PRIVACY POLICY

This privacy policy (“Policy”) applies to Amgine Technologies US Inc. (herein referred to as “AMGiNE,” “we” or “us“) with respect to the personal data we collect via our website, the AMGiNE App and online services we provide, and was last updated January 2, 2025. We may change this policy at any time, and the same will be updated here. If you are an AMGiNE registered user or customer, we will notify you of the changes either by sending an e-mail or a notification on the AMGiNE mobile application (“App“). Please read such notices carefully.

We sincerely believe that you should always know what personal data we collect from you and the purposes for which that data is used, and that you should have the ability to make informed decisions about the personal data you share with us.

This Policy explains (i) how and why we collect, use and disclose your personal data in the various capacities in which you interact with us; and (ii) the rights that you have with regard to the personal data we collect. While we strongly advise you to read this Policy in full, the following summary provides a snapshot of the key points covered by the Policy:

• This Policy applies to AMGiNE, a company incorporated under the laws of United States of America, and having its registered office at 3500 South Dupont Hwy, Suite BJ-101, Dover, DE 19901 US.
• The personal data we collect and how we use and disclose it varies based on the capacity in which you interact with us or use our products and services. For example, you could be (i) a visitor to www.amgine.ai (“Website”) or any pages of our Website (“Visitor”); (ii) a person individually or on behalf of an entity using one of our products and services (“Customer”); or (iii) an employee/agent/representative/appointee of a customer who uses any of our products and services (“User”).
• Based on whether you are a Visitor, Customer or User, the type of personal data we collect and the purpose for which we use and/or disclose it will differ, as explained in this Policy.
• This Policy identifies the rights available to you regarding the personal data you share with us.

If you have any questions or concerns with this Policy, please contact our Grievance Officer at the address indicated at the end of this Policy. If you do not agree with this Policy, we would advise you not to use the Website, the App or our products or services (collectively “Services”).

PERSONAL DATA WE COLLECT

The personal data we collect includes what you provide to us, as well as certain data collected through automated processes, such as the following:

HOW WE USE PERSONAL DATA

We may use personal data as follows:

Information transferred via the Google API. AMGiNE’s use and disclosure of data received from Google APIs will adhere to Google API Services User Data Policy, including its limited use requirements.

FOR THE AVOIDANCE OF ANY DOUBT, IF WE ANONYMIZE AND AGGREGATE PERSONAL DATA, WE MAY USE SUCH ANONYMIZED DATA FREELY, WITHOUT ANY RESTRICTIONS OTHER THAN THOSE THAT MAY BE IMPOSED BY APPLICABLE LAW.

If we intend to use personal data for a purpose unrelated to our rendering a Service to you, or in a manner not otherwise indicated in this Policy, we will request your consent. You may choose to withdraw your consent at any time by contacting our Grievance Officer at the address indicated at the end of this Policy.

AMGiNE uses artificial intelligence (AI) to enhance the Services. For example, we use AI to verify that personal data is processed accurately, efficiently and securely. All AI-driven data processing is performed with a commitment to safeguarding customer privacy. We implement strict access controls, utilize encryption and conduct regular audits designed to prevent unauthorized access to or use of personal data. Our AI models are trained only on data necessary to deliver our Services, and we adhere to industry practices to anonymize and aggregate data wherever possible to protect individual identities.

We do not use personal data to train external models or for any purpose beyond the agreed-upon scope of our Services. Any personal data processed by our AI systems is handled in compliance with those data protection laws that apply to AMGiNE in our providing the Services to you, such as the GDPR, CCPA and other U.S. state data protection laws, as applicable.

DISCLOSURE OF PERSONAL DATA In the ordinary course of business, we may employ other companies and people to assist us in providing certain components of our Services, such as subcontractors we engage. To do so, they may need access to personal data. We require these third parties to safeguard personal data consistent with this Policy. For example, we may engage subcontractors to provide data analysis, marketing assistance, credit card processing, and facilitate customer service.

We may also disclose personal data:

• To comply with applicable law or to respond to legal process or inquiries by law enforcement, such as a search warrant, court order or subpoena;
• To protect our safety, your safety or the safety of others, or in the legitimate interest of any party in the context of national security, law enforcement, litigation, criminal investigation or to prevent death or imminent bodily harm;
• If required in connection with legal proceedings brought against AMGiNE, its officers, employees, affiliates, customers, subcontractors or vendors;
• To establish, exercise, protect, defend and/or enforce our legal rights; and
• In connection with a corporate transaction, such as a merger, acquisition,

YOUR RIGHTS UNDER EU AND UK LAW

This section pertains to data subjects in the European Union (EU) and United Kingdom (UK), and addresses the General Data Protection Regulation (GDPR) and UK GDPR, as applicable. The controller of personal data for purposes of this Policy is AMGiNE.

If you are in the EU or UK, and our Processing is subject to the GDPR or UK GDPR, under the GDPR or UK GDPR you have the:

1. RIGHT TO BE INFORMED about the manner in which your personal data is collected, used and disclosed, which we have endeavored to do by way of this Policy.
2. RIGHT OF ACCESS to the personal data you have provided by requesting that we to provide you with the same.
3. RIGHT TO RECTIFICATION to request that we amend or update your personal data if it is inaccurate or incomplete.
4. RIGHT TO ERASURE to request that we delete your personal data.
5. RIGHT TO RESTRICT – to request that we temporarily or permanently stop processing all or some of your personal data.
6. RIGHT TO OBJECT to our processing of your personal data under certain circumstances. You have an absolute right to object to us processing your personal data for the purposes of direct marketing.
7. RIGHT TO DATA PORTABILITY to request that we provide you with a copy of your personal data in electronic format to use for a third party’s product or service.
8. RIGHT NOT TO BE SUBJECT TO A DECISION BASED SOLELY ON AUTOMATED DECISION-MAKING, including profiling.

If you want to exercise the rights set out above, you may contact our Grievance Officer at the address indicated at the end of this Policy.

The bases on which we engage in processing are as follows:

Where we process personal data based on your consent, you have the right to withdraw that consent at any time. As indicated above, we may process personal data to render Services to you, or in order to take steps in anticipation of rendering such Services. If you do not provide certain personal data, we may not be able to provide the Services or all of the Services.

We may also process personal data where we have a legitimate interest to do so. Our legitimate interests include the processing of personal data where it is necessary for us to understand our customers, enhance and promote our goods, products and services and operate effectively as an international provider of various products and services. Our legitimate interests may also include creating and publicizing new products and services, offering our customers a better experience, detecting fraud and abuse, and protecting our rights and the rights of others. For example, we may perform analytics as necessary to provide you with a tailored experience and so that we can improve, maintain and manage our products and services in a way that meets your expectations as a customer.

We may collect, process and store personal data in the United States (U.S.) and other countries not deemed ‘adequate’ by the European Commission (EC) or UK Secretary of States. In order for us to facilitate our operations, we may also transfer, process and store personal data at a database server in a third-country for contingency and disaster recovery purposes. Your rights and protections will, under no circumstances, be diluted by this transfer. Where applicable, if the entities to which transfers of personal data from the EU are not situated in countries deemed ‘adequate’ by the EC or UK Secretary of State, we will undertake measures consistent with the GDPR or UK GDPR, as applicable, to effectuate such transfers.

If you believe we have used your personal data in violation of the rights above or have not responded to your objections, you may contact our Grievance Officer at the address indicated at the end of this Policy, or lodge a complaint with your local supervisory authority.

Additionally, please note the following:

• If you are a Customer or User using one of our Services to collect data about an EU or UK data subject from third parties, it is your sole obligation to inform such data subject about the source of such data and to take the necessary steps to otherwise comply with the applicable law, including the GDPR and UK GDPR, as applicable, for example by providing appropriate notice and obtaining consent.
• We do not collect any Special Categories of Personal Data. Further, if you are a Customer or User, you agree not to, under any circumstances, whether directly or indirectly, use our Services to collect or process Special Categories of Personal Data, or transfer to us any such data.
• The term “Special Categories of Personal Data” has the meaning ascribed to it or the equivalent terminology under applicable law, including the GDPR and UK GDPR, as applicable, and shall include, without limitation, sensitive data and any data pertaining to a data subject’s race, ethnic origin, genetics, political affiliations, biometrics, health or sexual orientation.

YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

This section pertains to California consumers and addresses the CCPA.

