DATA PROTECTION NOTICE FOR CUSTOMERS

DATA PROTECTION NOTICE FOR CUSTOMERS

This Data Protection Notice (“Notice”) sets out the basis on which PRIMESOFT PTE. LTD. (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our users in accordance with the Personal Data Protection Act (“PDPA”).

This Notice applies globally to users of the CyberShieldAI App and complies with applicable data protection laws based on your location, including the EU General Data Protection Regulation (GDPR), China’s Personal Information Protection Law (PIPL), California’s Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), in addition to Singapore’s PDPA. Network activity data (e.g., IP addresses and ports) may constitute personal data under these laws. We do not “sell” or “share” personal information as defined under CCPA/CPRA. The App processes all data locally on your device (on-device only) with no upload to our servers or any third-party servers.

This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

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PERSONAL DATA

1. As used in this Notice: “customer” or “user” means an individual who has downloaded, installed, or uses the CyberShieldAI App; and “personal data” means data, whether true or not, about a user who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

2. Depending on the features you enable in the CyberShieldAI App, examples of personal data we may process include:

   • Network traffic data (e.g., IP addresses, ports, and packet features) processed in real time for anomaly detection;

   • Device identifiers and anonymised usage statistics (only if you voluntarily enable notifications or automatic updates).

   No biometric data, photographs, video, or audio content is collected or processed.

3. The CyberShieldAI App is intended exclusively for private home networks. Users must not monitor public networks or networks not under their exclusive private control.

4. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

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COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

1. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly after you have been notified of the purposes for which the data is collected and you have provided consent, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other applicable laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

2. We may collect and use your personal data for the following purposes:

   • Enabling core network security features of the CyberShieldAI App, including real-time on-device anomaly detection using local machine learning to protect your private home network;

   • Responding to, handling, and processing queries, requests, complaints, and feedback from you;

   • Managing your relationship with us;

   • Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

   • Any other purposes for which you have provided the information; and

   • Providing app features by locally processing network traffic and optional usage data on your device without uploading to our servers.

3. We may disclose your personal data only:

   • Where such disclosure is required for performing obligations in the course of or in connection with our provision of the services requested by you;

   • To third-party service providers, agents and other organisations we have engaged to perform any of the functions referenced above, with appropriate data protection obligations imposed on them; or

   • Where required or authorised by law, including to comply with legal obligations or respond to lawful requests from authorities.

4. No cross-border transfers of personal data occur. All processing takes place locally on your device.

5. Consent is obtained via in-app acceptance of this Notice and the Privacy Policy. For any optional features (e.g., notifications), separate consent is obtained through your explicit enabling of the feature.

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WITHDRAWING YOUR CONSENT

1. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is withdrawn by you. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by using the in-app “One-Click Withdraw All Consents” feature (which immediately withdraws consent, stops all monitoring, deletes any optional usage data, and uninstalls/deletes the App from your device) or by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

2. For requests made via the in-app “One-Click Withdraw All Consents” feature, withdrawal will be processed immediately: all monitoring stops, any optional usage data is permanently deleted, and the App will be uninstalled and removed from your device. For written requests, we will process them within ten (10) business days of receipt and notify you of the consequences.

3. Whilst we respect your decision to withdraw your consent, please note that use of the in-app feature results in the immediate and irreversible uninstallation of the App. If you submit a written request instead, we may not be in a position to continue providing the App’s services to you and we shall notify you before completing the processing of your request. Withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.

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ACCESS TO AND CORRECTION OF PERSONAL DATA

1. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

2. We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond within thirty (30) days, we will inform you in writing of the time by which we will be able to respond.

3. Depending on your location, you may have further rights (we respond within legal timelines, e.g., 30 days under GDPR/PIPL/PDPA; 45 days under CCPA/CPRA):

   • EU/EEA (GDPR): Erasure (“right to be forgotten”), data portability, objection to processing, restriction of processing. Lodge complaints with your national data protection authority.

   • China (PIPL): Similar rights, including for sensitive data. Complaints to relevant authorities (e.g., CAC).

   • California (CCPA/CPRA): Right to know categories/sources of personal information collected/disclosed (none sold/shared by us); right to delete; limit use of sensitive personal information (none collected); non-discrimination for exercising rights.

   To exercise these rights, contact our DPO (details below). We verify requests and may require identity proof.

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PROTECTION OF PERSONAL DATA

1. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as:

   • Minimised collection of personal data;

   • Strict data minimization and real-time processing only (no permanent storage of network traffic data);

   • Encryption of data;

   • Authentication and access controls;

   • Local/on-device processing only: all network traffic monitoring and anomaly detection occur exclusively on your device, with no upload to our servers;

   • Data protected by system-level encryption in the app’s designated local memory;

   • No permanent storage of network traffic data: all data is processed in real time and discarded immediately;

   • Regular app updates and vulnerability patching: we release updates to address security issues; users are encouraged to keep the app and device OS up-to-date.

2. You should be aware, however, that no method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

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ACCURACY OF PERSONAL DATA

1. We generally rely on personal data provided by you. In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

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RETENTION OF PERSONAL DATA

1. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

2. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes. Network traffic data is never stored.

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TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

1. We do not transfer your personal data to countries outside of Singapore. All processing occurs locally on your device.

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DATA PROTECTION OFFICER

1. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

   Contact Email Address: info@primesoft.com.sg

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EFFECT OF NOTICE AND CHANGES TO NOTICE

1. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

2. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

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Effective date: 06/03/2026

Last updated: 07/03/2026