Privacy Policy

1. Scope

1.1 This Privacy Policy (hereinafter “Privacy Policy”) covers all services provided by:

WelcomeBob Group A/S

CVR No 38600125

Pilestræde 52A

1112 Copenhagen K

(“WelcomeBob”, “we”, “our”, “us”, etc.) to Customers.

1.2 This Privacy Policy describes the types of Personal Data we collect, how we process such Personal Data and who you can contact if you have any questions or comments about this Privacy Policy.

1.3 The Privacy Policy describes our processing of Personal Data as the Data Controller for Personal Data. Our processing of Personal Data on behalf of Customers, as Data Processor, is governed by the Data Processing Agreement. See also Section 4 of this Privacy Policy.

2. Definitions

2.1 Terms and expressions with capital letters used in this Privacy Policy shall have the meanings set out in this clause 2.2.

2.2 “Customer”, “you”, “your”, etc., shall mean a customer of services provided by WelcomeBob.

2.3 “Data Controller” and “Data Processor” shall mean respectively “Responsible” and “Processor”, as defined in the GDPR.

3. Data processing

3.1. “Data Processing Agreement” shall mean the Data Processing Agreement entered into between Customer and WelcomeBob in connection with Customer's use of or subscription to the Services.

3.2 “GDPR” shall mean the General Data Protection Regulation (EU Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data. In Denmark, the GDPR is supplemented by the Act on Additional Provisions to the Regulation on the Protection of Individuals with regard to the Processing of Personal Data and on the Free Movement of Such Data (Act No 502 of 23 May 2018, as amended from time to time) (the “Data Protection Act”).

3.3 “Personal Data” shall mean any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is a person who can be directly or indirectly identified, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the the natural person concerned. The categories of Personal Data processed by WelcomeBob are specified in Section 5.

3.4 “Services” shall mean all services provided by WelcomeBob to Customers in connection with the WelcomeBob access control system, including the access control product actually purchased, corresponding systems and software, the WelcomeBob app or other software programs developed by WelcomeBob, support and help desk services, etc.

4. Data processing on behalf of Customers

4.1 With respect to all Personal Data entered, transferred or stored on behalf of Customers in the databases of WelcomeBob or third party providers in connection with WelcomeBob's provision of the Services, the Customer is the Data Processor and WelcomeBob is the Data Processor.

4.2 WelcomeBob's processing of Personal Data on behalf of the Customer in relation to the Services is governed by the Data Processing Agreement entered into by the Parties upon the Customer's subscription to the Services.

5. Application Features:
5.1 Ad-free Application: Our application does not contain advertisements and is designed to provide an ad-free user experience.
5.2 Suitable for all ages: We confirm that our application is suitable for users of all ages. We have taken into account the needs of different age groups and have implemented appropriate measures to ensure that the content is appropriate and safe for all users, regardless of age.
5.3 Using SMS Permissions: Our Android application requires permission to receive SMS messages (android.permission.receive_SMS) to automatically insert a one-time SMS code so that you can access an iLOQ key in the app. The app only collects SMS if the sender's number matches iLOQ. Text messages will only be stored locally. This permission is not required, but improves the user experience.

6. Categories of Personal Data

6.1 Personal Data includes information that can be used to identify you as an individual. If you sign up for a use, we ask you to provide us with certain personally identifiable information that can be used to identify you, including:

- Contact information such as name, phone number, email and postal address;

- Account information such as online password and other login details used to access WelcomeBob's Services;

- If you subscribe to our Services, we will ask you for an address and a company registration number (CVR No. );

- Product setup information such as the name and description of your WelcomeBob product and the location where you install your WelcomeBob product and adjustments you make to the product setup;

- Product usage information then

as door unlocking and sharing keys to identify users in case of abuse;

- Social media handles, content and other data posted on our official social media pages;

- Information we obtain from third party social media services (e.g. Facebook, Google) or payment services, if you choose to link to, create or log into your WelcomeBob account through these services;

- Information you submit in connection with a career opportunity with WelcomeBob, such as contact details, information in your application and details of your current employment; and

- Other personal information contained in content you submit to us, such as through our “Contact Us” feature or customer support tools on our websites or mobile apps.

