EU/Swiss-US Privacy Shield Policy

Zenon LLC ("we/us/our") are committed to protecting and respecting your privacy. We participates in the EU-U.S. and Swiss-U.S. Privacy Shield frameworks issued by the U.S. Department of Commerce. We commits to comply with the Privacy Shield Principles with respect to Consumer Personal Data the company receives from the EU and Switzerland in reliance on the Privacy Shield.

This policy (and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

We the data controller is Zenon LLC, a company incorporated in USA with office at 31 Hudson Yards, 11th Floor New York, NY 10001

Definitions:

Client- any entity that obtains analytics, strategic or management consulting or other services from the Zenon LLC.

Consumer- means any natural person who is located in the EU or Switzerland but excludes any individual acting in his or her capacity as a Worker.

Controller- means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

EU- means the European Union and Iceland, Liechtenstein and Norway.

Personal Data- means any information, including Sensitive Data, that is (i) about an identified or identifiable individual, (ii) received by Zenon LLC in the U.S. from the EU or Switzerland, and (iii) recorded in any form.

Privacy Shield Principles- means the Principles and Supplemental Principles of the Privacy Shield.

Processor- means any natural or legal person, public authority, agency or other body that processes Personal Data on behalf of a Controller.

Sensitive Data- means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership (including trade union-related views or activities), sex life (including personal sexuality), information on social security measures, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings, or the sentence of any court in such proceedings (including administrative proceedings and criminal sanctions).

Worker- means any current, former, or prospective employee of the Zenon LLC, who is in the EU or Switzerland. For purposes of this Policy, “Worker” includes any managing director, temporary worker, intern, other non-permanent employee, contractor, or consultant of Zenon LLC, who is in the EU or Switzerland.

1. Information We May Collect

We may collect and process the following data about you:

As Data Processor:

We may receive personal data of consumers of its clients’ for providing analytics services. The consumers of our clients might be located in the EU and Switzerland. For example, in connection to providing analytics consulting or other services to our clients, we may access or obtain personal data about a client’s consumers located in the EU and Switzerland. In addition, Zenon LLC may access or obtain Personal Data about a Client’s Consumers located in the EU and Switzerland in connection with providing support services to the subsidiary and affiliates of Zenon LLC, during the course of providing:

A. data storage facility, website and application hosting and maintenance, email, telephony and network connectivity, and other information technology infrastructure and services

B. data back-up and restoration, disaster recovery and business continuity planning and

C. other technical, organizational, and administrative functions and resources.

As Data Controller:

We may also collect consumers personal data directly. Such collection happens, when a consumer visits our website and provides his/her personal details through the website. For example,

A. Information that user provides by filling in forms on our website. This includes information provided at the time of registering to create an account on our site or requesting further services.

B. We may also ask you for information when you report a problem with our site.

C. If you contact us, we may keep a record of that correspondence.

D. Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

E. We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns and does not identify any individual.

F. Our site uses certain cookies. A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our site. The cookies we use are "analytical" cookies (Google Analytics). They allow us to recognize and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way our website works, for example by ensuring that users are finding what they are looking for easily. You can change your website browser settings to reject cookies although this may impair the functionality of our website.

1.2 Information We May Disclose

As Data Processor:

We do not offer or otherwise disclose any personal information we collect as data processor except as described in this privacy policy. Information we get from clients and data is transferred to us in US on behalf of clients and since we do not have a direct relationship with client’s consumers, which might be in EU and Switzerland. Our clients are responsible for providing the relevant consumers with certain choices, appropriate notice, obtaining requisite consent.

As Data Controller:

We do not offer or otherwise disclose personal information we collect as data controller to any third party except as described in this privacy policy. We may disclose information about you

A. if we are required to do so by law or legal process

B. to law enforcement authorities or other government entities

C. when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation)

2 Notice

Information provided in this policy and the company’s website privacy policy about handling of personal data practices, comprising the types of personal data we may collect, the types of third parties to which we may disclose the personal data and the purposes for doing so, the rights and choices consumers have for limiting the use and disclosure of their personal data, and how to contact us about its practices concerning personal data. When we act as a processor and consumer personal data is transferred to Zenon LLC in the U.S. on behalf of a client, the client is responsible for providing appropriate notice to its consumers and obtaining the requisite consent. Relevant information also may be found in privacy notices pertaining to specific data processing activities.

3 Choice

As Data Controller:

When we collect personal data directly from consumers, the company generally offers those consumers the opportunity to choose whether their personal data may be

A. disclosed to third-party Controllers or

B. used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant Consumer.

To the extent required by the Privacy Shield Principles, we obtain opt-in consent for certain uses and disclosures of sensitive data. Consumers may contact us as indicated below regarding the company’s use or disclosure of their personal data. Unless we offer consumers an appropriate choice, the company uses Personal Data only for purposes that are materially the same as those indicated in this Policy or the company’s website Privacy Policy .

As Data Processor:

When we maintains personal data about consumers with whom we does not have a direct relationship because we obtained or maintains the consumers’ data as a Processor, our clients are responsible for providing the relevant consumers with certain choices with respect to the clients’ use or disclosure of the consumers’ personal data. We share consumer personal data with its affiliates and subsidiaries. We may disclose consumer personal data without offering an opportunity to opt out, and may be required to disclose the personal data, (a) to third-party processors the company has retained to perform services on its behalf and pursuant to its instructions, (b) if it is required to do so by law or legal process, or (c) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. We also reserves the right to transfer personal data in the event of an audit or if the company sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).

