Last Updated Date: January 11, 2024

This Privacy Policy (the "Policy") explains how Safemo (as defined below) collects, uses and more generally processes your personal data in connection with your relationship with us when you use our websites, products, and mobile applications (collectively, the "Safemo Products and Services").

The Safemo Products and Services is provided or controlled by Safemo Pte. Ltd. and its affiliates (collectively, "Safemo", "We" or "Us").

To the extent that our processing of your personal data is subject to certain data privacy protection laws (including, but not limited to, Personal Data Protection Act ("PDPA"), the European Union' s General Data Protection Regulation ("GDPR"), the California Consumer Privacy Act of 2018 ("CCPA"), collectively hereafter "applicable laws").

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the processing of personal data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy. If you do not agree to this Policy, please do not access the website, the App or otherwise use the Service.

Contents

1.Collection and Creation of Personal Data

2.Purposes of Processing

3.Disclosure of Personal Data to Third Parties

4.International Transfer of Personal Data

5.Security of Your Personal Data

6.Retention of Your Personal Data

7.Your Control and Choices

8.Protection of Minors

9.Contact Us

1.Collection and Creation of Personal Data

We collect or obtain, and may process Personal Data about you from the following sources.

•Data provided to us: We collect or obtain the following categories of Personal Data when those data are provided to us (e.g., when you register an account with us, or when you contact us for customer services).

◦Basic contact details: such as email address when you create an account or contact us for customer service.

◦Customer support services related information: the information automatically stored or collected when providing customer support services, including communication records and contents; pictures or videos you upload; your email address provided when you leave a message to us; your requests and comments; name and contact information you provide, your purchase records; order information; and other necessary information.

•Device data: We do not collect personal data from your devices (Camera, Hub or any other hardware device), unless in certain specific scenarios, such as when you contact us for assistance with troubleshooting issues. In such scenario, we will ask for your permission.

•App data: We collect or obtain, and may process the following categories of Personal Data when you use our App.

◦Safemo account information: username, country/region, email address.

◦Operation information: operational behavior data, App usage frequency, crash data, running status, network log information (including App error logs, usage data).

◦Other personal data contained in content you submit to us, such as through our "Contact Us" feature, "Send Feedback" feature, "Upload Log" feature or customer support tools on our websites or mobile apps.

•Information you voluntarily share or post: we may collect personal data that you provide on Safemosite and Safemo-marked Web Apps and Mobile Apps, or post in a public space on our website, such as message boards. As another example, you can choose to share your Safemo camera access through an invitation link that you can send to friends.

2. Disclosure of Personal Data to Third Parties

Your personal data is securely stored and processed within the servers and facilities of Safemo, and may only be shared or disclosed under one of the following circumstances:

•share your Safemo products with whom you invite to access your products when you explicitly send a sharing invitation link or request;

•sending data to third party service providers who perform services on our behalf based on our instructions and in compliance with appropriate confidentiality and security measures. Examples of such services include: sending emails for customer support or marketing communications. We do not authorize our service providers to use or disclose your personal data except as necessary to perform services on our behalf or comply with legal requirements;

•legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;

•any relevant third-party provider, where the App uses third-party SDKs. Your personal data may be shared with the relevant third-party providers. We recommend that you review that third parties' privacy notices before interacting with their SDKs;

•disclosing your personal data with your explicit request and consent.

If we engage a third-party processor to process your personal data, the processor will be subject to binding contractual obligations to: (i) only process the personal data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the personal data; together with any additional requirements under applicable law.

3. International Transfer of Personal Data

We maintain servers located in the United States and Europe, and your personal data may be processed on servers located inside or outside of the country where you live. For example, personal data of users in the US are stored the US, but personal data of useres in United Kingdom may be stored in Germany. Because of the international nature of our business, your personal data may also be accessed by our affiliates to provide our products and services and for provision of IT systems for business support, or be transferred to third-party customer service providers and third-party SDK providers, in connection with the purposes set out in this Policy. For this reason, we transfer personal data to other jurisdictions that may have different laws and data protection compliance requirements to those that apply in the jurisdiction in which you are located. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your personal data is processed, we apply the same protections described in this Policy.

In the event of an international transfer of personal data, when required by applicable law, we will provide an adequate level of protection for your personal data using various means, including where appropriate, relying on a formal decision that a certain country ensures an adequate level of protection for personal data, or implementing the European Commission approved Standard Contractual Clauses and UK International Data Transfer Agreement between our affiliates and third parties (where applicable) or any other lawful approach that permits the lawful transfer of personal data from those countries.

4. Security of Your Personal Data

We have implemented appropriate technical and organizational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing, in accordance with applicable law.

Please note, the Internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any personal data that you send to us are sent securely.

5. Retention of Your Personal Data

We will use your personal data as described in Section I above and store your personal data with third-party cloud services providers. We take every reasonable step to ensure that your personal data are only processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain your personal data are as follows:

•we will retain personal data in a form that permits identification only for as long as:

◦we maintain an ongoing relationship with you (e.g., where you are a user of the App); or

◦your personal data are necessary in connection with the lawful purposes set out in this Policy, for which we have a valid legal basis to collect and process such personal data,

plus:

•the duration of:

◦applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your personal data, or to which your personal data are relevant); and

◦an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any personal data that are relevant to that claim),

and:

•if any relevant legal claims are brought, we continue to process personal data for such additional periods as are necessary in connection with that claim; we may also continue to process personal data if deleting the data would conflict with the requirement to protect the interest of the persons concerned; or if the processing is otherwise necessary in accordance with Art.17 (3) of the GDPR.

During the periods noted in paragraphs ii. a) and ii. b) above, we will restrict our processing of your personal data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods in paragraphs i., ii., and iii. above, each to the extent applicable, have concluded, we will either:

•permanently delete or destroy the relevant personal data; or

•anonymize the relevant personal data.

6. Your Control and Choices

Subject to applicable law, you may have the following rights regarding the processing of your personal data:

•the right not to provide your personal data to us (however, please note that we will be unable to provide you with the full benefit of the App if you do not provide us with some or all of your personal data);

•the right to request access to, or copies of, your personal data, together with information regarding the nature, processing and disclosure of those personal data;

•the right to request rectification of any inaccuracies in your personal data;

•the right to request deletion of your personal data;

•the right to restrict the processing of your personal data;

•the right to object on grounds relating to your particular situation, to the processing of your personal data by us or on our behalf;

•the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation;

•where we process your personal data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of your personal data in reliance upon any other available legal bases); and

•the right to lodge complaints regarding the processing of your personal data with an applicable data protection authority.

Depending on your jurisdiction, you may be entitled to additional rights in relation to your personal data. Please find more details of these rights in Section IX below.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy or about our processing of your personal data, or to file a complaint about how we process your personal data, please use the contact details provided in Section X below. We will respond to your request or complaint in due course under applicable data protection laws. Please note that:

•in some cases, it will be necessary to provide evidence of your identity before we can give effect to these rights; and

•where your request requires the establishment of additional facts (e.g., a determination of whether any processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

7. Protection of Minors

As required by applicable laws, we consider a user under the age of 18 as a minor. The Safemo Products and Services is not aimed at minors, and we do not knowingly collect personal data from minors. If you become aware that personal data about a minor has been provided to us, please immediately contact us by using the contact details provided in Section X below. That way, we can delete the information from our records.

8. Contact Us

If you have any questions or comments on this Policy or if you have any requests to exercise your rights, please email us at support@safemo.com or contact us at 505, Heng Loong Building, 61 Bukit Batok Cres, Singapore. We will review the issues involved as soon as possible and reply after verifying your user identity as soon as possible.