Data Handling Policy

This Data Handling Policy for Brobintech ("we," "us," "our", or "Brobintech"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our website, all related websites (subdomains), other services provided by Brobintech ("Services"), including when you:

• Visit our website at https://www.brobintech.com/ , or any website of ours that links to this Privacy Policy
• Engage with us in other related ways (written or oral), including any sales, marketing, or events.

Summary of key points

This summary provides key points from our Privacy Policy, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

• What personal information do we process?

We may process personal information when you visit, use, or interact with our Services. The type of information depends on how you engage with us.

• Do we process any sensitive personal information?

We do not process sensitive personal information (e.g., data concerning racial or ethnic origin, sexual orientation, or religious beliefs), even if it is classified as such under certain data protection laws.

• Do we collect any information from third parties?

We do not intentionally collect personal data from third parties. However, in some cases, we may receive information about you from publicly available sources or other individuals. For example, this may happen if you publish your CV online, or if someone recommends you as a potential job candidate. If we receive such information, we handle it in accordance with this Privacy Policy and applicable data protection laws.

• How do we process your information?

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with legal obligations. In some cases, we process information based on your consent or other lawful grounds. We process your information only when we have a valid legal reason to do so.

• Do we share personal information with third parties?

We may share information in specific situations and with specific third parties. We do not sell your personal information.

• How do we keep your information safe?

We implement appropriate technical and organizational measures to safeguard your personal data. However, no system is entirely secure, and we cannot guarantee absolute protection against unauthorized access, cyberattacks, or other security breaches.

• 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.

• How do you exercise your rights?

The easiest way to exercise your rights is by contacting us info@brobintech.com . We will review and respond to your request in accordance with applicable laws.

• Want to know more?

Please read the full Privacy Policy for more detailed information on how we handle personal data.

What information do we collect?

Personal information you 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 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 features you use. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• job titles
• company name

In addition, we may collect data about our communications with you, the content and results of such communications, our internal records about you, and publicly available professional information about you.

Sensitive Information.

We do not process sensitive information.

We receive and process personal information as provided by you and do not independently verify its accuracy. You are responsible for ensuring that all personal information you provide is true, complete, and accurate. Where required by law, we may take reasonable steps to correct or update inaccurate information.

Information automatically collected

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

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact 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 use our Services, 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.

The information we collect includes:

• Log and Usage Data.

  Information our servers collect automatically, including diagnostic, usage, and performance data (e.g., IP address, browser type, access times, pages visited, crash reports, etc.).

• Device Data.

  Information about the device you use to access our Services, which may include device ID, hardware model, browser type, IP address or proxy, operating system, system configuration, ISP or mobile provider.

• Location Data.

  Information about your device's location, which may be either precise or general. For example, we may collect your IP-based location. You can disable location tracking in your device settings, but doing so may limit your use of certain features.

How do we process your information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To provide and improve our services.

  We collect and process personal data to deliver our services, ensure functionality, and enhance user experience.

• To fulfill contractual obligations.

  Processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract.

• Comply with legal obligations.

  We may process personal data to comply with applicable laws, regulations, and legal processes.

• To communicate with you.

  We use personal data to respond to inquiries, provide customer support, and send important updates.

• For marketing and promotional purposes.

  With your consent, we may process data to send newsletters, offers, and other marketing communications.

• Contacting candidates who have expressed interest in working with us.

What legal bases do we rely on to process your information?

In Short: We only process your personal information when we believe 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, or to fulfill our legitimate business interests.

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

• Consent.

  We may process your information 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.

• Performance 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.

• 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.

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

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

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For business transactions provided certain conditions are met
• If it 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 a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the information is publicly available and is specified by the regulations

No Solely Automated Decision-Making.

We do not use your personal information to make decisions that are based solely on automated processing which produce legal effects concerning you or similarly significantly affect you.

When and with whom do we share your personal information?

In Short: We may share information in specific situations described in this section and/or with the following 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.

We also may need to share your personal information in the following situations:

• Business Transfers.

  We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Affiliates.

  We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

Do we use cookies and other tracking technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising. The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?"

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

R! B2B Services

We may share your information with RB2B. When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email. We (or service providers on our behalf) may then send communications and marketing to these email. You also have the option to opt out of the collection of your personal data in compliance with GDPR. To exercise this option, please visit https://www.rb2b.com/rb2b-gdpr-opt-out. For more information on the privacy practices of R! B2B Services, please visit the Privacy Policy page.

