Netision Privacy Policy

Netision is committed to the following principles for processing personal data:

• Lawfulness, Fairness, and Transparency: Data will be collected and processed lawfully, fairly, and transparently, ensuring individuals understand how their data is being used.
• Purpose Limitation: Data will be collected for specific, legitimate purposes and will not be used in a manner incompatible with those purposes.
• Data Minimization: Only the data that is necessary for specific purposes will be collected and processed.
• Accuracy: Netision will take reasonable steps to keep personal data accurate and up-to-date.
• Storage Limitation: Data will only be kept for as long as it is necessary for processing and in accordance with legal and contractual requirements.
• Integrity and Confidentiality: Personal data will be secured against unauthorized access, loss, or damage through appropriate technical and organizational measures.
• Accountability: Netision will be responsible for complying with data protection laws and will maintain appropriate documentation and processes.

Data Collection and Use

Netision collects personal data for the following purposes:

• Employee onboarding, payroll, and HR management.
• Customer relationship management and service delivery.
• Marketing, sales, and engagement.
• Legal compliance and regulatory reporting.

All data collected will be limited to what is necessary for the intended purpose, and all users will be informed about why their data is being collected.

Data Subject Rights

Netision recognizes the rights of individuals regarding their personal data, including:

• Right to Access: Individuals may request access to their personal data held by Netision.
• Right to Rectification: Individuals can request corrections of inaccurate or incomplete data.
• Right to Erasure (Right to be Forgotten): Individuals may request deletion of their data when it is no longer necessary for processing.
• Right to Restrict Processing: Individuals may request limited use of their data under specific conditions.
• Right to Data Portability: Individuals may request a copy of their data in a structured, commonly used, and machine-readable format.
• Right to Object: Individuals may object to the processing of their data based on legitimate interests or direct marketing.

Requests from data subjects will be responded to within the timeframe required by applicable regulations. Netision will verify the identity of the individual making the request to prevent unauthorized disclosures.

Data Protection Impact Assessments (DPIAs)

Netision conducts Data Protection Impact Assessments when introducing new data processing activities that may pose high risks to individuals' privacy. DPIAs help to evaluate and mitigate risks, ensuring that data protection principles are adhered to and potential impacts are identified and minimized.

Data Sharing and Third Parties

Netision only shares personal data with third parties when it is necessary for business operations, contractual obligations, or legal compliance. Before sharing data:

• Netision performs due diligence on third-party data protection standards.
• Netision ensures that data-sharing agreements with third parties reflect applicable data protection requirements.
• Netision requires third parties to protect personal data and use it only as agreed upon.

If data is transferred to third parties outside the EU, Netision ensures that appropriate safeguards are in place to protect data, such as EU Standard Contractual Clauses or Binding Corporate Rules.

Data Security Measures

Netision employs both technical and organizational measures to ensure the security and confidentiality of personal data. Security measures include:

• Access Control: Limiting access to data based on roles and responsibilities to prevent unauthorized access.
• Encryption: Encrypting data at rest and in transit to protect it from unauthorized access.
• Data Anonymization: Removing identifiable information from data sets to reduce risk when full identification is unnecessary.
• Regular Security Audits: Conducting periodic security assessments and audits to identify vulnerabilities and ensure compliance.
• Incident Response and Breach Notification: Establishing a response plan to handle security incidents, including notifying affected individuals and authorities within 72 hours when required by law.

Netision Privacy Notice

If you are located in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this GDPR Privacy Notice, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data, such as collection, use, storage and disclosure. Netision (“Netision”) will be the controller of your Personal Data processed in connection with the Services, except where we process Personal Data of our customers’ end users or employees while providing services to those customers—in which case, we act as the processor, and the customer acts as the controller.

For information about your data rights and processing activities where we are the controller, please contact us at privacy@netision.com. For inquiries regarding data processing where we act as the processor, please reach out to the respective controller.

This GDPR Privacy Notice is intended to supplement, not replace, our existing privacy policy. In the event of a conflict between this GDPR Privacy Notice and our Privacy Policy, the policy or provision that is more protective of Personal Data shall prevail.

If you have any questions about this notice or whether it applies to you, contact us at privacy@netision.com.

1. Processing Personal Data

We process your Personal Data only when we have a lawful basis to do so. Lawful bases include consent, contractual necessity, and our legitimate interests or those of a third party. In some cases, we may process your data to comply with legal obligations or protect your or others' vital interests.