6.2 When you use our website, www.WelcomeBob.com, we collect information about your use of our website through so-called “cookies”. See section 11 of this Privacy Policy for more information.

6. Our Purpose of Processing Personal Data

6.1 Our Services are designed to allow you to see, hear and talk to anyone through your WelcomeBob device or mobile device and collaborate with others in your local community. To provide you with the Services, we process and store logs (and related information) captured when you use our Services, such as live video or audio streams, images, comments and data our products collect from their surroundings to perform their functions. We do not record video or audio streams. Logs are encrypted and stored securely in a separate database. See also paragraph 10 on “Safeguards”.

7.2 Privacy, data protection and video surveillance laws in your jurisdiction may apply to your use of our products and services and the processing of personal data in connection therewith. You are responsible for ensuring that you comply with applicable law when using our products or services, and process personal data about individuals in this context. For example, you may need to display a notice informing visitors to your home that you are using our products or services. Recording, recording or sharing video or audio content involving other individuals, or recording other people's facial features, may affect their privacy and data protection rights.

7.3 We process the Personal Data we collect for the following purposes:

- Establish and manage your WelcomeBob account and profile;

- Process and fulfill requirements and orders related to our products and services and keep you informed of the status of your order;

- Personalize your experience with our products and services;

- Allow you to stream content through our services;

- Identify and authenticate you so that you can access certain content or use certain of our services;

- App use to create log for accessing and sharing users;

- Communicate with you and provide customer support;

- Allow you to interact with certain third-party products or services (for example, to enable you to link to or view content from third-party sites within our Services, or to connect to third-party products and services through the WelcomeBob Service);

- Provide functionality, analyze performance, troubleshoot, correct errors, and improve the usability and efficiency of our products and services;

- Evaluate, develop and improve our business (including analyzing and improving our products and services; conducting research and developing new products and services; managing and evaluating the effectiveness of our communications; performing accounting, auditing, billing reconciliation and recovery).

8 Transfer of Personal Data

8.1 WelcomeBob is located in Denmark and Personal Data is primarily processed in Denmark or other Member States within the EU/EEA. We store Personal Data on servers located in the Europe-West data region (currently located in Belgium).

8.2 However, from time to time, we may use third party providers located outside the EU/EEA or in the United States to facilitate, service or analyze the use of our Website or Services or for data hosting and storage. These third party suppliers and will only have access to your Personal Data if it is necessary to perform the agreed tasks. We ensure that third parties with access to Personal Data are obliged not to disclose or use Personal Data for any purpose other than to perform the agreed tasks.

8.3 Before transferring Personal Data to a third country or international organisation outside the EU/EEA, we will assess whether such transfer of Personal Data ensures an adequate level of protection for the Personal Data. We ensure that the transfer takes place in accordance with the rules on the transfer of personal data to third countries

or international organisations in the GDPR and the Danish Data Protection Act, including, where necessary, entering into data processing agreements with our data processors (see paragraph 8) on the basis of the European Commission's standard contractual provisions for the transfer of data between the EU and non-EU countries or under the EU-US Privacy Shield Framework.

7.4 Third Party Services

7.4.1 Through our WelcomeBob Service, you may choose to connect to certain third-party services offered by our business partners. To enable a connection and allow WelcomeBob products and services to interact with an available third-party service, each WelcomeBob connection requires the exchange of certain information between WelcomeBob and our business partner providing the third-party service. For example, to allow you to integrate WelcomeBob's products and services with those of our business partners, we may share certain account information with those business partners, such as your account ID and email address. In addition, we may share certain data our products collect from their surroundings that are necessary to perform their functions. In each case, we will only be part of a given third-party service if you choose to enable such a connection. You may revoke a connection to a third-party service at any time by contacting WelcomeBob at service@welcomebob.com or, depending on the specific third-party service, accessing your settings under your account with that service. Our business partners' privacy statements apply to any information practices of those partners and to the information shared with them.

9. Our Use of Data Processors

9.1 If third party providers act as data processors and process Personal Data on our behalf, we make sure to conclude data processing agreements with the data processors before the data processors carry out any processing of Personal Data on our behalf.

10. Retention of your Personal Data and Deletion

10.1 In accordance with the general principles of retention limitation set out in the GDPR, we will only retain your Personal Data for as long as necessary. The retention period (or retention) depends on the nature of the information and the background of the storage. Therefore, it is not possible to specify a specific time frame for the deletion of Personal Data in each case in this Privacy Policy. However, we have described our general storage rules in section 9.2 below.

10.2 Generally, we retain “keyholder” logs and related Personal Data for as long as the keyholder in question has an active user account with WelcomeBob and up to 6 months after its effective termination. Daily logs and related Personal Data are kept for 3 months from the effective termination of the Customer's use of our Services. However, Personal Data related to payments must be kept for five (5) years + the current calendar year after the end of the financial year in accordance with Danish accounting regulations. Personal data may be stored for a longer period if the Personal Data are necessary to establish, exercise or defend a legal claim.

11. Security measures

11.1 We have taken technical and organisational measures to prevent your information from being deleted, disclosed, lost, damaged, misused or otherwise unlawfully infringed.

11.2 All data transmitted between the gateway phone and users is encrypted. User profile information is stored in a separate database from other information. User passwords are encrypted and cannot be accessed by WelcomeBob. To access your account you must use your personal username and password and must go through our authentication process.

11.3 We host all data on up-to-date servers that are protected from unauthorized access by a firewall. We make a backup copy of Personal Data on our servers every 24 hours.

11.4 We have internal rules on information security. We have adopted internal rules on information security that contain instructions and measures to protect Personal Data from being destroyed, lost or altered, against unauthorized disclosure, and against unauthorized access or knowledge of it. We ensure that collected Personal Data is treated with care and protected in accordance with applicable security standards. We have strict security procedures for the collection, storage and transfer of Personal Data to prevent unauthorized access and comply with applicable laws.

11.5 The security of your data is very important to us, but remember that no online transmissions or methods of electronic storage are 100% secure. While we strive to use commercially validated means to protect your Personal Data, we cannot guarantee its absolute security.

11.6 We continuously assess the risks associated with the processing of Personal Data and implement all necessary technical and organisational measures to maintain an appropriate level of security for the Personal Data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage by applying appropriate technical and organisational measures.

I'm 12. Cookies and Tracking Technologies

12.1 Cookies are small text files that are placed on your computer, mobile phone or other device when you visit a website. Cookies are used to ensure the proper functioning of the website, as well as to provide information to the website owner.

12.2 We use cookies to improve your experience of our Website and Services. By using our Website and Services, you agree that we may place these types of cookies on your computer:

- Necessary cookies: These cookies are necessary for the proper functioning of the website. They provide basic features, like navigation and access to secure areas of the site.

- Preferences cookies: These cookies allow the website to remember information that changes the way the website behaves or looks, such as your preferred language or the region you are in.

- Statistics cookies: These cookies help us understand how visitors interact with our website by collecting and reporting information anonymously.

- Marketing cookies: These cookies are used to track visitors across websites. The intent is to show ads that are relevant and engaging to the individual user and thus more valuable to publishers and third-party advertisers.

12.3 For more information about cookies and how to manage them, please see our Cookie Policy.

I'm 13. Your Rights

13.1 The GDPR gives you certain rights in relation to your Personal Data. You have the right to request access to your Personal Data and to correct, update, delete or restrict the processing of your Personal Data. You also have the right to object to our processing of your Personal Data and to receive your Personal Data in a structured, commonly used and machine-readable format and to transfer this information to another data controller.

13.2 If you wish to exercise any of your rights under the GDPR, please contact us using the contact details provided below. We will respond to your request without undue delay and in accordance with applicable law.

He's 14. Contact Us

14.1 If you have any questions or comments about this Privacy Policy, your Personal Data or our processing of your Personal Data, please contact us:

Supporto

WelcomeBob Group A/S

Crown Princess Street 8

1306 Copenhagen K

service@welcomebob.com

15. Changes to this Privacy Policy

15.1 We reserve the right to update or amend this Privacy Policy from time to time. Any changes to this Privacy Policy will take effect when posted on our website.

15.2 If we make material changes to this Privacy Policy, we will notify you either by sending you an email to the email address you have provided us or by placing a prominent notice on our website. We encourage you to review this Privacy Policy regularly to keep you informed of how we protect your Personal Data.

‍