Ziwo - App Privaty Policy

General Information

This Privacy Policy applies to Ziwo Agent, our Android mobile application (our “App”). In the below policy, we inform you about the scope of the processing of your Personal Data. What law applies? In principle, we will only use your personal data in accordance with the applicable data protection laws, in particular the UAE`s Personal Data Protection Law (“PDPL”) and the EU counterpart the General Data Protection Regulation (“GDPR”). What is Personal Data? Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address and device ID. What is processing? “Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data. Responsible for data processing The responsible party within the meaning of the PDPL and the GDPR is ASWAT FZ LLC, 154, Floor 1, Building 17, Dubai Internet City, Dubai, (“ASWAT”, “we”, “us”, or “our”). If you have any questions or if you wish to exercise your rights, please feel free to email cs@ziwo.io, call +971 4 278 99 02. The Legal Bases for processing Personal Data In accordance with the the PDPL and the GDPR, we have to have at least one of the following legal bases to process your Personal Data: i) you have given your consent, ii) the data is necessary for the fulfillment of a contract / pre-contractual measures, iii) the data is necessary for the fulfillment of a legal obligation, or iv) the data is necessary to protect our legitimate interests, provided that your interests are not overridden. How We Use Information The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you and as follows: to administer your account and provide our services to you, create and manage your account; provide you with customer support and respond to your requests, communicate with you about our services, to improve our services and develop new ones, to prevent, detect and fight fraud or other illegal or unauthorized activities, address ongoing or alleged misbehavior, to ensure legal compliance, comply with legal requirements, assist law enforcement; and enforce or exercise our rights, for example our Terms.

Processing of Automatically Collected Data

Downloading the App The App can be downloaded from the “Google Playstore” a service offered by Google LLC. Downloading it may require prior registration with the Google Play Store and/or installation of the respective Google Play Store software. Installing the App As far as we are aware, Google collects and processes the following data: License check, network access, network connection, WLAN connections, and location information. However, it cannot be ruled out that Google also transmits the information to a server in a third country. We cannot influence which personal data Google processes with your registration and the provision of downloads in the Google Play Store and Google Play Store software. The responsible party in this respect is solely Google as the operator of the Google Play Store. Device information Google may collect information from and about the device(s) you use to access the App, including hardware and software information such as IP address, device ID and type, device-specific and App settings and properties, App crashes, advertising IDs (AAID), information about your wireless and mobile network connection such as your service provider and signal strength; information about device sensors such as accelerometer, gyroscope, and compass. Authorizations and Access We may request permission to access your Internet Connection and Network your Microphone and Phone Status. The legal basis for data processing is our legitimate interest and the provision of contractual or pre-contractual measures. You can deny access on your device via the Settings/Notifications/ options of your device; however, this means that our App may not function as intended. Push messages When you use our App, you will receive so-called push messages from us, even if you are not currently using our App. These are messages that we send you as part of the performance of the contract. You can adjust or stop receiving push messages at any time via the device settings of your device. Insofar as you consent to the use of push messages, consent is the legal basis for the processing. Firebase We use the Google Firebase developer App and related features and services provided by Google. We use the following Google Firebase services in our Platform: a) Firebase Analytics, b) Firebase Crashlytics, c) Firebase Cloud Messaging for Push Notifications. By integrating Google services, Google may collect and process information (including personal data). It cannot be excluded that Google also transfers the information to a server in a third country. We cannot influence which data Google collects and processes. Firebase’s key security and privacy information can be found here: https://firebase.google.com/support/privacy The legal basis is the implementation of the user contract for the use of the App. Google Analytics for Firebase Our App uses the web analytics service Google Analytics for Firebase, which uses tracking technologies to track your use of our App. In this respect, information is generated about, among other things, the number of users and their sessions, the session duration, the operating system used by the users, their device model, the region from which our App is accessed, the first start of our App, our App execution and any updates. In order to provide the relevant data for analysis, Firebase Analytics uses your a) device’s advertising ID, b) an App instance ID (a randomly generated number that identifies a single app installation), c) and the IP address, which is shortened (IP masking) before being processed on Google’s servers (which may be located outside the UAE/EEA) to generate the usage analysis. You can object to the use of Firebase Analytics at any time by disabling the sending of usage statistics in your device settings (Reset Advertising ID). We have no influence on these data processing operations.The basis for processing is our legitimate interest and your consent.

