Effective date: January 1, 2025

Protecting your privacy is important to DashThru Technology Ltd.(hereinafter referred to as “DashThru”). This Privacy Statement explains how DashThru processes personal data collected through websites, products, and services (“applications”), including those distributed by our resellers and other channel partners, and through in-person and digital events, webinars, surveys, marketing activities, and visits to our premises (along with applications, collectively our “offerings”). References to “DashThru,” “we,” or “our” means DashThru, Ltd. and other entities that belong to the DashThru corporate family and that link to this Privacy Statement.

We may display just in time privacy notices on occasion, such as when we believe on-the-spot transparency would help you make an informed choice about whether to provide personal data. For example, you may see a just in time privacy notice explaining a particular data collection program, or you may see a just in time privacy notice when registering for an event.

This Privacy Statement describes how we process personal data for our own purposes. We also process personal data on behalf of our customers subject to a written contract. We do not control the data processing or protection practices of our customers, which may differ from those set out in this Privacy Statement. Our Privacy Statement applies only to data collected by DashThru. We may provide links to third-party websites, but we are not responsible for their privacy practices. When you click on these links, you will be subject to the privacy practices of those websites. We encourage you to review their privacy statements before providing any information.

“Personal data” is information that identifies, or can reasonably be linked directly or indirectly to, an identifiable person. Personal data does not include information that is anonymous, de-identified, or aggregated, as those terms may be defined under applicable law. For purposes of this Privacy Statement, “personal data” and “personal information” have the same meaning and are used interchangeably. In some jurisdictions, publicly available information is also not considered personal data, and this Privacy Statement may not apply in those cases.

What information does DashThru collect about you?

We obtain personal data in different ways. Some personal data is collected directly from you. Other data is automatically collected or generated about how, when, and why you interact with us through our offerings, including data obtained through the use of cookies and other tracking technologies. We also obtain data about you from third parties.

Information you provide us:

We collect information directly from you, such as when you sign up for an account or use our offerings, register a product or service, sign up for our newsletter or for one of our events, interact with one of our events, surveys, activities or with social media, visit our premises, or otherwise contact us. The types of information we may collect from you include:

·Identifiers, such as your name, telephone number, physical and/or email addresses, account username, and account password.

·Professional information, such as your occupation, industry, professional licenses, work experience and employment history, and other qualifications.

·Commercial information, such as details about your subscription plans, the offerings that you have purchased, used and/or expressed interest in, and events you have attended.

·Financial account information, such as payment information you provide when making a purchase of or through an offering (we use third party payment providers to process these transfers as described below).

·Education information, such as your educational background and training records.

·Protected characteristics, such as your date of birth (where applicable).

·Information that may be deemed sensitive under applicable laws, such as usernames and passwords used to access your account, government identification numbers, and information regarding children.

·Visual, audio, and electronic information, such as your picture or signature; records of our interactions, such as correspondence, details of complaints and their resolutions, service records; your preferences, including your preferred tools, experience, language, and the frequency at which you wish to receive marketing communications.

Information we obtain or generate:

We automatically collect or generate certain personal data about you based on your interactions with us, such as when you use our offerings, and we may associate that information with your account. The information we automatically collect or generate includes:

·Identifiers, such as unique user identifiers, unique device identifiers, IP addresses, cookie identifiers, information about product licenses, and usernames.

·Internet or other electronic network activity information, such as the website domain visited; which activities and offerings are used, how, and for how long; posts, discussions, and other types of engagement with us, including on our blogs, discussion forums, or chat rooms; the use of any hyperlinks or downloadable content available through the offerings.

·Geolocation information, such as region, country, state, Zip or postal code.

·Electronic information, such as information about operating systems, device types, information about browsers, information relating to automatic updates and technical errors, information about your use of our offerings, including your preferred tools and experiences, and your engagement with our activities.

·Commercial information, such as records about interest in our offerings or completed purchases.

·Information that may be deemed sensitive under applicable laws, such as usernames and passwords used to access your account, and precise geolocation information.

·Physical characteristic data, such as data regarding your facial features, body/eye movements, and voice interactions, that is processed in limited circumstances, such as when you use a VR headset with DashThru products. This data is not used to identify you.

·Inferences drawn from any of the personal and offering usage information available to us.

We also use cookies (small text files stored by your web browser when you use websites) and related technologies, such as pixels and beacons (collectively “Cookies”), to collect and store information when you use our applications.

Except as described in our Privacy Statement and our Cookie Statement, whether we collect data through the use of Cookies is up to you. You can change your mind at any time by going into your application settings or by clicking a link in the footer of our websites. The relevant link may be titled “Cookie preferences," “Privacy settings,” or something similar.

Social Networking Data: We may include content, pixels, tags, buttons, or other tools that link to another company’s services and/or platform(s) (“Plugins”). If you use one of our offerings that contains Plugins, information can be transferred directly from your device to a third-party provider of services and/or platforms. We may not control the data collected by Plugins. If you are logged into a social network, the social network may be able to link your use of our offerings to their services and/or platform.

