TELIMA Privacy Policy:

Effective Date: August 22, 2024

This Privacy Policy and its addenda (“Privacy Policy”) describe how Telima SAS collects, uses, processes and discloses your personal data through the use of Telima mobile applications and websites (respectively “Applications” and “Websites”), as well as products, features and other services worldwide, operated by Telima (collectively, “Services”).

This policy applies to our consumers, agents, vendors, suppliers, partners (such as drivers, delivery people and merchant partners), contractors and service providers (collectively “you”, “your” or “yours”).

“Personal Data” is any information that can be used to identify you or from which you are identifiable. This includes, but is not limited to, your name, nationality, telephone number, bank and credit card details, personal interests, email address, image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, vehicle and insurance information, employment information and financial information.

We generally collect, use, disclose or otherwise process your personal data in accordance with this Privacy Notice with your consent or in accordance with applicable laws, for example where:

it is necessary for us to comply with legal requirements;

it is necessary for us to enter into or perform a contract with you; and/or

for our legitimate interests or the legitimate interests of any other person, including, but not limited to, for the purposes set out in this Privacy Notice.

I. COLLECTION OF PERSONAL DATA

We collect personal data about you in the manner set out below. We may also combine personal data collected through these different channels:

You provide us with your personal data

We collect your personal data when you provide it to us. For example, when you:

complete a user profile or registration forms (such as your name, contact details and other identifying information if necessary);

provide information to assess your eligibility to provide services as a Telima driver partner or delivery partner (such as your driver’s license information, vehicle information and background check results);

interact with our social media pages (such as your social media account ID, profile picture and any other publicly available data);

participate in contests or events hosted by us (such as photos, audio or videos you may submit, which may include images of yourself);

verify your identity through various means (such as social media logins, selfie image submissions or independently verified payment card information);

complete demographic information in surveys (such as your age, gender and other information you may voluntarily provide, such as your marital status, occupation and income); and

agree to ride with in-car audio and/or video recording features.

When our services are used

Personal data may be collected as part of the normal operation or use of our apps, websites and services. Examples include:

your location information;

We collect the precise or approximate locations of users, drivers,
delivery personnel, or service providers to enable different services, enable tracking
and safety features, prevent and detect fraud, and comply with legal requirements.
We collect this information when the app is running in the foreground or background
of the user's mobile device.

We collect location data, such as information about your device's location, which can
be either precise or imprecise. How much information we collect depends on the
type and settings of the device you use to access the mobile application. For
example, we may use GPS and other technologies to collect geolocation data that
tells us your current location (based on your IP address). You can opt out of allowing
us to collect this information either by refusing access to the information or by
disabling your location setting on your device. Note, however, that if you choose to
opt out, you may not be able to use certain aspects of the services.

comments, ratings and compliments;

transaction information (such as payment method);

information about how you interacted with our apps, website or services (such as features used and content viewed);

device information (such as hardware model and serial number, IP addresses), file and app names and versions, GPS location, IMEI number and advertising identifiers or any information that may indicate a change to the device or app);

telematics data (such as your speed, acceleration and braking data);

we work with partners to install telematics devices in rental vehicles for the following purposes:

to ensure that vehicles are properly maintained and repaired in a timely manner;

to help maintain the safety, security and integrity ofgrity of our products and services;

to improve and optimize our products and services; and

for internal vehicle tracking, analytics and administrative purposes.

these partners own and share this telematics data with us:

our partners are also contractually obligated to protect this data.

personal data that you enter in messages when you use our in-app communication features; and

personal data that may be captured through your interaction with us, our agents, in-vehicle audio and/or video recording during a trip (such as your image and/or voice, and its associated metadata).

our in-vehicle applications or devices

we may install in-vehicle audio and/or video recording applications or devices to promote the safety of our driver partners, delivery partners and consumers.

Your personal data may be captured in these audio and/or video recordings. When audio and/or video recordings are made in the vehicle, these recordings are collected, processed, used and stored in a manner consistent with this Privacy Statement and applicable laws.

Personal applications or devices embedded in the vehicle

Some of Telima’s partners may install applications or personal devices embedded in their vehicles for their own purposes. This practice is neither endorsed nor prohibited by Telima;

The collection, use and disclosure of personal data obtained from applications or personal devices embedded is the responsibility of the relevant partner. Please check with the relevant partner if you have any questions about their use of personal cameras embedded in the vehicle.

Other sources

We may collect personal data, including but not limited to your name, contact details and other identifying information as necessary from other sources. These sources include:

Orientation programs;

our business partners, such as fleet partners, payment providers, rideshare partners, and transportation partners;

insurance and financial service providers;

credit bureaus, alternative credit reporting agencies, and any other credit reporting organizations;

publicly available or government data sources;

when our users add you as an emergency contact;

when our users add you as a recipient or beneficiary of any use of our Services;

when you use our in-app chat; and

marketing service providers or partners.

Sensitive Personal Data

Some of the personal data we collect may be sensitive. This may include personal data relating to your race, national identity information, religious beliefs, background (including financial and criminal history, where permitted by law), health data, disability, marital status, and biometric data, if applicable. We collect sensitive personal data only with your consent and/or in strict compliance with applicable laws. In the event that you are required to provide us with documents or information for purposes that may contain such sensitive personal data (which are not required for this purpose), you agree to redact such sensitive personal data before providing us with such documents or information.

When you provide us with personal data of others

In certain situations, you may provide us with personal data of others (such as your spouse, family members or friends). For example, you may add them as an emergency contact, when you use the in-app chat or when you add them as recipients or beneficiaries of any use of our services. If you provide us with their personal data, you represent and warrant that you have obtained their consent for their personal data to be collected, used and disclosed as set forth in this Privacy Policy .

Personal data of minors

As a parent or legal guardian, please do not allow minors in your care to submit personal data to Telima. In the event that such personal data of a minor is disclosed to Telima, you hereby consent to the processing of the minor's personal data and agree to be bound by this notice and to assume responsibility for his/her actions.

II. USE OF PERSONAL DATASONNELLES

Telima may use your personal data for the following purposes, set out in the list below. (“Purposes”). In addition, if you use Telima in different capacities (for example, if you use multiple Telima services, or if you are both a driver/delivery partner and a consumer), we may link your personal data collected across your different capacities to facilitate your use of our services and for the purposes described below:

Providing services and features

Your personal data will be used to provide, personalize, maintain and improve our applications, websites and services. This includes using your personal data to:

engage you to provide you with Services in our various business lines;

create, administer and update your account;

process, manage or verify your eligibility or application for products, services, promotions, rewards and subscriptions with Telima;

conduct due diligence checks and risk assessments/analyses;

verify your identity and age (if necessary);

validate your trip and process payments;

offer, obtain, provide, facilitate or maintain insurance or financing solutions;

track the progress of your trip and detect abnormal variations in your journey;

allow you to participate in loyalty programs or marketing activities organized by our merchant partners and/or in collaboration with Telima;

personalize your experience of the application (for example to recommend products and services relevant to you, identify your preferences or otherwise personalize your experience with Telima);

make your experience more seamless, for example by automatically filling in your registration information (such as your name or phone number) from one Service to another Service or when you participate in our surveys;

carry out internal operations necessary to provide our Services, including resolving software bugs and operational problems, conducting data analysis, testing and research, monitoring and analyzing usage and activity trends;

protect the security or integrity of the Services and any facilities or equipment used to make the Services available;

enable communications between our users;

invite you to participate in our surveys and studies;

enable our partners to manage and allocate fleet resources; and

provide services to you as a data processor, where you have given your consent to the data controller (i.e. the organisation from which you have purchased goods or services and on whose behalf Telima provides services) for such services to be rendered.

Safety and Security

We use your data to ensure the safety of our Services and all users. This includes:

screening drivers and delivery partners before allowing them to use our Services;

identifying unsafe driving behaviours such as speeding, harsh braking and acceleration, and providing personalised feedback to driver partners;

verify your identity when you log in to Telima;

use device, location, profile, usage, and other personal data to prevent, detect, and combat fraud or dangerous activities;

share with drivers and passengers the location and contact information of driver partners when the emergency button or the “Share My Ride” feature is activated; and

monitor compliance with our terms and policies.

User Support

We use personal data to resolve user support issues. For example, we may:

investigate and respond to concerns;

monitor and improve our user support responses;

respond to questions, comments, and feedback; and

notify you of steps taken to resolve user support issues.