Data processing by us

Contacting us Personal Data is processed depending on the contact method. In addition to your name and email address, IP address or telephone number, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is processed for the purpose of dealing with your request and the legal basis is your consent. The use of your IP address takes place exclusively in the context of law enforcement and security measures in compliance with our legal requirements. Account and Sign on If you register, we will request mandatory and, where applicable, non-mandatory data in accordance with our registration form (Username Full Name, Email Address, Company Details) through our web portal (www.ziwo.io). The entry of your data is encrypted so that third parties cannot read your data when it is entered. We also use a Token-based Authentication system which is a protocol that generates encrypted security tokens and enables users to verify their identity and then generates a unique encrypted authentication token. When using our services We process the data of our registered users in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. This includes in particular our support, correspondence with you, invoicing, fulfillment of our accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfill our legal obligations. The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as your consent. Data management and technical support If you create a support ticket, we will request personal and, where applicable, non- personal data in accordance with your request, this may include your name, email address and other order related data you voluntarily provide. The data provided is not shared with third parties and cannot read your data when it is entered. If you submit a support ticket, we process the data for the purpose of processing and handling your ticket. The legal basis of the data processing is our obligation to fulfill the contract and/or our legitimate interest in processing your support ticket. You can delete data provided at any time in the ticket or by contacting us. When making a purchase or take out a subscription To make a purchase or take out a subscription, you may need to provide a valid payment method (e.g., credit card). Your payment information will be collected and processed by our authorized payment vendor through our web portal (www.ziwo.io). We do not directly collect or store credit or debit card numbers ourselves in the ordinary course of processing transactions. The legal basis for the provision of a payment system is the establishment and implementation of the contract. Administration, financial accounting, office organization, contact management We process data in the context of administrative tasks as well as the organization of our business and your subscription, managing your obligations and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interests.

General Principles

Minors Persons under the age of 18 should not transmit any Personal Data to us without the consent of their parents or legal guardians. We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties. Automated decision-making Automated decision-making including profiling does not take place. Do Not Sell We do not sell your Personal Data. Sharing We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services, b) you have consented to the disclosure, c) or the disclosure of data is permitted by relevant legal provisions. In addition, we may disclose your Personal Data: in connection with law enforcement, fraud prevention or other legal proceedings; as required by law or regulation; if ASWAT or Ziwo (or a part of ASWAT or Ziwo ) is sold to or merged with another company; or if we have reason to believe that disclosure is necessary to protect ASWAT or Ziwo. International Transfer Our main operations are based in the UAE and your Personal Data is generally processed, stored and used within the UAE. We take steps to ensure there is an appropriate level of security, so your Personal Data is protected in the same way as if it was being used within the UAE. Where we need to transfer your data outside the UAE, we will use approved standard contractual clauses in contracts for the transfer of personal data to third countries. Data Security Our data processing is subject to the principle that we only process the Personal Data that is necessary for the use of our services. In doing so, we take great care to ensure that your privacy and the confidentiality of all Personal Data are always guaranteed. Nonetheless, databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notice will be accompanied by a description of the action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.

Your Rights and Privileges

Privacy rights You can exercise the following rights: Right to information Right to rectification Right to deletion Right to data portability Right of objection Right to withdraw consent Right to complain to a supervisory authority Right not to be subject to a decision based solely on automated processing. If you wish to exercise any of your rights, please contact us. Updating your information If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us. Withdrawing your consent You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation. Access Request In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above). Complaint to a supervisory authority You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The competent data protection authority in the UAE is: The UAE Data Office, Abu Dhabi, United Arab Emirates, https://u.ae/. However, we would appreciate the opportunity to address your concerns before you contact the UAE Data Office.

Changes

We may update this policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us using email cs@ziwo.io, call +971 4 278 99 02. Effective Date Friday, 3rd of November, 2023