2. Use of Personal Data

a. Information Collected Directly

We may collect Personal Data directly from you, such as:

• First name
• Last name
• Email address
• Mailing address
• Phone number
• Country
• Job title

This information is generally collected to fulfill contractual obligations (e.g., account creation, service access). If you do not provide required data, some services may be unavailable.

We may also collect user-generated content such as comments, posts, or uploaded materials that may include Personal Data. Such data is processed under our legitimate interest to operate and improve the Services.

We use your data to:

• Create and manage user profiles
• Provide customer support
• Communicate service updates
• Personalize content and communications
• Meet legal and contractual obligations
• Detect and prevent fraud or harmful activities
• Enforce our Terms of Service

b. Information from Third Parties

We may receive your Personal Data from:

• Third-party account services: If you use a service like Google or LinkedIn to sign in, we may receive your name, token, ID, or profile picture (subject to your privacy settings).
• Advertising partners: Our marketing providers (e.g., Google Ads, Facebook) may share information about your interactions with our ads.

We process such data to personalize and enhance user experience and marketing effectiveness.

c. Information Automatically Collected

We automatically collect certain Personal Data, such as:

• IP address
• Device/browser identifiers
• Geolocation (based on IP)
• Access logs and usage data
• Cookies and tracking technologies (e.g., pixels, SDKs)

We use this data for:

• Web analytics
• Content personalization
• Fraud detection and prevention
• Reward tracking and administration
• Website functionality and performance

Cookies

Netision uses the following types of cookies:

• Essential Cookies: Required for functionality (e.g., login)
• Functionality Cookies: Store user preferences
• Performance/Analytical Cookies: Track usage and performance metrics
• Advertising/Retargeting Cookies: Personalize marketing efforts

To manage cookies, please adjust your browser settings.

d. Other Uses

In addition to the above, we may process your data for:

• Operating and improving our services
• Complying with legal obligations
• Supporting customer service
• Preventing fraud or abuse
• Performing corporate transactions (e.g., acquisitions)

3. Sharing Personal Data

We may share your data with:

• Service providers (e.g., analytics, hosting, contractors)
• Third-party platforms you connect with (e.g., social media logins)
• Business partners you access through our platform
• Other users, if you make data publicly visible
• Legal authorities, when required by law
• Buyers or successors, in case of corporate restructuring

We only share Personal Data necessary for the above purposes and ensure such recipients are bound by appropriate confidentiality and data protection obligations.

4. Data Retention

We retain Personal Data for as long as:

• You maintain an account with us
• It is necessary to provide the Services
• It is required to comply with legal obligations, enforce policies, or resolve disputes

In some cases, we may retain data longer if permitted or required by law.

5. Your GDPR Rights

Subject to applicable laws, you have the following rights:

• Right to Access — Obtain confirmation and a copy of your Personal Data
• Right to Rectification — Correct inaccurate or incomplete data
• Right to Erasure — Request deletion of your data under certain circumstances
• Right to Restriction — Request limited processing of your data
• Right to Data Portability — Receive your data in a portable format
• Right to Object — Object to data processing based on legitimate interests
• Right to Withdraw Consent — Withdraw consent at any time (without affecting prior processing)

To exercise any of these rights, contact privacy@netision.com.

You may also lodge a complaint with your local supervisory authority in the EEA or UK.

6. International Data Transfers

If we transfer your Personal Data outside the EEA, we ensure appropriate safeguards are in place, such as:

• Adequacy decisions
• Standard contractual clauses approved by the European Commission
• Binding corporate rules (if applicable)

What Rights Do You Have Regarding Your Personal Data?

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email privacy@netision.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include

Personal Data, if necessary to verify your identity and the nature of your request.

Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by emailing us at privacy@netision.com.

Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement Personal Data by emailing us at privacy@netision.com

• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

What if You Have Questions Regarding your Personal Data?

If you have any questions about this GDPR Privacy Notice or our data practices generally, please contact us using the following information:

Attn: Data Protection Officer

Email: privacy@netision.com

DATA PROTECTION OFFICER

Netision has appointed a Global Data Protection Officer. If you believe your personal information has been used in a way that is not consistent with the Privacy Policy or your choices, or if you have further questions, comments or suggestions related to this Privacy Policy, please email to privacy@netision.com

Written inquiries to the Global Data Protection Officer may be addressed to:

DISPUTE RESOLUTION OR FILING A COMPLAINT

If you have any complaints regarding our compliance with this Privacy Policy, please contact us first. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with this Privacy Policy and in accordance with applicable law. You also have the right to file a complaint with a competent data protection authority if you are a resident of a European Union member state.