Research and Development and Security

We may use the personal data we collect for testing, research, analysis, and product development purposes. This allows us to understand and analyze your needs and preferences, protect your personal data, improve and strengthen the security of our services, develop new features, products and services and facilitate the development of insurance and financing solutions.

Legal purposes

We may use the personal data we collectllectons for legal purposes, such as to investigate and resolve claims or disputes, detect/prevent/prosecute crimes, or as permitted or required by applicable law.

We may also use your personal data when we are required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority.

For example, we may use your personal data to:

comply with court orders or other legal, governmental or regulatory requirements;

enforce our terms of service or other agreements; and

protect our rights or property in the event of a claim or dispute.

Marketing and promotions

We may use your personal data to send you marketing communications relating to personalized products or services (which may be of interest or relevance based on your profile), or to the products, services, events or promotions of Telima's partners, sponsors and advertisers. For example, we may:

send you special offers that may be of interest to you or of interest to you among all of Telima's service offerings;

send you alerts, newsletters, updates, mailings, promotional materials, special privileges, holiday greetings; and

notify, invite and manage your participation in our events or activities.

We may communicate this type of marketing to you by various means, as appropriate (including by SMS, chat applications (e.g. WhatsApp, Telegram, LINE, Viber, WeChat, Zalo), push notification, call and by email).

If you wish to unsubscribe from receiving such marketing communications, please click on the unsubscribe link in the relevant email or message. You can also update your preferences in our application settings. Please note that while you may opt out of marketing or promotional communications, Telima may still send you messages related to your account and/or services (such as two-factor authentication, information about your transactions, rewards, etc.).

User-Published Content

If you post content (such as a review or comment) on Telima’s platform, it will be displayed publicly along with your personal data (such as your profile name, uploaded photos) and other information you choose to include in your content. For more information, see our Review Guidelines .

III. DISCLOSURE OF PERSONAL DATA

We need to share personal data with various parties for the purposes. These parties include:

Other users

For example:

if you are a passenger of partner drivers, we may share your username, pick-up and drop-off locations with our partner driver who fulfills your service request;

if you are a driver partner, we may share your personal data with your passenger, including your name and photo; the make, model, license plate, location and average rating of your vehicle;

if you use our TelimaFood or TelimaMart service, we may share your personal data with our delivery partner and our selected merchant partner, including your order details and drop-off location;

if you participate in loyalty programs or marketing activities organized by our merchant partners, we may share your personal data with them, including your name and contact details;

if you are a delivery partner, we may share your personal data with the merchant partner and user you have selected, including your name and photo; the make, model, location and average rating of your vehicle;

if you use our TelimaExpress service, we may share your personal data with the recipient of your parcel, and vice versa, as well as with the delivery partner responsible for fulfilling your service request; and

if you use our in-app chat service, we may share your mobile phone number and your name registered on Telima with the other parties in your chat.

With third parties

With third parties related to your use of Telima services

For example:

if you are a passenger of driver partners, we may share the location of a vehicle and the name of the driver and/or your name with third parties when you use the “Share my ride” feature or activate the emergency button.

if you are a driver-partner, we may disclose the license plate numberion of your vehicle or other personal data to the insurance company and/or your passenger for the purpose of submitting insurance claims.

if you use our payment services, we may share your personal data with another person if you authorize and enable the connection of their third-party service payment method to our payment service for the purpose of enabling your payment on Telima.

With administrators of Telima accounts that you may use

For example:

your employer may receive transaction data (labeled as business expenses) when you use your employer's Telima for Business account.

the administrator of any community group to which you link your Telima account may receive transaction data when you make a transaction.

With subsidiaries and affiliates

We share personal data with our subsidiaries, associated companies, jointly controlled entities and affiliates. Telima Group companies share resources, such as infrastructure and technology, to provide you with a consistent, relevant and secure experience when you use our products or services, and for the purposes set out in this Privacy Policy.

For example, we do this to make your experience more seamless, such as by automatically completing your registration information from your use of a Telima product or service when you sign up for a new Telima product or service.

With Telima Service Providers and Business Partners

We may share personal data with our suppliers, consultants, marketing partners, research companies and other service providers or business partners. This includes:

payment processors and facilitators;

debt collectors;

credit bureaus, alternative credit reporting agencies and any other credit reporting bodies;

background check and anti-money laundering service providers;

cloud storage providers;

storage and document management providers;

advertising and marketing partners and platform providers;

data analytics providers;

research partners, including those who conduct surveys or research projects in partnership with or on behalf of Telima;

educational and training institute partners;

fleet and merchant partners;

insurance and financing partners;

third-party intermediaries involved in the managed investment of funds, such as brokers, asset managers and custodians;

service providers who provide identity verification services;

automotive solution partners, suppliers or third-party vehicle providers.

For example:

If you have requested a service through a Telima partner or used a promotion provided by a Telima partner, Telima may share your personal data with that Telima partner.

If you have rented a vehicle from our recommended fleet partners to drive with Telima, we may share relevant information (e.g., your account status, applicable incentives/promotions, your ride statistics) for collaborative efforts (e.g., creating new incentives and benefits for you or improving the driver partner offering).

With our legal advisors and government authorities

We may share your personal data with our legal advisors, law enforcement, government authorities and other third parties. This may be to meet the legal purposes (mentioned above) or in one of the following circumstances:

when it is necessary to respond to an emergency that threatens the life, health or safety of a person; or

when it is necessary in the public interest (e.g. in the event of a public health crisis, for contact tracing purposes and to protect our community).

Business Transfers

We may share your personal data with other parties, in connection with acquisitions, sales, mergers, joint ventures, consolidations, restructurings, financings or any other type of business transactions. Your personal data will, however, remain subject to our obligations set forth in any pre-existing privacy notice to which you have agreed.

We retain user data for as long as necessary for the purposes
described above, including to provide its services and comply with legal obligations.
The user has the right to delete all personal data collected by the app. Please follow
the below process to request data deletion.

Steps to Request Data Deletion:
Users may request deletion of their account via application only. Follow the path
"Login into the application >> Go to Profile Section >> Find "Account Settings" >>
Tap on "Manage Accounts" >> Look for the option "Delete Account" to request data
deletion.
You will be prompted to select the reason for your decision. Once you choose the
reason and submit your request, your account deletion process will begin to take
effect

IV. RETENTION OF PERSONAL DATA

We retain your personal data for the period necessary to fulfill the purposes described in this Policy, unless a retention periodlonger is required or permitted by law. Once your personal data is no longer necessary for the Services or Purposes, or we no longer have a legal or business purpose for retaining your personal data, we take steps to erase, destroy, anonymize, or prevent access to or use of such personal data for any purpose other than complying with this Policy, or for security, safety, fraud prevention and detection purposes, in accordance with the requirements of applicable laws.

V. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Your personal data may be transferred from the country, state, and city (“Home Country”) in which you are located when using our Services to another country, state, and city (“Other Country”).

When we transfer your personal data from your home country to the alternative country, we will comply with our legal and regulatory obligations regarding your personal data, including having a lawful basis to transfer the personal data and putting in place appropriate safeguards to ensure an adequate level of protection for the personal data. We will also ensure that the recipient in the alternative country is obliged to protect your personal data to a level of protection comparable to that provided by applicable laws.

Our legal basis will be either consent (i.e. we may ask for your consent to transfer your personal data from your home country to the alternative country at the time you provide your personal data) or one of the safeguards permitted by the laws.

VI. COOKIES, RELATED TECHNOLOGIES AND ADVERTISING ON THIRD-PARTY PLATFORMS

Cookies

Telima and the third parties we partner with may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers and similar technologies (such as software development kits (SDKs), which have similar functions to cookies and which may be installed in the Telima application to enable partners to collect certain information about your interaction with the Telima application) (collectively, “Cookies”) in connection with your use of the Websites and Applications, which may be persistent or stored only during an individual session on your browsers or devices.

Cookies may have unique identifiers and reside, among other places, on your computer or mobile device, in emails we send to you and on our web pages. Cookies may be used for a variety of purposes, including to:

provide the essential and basic functions of using our websites, services or applications;

authenticate you or remember your user preferences and settings;

deliver and measure the effectiveness of advertising campaigns, for example by measuring the number of views or clicks;

analyze site traffic and trends;

provide you with relevant advertisements on other applications and websites owned by other companies (whether by us or by other advertisers); and

improve the user interface and experience by generally understanding the online behaviors and interests of users who interact with our website, services or applications.

Telima may allow third parties to use cookies on websites and applications to collect the same type of personal data for the same purposes as Telima does for itself. Third parties may be able to associate the personal data they collect with other personal data they have about you from other sources. We do not necessarily have access to or control over the cookies they use.

Disabling the collection of cookies on our websites

You have the right to choose to disable, block or otherwise disable cookies. Please note that refusing or deleting certain cookies may affect the availability, functionality or use of our website, services or applications.

You can adjust your internet browser settings to disable, block or otherwise disable cookies, delete your browsing history or clear your internet browser cache. The settings may be contained in the “History”, “Preferences”, “Settings” or “Privacy” section of your internet browsers, or you can consult the help section of your internet browser for more information. You can also adjust your cookie settings here:

Cookie Settings

Opt out of targeted advertising on other platforms

NWe may facilitate the display of targeted advertising on other platforms, such as on other online platforms that you may be a user of.

You can limit our use of your personal data to display targeted advertising on behalf of our advertisers, by changing your preferences through our Telima application. Depending on the type of phone and operating software you use, you may have the option to opt out of our use of mobile identifiers (such as Apple's IDFA or Google's GAID) and the ability to track you across apps and websites owned by other companies by changing the settings available on your mobile devices. By changing the settings on your device, you can generally reset, delete, limit and/or restrict the use of these mobile identifiers.

Although we do not use your personal data to show you such targeted advertising on other platforms, you may still see generic ads that seem relevant to you. This may be because we have engaged third-party advertisers/platforms to display ads to users with specific attributes or demographic profiles who may find them relevant. You may be able to limit the viewing of these ads by managing your preferences on those platforms.

VII. PROTECTION OF PERSONAL DATA

We will take reasonable legal, organizational and technical measures to ensure that your personal data is protected. This includes measures to prevent loss, use of, or unauthorized access to personal data. We limit access to your personal data to our employees on a need-to-know basis. Those who process your personal data will only do so in an authorized manner and are required to treat your information confidentially.

However, please be aware that the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted by any means online. Therefore, any transmission remains at your own risk.

VIII. YOUR RIGHTS REGARDING YOUR PERSONAL DATA

In accordance with applicable laws and regulations, you may have the right to:

inquire about the processing of your Personal Data and obtain a copy of it;

in some cases, request the rectification and/or deletion of your Personal Data;

in some cases, request the restriction of or object to the processing of your Personal Data;

withdraw your consent to the processing of your personal data in our possession or control (and where we process your personal data on the basis of your consent);

request the receipt or transmission to another organization, in a machine-readable form, of the personal data you have provided to us when we use your personal data on the basis of consent or the performance of a contract; and

lodge a complaint with the competent data protection authority if your data privacy rights are violated or if you have suffered harm due to unlawful processing of your personal data.

Where you have the option to share your personal data with us, you can always choose not to do so. If we have asked for your consent to the processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. However, choosing not to share your personal data with us, withdrawing your consent to our use of it or agreeing to our privacy notice could mean that we are unable to perform the actions necessary to achieve the processing purposes described in Section II (Use of Personal Data) or that you are unable to use the App or Services.

After you choose to withdraw your consent, we may continue to process your personal data to the extent required or permitted by applicable laws and regulations.

We will review and verify all requests in advance. In order to verify your authority to make the request, we may ask you to provide supporting information or documentation to corroborate the request. Once verified, we will respond to your request within the time limits prescribed by applicable laws.

IX. MODIFICATIONS AND UPDATES

Telima may modify, update or amend the terms of this Privacy Policyity at any time. Such changes will be notified to you via the App and/or by any other appropriate means at least five (5) business days prior to the effective date. The updated version will be posted on the website https://www.Telima.app . It is your responsibility to review the Privacy Policy regularly. Your continued use of the Apps, Websites or Services, purchase of products from Telima or continued communication or engagement with Telima after any changes, updates or amendments to this Policy, whether or not you have reviewed them, will constitute your agreement to be bound by such changes.

X. HOW TO CONTACT US

If you have any questions regarding this Notice or wish to exercise your rights set forth in this Notice, please complete the form on our Site which will be handled by our Data Protection Officer Michel DORE

In order for us to respond to your questions promptly, we prefer that requests be made via the online form.

ADDENDUM 1: ENTER FOR BUSINESS

I. INTERPRETATION

All capitalized terms, but undefined terms used herein, shall have the same meaning as those defined in Telima’s Terms of Use and Privacy Policy.

This addendum is part of Telima’s Privacy Policy. In the event of any inconsistency between Telima’s Privacy Policy and this addendum, this addendum shall prevail.

II. TELIMA’S RELATIONSHIP WITH USERS AND CUSTOMERS

How Telima for Business Works

Telima for Business is provided as an add-on feature for organizations (“Customer”) to facilitate the company’s billing for the use of Telima’s services by its authorized users (e.g. employees) in the course of their employment.

When a Customer chooses to use Telima for Business, the Authorized User has the option to label their trips or other transactions on behalf of the Customer or to label them as a personal trip. As part of this functionality, Telima will disclose to the Customer detailed information about trips and bookings that Authorized Users have labeled as being for business purposes. Other than this, Telima does not disclose any other personal data of Authorized Users to the Customer.

Alternatively, an Individual User may choose to create a business profile in the App to facilitate the labeling of business-related trips and to generate consolidated trip reports to facilitate the submission of claims by their employer. When this mode is used, the claims process is user-driven and the User’s employer does not need to be a Customer.

For convenience, Authorized Users and Individual Users will each be referred to as a “User” and collectively as “Users” in this Addendum.

Telima is a data controller, just like our customers

Telima acts as the data controller of any user's personal data. For more information on how Telima collects, uses and discloses users' personal data, please refer to Telima's Privacy Policy.

Due to the way Telima for Business operates, Telima does not process any personal data for and on behalf of the Customer. Accordingly, Telima is not the data processor of the Customer, but an independent data controller for all personal data it processes in the context of providing the Telima for Business functionality. Similarly, the Customer is an independent data controller of the personal data it discloses to Telima and/or receives from Telima.

As independent data controllers, Telima and the Customer individually determine the purposes and means of the processing of Personal Data, subject to the provisions set out in the Terms of Use and this Privacy Statement. Telima and the Customer are also individually responsible for the protection of the Personal Data for which they are responsible.

III. WHAT PERSONAL DATA IS COLLECTED, PROCESSED AND DISCLOSED

What Telima collects as part of Telima for Business

In order to provide the Telima for Business functionality, the User or the Customer must provide Telima with the following information about the User:

first and last name;

professional email address; and

other identifying information about the User reasonably requested by Telima.

Telima will use this information for the purposes of:

authenticating the User;

the cas where applicable, link the Authorized User’s account to the Customer’s Telima for Business account or track bookings from the Authorized User’s business profile on the Applications, as applicable;

where applicable, check the corporate billing status of such Authorized User from time to time; and

contact the User in accordance with the purposes set forth in Telima’s Privacy Statement.

When onboarding a User into the Application, Telima will process the User’s personal data in accordance with Telima’s Privacy Notice and this Addendum.

What Telima Discloses to Its Customers

Telima will disclose to the Customer relevant travel and booking information, as determined by Telima from time to time, in order to facilitate corporate billing.

What Telima Discloses to Its Individual Users

Depending on the business profile settings selected by the individual user, the user may retrieve and generate reports containing their relevant travel and booking information.

IV. OBLIGATIONS OF THE PARTIES

The Client and Telima shall each:

Individually inform their data subjects of how each processes personal data and allow their data subjects to exercise their rights under local data protection/data privacy laws;

Comply with each party’s obligations under applicable data protection/data privacy laws when processing any personal data of proposed or authorized users;

Obtain necessary consents (if any) for the disclosure of their personal data to facilitate the provision of the Telima for Business functionality; and

implement appropriate legal, technical and organizational measures to protect Personal Data against unauthorized or unlawful processing and against unauthorized loss, destruction, damage, alteration or disclosure, as well as any breach or attempted breach of its security measures (“Information Security Incident”).

ADDENDUM 2: TELIMADEFENCE PRIVACY STATEMENT

This Privacy Statement (“Statement”) describes how Telima collects, uses, processes and discloses data through the use of Telima Defence and its associated services (“TelimaDefence”).

Telima provides its customers (“GD Customers”) with the TelimaDefence service that helps prevent, detect and combat fraud or dangerous activities on their platforms and applications (such as web-based e-commerce platforms and mobile applications) (“Digital Platforms”). GD Customers will integrate TelimaDefence into their digital platforms to identify potentially fraudulent activities on their digital platforms.

This Statement applies to users of GD Clients’ digital platforms (“you”) and strictly concerns data collected, used and disclosed on behalf of GD Clients for the purpose of providing TelimaDefence. Please refer to the applicable GD Clients’ terms of service and/or privacy notices to understand how they collect, use and disclose your data.

I. DATA COLLECTION

To provide TelimaDefence to GD Clients, information from your device and information relating to your use of the GD Clients’ digital platform will be collected from GD Clients. This information includes device identification information (such as IMEI, Android ID, MAC address, etc.), device and hardware information (such as device name, screen size, etc.), account information (such as email address, phone number, etc.) and other contextual data related to your use of GD Clients’ Digital Platforms (such as IP address, Wi-Fi address, GPS location data, address, payment details, etc.). This information is collected by GD Clients when you interact with GD Clients’ Digital Platforms, in accordance with GD Clients’ Terms of Service and/or Privacy Notices. We may combine the information we have collected from GD customers with data points from the Telima ecosystem to obtain relevant information (e.g., information about the presence of signs of application modification, data manipulation, device tampering, GPS spoofing). We do not attempt to personally identify you based on the above information in order to provide TelimaDefence to GD customers.

II. USE OF DATA

We generally process your information on behalf of GD customers to assist them in their fraud detection efforts. It is up to GD customers to decide whether to apply the results obtained from the use of Telima Defence on their digital platforms.

In this regard, we may use, combine and process your information for the following purposes (“Purposes”):

providing, operating and maintaining TelimaDefence;

defect investigation and troubleshooting of TelimaDefence;

research and development for TelimaDefence, including but not limited to improving existing features and services, or developing new features and services, for Telima Defence;

detecting patterns in collected datasets to gather information about fraudulent activities;

for regulatory compliance and internal audit purposes; and

respond to any law enforcement request or court order.

Please be assured that the information collected will not be used by Telima for marketing purposes or combined with other data sets available to Telima in a manner that would unfairly prejudice you.

III. DATA DISCLOSURE

We may share information with various parties for the purposes intended. These parties include:

GD Customers, with whom you are registered as a user;

Our subsidiaries and affiliates;

Our service providers (for example, we use the Amazon Web Services cloud to host your information); and

Our legal advisors, law enforcement officials and government authorities.

Except for the parties mentioned above, we will not disclose your information to third parties.

IV. YOUR RIGHTS OVER YOUR DATA

In accordance with applicable privacy laws and to the extent that any information collected in connection with the use of TelimaDefence may constitute personal data, you may have the right to access or update your personal data. Since the processing of your personal data by Telima Defence is based on the use of TelimaDefence by GD customers when you use their digital platforms, if you wish to exercise your rights, we recommend that you contact the operator of the digital platform you use directly to obtain more information on how your information is used and processed, and to exercise your rights over your personal data.

V. DATA RETENTION

We retain your information for as long as we have a business purpose (i.e. to provide TelimaDefence and to achieve the objectives) or a legal purpose for doing so. Once these purposes have been achieved, we take steps to destroy or anonymize your information.

VI. INTERNATIONAL DATA TRANSFERS

Your information may be transferred from the country, state and city (“Home Country”) in which you are present when using GD Customer Digital Platforms to another country, state and city (“Other Country”).

VII. DATA PROTECTION

We will take reasonable legal, organizational and technical measures to ensure that your information is protected. This includes measures to prevent loss, use or unauthorized access to data. We limit access to your information to our employees on a need-to-know basis. Those who process your data will do so only in an authorized manner and are required to treat your information confidentially.

However, please be aware that the transmission of information via the Internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of your information transmitted by any online means. Therefore, any transmission remains at your own risk.

VIII. CHANGES AND UPDATES

Telima shall have the right to modify, update or amend the terms of this Statement at any time by posting the updated Statement on its website.

If you have any questions about how your data is used, please contact the GD client with whom you may be registered as a user. If you have any further questions regarding TelimaDefence, please contact our Data Protection Officer via the form provided in Telima's Privacy Statement.

Conclusion:

This Privacy Policy aims to ensure transparency about how user data is managed, while respecting their privacy and being in accordance with current regulations.