Privacy Policy

This policy applies to all processing of personal data carried out by AppSteer Inc and has the objective of informing the user regarding the way in which AppSteer Inc carries out the processing of personal data (including details of the type of personal data collected and the purpose of processing) and regarding the right of the user in relation to their personal data.

In case of having any questions about the Privacy Policy, the user can contact AppSteer Inc through the following means: Headquarters are located at: Suite 100, 5900 Balcones Drives Austin, Texas 78731, United States Contact phone number is: +1 (972) 370-3085 The user may establish direct and effective communication with AppSteer Inc by written communication sent to any of the indicated addresses or also by sending an email to the address: info@appsteer.io In addition, information of the officer in charge of processing your personal data is listed below: Trade name: AppSteer Inc Identity of the controller: AppSteer Inc Address: Suite 100, 5900 Balcones Drives Austin, Texas 78731, United States Email: info@appsteer.io

Processing identification – How do we collect personal data? In compliance with current regulations on the protection of personal data, especially, Regulation (EU) 2016/679 of the European Parliament and Council, dated April 27, 2016 on the protection of natural persons regarding the processing of personal data and the free circulation of these data (hereinafter, the “GDPR”), The California Consumer Privacy Act (CCPA), Assembly bill No. 375 AppSteer Inc collects personal data in its possession when the user: (i). completes the forms of www.appsteer.io (“Site”), app and/or company platform; (ii). subscribes to the newsletter; (iii). answers a poll or completes a web form; (iv). completes a printed form; (v). sends an email or communicates by phone, which are then loaded in the corresponding forms; Personal Data Collected - What personal data do we collect? AppSteer Inc collects information when visiting their web page, using their application and/or platforms, and mainly by completing its registration forms. The following data is collected: full name, email, phone number, gender, date of birth and address. As a rule, when personal data is requested to use a service or access certain content, its delivery will not be mandatory, except for those cases where it is specifically indicated that it is data required for the provision of the service. In this case, the user may freely choose not to register and/or not to contract the services. The user declares and guarantees that all the data provided by him are true and correct and undertakes to keep them updated. The changes may be communicated to the Data Protection Delegate or to the address indicated in Section 2 hereof. Likewise, the user acknowledges that the data required by AppSteer Inc are necessary, adequate, and not excessive to carry out the purposes expressed in Section 5 hereof, which would be impossible to fulfill if said data are not provided. Any false or inaccurate statement that occurs as a result of the information and data given, as well as the damages that such information may cause, will be the responsibility of the user. Purpose - What do we use personal data for? The personal data requested to the user will be used for the following purposes: In the event of contracting services offered through the Site, to create and maintain the commercial relationship, and to carry out the activities and provide the services of AppSteer Inc (including, without limitation, the management, administration, provision and improvement of services). Send newsletters, as well as commercial communications, promotions and/or advertisements of AppSteer Inc, either occasionally or periodically. Accordingly, the email address that the user provides when completing the form on the Site may be used to send information and updates on the request for services, as well as news about AppSteer Inc (either occasionally or periodically), updates, information on related products or services, among others. This treatment is based on our legitimate interest in promoting our products and services. Conduct a survey or run a contest Personalize the user experience, increasing our ability to respond to their needs. Improve the Site and the service offer of AppSteer Inc, based on the legitimate interest of AppSteer Inc in constantly improving its products and services. Process transactions and comply with the legal obligations to which AppSteer Inc is subject, such as tax obligations. The data subject to treatment will not be used for purposes other than or incompatible with those mentioned above and that motivated its collection. Notwithstanding the foregoing, it is stated that the recorded data may be used, in addition to the purposes for which it was expressly collected, for the purpose of carrying out statistics, managing incidents or conducting market studies. However, in the event that personal data is processed for a purpose other than that initially specified when collecting said data, a compatibility analysis will be carried out by AppSteer Inc in accordance with applicable regulations. The processing will only be authorized if the original purpose is compatible with the new purpose or allowed in accordance with an independent legal basis. In these cases, the user will be informed of the changes in purpose or legal justification for the processing of their data. We remind the user that they can oppose the sending of commercial communications (unsubscribe) and stop receiving emails from AppSteer Inc, reliably notifying AppSteer Inc, which will proceed to interrupt in the shortest possible time after receiving such communication. For this purpose, it may send an email to the address indicated in Section 2, a postal mail addressed to the address indicated in Section 2 hereof, or directly follow the unsubscribe instructions detailed at the end of each email of AppSteer Inc. How we use your information? We will use the information that we collect about you for the