As a California consumer, under the CCPA you have the right to:

• Notice of our personal information collection, use and disclosure practices (via this Policy)
• Request the—
  • Categories of personal information collected
  • Categories of sources from which personal information is collected
  • Business or commercial purpose for collecting, selling or sharing personal information
  • Categories of third parties to whom personal information is disclosed
  • Categories of personal information sold or shared, if any
  • Categories of third parties to whom personal information was sold or shared
  • Categories of personal information disclosed for a business purpose
  • Categories of persons to whom personal information was disclosed for a business purpose
  • Specific pieces of personal information collected
  • Correction of inaccurate personal information
  • Deletion of personal information
• Opt-out (or opt-in for children under 16) to the sale or sharing of personal information
• Equal service (no retaliation or discriminatory practices for exercising your CCPA rights
• Limit use of sensitive personal information to that necessary to perform the Services or provide the goods reasonably expected by an average consumer

Do Not Sell My Personal Information. Under the CCPA, sell means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, In writing, or by electronic or other means, a consumer’s personal information by the business to a third party for monetary or other valuable consideration.

We do not sell your personal information.

Do Not Share My Personal Information. Under the CCPA, share means the sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, of consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged.

We do not share your personal information.

Limit the Use of My Sensitive Personal Information. As a California consumer, you have the right to limit the use or disclosure of your sensitive personal information.

We do not anticipate receiving sensitive personal information.

If you would like to exercise the rights set out above, you may contact our Grievance Officer at the address indicated at the end of this Policy.

YOUR RIGHTS UNDER CERTAIN U.S. STATE DATA PROTECTION LAWS

This section pertains to consumers of certain U.S. states having data protection laws, other than California.

The rights of consumers in each state differ; however, generally, as a consumer of one of the states having data protection laws, you may have the right to:

• Confirm whether or not we are processing your personal data, and access to your personal data
• Correct inaccurate personal data
• Delete personal data
• Obtain a copy of personal data
• Opt-out of (i) the sale of personal data, (ii) targeted advertising, and/or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer

If you would like to exercise the rights set out above, you may contact our Grievance Officer at the address indicated at the end of this Policy.

Sale of Personal Data. Under certain U.S. state laws, you may have the right to opt-out of the sale of your personal data.

We do not sell your personal data.

Targeted Advertising. Under certain U.S. state laws, you may have the right to opt-out of targeted advertising.

We do not process your personal data for targeted advertising.

Profiling. Under certain U.S. state laws, you may have the right to opt-out of the use of your personal data for profiling in furtherance of decisions that produce legal or similarly significant effects.

We do not process your personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

Sensitive Data. Under certain U.S. state laws, you may have the right to opt-out of the processing of your sensitive personal data.

We do not anticipate receiving sensitive personal data.

RETENTION OF PERSONAL DATA

We will store personal data as long as it is necessary to facilitate your use of the Services and for legitimate legal and/or business purposes, such as improving our Services, attending to technical issues, and dealing with disputes, claims and legal actions.

We may need to retain your personal data even if you seek its deletion, if needed to comply with our legal obligations, such as to resolve disputes, claims and legal actions, and to enforce our agreements.

If you are a Customer, please be advised that (i) you will need to inform your leads about how you store and deal with any data you collect from them using one of our Services, in compliance with applicable laws including the GDPR and UK GDPR, as applicable; and (ii) after you terminate your usage of a Service, we may, unless legally prohibited, delete all data provided or collected by you from our servers.

TOOLS USED BY OUR CUSTOMERS

If you are a Customer, you may be able to use third party technologies. It is your sole obligation to review and understand the policies of the third parties providing such technologies as they pertain to personal data that may be processed by those technologies, and to inform your stakeholders about any such data processed and the implications of those policies.

SECURITY OF PERSONAL DATA

We implement industry-standard technical and organizational measures by using a variety of security technologies and procedures to help protect your personal data from unauthorized access, use, loss, destruction or disclosure. When we collect particularly sensitive data, it is encrypted using industry-standard cryptographic techniques such as SSL, TLS, RSA, and AES.

We adhere to the ISO/IEC 27001:2022 standard, an internationally recognized framework for Information Security Management Systems (ISMS). Our commitment to ISO 27001 requires that we follow rigorous security practices and maintain high standards for information security. We follow the following security practices to protect personal data:

GRIEVANCE OFFICER

The name and contact details of our Grievance Officer, who you may contact if you have any concerns, complaints or feedback pertaining to this Policy, are as follows: