Data Protection Policy

BEYONDBYTES INVEST LTD (referred to in these Terms of Use as "BBIL", "we", "us", "our") values your security and privacy.

BBIL is a Free Zone company, registered in the Dubai International Financial Center ("DIFC"), Emirate of Dubai, United Arab Emirates. A reference to BBIL in these Terms of Use, includes where appropriate, a reference to BBIL's affiliates.

BBIL is subject to DIFC Law No. 5 of 2020 (the "DP Law"), and for certain types of personal data processing, may also be subject to laws from other jurisdictions.

It is the policy of BBIL to respect the privacy of our website users. In accordance with DIFC DP Law and as applicable under our Terms of Use, BBIL collects certain limited information about you when you use or access our website (the "Website Services").

This online data protection policy (the "Policy") sets out the conditions on which any information, including any personal data, we collect from you, or you provide to us, will be processed by BBIL. Each time you access or use the Website Services or provide us with information, by doing so you are accepting and, when permitted under the DIFC DP Law, consenting to the practices described in this Policy.

1. Scope and Application

This Policy applies to persons anywhere in the world who access or use BBIL's Website Services ("Users").

2. Collection of Information

Information you give us

This is information you give us about yourself by providing information or filling in forms on the Website Services, or by corresponding with us (for example, by e-mail or any other digital or electronic form). It includes for example information you provide when you send us a message by completing a form on our Website. If you contact us, BBIL will keep an electronic record of such correspondence, including personal information shared at that time. The personal information you give us may include your name, address, e-mail address and phone number, certain device information, work address, photograph and other information you choose to provide ("Personal Information" or "Personal Data").

The Website Services collect and process Personal Data for specific, lawful purposes only, and/or for the performance of tasks carried out in the interests of BBIL which BBIL will inform you of at the time the Personal Data is collected.

Information we collect about you and your device

Each time you use our Website Services we will automatically collect the following information:

• technical information, including the type of mobile device you use, a unique device identifier (for example, mobile network information, your mobile operating system, the type of mobile browser you use, device token, device type, time zone setting ("Device Information");
• details of your use of our Website Services including, but not limited to traffic data, weblogs and other communication data, and the resources that you access ("Log Information").
• location information, to determine your current location, if your mobile device settings permit this functionality.

Other Information We May Collect Through Your Use of the Website Services

If you contact us concerning potential employment, and submit Personal Information to us, we may collect Personal Information and demographic information, for example post code, age/birth date, current residence, hometown, gender, mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, device location and IP address ("Demographic Information").

3. Use of Personal Data

We may use Personal Data which you provide to us or we collect from you to:

• Provide, maintain, and improve our Website Services;
• Perform internal administration and operations, including, for example to prevent fraud or abuse of our Website Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends;
• Send you communications we think will be of interest to you.

4. Processing, Storage and Transfer of Personal Data

We will take all steps reasonably necessary to ensure your data is processed fairly and lawfully, in accordance with the DP Law, other applicable laws and this Policy. By submitting your Personal Data (including Log, Device and / or Demographic Information), you agree to such transfer, storing or processing for the purpose indicated to you at the time the information was collected. BBIL does not implement automated decision making when processing your Personal Data.

You agree that we have the right to transfer the Personal Data described in this Policy to and from, and process and store it in, the United Arab Emirates and (where applicable or required) with processors in other countries, some of which may have less protective privacy laws than those where you reside. Where this is the case, we will take appropriate security measures to protect your Personal Data in accordance with the DP Law and this Policy. BBIL's IT service provider is ISO 27001 certified and all information security policies are strictly enforced. Please see section 7 below for further details.

To preserve the integrity of our databases, to carry out on-going Website Services and to ensure compliance with applicable laws and regulations, we retain Personal Data submitted by Users for a period of time sufficient for the purposes indicated to you at the time the data was collected, unless otherwise prescribed by applicable law. BBIL is not responsible for the accuracy of the information you provide, and will modify or update your Personal Data in our databases upon your request, as further outlined below. We will erase or archive from active use your Personal Data upon request, unless we are required to retain it in accordance with DIFC or other applicable laws. By accessing or using the Website Services, you represent and warrant that you understand that all information submitted to BBIL by you through the Website Services or otherwise may be used by BBIL in accordance with applicable laws and its policies.

5. Sharing of Personal Data

We do not sell nor share Personal Data and we will not proactively market products or services to you. However, as an exception we may share Personal Data which we collect about you as described in this Policy or, as described at the time of collection, including as follows:

• In response to a request for information by a competent authority or government entities if we determine that such disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
• With law enforcement officials, government entities or authorities, or other third parties as required by applicable law;
• If we otherwise notify you and you consent to the sharing;
• With third parties (including notably Google Analytics) in an aggregated and/or anonymized form which cannot reasonably be used to identify you.