4 Accountability for Onward Transfer of Personal Data

As Data Controller:

This Policy and our website Privacy Policy describe our sharing of consumer personal data.

To the extent we act as a Controller, except as permitted or required by applicable law, we provide consumers with an opportunity to opt out of sharing their personal data with third-party controllers. We requires third-party controller or affiliates and subsidiaries to whom it discloses consumer personal data to contractually agree to (a) only process the personal data for limited and specified purposes consistent with the consent provided by the relevant consumer, (b) provide the same level of protection for personal data as is required by the Privacy Shield Principles, and (c) notify us and cease processing personal data (or take other reasonable and appropriate remedial steps) if the third-party controller or affiliates and subsidiaries determines that it cannot meet its obligation to provide the same level of protection for personal data as is required by the Privacy Shield Principles. With respect to transfers of consumer personal data to third-party controller or affiliates and subsidiaries processors, we (a) enters into a contract with each relevant processor, (b) transfers personal data to each such processor only for limited and specified purposes, (c) ascertains that the processor is obligated to provide the personal data with at least the same level of privacy protection as is required by the Privacy Shield Principles, (d) takes reasonable and appropriate steps to ensure that the processor effectively processes the personal data in a manner consistent with our obligations under the Privacy Shield Principles, (e) requires the processor to notify us if the processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, (f) upon notice, including under (g) above, takes reasonable and appropriate steps to stop and remediate unauthorized processing of the personal data by the processor, and (h) provides a summary or representative copy of the relevant privacy provisions of the processor contract to the Department of Commerce, upon request. we remain liable under the Privacy Shield Principles if the company’s third-party processor or affiliates and subsidiaries processors onward transfer recipients process relevant personal data in a manner inconsistent with the Privacy Shield Principles, unless we proves that it is not responsible for the event giving rise to the damage.

5 Security

We take reasonable and appropriate measures to protect consumer personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction, considering the risks involved in the processing and the nature of the personal data.

6 Data Integrity and Purpose Limitation

We limit the consumer personal data it processes to that which is relevant for the purposes of the processing. We do not process consumer personal data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant consumer. In addition, to the extent necessary for these purposes and consistent with its role as a Controller or Processor, we takes reasonable steps to ensure that the personal data the company processes is (a) reliable for its intended use, and (b) accurate, complete and current. In this regard, we relies on its consumers and clients (with respect to personal data of consumers with whom we do not have a direct relationship) to update and correct the relevant personal data to the extent necessary for the purposes for which the information was collected or subsequently authorized. Consumers (and Clients, as appropriate) may contact us as indicated below to request that we update or correct relevant Personal Data. Subject to applicable law, we retain consumer personal data in a form that identifies or renders identifiable the relevant consumer only for as long as it serves a purpose that is compatible with the purposes for which the personal data was collected or subsequently authorized by the consumer.

7 Access

As Data Controller:

Consumers generally have the right to access their personal data. Accordingly, to the extent we act as a Controller, where appropriate, we provide consumers with reasonable access to the personal data we maintain about them. We also provide a reasonable opportunity for those consumers to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles, as appropriate. We may limit or deny access to Personal Data where the burden or expense of providing access would be disproportionate to the risks to the consumer’s privacy in the case in question, or where the rights of persons other than the consumer would be violated. Consumers may request access to their personal data by contacting us as indicated below.

As Data Processor:

When we maintain personal data about consumers with whom we do not have a direct relationship because we maintain the consumers’ data as a Processor for its Clients, our clients are responsible for providing consumers with access to the personal data and the right to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles, as appropriate. In such circumstances, consumers should direct their questions to the appropriate our client. When a consumer is unable to contact the appropriate client, or does not obtain a response from the client, we will provide reasonable assistance in forwarding the Consumer’s request to the Client.

8 Recourse, Enforcement and Liability

As Data Controller:

We have procedures in place to help assure compliance with the privacy shield principles. We conducts an annual self-assessment of its consumer personal data practices to verify that the attestations and assertions we makes about its privacy shield privacy practices are true and that our privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.

In compliance with the Privacy Shield principles, we promise to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at dataprivacy@zenon.ai

In case consumer’s complaint cannot be resolved through our internal processes, we will cooperate with JAMS pursuant to the JAMS Privacy Shield Program, which is described on the JAMS website. JAMS mediation may be commenced as provided for in the JAMS rules. Following the dispute resolution process, the mediator or the consumer may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers over us. Under certain circumstances, consumers also may be able to invoke binding arbitration to address complaints about our compliance with the Privacy Shield Principles.

We have further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.

As Data Processor:

When we maintain personal data about consumers with whom we do not have a direct relationship because we maintain the consumers’ data as a processor for its clients, consumers may submit complaints concerning the processing of their personal data to the relevant Client, in accordance with the client’s dispute resolution process. We will participate in this process at the request of the client or the consumer.

9 Privacy Shield Website

To learn more about the Privacy Shield program, and to view our certification, please visit Privacy Shield website

10 How to Contact Us

If you would like us to update information we have about you or your preferences, please contact us by email at dataprivacy@zenon.ai. You also may write to:

Zenon, LLC

Attn: Legal Department

31 Hudson Yards, 11th Floor

New York, NY 10001