Version: 1.0 | Effective Date: 6 March 2026

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CyberShieldAI is a network security app that processes data in compliance with China's Personal Information Protection Law (PIPL), the EU General Data Protection Regulation (GDPR), Singapore's Personal Data Protection Act (PDPA), the California Consumer Privacy Act (CCPA), and the California Privacy Rights Act (CPRA).

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This Policy follows the principles of necessity, proportionality, privacy by design, data minimization, user rights, transparency, and robust security measures in accordance with all applicable laws.

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The app uses a local processing model: all data is processed solely on your device and is not uploaded to any servers. We do not sell or share personal data for commercial purposes (e.g., targeted advertising). For California residents, we comply with CCPA/CPRA requirements, including no sale or sharing of personal information and rights to know, delete, and limit use of sensitive personal information.

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1. Data Collection

• Network Traffic Monitoring: Real-time monitoring of network traffic data (e.g., IP addresses, ports, and packet features) using on-device machine learning for anomaly detection. No network traffic data is stored. The app starts in a fully disabled state with no monitoring or processing. Monitoring begins only after you manually click “Start Monitoring”.

• Optional Device and Usage Data : If you voluntarily enable notifications or automatic updates, the app may collect device identifiers and anonymized usage statistics solely for app functionality and improvement. These data points are processed locally where possible. No personal data of any kind is transmitted to our servers or any third party.

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2. Processing and Storage

• All data is encrypted and stored (where temporarily needed for real-time processing) in the app’s designated local memory on your device.

• No network traffic data, device identifiers, or usage statistics are uploaded to the cloud or transmitted to any servers. Processing occurs entirely on-device.

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3. Purposes of Processing

• Solely for providing the app’s network security features (e.g., anomaly detection and protection of your private home network).

• Optional usage data is used only to improve app performance and reliability.

• No other purposes. No sale or sharing of personal data with third parties for commercial use. Processing is limited to small-scale private use (not public or commercial networks).

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4. Data Deletion

• Network traffic data is processed in real-time and discarded immediately; it is never stored.

• Any optional device/usage data can be deleted at any time via app settings or by uninstalling the app (no backups are kept).

• All consents can be withdrawn via the settings page (“One-Click Withdraw All Consents”) (which immediately withdraws consent, stops all monitoring, permanently deletes any optional usage data, and uninstalls/deletes the App from your device) or by uninstalling the app manually. Monitoring and processing stop immediately.

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5. Third-Party Data

• Network traffic may incidentally include data from other devices or users on your private home network (e.g., family members or visitors). Processing is based on your explicit consent as the network administrator (GDPR Art. 6(1)(a), PDPA consent, PIPL consent, CCPA/CPRA informed consent) — not legitimate interests.

• Safeguards include full on-device processing, strict data minimization, no storage, and in-app transparency notices. The app is intended exclusively for private home networks.

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6. User Rights

• Monitoring and optional features are entirely voluntary.

• View or delete data via the app’s settings page.

• Rights under GDPR, PDPA, PIPL, CCPA/CPRA include access, correction, deletion, objection, and withdrawal of consent.

California Residents (CCPA/CPRA) Specific Rights:

• Right to Know: Categories collected include Internet or other electronic network activity information (e.g., IP addresses, ports, packet features) and device/usage data (if enabled).

• Right to Delete: Request deletion via the app or by contacting support.

• No Sale/No Share: We do not sell or share personal information for commercial purposes; no opt-out is needed.

• Limit Sensitive Personal Information Use: We do not collect or use sensitive personal information; network activity data is used solely for security purposes.

• Non-Discrimination: Exercising rights will not result in service degradation.

• How to Exercise: Contact info@primesoft.com.sg. We respond within 45 days (extendable by 45 days). Identity verification is required. Processing is free (limited to 2 requests per year).

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For other jurisdictions (GDPR/PDPA/PIPL), third parties may contact info@primesoft.com.sg; we respond within 1 month (or as required by law), free of charge.

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7. Security Measures

• Technical: All processing is on-device using local machine learning. Data is protected by system-level encryption in the app’s designated local memory. No permanent storage of network data occurs. Regular app updates address vulnerabilities.

• Notifications: A mandatory privacy popup appears on first launch, requiring explicit consent and commitment to “private home network use only; do not monitor public networks”.

• Restrictions: The Terms of Service prohibit public-network monitoring. In-app prompts help prevent misuse.

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8. Contact Information

Data Controller: PRIMESOFT PTE. LTD.

Email: info@primesoft.com.sg

Website: www.primesoft.com.sg

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9. Reminders

• For private home network use only. Do not monitor public networks. A popup reminder appears on install/first launch: “Do not monitor public networks; private home network use only.”

• The app is not intended for children under 13. We do not knowingly collect data from children.

• By using CyberShieldAI, you agree to this Policy.

Through privacy by design (local processing, data minimisation, strong encryption, and prominent notices) and best practices aligned with applicable standards, privacy risks are effectively controlled to an acceptably low level in compliance with GDPR, PDPA, PIPL, CCPA, and CPRA.

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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