale or sharing of personal data; the right to correct inaccurate personal data; and the right to non-discrimination for exercising these rights. To submit a CCPA/CPRA request, please contact privacy@kamios.ai.
• Rights under the Singapore PDPA: if you are located in Singapore, you have rights under the Personal Data Protection Act 2012, including the right to access and correct personal data held about you by Neutrinos.
• Right to lodge a complaint: you have the right to lodge a complaint with the data protection supervisory authority in your jurisdiction.

To exercise any of the above rights, please contact Neutrinos at privacy@kamios.ai. Neutrinos will respond to verified requests within the period required by applicable law (which is typically thirty (30) days, extendable in complex cases). Neutrinos may be required to verify your identity before acting on a request.

9. Security

9.1 Neutrinos implements appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing, accidental loss, destruction, damage or disclosure. These measures include, as applicable: encryption of data in transit and at rest; role-based access controls; network and system monitoring; security assessment and testing; and personnel training on data protection and information security.

9.2 Neutrinos' security measures are designed to be proportionate to the nature and sensitivity of the personal data processed and the risks presented by the relevant processing activities. Platform environments designated for commercial production use are subject to a higher level of security controls than evaluation or trial environments.

9.3 In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of individuals, Neutrinos will notify the relevant supervisory authority without undue delay and, where required by applicable law, will also notify the affected individuals.

10. Cookies and Tracking Technologies

10.1 Neutrinos uses cookies and similar tracking technologies (collectively, "Cookies") on its websites and, to a limited extent, within the Platform. Cookies are small text files placed on your device to enable certain functionality and to collect information about your interaction with Neutrinos' digital properties.

10.2 Neutrinos uses the following categories of Cookies:

• Strictly necessary Cookies: required for the operation of Neutrinos' websites and the Platform, including for session management, authentication and security. These Cookies cannot be disabled without affecting functionality.
• Functional Cookies: used to remember your preferences and settings to enhance your experience.
• Analytics Cookies: used to collect information, on a pseudonymous or aggregated basis, about how users interact with Neutrinos' digital properties, to enable Neutrinos to improve its products and services.
• Marketing and tracking Cookies: used, where consent has been obtained, to deliver relevant marketing communications and to measure the effectiveness of Neutrinos' marketing activities.

10.3 Where required by applicable law, Neutrinos will request your consent before placing non-essential Cookies. You may withdraw consent or manage your Cookie preferences at any time through your browser settings or through Neutrinos' cookie preference centre, where available. Please note that disabling certain Cookies may affect the functionality of Neutrinos' websites or the Platform.

11. Children's Privacy

The Kamios platform and Neutrinos' services are directed at business professionals and are not intended for use by individuals under the age of 18. Neutrinos does not knowingly collect personal data from minors. If Neutrinos becomes aware that it has collected personal data from an individual under the age of 18 without appropriate parental consent, it will take steps to delete such data promptly. If you believe Neutrinos has inadvertently collected such data, please notify privacy@kamios.ai immediately.

12. Third-Party Websites and Services

Neutrinos' websites and the Platform may contain links to third-party websites, services or resources that are not operated or controlled by Neutrinos. This Privacy Notice does not apply to such third-party properties. Neutrinos has no responsibility or liability for the privacy practices or content of third-party websites. You are encouraged to review the privacy notices of any third-party sites you visit.

13. Automated Decision-Making

Neutrinos does not use fully automated decision-making processes that produce legal or similarly significant effects on individuals solely on the basis of automated processing, except where required by law or where you have given your explicit consent. Where the Platform is used by a customer to automate decisions within the customer's own operations, the customer is responsible as controller for ensuring compliance with applicable laws governing automated decision-making, including any obligation to provide human oversight or intervention.

14. Changes to This Privacy Notice

Neutrinos may update this Privacy Notice from time to time to reflect changes in its data processing practices, legal requirements or business operations. Material changes will be communicated by email to registered users and/or by prominent notice on Neutrinos' websites and within the Platform. The effective date of the current version is stated at the top of this Notice. Continued use of the Platform or Neutrinos' services after the effective date of any update constitutes acknowledgement of the updated Notice.

15. Contact Information and Supervisory Authority Complaints

For any questions, requests or concerns regarding this Privacy Notice or the processing of your personal data, please contact Neutrinos at: