Privacy Policy

Effective date: January 29, 2024

At Naas, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, including as an Individual Customer, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use, and share your information as described in this Privacy Policy.

Remember that your use of Naas' Services is at all times subject to our Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.

Privacy Policy Table of Contents

1. What this Privacy Policy Covers
2. Personal Data
   • Categories of Personal Data We Collect
   • Categories of Sources of Personal Data
   • Our Commercial or Business Purposes for Collecting Personal Data
3. How We Share Your Personal Data
4. Tracking Tools, Advertising, and Opt-Out
5. Data Security and Retention
6. Personal Data of Children
7. Other State Law Privacy Rights
8. European Union and United Kingdom Data Subject Rights
9. Changes to this Privacy Policy
10. Contact Information

1. What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you — including as an Individual Customer — access or use our Services. "Personal Data" means any information that identifies or relates to a particular individual and also includes information referred to as "personally identifiable information" or "personal information" under applicable data privacy laws, rules, or regulations.

Naas allows both Individual Customers and Enterprise Customers to create an account through Naas' websites to access the Naas Products. Naas offers a suite of business-to-business offerings and, in the ordinary course of providing those products, we may process personal data at the direction of our Enterprise Customers. This Privacy Policy does not apply to our data use practices in connection with personal data collected from or on behalf of our Enterprise Customer. The Enterprise Customer (e.g., your employer or another entity or person) that entered into a Master Service Agreement, applicable terms, or another written agreement executed by us controls such data.

If you have any questions related to that Enterprise Customer's settings or privacy practices, please contact such organization. If we process your personal data on behalf of one of our Enterprise Customers and you wish to discontinue such processing, or if you seek to correct, amend, or delete inaccurate personal data, please directly contact the organization on whose behalf we are processing such personal data. We will follow the Enterprise Customer's instructions with regard to the personal data at issue. We will retain such personal data pursuant to our retention policy and will retain it as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

This Privacy Policy does not cover the practices of companies we don't own or control, such as our Enterprise Customers, or people we don't manage.

2. Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

Category of Personal Data	Examples of Personal Data We Collect	Categories of Third Parties With Whom We Share this Personal Data
Profile or Contact Data	First and last name, Email	Service Providers, Business Partners, Parties You Authorize, Access or Authenticate
Identifiers	Account username, including for integrations	Service Providers, Business Partners (Account username only), Parties You Authorize, Access or Authenticate
Payment Data	First and last name, Email	Service Providers (specifically our payment processing partner, currently Stripe, Inc.)
Device	IP Data	IP address, Device ID, Domain server, Type of device/operating system/browser used to access the Services
Web Analytics	Web page interactions, Referring webpage/source through which you accessed the Services, Non-identifiable request IDs, Statistics associated with the interaction between device or browser and the Services	Service Providers, Advertising Partners, Analytics Partners
Geolocation Data	IP-address-based location information	Service Providers, Advertising Partners, Analytics Partners, Business Partners
Other Identifying Information that You Voluntarily Choose to Provide	Identifying information in emails or letters you send us, Information voluntarily provided about your use of Naas, User-provided code, User-provided data and data sets, Data derived from inputs using user code and configurations	Service Providers, Parties You Authorize, Access or Authenticate

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You

• When you provide such information directly to us.
• When you create an account or use our interactive tools and Services.
• When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
• When you send us an email or otherwise contact us.
• When you use the Services, and such information is collected automatically.
• Through Cookies (defined in the "Tracking Tools, Advertising, and Opt-Out" section below).
• If you use a location-enabled browser, we may receive information about your location and mobile device.

Third Parties

• Vendors: We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support. We may use vendors to obtain information to generate leads and create user profiles.
• Advertising Partners: We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, products, Services, advertisements, or communications. We may receive information about you from third parties, including our strategic partners.
• Social Networks: If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

Our Commercial or Business Purposes for Collecting Personal Data

• Providing, Customizing and Improving the Services: Creating and managing your account or other user profiles and providing you with the products, services, or information you request. Providing support and assistance for the Services. Improving the Services, including testing, research, internal analytics, and product development. Personalizing the Services, website content, and communications based on your preferences. Doing fraud protection, security and debugging, including preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities. Processing orders or other transactions; billing. Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.
• Marketing the Services: Marketing and selling the Services.
• Corresponding with You: Responding to correspondence, contacting you when necessary or requested, and sending you information about Naas or the Services. Sending emails and other communications according to your preferences or that we think will interest you.
• Meeting Legal Requirements and Enforcing Legal Terms: Fulfilling our legal obligations under applicable law, regulation, court order, or other legal process. Resolving disputes, protecting the rights, property, or safety of you, Naas, or another party, and enforcing agreements. Responding to claims that any posting or other content violates third-party rights.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

3. How We Share Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a "sale" of your Personal Data. For more information, please refer to the state-specific sections below.

Service Providers: These parties help us provide the Services or perform business functions on our behalf. They include:

• Hosting, technology, and communication providers.
• Security and fraud prevention consultants.
• Support and customer service vendors.
• Payment processors.

Our payment processing partner Stripe, Inc. ("Stripe") collects your voluntarily provided payment card information necessary to process your payment. Please see Stripe's terms of service and privacy policy for information on its use and storage of your Personal Data.

Advertising Partners: These parties help us market our services and provide you with other offers that may be of interest to you. They include:

• Ad networks.
• Marketing providers.

Analytics Partners: These parties provide analytics on web traffic or usage of the Services. They include:

• Companies that track how users found or were referred to the Services.
• Companies that track how users interact with the Services.

Business Partners: These parties partner with us in offering various services. They include:

• Companies that we partner with to offer joint promotional offers or opportunities.
• Integration partners.

Parties You Authorize, Access, or Authenticate: Third parties you access through the services. Social media services.

Legal Obligations: We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under "Meeting Legal Requirements and Enforcing Legal Terms" in the "Our Commercial or Business Purposes for Collecting Personal Data" section above.

Business Transfers: All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data: We may create aggregated, de-identified, or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified, or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build, and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

4. Tracking Tools, Advertising, and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, "Cookies") to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base, and operate and improve our Services. Cookies are small pieces of data—usually text files—placed on your computer, tablet, phone, or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support "Do Not Track" requests sent from a browser at this time.

We use the following types of Cookies:

• Essential Cookies: Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• **

Functional Cookies:** Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time, and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).

• Analytics and Performance Cookies: Analytics and Performance Cookies collect information on how users interact with our Services, including what pages are visited most, as well as other analytical data. We use these details to improve how our Services function and to understand how users interact with them.
• Advertising Cookies: Advertising Cookies are used to deliver relevant advertisements to users both on and off our Services. We analyze what pages you visit on these sites, what products or services you view, and whether you view or click on ads that are shown to you. We may also use a Cookie to learn whether someone who saw an ad later visited and made a purchase on the advertiser's site. Similarly, our partners may use a Cookie to determine whether we've shown an ad and how it performed or provide us with information about how you interact with ads. We may also work with a partner to show you an ad on or off our Services, such as after you have visited a partner's site or application.

If you would like to opt-out of the use of Cookies or set your preferences for Cookies usage, you can do so by adjusting your browser settings. Please note that disabling or blocking certain Cookies may affect the functionality of the Services.

5. Data Security and Retention

We take the security of your Personal Data seriously and use appropriate technical and organizational measures to protect your Personal Data against unauthorized or unlawful processing and against accidental loss, destruction, or damage. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the "Contact Information" section below.

We retain your Personal Data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

6. Personal Data of Children

The Services are not intended for individuals under the age of 16, and we do not knowingly collect Personal Data from individuals under the age of 16. If we learn that we have collected Personal Data from a child under the age of 16, we will take steps to delete that information as soon as possible. If you believe that a child under the age of 16 may have provided us with Personal Data, please contact us in accordance with the "Contact Information" section below.

7. Other State Law Privacy Rights

California Privacy Rights

Under the California Consumer Privacy Act ("CCPA"), California residents have certain rights regarding the Personal Data collected about them.

Right to Know: California residents have the right to request that we disclose the categories of Personal Data we have collected about them, the categories of sources from which we collected the Personal Data, the purposes for collecting the Personal Data, the categories of Personal Data that we have disclosed, and the categories of third parties with whom we have shared the Personal Data.

Right to Delete: California residents have the right to request the deletion of their Personal Data that we have collected or

maintained.

Right to Opt-Out of Sale: California residents have the right to opt-out of the sale of their Personal Data. We do not sell Personal Data.

Right to Non-Discrimination: California residents have the right not to receive discriminatory treatment by us for the exercise of their privacy rights conferred by the CCPA.

To exercise your rights under the CCPA, you may submit a verifiable consumer request to us by contacting us using the information provided in the "Contact Information" section below. We will verify your request using the information associated with your account, including your email address. If you do not have an account with us, we may request additional information to verify your identity and fulfill your request.

Nevada Privacy Rights

Nevada residents have the right to opt-out of the sale of their Personal Data. We do not sell Personal Data.

Other State Laws

We will comply with state-specific privacy laws as applicable to the extent they differ from the practices described in this Privacy Policy.

8. Changes to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where required by applicable data protection laws.

You can see when this Privacy Policy was last updated by referring to the "Last Updated" legend at the top of this page.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, you can contact us at:

Email: [email protected] Mail: NaasAI, Inc. 8 The Green, STE 4000, Dover, DE 19901, United States