following purposes: Creating user account Enforce T&C Manage customer order Support Administration info User to user comments Manage user accounts If we want to use your information for any other purpose, we will ask you for consent and will use your information only on receiving your consent and then, only for the purpose(s) for which grant consent unless we are required to do otherwise by law. We will retain your personal information with us for 24 months after user accounts remain idle or for as long as we need it to fulfill the purposes for which it was collected as detailed in this Privacy Policy Consent By providing personal data to AppSteer Inc, the user declares to accept their processing fully and unreservedly by AppSteer Inc. The user hereby grants his free, express, and informed consent for AppSteer Inc to use the data collected for the purposes indicated in Section 5 hereof, as well as its incorporation into a AppSteer Inc database. AppSteer Inc carries out the processing of the user's data legitimized in: (i) the contracting of AppSteer Inc services by the user, in accordance with the terms and conditions that are made available to the user at the end of completing the request form for services (prior to a possible hiring) and that the user (after reading it), and if they agree, can accept by checking the box that has been included for this purpose; and (ii) the free, informed and unequivocal consent of the user, made after reviewing this privacy policy where AppSteer Inc informs the treatment that it will carry out with your data, and if you agree, by checking the box that has been included for this purpose in the service request form. The processing of data that is not covered by any of the legal bases indicated above, will be carried out if AppSteer Inc considers it necessary to protect a legitimate interest and only if they do not contravene the fundamental rights and freedoms of the user. Expiration - How long do we store them? The data will be destroyed or archived when it is no longer strictly necessary or relevant for the purposes detailed in Section 5 above. In particular, personal data will be kept as long as the business relationship is in force (and to the extent that the user has not previously requested its deletion) and during the period during which obligations, indemnities and/or responsibilities may arise under the business relationship or for the services provided. AppSteer Inc informs that it will retain the essential information to identify the origin of the data stored for the duration of the client's relationship with AppSteer Inc and/or revocation of consent by the user in accordance with the information in Section 5 of this Privacy Policy and / or the time required by applicable law. Confidentiality / Assignment / International Transfer - Do we disclose data to third parties? AppSteer Inc will keep the personal data collected private and confidential, and will not use them for purposes other than those established in Section 5 hereof. AppSteer Inc requires the signing of confidentiality agreements and personal data processing by its employees and third parties that provide services that access the content of the databases (or include such obligations within the service agreements that it signs with such providers as indicated in the next paragraph). The personal data of the user collected by AppSteer Inc will not be transferred, sold, exchanged, transmitted and/or communicated to any third party outside of AppSteer Inc without the consent of the user, except legal obligation and/or for the purpose of providing the services to the user. This does not include certain employees and service providers that allow AppSteer Inc to keep the Site operational, comply with the purposes established in Section 5 hereof and/or provide services to the user, who have assumed the obligation to maintain the confidentiality of the data provided and commit to compliance with the applicable regulations on the protection of personal data, at the time of hiring. The contracts with the service providers stipulate the objective, scope, content, duration, nature and purpose of the data processing, the type of personal data, the categories of data owners and the obligations and responsibilities of AppSteer Inc and of the contracted third parties. In particular: AppSteer Inc may share the personal information provided with controlling companies, affiliates, subsidiaries, related companies and/or intermediaries related to AppSteer Inc. AppSteer Inc may share certain personal information provided by the user internally within AppSteer Inc, with certain departments, such as administration, marketing, or IT. **- In certain cases, AppSteer Inc transfers personal data based on legitimate interest and the economic and technical advantages associated with the use of specialized providers. In this sense: - Maps. AppSteer Inc uses Google Maps to include maps on the Site. Integration to Google Maps allows Google to collect the user's IP address. The user can consult the privacy policy and other legal aspects of said company at the following link: http://www.google.com/intl/en/policies/privacy/. - YouTube. The Site has links to YouTube in relation to videos linked to AppSteer Inc services. As indicated in Section 13 hereof, by using these links the user is leaving the Site and is redirected to the YouTube page. The user can consult the privacy policy and other legal aspects of YouTube in the following link: https://policies.google.com/privacy - Facebook. AppSteer Inc has integrated Facebook components on the Site. In particular, AppSteer Inc uses the Facebook advertising platform. The company that operates the Facebook services is Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. The user can consult the privacy policy and other legal aspects of said company in the following link: https://en-en.facebook.com/about/privacy/. - Linkedin. The Site has links to Linkedin. As indicated in Section 13 hereof, by using these links the user is leaving the Site and is redirected to Linkedin. The user