Last updated December 21, 2023

This privacy notice for PIHL T/A Kway.ai ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

● Visit our website at https://kway.ai, or any other website of ours that links to this privacy notice

● Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at compliance@kway.ai.

SUMMARY OF KEYPOINTS

This summary provides key points from our privacy notice, but you can find more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about the personal information you disclose to us.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, ensure security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with certain categories of third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the privacy notice in full.

TABLE OFCONTENTS

1. WHATINFORMATIONDOWECOLLECT?

2. HOWDOWEPROCESSYOURINFORMATION?

3. WHATLEGALBASESDOWERELYONTOPROCESSYOURPERSONAL INFORMATION?

4. WHENANDWITHWHOMDOWESHAREYOURPERSONAL INFORMATION?

5. DOWEUSECOOKIESANDOTHERTRACKINGTECHNOLOGIES?

6. IS YOURINFORMATIONTRANSFERREDINTERNATIONALLY?

7. HOWLONGDOWEKEEPYOURINFORMATION?

8. HOWDOWEKEEPYOURINFORMATIONSAFE?

9. DOWECOLLECTINFORMATIONFROMMINORS?

10. WHATAREYOURPRIVACYRIGHTS?

11. CONTROLS FORDO-NOT-TRACKFEATURES

12. DO UNITEDSTATESRESIDENTSHAVESPECIFICPRIVACYRIGHTS?

13. DO WEMAKEUPDATESTOTHISNOTICE?

14. HOWCANYOUCONTACTUSABOUTTHISNOTICE?

15. HOWCANYOUREVIEW,UPDATE,ORDELETETHEDATAWECOLLECT FROMYOU?

16. WHATINFORMATIONDOWECOLLECT? Personalinformationyou disclose to us In Short: We collect personal information that you provide to us

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

● Names ● Phone numbers ● Email addresses ● Company names

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics —iscollected automatically when you visit our Services.

Weautomatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your nameorcontact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you useourServices, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: https://kway.ai/cookies.

Information collected from other sources In Short: We may collect limited data from public databases, marketing partners, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

1. HOWDOWEPROCESSYOURINFORMATION?InShort:Weprocess your information to provide, improve, and administer our Services, communicate with you, ensure security and fraud prevention, and comply with the law. We mayalso process your information for other purposes with your consent.

Weprocess your personal information for a variety of reasons, depending on howyouinteract with our Services, including:

● Todeliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

● Torespondtouserinquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

● Tosendadministrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

● Tofulfill and manageyourorders. We mayprocess your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.

● Toenableuser-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.

● Torequestfeedback. Wemayprocessyour information when necessary to request feedback and to contact you about your use of our Services.

● Tosendyoumarketingandpromotionalcommunications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHATAREYOURPRIVACYRIGHTS?"below.

● Todeliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more. For more information, see our Cookie Notice: https://kway.ai/cookies.

● ToprotectourServices. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

● Toidentify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

● Todeterminetheeffectiveness of our marketing and promotional campaigns. We mayprocess your information to better understand howtoprovide marketing and promotional campaigns that are most relevant to you.

● Tosaveorprotect anindividual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

1. WHATLEGALBASESDOWERELYONTOPROCESSYOUR INFORMATION?InShort: We only process your personal information whenwebelieve it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information

● Consent. Wemayprocessyourinformation if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.

● PerformanceofaContract. We mayprocess your personal information whenwebelieve it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into aPerformance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not override your interests and fundamental rights and freedoms. For example, we mayprocess your personal information for some of the purposes described in order to:

● Sendusersinformation about special offers and discounts on our products and services

● Developanddisplay personalized and relevant advertising content for our users

● AnalyzehowourServices are used so wecanimprovethemtoengage and retain users

● Supportourmarketing activities

● Diagnoseproblemsand/or prevent fraudulent activities

● Understandhowourusersuseourproducts andservices so we can improve user experience

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

Wemayprocessyourinformation if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In someexceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

● Ifcollection is clearly in the interests of an individual and consent cannot be obtained in a timely way

● Forinvestigations and fraud detection and prevention

● Forbusiness transactions provided certain conditions are met

● Ifit is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

● Foridentifying injured, ill, or deceased persons and communicating with next of kin

● Ifwehavereasonable grounds to believe an individual has been, is, or maybeavictimoffinancial abuse

● Ifit is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or acontravention of the laws of Canada or a province ● Ifdisclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

● Ifit wasproduced byanindividual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

● Ifthecollection is solely for journalistic, artistic, or literary purposes

● Iftheinformation is publicly available and is specified by the regulations 4. WHENANDWITHWHOMDOWESHAREYOURPERSONAL INFORMATION?InShort: We mayshareinformation in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:

● Sales&Marketing Tools

● DataAnalytics Services

● AdNetworks

● Affiliate Marketing Programs

● PerformanceMonitoring Tools

● ProductEngineering & Design Tools

● Retargeting Platforms

● UserAccountRegistration & Authentication Services

● DataStorageService Providers

Wealso mayneedtoshareyourpersonal information in the following situations:

● Business Transfers. We mayshare or transfer your information in connection with, or during negotiations of, any merger, sale of companyassets, financing, or acquisition of all or a portion of our business to another company.

5. DOWEUSECOOKIESANDOTHERTRACKINGTECHNOLOGIES?In Short: We mayusecookies and other tracking technologies to collect and store your information.

Wemayusecookiesandsimilar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://kway.ai/cookies.

6. IS YOURINFORMATIONTRANSFERREDINTERNATIONALLY?InShort: Wemaytransfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom wemayshareyourpersonal information (see "WHEN AND WITHWHOMDOWESHAREYOURPERSONALINFORMATION?"above), in the United States, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

7. HOWLONGDOWEKEEPYOURINFORMATION?InShort:Wekeep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

Wewill only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

Whenwehavenoongoinglegitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOWDOWEKEEPYOURINFORMATIONSAFE?InShort:Weaimto protect your personal information through a system of organizational and technical security measures.

Wehaveimplementedappropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. DOWECOLLECTINFORMATIONFROMMINORS?InShort:Wedonot knowingly collect data from or market to children under 18 years of age.

Wedonotknowinglysolicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at compliance@kway.ai.

10. WHATAREYOURPRIVACYRIGHTS?InShort: Insomeregions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In someregions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CANYOUCONTACTUSABOUTTHISNOTICE?"below.

Wewill consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your MemberState data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOUCONTACTUSABOUTTHISNOTICE?"below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance

on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACTUSABOUTTHISNOTICE?"below.Youwillthenberemovedfrom the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice: https://kway.ai/cookies.

If you have questions or comments about your privacy rights, you may email us at compliance@kway.ai..

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most webbrowsers andsomemobileoperating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been f inalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

12. DO IRISH RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of Ireland, Colorado, please see your privacy rights here.

13. DO WEMAKEUPDATESTOTHISNOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

Wemayupdatethisprivacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

For European Data Protection and Online Privacy please see more information here.

14. HOWCANYOUCONTACTUSABOUTTHISNOTICE?

If you have questions or comments about this notice, you may email us at help@kway.ai or contact us by post at:

PIHL LTDT/A Kway.ai Heritage Business Park, Mahon, Cork, T12 P1HX Ireland

15. HOWCANYOUREVIEW,UPDATE,ORDELETETHEDATAWECOLLECT FROMYOU?

Based ontheapplicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please fill out and submit a data subject access request