Siargo digital data privacy policy

1. Introduction At Siargo Ltd. (“we”, “our”, “us”, or “the Company”), we recognize that privacy is not just a legal obligation—it is a fundamental component of trust. As a global innovator in micromachined sensor technologies and digital solutions, we are committed to protecting the privacy and security of the personal data we collect from our customers, employees, partners, and stakeholders. This Digital Data Privacy Policy outlines how we collect, process, use, store, share, and protect personal data across our digital platforms, products, services, and corporate operations. By using our products or services, you agree to the terms of this policy.

2. Scope of This Policy This policy applies to all personal data processed by the Company, regardless of the medium through which it is collected. This includes, but is not limited to:

• Our corporate website visitors.

• Customers who purchase and use our products (including connected devices, smart electronics, and software). • Mobile applications and cloud-based platforms.

• Embedded software in our sensor-based modules and devices.

• Customer support portals and technical documentation systems.

• Employees and job applications.

• Data collected through business development, marketing, business partners, and investor relations activities. This policy is designed to comply with applicable data protection laws, including the EU General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), Malaysia’s Personal Data Protection Act (PDPA), and other relevant international frameworks.

3. Types of Data We Collect We collect various categories of personal and technical data, depending on the context of interaction with the Company:

a. Identity and Contact Information

• Full name, job title, company name.

• Email address, phone number, mailing address.

• Government-issued identifiers (where legally required).

b. Technical and Device Data

• Information from connected devices, such as device identifiers, usage statistics, and performance data.

• Browser type, operating system, and language settings. When using our mobile apps, we may collect data on app usage, interactions, and diagnostic information.

• Geolocation data (with user consent).

c. Usage and Interaction Data

• Log files, clickstream data, session duration, and records of your correspondence with us, such as customer support inquiries.

• Preferences, feedback, and survey responses.

• Error reports and diagnostic logs.

d. Transactional and Commercial Data

• Purchase history, order details, invoice records.

• Payment information (processed via secure gateway and compliant third-party providers).

e. Sensor-Generated or Embedded Data

• Data streams from micromachined sensors (e.g., flow rate, pressure, temperature).

• Device calibration logs and firmware metadata.

• Anonymized or pseudonymized datasets used for analytics or product improvement.

4. Purposes of Data Processing We process your data for specific, explicit, and legitimate business purposes, as detailed below, each grounded in a lawful basis:

• To Provide and Improve Products and Services: We use your data to fulfill orders, process payments, provide customer support, troubleshoot issues, and provide technical assistance, including MOUs, NDAs, and supply agreements. We also use it to analyze and improve the performance and functionality of our products and services.

• For Marketing and Communications: We may send you marketing communications about our product updates, newsletters, and promotional materials, but you have the right to opt out at any time.

• For Analytics and Research: We analyze usage trends to develop new features and better understand how our products and services are used and to inform business decisions.

• For Security and Fraud Prevention: We use data to protect against fraudulent, cyber threats, unauthorized access, or illegal activities and to ensure the security of our services.

• To Comply with Legal Obligations: We may process and retain your data to meet legal, regulatory, and audit requirements in jurisdictions where we operate.

5. Legal Bases for Processing Depending on the jurisdiction and context, we rely on one or more of the following legal bases:

• Consent: When you voluntarily provide data or opt in to communications.

• Contractual Necessity: When processing is required to fulfill a contract or pre-contractual request.

• Legal Obligation: When required by law, regulation, or court order.

• Legitimate Interests: When processing supports our business operations and does not override your rights.

• Vital Interests: In rare cases, to protect life or safety.

6. Data Sharing and Third Parties We do not sell, rent, trade, or disclose your personal or any confidential information to any third party. We may share personal data with trusted third parties under strict confidentiality and data protection agreements:

• Service Providers: We engage vendors who perform services on our behalf, such as payment processing, IT infrastructure, cloud hosting, logistics, and data analysis. These vendors are contractually obligated to protect your data.

• Business Partners: Joint ventures, OEMs, and distributors under formal agreements.

• Regulatory Bodies: We may disclose your information to comply with legal processes, such as government agencies, customs authorities, or legal entities as required by law, to protect our rights.

• Corporate Affiliates and Transactions: Subsidiaries and parent companies for internal governance and resource allocation. If we are involved in a merger, acquisition, or asset sale, your data may be transferred to the new owner.

• With Your Consent: We may share your data with other third parties when you give us your explicit consent.

7. International Data Transfers As a company with global operations and partnerships, we may transfer your personal data across borders. We ensure that any such transfers comply with applicable data protection laws. We implement appropriate safeguards, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission.

• Binding Corporate Rules (BCRs) where applicable.

• Data Processing Agreements (DPAs) with third-party vendors.

• Local compliance mechanisms in countries such as Malaysia, the United States, and the European Union. We assess the legal and technical adequacy of each transfer and ensure that data subjects’ rights are preserved.

8. Data Retention and Archiving We retain personal data only for as long as necessary to fulfill the purposes outlined in this policy, or as required by applicable law. Retention periods vary based on:

• Contractual obligations.

• Regulatory requirements (e.g., tax, export control, product traceability).

• Internal audit and risk management policies. Upon expiration of the retention period, data is securely deleted or anonymized.

9. Data Security Measures We implement robust technical and organizational measures to protect your personal data from unauthorized access, disclosure, and loss, including:

• Encryption: Data at rest and in transit is encrypted using industry-standard protocols.

• Access Controls: Role-based access, multi-factor authentication, and audit trails. Access to personal data is limited to authorized personnel with a legitimate business need.

• Network Security: Firewalls, intrusion detection systems, and endpoint protection.

• Regular Audits: We conduct regular audits to assess the effectiveness of our privacy and security measures.

• Operational Safeguards: Employee training, incident response plans, and regular penetration testing.

• Secure Disposal: When no longer needed, data is securely disposed of. We continuously monitor and update our security posture to address emerging threats.

10. Your Rights and Choices Depending on your jurisdiction and applicable law, you may have the following rights:

• Access: Request a copy of your personal data.

• Correction: Request corrections to inaccurate or incomplete data.

• Deletion: Request erasure of your data (“right to be forgotten”), subject to legal requirements.

• Restriction: Request limited processing under certain conditions.

• Portability: Receive your data in a structured, machine-readable format.

• Objection: Object to processing based on legitimate interests or direct marketing.

• Consent Withdrawal: Revoke previously granted consent at any time. To exercise these rights, please contact us using the details in Section 13. We will respond within the legally mandated timeframe.

11. Children’s Privacy Our products and services are not directed to individuals under the age of 16. We do not knowingly collect or process personal data from minors without parental consent. If we become aware of such data, we will delete it promptly.

12. Policy Updates and Notifications We may revise this policy periodically to reflect changes in law, technology, or business practices. When updates are material, we will notify affected individuals via email, in-app notifications, or on our website. The “Last Updated” date at the top of this policy reflects the most recent changes.

13. Contact Information If you have questions, concerns, or requests regarding this policy or your personal data, please contact:

Siargo Privacy Office

Email: support@siargo.com

Address: 4677 Old Ironsides Drive, Suite 310, Santa Clara, CA 95054 USA

Phone: +01 408 9690368

Website: www.Siargo.com

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