can consult the privacy policy and other legal aspects of Linkedin at the following link: https://www.linkedin.com/legal/privacy-policy. ** **- Social Networks. AppSteer Inc also uses social networks, such as Facebook or Instagram, and has integrated functions of these networks into its services. The user may only use these social networks to the extent that they are registered in them and have accessed the corresponding social network with their user. These social networks have their own privacy policies and their own terms and conditions, over which AppSteer Inc has no interference or control. ** Finally, the user must know that AppSteer Inc may (and that AppSteer Inc reserves the right to) disclose their information in the following cases: (i) if required by a judicial or administrative authority; (ii) if necessary in order to exercise your rights under the Terms and Conditions of AppSteer Inc and under this Privacy Policy; (iii) if necessary to comply with the law; (iv) if said data could be useful for the protection of the rights of third parties; (v) when it is useful for the protection of the rights, property or security of AppSteer Inc, its controllers, subsidiaries, affiliates, directors, managers, employees, users or the general public; and (vi) when there are well-founded reasons related to public security, national defense, or public health. Security - How do we ensure data security? AppSteer Inc declares its intention to adopt the technical and organizational measures necessary to guarantee the security, integrity, and confidentiality of the data in accordance with the provisions of the RGPD in order to avoid its adulteration, loss, consultation or unauthorized processing. AppSteer Inc does not guarantee absolute privacy in the use of the Site since the possibility that unauthorized third parties may have knowledge of it should not be ruled out. The user acknowledges that the existing technical means that provide security are not impregnable and that even when all reasonable security precautions are adopted, it is possible to suffer manipulation, destruction and / or loss of information. In the event that a security incident is detected and that it implies a significant risk for the owner of the data, such event will be communicated without delay to the competent control authority, together with the corrective and palliative measures implemented and / or to be implemented. AppSteer Inc is not responsible for the loss or deletion of data by users. Likewise, AppSteer Inc does not accept any responsibility for possible damages caused by computer viruses. Finally, the user must also take measures to protect their information. AppSteer Inc insists that you take every precaution to protect your personal information while on the Internet. At least, you are advised to change your password periodically, using a combination of letters and numbers, and make sure you are using a secure browser. Rights of the owner of the data and procedures to respond to their exercise - What rights do I have as the owner of the data? The user who owns the data may at any time exercise the rights of access, rectification, cancellation, opposition, limitation of processing, portability, confidentiality and deletion regarding their personal data, in accordance with the provisions of articles 15 and following of the RGPD, as appropriate. The exercise of these rights can be carried out by the user himself through an email addressed to info@appsteer.io, or by any of the methods provided for in the applicable regulations referenced above. AppSteer Inc may request the necessary data to validate the identification of the owner of the data. The deletion of some data will not proceed when it could cause damage to the legitimate rights or interests of third parties, or when there is a legal obligation to keep the data. Training - Do we train? The AppSteer Inc staff whose functions are related to the processing of personal data are trained in order to guarantee better protection of personal data and the rights of its holders. Links to third parties - Does our Site contain links to other sites? The Site may contain links to third party sites, with or without advertising content, whose privacy policies are foreign to AppSteer Inc. The linked sites are not related to AppSteer Inc and, their existence in no way presupposes that there is any kind of suggestion, invitation, or recommendation for the visit of the destination places or any kind of link or association between AppSteer Inc and such sites. AppSteer Inc is not responsible or liable for the content, use and activities of these linked websites, or for damages, whether current or eventual, material or moral, direct or indirect, suffered by users and derived from the information contained in such sites or of the relationship that users may establish with third parties whose services have been published on the Site. Notwithstanding the foregoing, any comment on these linked websites will be useful to AppSteer Inc in order to improve services and/or ensure the integrity of the Site. AppSteer Inc undertakes to do everything possible to prevent the existence on its Site of links to sites with illegal content. Location Information We may collect and use your device's background location data to provide location-based services, such as our employee attendance module where the employer/ organization can keep track of their employees' movements within and outside of the premises during the time employees are logged in. We will obtain your prior consent to collect this data and provide you with clear information about how it will be used. You may opt-out of sharing your location data with us at any time. We may also share this data with third-party service providers who assist us in providing location-based services, but we will not sell your location data to third parties without your explicit consent. We comply with all applicable laws and regulations, including the California Consumer Privacy Act (CCPA), and we are committed to protecting your privacy and data security.

Cookies - Do we use cookies? When the user enters the Site, AppSteer Inc may store some information on their computer in the form of a "cookie" or similar file. The Site uses cookies to (i) track advertising, (ii) collect data about Site traffic, and (iii) improve the user experience when using the Site. The user should know that to navigate the Site, it is not necessary for the user to allow the installation of cookies sent by the Site. This may only be required in relation to certain services. The user can erase cookies from the hard drive of his/her computer, prevent access to his/her computer either through his/her browser or by choosing the corresponding option when asked about the possibility of using cookies for these purposes and in compliance with the Cookies Policy of AppSteer Inc. Cookies are information files that a website or the provider of certain services of the site transfers to the hard drive of the user's computer through the browser program. Cookies by themselves cannot personally identify the user (although they can contain the user's IP address) but they allow them to recognize the user's browser, and capture and store certain data (user's operating system, domain name of the website from which the Site was linked, among others). AppSteer Inc reserves the right to contract the services of third parties to analyze and understand the users of the Site, who may not use the information collected for purposes other than to improve AppSteer Inc services. Approval The use of the Site by the user implies the knowledge and full approval of the Privacy Policy of AppSteer Inc and the Terms and Conditions of AppSteer Inc, if any. Likewise, the user accepts the Privacy Policy of AppSteer Inc and the Terms and Conditions of AppSteer Inc by completing the request for services. Modifications - Is this the most current version? This is the current version of the AppSteer Inc Privacy Policy, updated on March 14, 2023. AppSteer Inc may at any time and without prior notice, modify this Privacy Policy. Such modifications will be operative from their publication on the Site or when they are notified to users by any means, whichever occurs first. The user must keep informed about the terms included here by entering periodically.

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”). The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to "The California Consumer Privacy Act of 2018" (Users are referred to below, simply as “you”, “your”, “yours”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy. This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA). Categories of personal information collected, disclosed or sold In this section we summarize the categories of personal information that we've collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document. Information we collect: the categories of personal information we collect We have collected the following categories of personal information about you: internet information. We will not collect additional categories of personal information without notifying you. How we collect information: what are the sources of the personal information we collect? We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use this Application. For example, you directly provide your personal information when you submit requests via any forms on this Application. You also provide personal information indirectly when you navigate this Application, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof. How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement. We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service. To find out more about the purposes of processing, please refer to the relevant section of this document. Sale of your personal information For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration”. Your right to opt out of the sale of personal information You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request. Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below. Instructions to opt out of the sale of personal information If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by this Application, both online and offline, you can contact us for further information using the contact details provided in this document. What are the purposes for which we use your personal information? We may use your personal information to allow the operational functioning of this Application and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes. We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage. We will not use your personal information for different, unrelated, or incompatible purposes without notifying you. Your California privacy rights and how to exercise them The right to know and to portability You have the right to request that we disclose to you: the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared; in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose: for sales, the personal information categories purchased by each category of recipient; and for disclosures for a business purpose, the personal information categories obtained by each category of recipient. The disclosure described above will be limited to the personal information collected or used over the past 12 months. If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible. The right to request the deletion of your personal information You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.). If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so. How to exercise your rights To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document. For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must: provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you. If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf. If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority. You can submit a maximum number of 2 requests over a period of 12 months. How and when we are expected to handle your request We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request. We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request. Our disclosure(s) will cover the preceding 12 month period. Should we deny your request, we will explain you the reasons behind our denial. We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.