For example, if you interact with a Plugin by clicking on “Like,” “Follow,” or “Share,” or by writing a comment, this information may automatically appear in your profile on the relevant social network service or platform. Even if you are not logged in, the Plugins may send your IP address to social network services and/or platforms. Please note this when using our offerings.

When you connect to a social networking service or platform on a device that is also used by others, these other users may be able to see information that is stored or displayed in connection with your profile on the social networking service page.

Information we collect from other parties:

We receive and process information from our affiliates and from third-party sources, including employers, business partners, business contact databases, enrichment services, channel partners (e.g., resellers), marketing service providers, third-party data aggregators, and social networking services and platforms (e.g., LinkedIn and Facebook). We also receive information from publicly available sources and licensors. The categories of personal information we collect from these sources include:

·Identifiers, such as names, phone numbers, and email addresses.

·Professional information, such as occupations, industries, professional licenses, work experience and employment histories, and other qualifications.

·Education information, such as your educational background.

·Commercial information, such as events you have attended or activities you have participated in.

·Inferences, such as regarding usage information and your preferences, behaviors, and other attributes.

In accordance with applicable law, we may combine your personal data with information we collect from other parties to help keep our databases current and accurate, and to provide you with more relevant content, experiences, applications, and other offerings.

How does DashThru use the information it collects about you?

We collect and use your personal information for the following purposes:

·To validate your identity as necessary to perform our contract with you.

·To deliver services, products, and other offerings, including information such as insights and recommendations, as necessary to fulfill our contractual obligations. For example, we may analyze usage information for billing or discount purposes.

·To send you important information, such as about your account or purchases, updates and patches within the scope of our contract with you.

·To send you information you requested to the extent necessary to perform our contract with you or, when not necessary to perform a contract, in furtherance of our legitimate interest, for example, in responding to customer inquiries.

·To maintain and improve the security of, and to troubleshoot any issues relating to, our offerings as necessary to perform our contract with you or, when not necessary to perform a contract, in furtherance of our legitimate interest in protecting our business.

·To anonymize, aggregate, or de-identify your personal data so it can no longer identify you in furtherance of our legitimate interest in conducting research and analysis. When we de-identify personal data, we will not attempt to re-identify the data except for the purpose of confirming that it is de-identified.

·To develop and improve our current and future offerings and your experience, including through the use of automated systems that analyze data using machine learning and other analytic techniques, in furtherance of our legitimate interests or, where needed, with consent.

·To understand the ways our offerings are used and who is using them in furtherance of our legitimate interest in improving our offerings and the overall user experience or, where needed, with consent.

·To analyze information about how you interact or may interact with us or our offerings in furtherance of our legitimate interest in improving our offerings and your experience with us or, where needed, with consent.

·To make strategic decisions concerning our business operations, including reporting on the performance of our business, in furtherance of our legitimate interest in making those decisions or, where needed, with consent.

·To send you learning content, tutorials, suggestions, newsletters, surveys, or other information, including information that may be relevant to your interests or preferences, in furtherance of our legitimate interest in improving your customer experience or, where needed, with consent.

·To deliver targeted advertising and send you promotional offers, advertising, or other marketing content in furtherance of our legitimate interest to engage in direct marketing or with consent as required by applicable law.

·To detect, prevent, or otherwise address non-valid use such as through fraud and software piracy (e.g., to confirm that software is genuine and properly licensed) and to protect you, DashThru, and/or third parties in furtherance of our legitimate interests.

·To enforce, and review compliance with, the legal terms that govern our offerings in furtherance of our legitimate interest in ensuring adherence to the relevant terms.

·To comply with our legal obligations under applicable laws.

·To protect the rights, safety, and property of DashThru, you, or any third party in furtherance of our legitimate interest in protecting us, our users, and third parties.

·For other purposes for which we obtain your consent.

·As further described in our offerings, such as in a supplemental notice, or in our About Boxes (available via Settings in your application).

Where we rely on your consent to process personal data, you may withdraw your consent at any time by contacting us at the contact details below or as otherwise indicated to you in writing. Please note that your withdrawal of consent will not affect our processing activities based on your consent that occurred before your withdrawal.

Where we rely on our legitimate interests to process your personal information, we balance your rights against ours so that our interest is not overridden by the interests you have to protect your information. You may also have the right to object to that processing on the basis of circumstances specific to you.

When we process personal data about you to comply with legal requirements or to perform our obligations under a contract with you or with our customer through whom you use our offerings, failure to provide such data may prevent or delay our fulfillment of these obligations.

How does DashThru disclose your personal data?

We disclose the categories of information described above to the following categories of persons:

·Our service providers, including vendors, consultants, contractors, and other service providers who perform services or functions on our behalf, for business purposes. For example, our service providers include companies who support us with marketing, sales, consulting, communications, software maintenance and support, analytics, social media, market research, auditing for valid use, license compliance, security, user verification, localization, and payment processing. Our service providers process your information subject to contractual terms that restrict their ability to use your information.

·Our business partners, such as integration partners, channel partners (e.g., resellers), event sponsors, partners, and attendees, Ad Partners, and DashThru’s App Store publishers, with whom you interact to facilitate your relationship with DashThru and those business partners for any of the purposes described in our or those business partners’ privacy statements.

·Our affiliates, for any of the purposes and uses of information described in this Privacy Statement, including providing you with integrated offerings (including administering purchases, services, and payments across our integrated offerings) in furtherance of our legitimate interests.

·Social networking services and platforms to connect with or share information publicly, with service providers, or with your contacts on such services or platforms.

·Persons to whom we are required by law to provide information, such as pursuant to a subpoena or a court order.

·Law enforcement, legal counsel, or other reasonably necessary parties when we determine that such disclosure is reasonably necessary to: (a) comply with any applicable law, regulation, legal process, or appropriate government request or to enforce or apply our terms and conditions or to establish, exercise or defend the rights of DashThru, DashThru personnel, customers or others; (b) prevent or respond to fraud or software piracy; (c) protect the rights, property, or safety of DashThru, our customers, and the public.

·Persons involved in the consideration, negotiation, completion of a business transaction, including the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, and any subsequent integration.

We may also disclose your personal information to other parties when we have your consent to do so or when you direct us to, for any purposes requested or permitted by you.

We may share aggregate, anonymous, or de-identified demographic, statistical, and other information regarding use of our offerings with third parties for marketing, analytics, planning, and other purposes. Such information will not specifically identify any particular user.

How does DashThru protect your data?

We maintain a combination of reasonable and appropriate physical, organizational, administrative, and technological procedures and controls to protect your data from unauthorized access, use, loss, alteration, destruction, modification or other malicious actions.

We take reasonable steps to limit the access employees, contractors, and agents of DashThru have to your personal data to those who need to know this data to perform their assigned functions. We limit the collection of personal data to what is reasonable and necessary to provide our offerings.

What are DashThru’s storage and data retention practices?

We store your personal data and content on our servers and the servers of our service providers. Because we and our service providers maintain servers in global locations, your personal data may be transferred across national borders and stored on the servers outside of your country or region. We will retain your personal data for as long as reasonably necessary or permitted and proportionate to the purpose for which it was collected. For example, to provide you with the offerings that you are using or have requested, for the establishment, exercise or defense of legal claims, and as needed to comply with our legal obligations. The criteria that we use to determine our retention period include the duration of our relationship with you, nature and sensitivity of the processed data, whether we have a legal obligation to keep the data, the risk of harm from unauthorized disclosure of data and whether the purpose of processing can be achieved by other means. Data may persist in copies made for backup and business continuity purposes for additional time. As described further below, you have the ability to delete information from your account at any time. There may be occasions where we are unable to fully delete, anonymize or de-identify your personal data due to technical, legal, regulatory compliance or other operational reasons.

What are DashThru’s marketing and advertising practices?

We use analytics tools and also work with one or more advertising networks and digital advertising partners (our “Ad Partners”) that use Cookies to collect information about application visitors, to serve ads, and to help us track results of advertising and marketing campaigns. Partners of our Ad Partners may also use Cookies to collect information from you for these purposes. Through these means, we and/or our Ad Partners and their partners may be able to collect information from application visitors, including websites visited, how and when applications are used, marketing preferences, IP addresses, device IDs, and browser information. This information is used to display personalized advertising in websites and other applications, to calculate and control the number of unique and repeat views of a given ad, to deliver ads that relate to a visitor’s interests, and to measure the effectiveness of ad campaigns. We process your personal data for the above activities in furtherance of our legitimate interests or, where required, with your consent.

You can opt out of the use of your information by certain Ad Partners for online behavioral advertising by using the Digital Advertising Alliance’s Your AdChoices tool. The Your AdChoices tool may not work if your browser does not accept third-party Cookies, and if you delete Cookies, use a different browser, or use a different computer, you will need to use the tool again to renew your opt-out.

As described above, you can change your Cookie preferences. Cookie choices are generally application-, browser-, and device-specific, so you may need to refresh your choices if you visit a different application, use a new browser or device, or clear your browser’s cookies.

Is the personal data you give us ever displayed publicly?

As always, we urge you to be mindful when deciding to disclose personal data, including on our offerings. Our offerings may allow you to post content, including comments and “likes,” that can be visible to the public.

In some cases, you can limit who can view or access the information and content you post. In other cases, the information and content might be available to registered members of the offering, or even to the general public. Your name, username, profile image, or email address (particularly if this is your username) may be posted along with any message or other content you post through some of our offerings.

If you are posting information you do not want to be disclosed publicly, make sure you are using an offering that allows you to control who sees information you have posted.

Will this Privacy Statement change?

We may change this Privacy Statement to reflect changes in the law, our data handling practices, or the features of our business. If we make material changes to our Privacy Statement, we will endeavor to provide you with notice before such changes take effect, such as through prominent notice on our website or services or by email.

How to contact us?

To contact us, please use the following contact information. When you do so, please tell us the name of the offering about which you are contacting us:

By email at: contact@dashthru.com

By postal mail:

RM A27,24TH FL

REGENT’S PARK PRINCE INDUSTRIAL BD

NO. 706 PRINCE EDWARD RD EAST

KL,HK