6. Your Rights and Choices

> Marketing and Opting Out

BBIL supports Users' legal rights to opt-out of receiving communications from us. You have the option to ask us not to process your Personal Data and to remove it from our database, and to not receive future communications. You may change your preferences at any time by contacting us as indicated on the last page.

> Access to and Correction of Your Personal Information

You have the right to access information held about you. Your right of access can be exercised in accordance with DIFC and other applicable laws. Any access request generally comes at no cost to you.

When you contact us about a potential Personal Data error, we will endeavor to confirm or verify the information in question, then correct verified inaccuracies and respond to the original inquiry.

You may also request that we restrict, erase or otherwise process your Personal Data in line with the relevant articles providing for such rights set out in the DP Law.

The DIFC Data Subject Access and Requests policy is available for your review, and you may contact us using the information provided therein or as indicated on the last page.

> Changes to this Policy

We may change this Policy from time to time and without notice. We encourage you to periodically review this Policy for the latest information on our privacy practices. We provide links to it through:

• The Website Services
• Referencing it in our Terms of Use
• References to it in our contracts, agreements, and other documents as appropriate.

7. Security Precautions

BBIL makes every effort to ensure that your Personal Data is secure on the servers of its IT provider, who have staff dedicated to maintaining our data protection and security policies, which we periodically review to ensure their staff is aware of our data protection and security practices. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, BBIL cannot warrant or guarantee the security of any Personal Data you transmit to us, and you do so at your own risk.

BBIL and its IT provider have established policies and procedures for securely managing information and protecting Personal Data against unauthorized access. We frequently assess our data privacy, information management and security practices. We do this in the following ways:

• Establishing policies and procedures for securely managing information;
• Limiting employee access to viewing only necessary information in order to perform his or her duties;
• Protecting against unauthorized access to Personal Data by using data encryption, authentication and virus detection technology, as required;
• Requiring service providers with whom we do business to comply with relevant data privacy legal and regulatory requirements;
• Monitoring our websites through recognized online privacy and security organizations;
• Conducting background checks on employees and providing training to our employees.

If you have any further questions about our security and processing activities, please contact the Group Data Protection Officer or refer to our Terms of Use. To the extent permitted by applicable law, BBIL expressly disclaims any liability that may arise should any other third parties obtain the Personal Data you submit.

8. Cookies

A cookie is a small text file that is unique to the web browser on your computer or mobile device, which is used to retain user preferences, and enhance browsing experience ("Cookie"). BBIL uses Cookies to track overall site usage and enables us to provide a better user experience. We do not use Cookies to "see" other data on your computer or determine your email address.

Types of cookies we drop and the information collected using them include but are not necessarily limited to:

> Essential

Google Tag Manager - helps make tag management simple, easy and reliable by allowing marketers and webmasters to deploy website tags all in one place.

> Site Analytics

Google Analytics - gives website owners the digital analytics tools needed to analyse data from all touchpoints in one place, for a deeper understanding of the customer experience.

LinkedIn Analytics - enables website owners to promote their company updates to targeted audiences on desktop, mobile, and tablet.

Most browsers accept and maintain Cookies by default. Check the 'Help' or 'Settings' menu of your browser to learn how to change your Cookie preferences. You can choose to alter Cookies settings related to the use of our Website Services, but this may limit your ability to access certain areas of the Website.

Alternatively you may wish to visit an independent source of information, www.aboutcookies.org, which contains comprehensive information on how to alter settings or delete Cookies from your computer as well as more general information about Cookies. For information on how to do this on the browser of your mobile phone, please refer to your handset manual or network operator for advice.

9. External Links

The Website may contain links to other websites on the Internet that are owned and operated by third parties (the "External Sites"). These links are provided solely as a convenience to you and not as an endorsement by BBIL of the contents of or reliability on such External Sites. You acknowledge that BBIL is not responsible for the availability, accuracy and legality of the information and content of any External Site. You should contact the site administrator or webmaster for those External Sites if you have any concerns regarding such links or the content located on such external Sites. If you decide to access linked third party websites, you do so at your own risk. BBIL does not accept liability, and shall not be liable to you for any loss or damage arising from or as a result of your acting upon the content of another website to which you may link from the Website Services.

Contact Us

BBIL has appointed the Priora Group Data Protection Officer to implement this policy in compliance with the DP Law. If you have any questions, comments and requests related to this PriacyPolicy, or if you have any complaints related to how BBIL processes your personal data, please contact the Group Data Protection Officer at:

[email protected]
+971 4 355 38 18