Is your information transferred internationally?

In Short: We may transfer, store, and process your information in countries other than your own.

If you are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, please note that your personal data may be transferred to and processed in countries outside your jurisdiction, including the United States, where data protection laws may differ. We take appropriate safeguards to ensure that such transfers comply with applicable data protection laws, including the General Data Protection Regulation (GDPR). Where necessary, we rely on legally recognized mechanisms such as Standard Contractual Clauses approved by the European Commission, or other lawful bases under Article 49 GDPR.

By supplying BroBinTech.com with your Personal Data, you permit its transfer outside the country within the bounds of use of such Personal Data in accordance with the applicable local laws and General Data Protection Regulation requirements.

How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law.

We keep your personal data for as long as it is necessary to do so to fulfil the purposes for which it was collected as described above. The criteria we use to determine data retention periods for personal data includes the following: retention in accordance with legal and regulatory or internal business requirements. We may retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse or till there is legitimate interest need.

By supplying BroBinTech.com with your Personal Data, you permit its transfer outside the country within the bounds of use of such Personal Data in accordance with the applicable local laws and General Data Protection Regulation requirements.

Personal data may be retained in backups and/or historical system archives. If we no longer need your personal data as described above, we delete or anonymize the personal data, in accordance with regulatory provisions and applicable law.

How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate 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.

Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. 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 take reasonable measures to promptly delete such data from our records.

If you are under 18 years of age (or any other age under the applicable law), then please do not use or access the website at any time or in any manner or contact us and provide the consent of your parent or legal guardian.

If you become aware of any data we may have collected from children under age 18, please contact us at info@brobintech.com .

What are your privacy rights?

In Short: Depending on your state of residence in the US or in some regions, 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.

In some regions (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 CAN YOU CONTACT US ABOUT THIS Policy?" below.

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

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 YOU CONTACT US ABOUT THIS Policy?" 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.

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.

Controls for do-not-track features

In Short: Depending on your state of residence in the US or in some regions, 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.

Most web browsers and some mobile operating 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 finalized. 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 Policy.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

Do United States residents have specific privacy rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

Category	Examples	Collected
Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	Yes
Personal information as defined in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	Yes
Protected classification characteristics under state or federal law	Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data	No
Commercial information	Transaction information, purchase history, financial details, and payment information	No
Biometric information	Fingerprints and voiceprints	No
Internet or other similar network activity	Browse history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	Yes
Geolocation data	Device location	No
Audio, electronic, sensory, or similar information	Images and audio, video or call recordings created in connection with our business activities	No
Professional or employment-related information	Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us	Yes
Education Information	Student records and directory information	No
Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics	Yes
Sensitive personal information		No

We may also collect other personal information outside of the categories listed above in situations where you interact with us in person, online, by phone, or by mail. These interactions may include:

• Receiving assistance through our customer support channels;
• Applying for job vacancies or submitting your CV;
• Participating in customer surveys or contests; and assisting in the delivery of our Services and responding to your inquiries.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

• Category A. Identifiers
• Category B. Personal information as defined in the California Customer Records law
• Category D. Commercial information
• Category F. Internet or other electronic network activity information
• Category H. Audio, electronic, visual, and similar information
• Category I. Professional or employment-related information
• Category K. Inferences drawn from collected personal information

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

The categories of third parties to whom we shared personal information with are:

• Advertising, Direct Marketing, and Lead Generation

• Affiliate Marketing Programs

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including Minnesota’s privacy law)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California's and Delaware's privacy law)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Minnesota's and Oregon's privacy law)
• Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including Minnesota’s privacy law)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)

How to Exercise Your Rights

To exercise these rights, you can contact us by email info@brobintech.com, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at info@brobintech.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS Policy?"

Do other regions have specific privacy rights?

In Short: You may have additional rights based on the country you reside in.

Australia

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 (Privacy Act).

This Privacy Policy satisfies the notice requirements defined in the Privacy Act, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:

• offer you the products or services that you want
• respond to or help with your requests

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"

Do we make updates to this policy?

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

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, 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 Policy frequently to be informed of how we are protecting your information.

How can you contact us about this policy?

If you have questions or comments about this Policy, you may email us at info@brobintech.com.

How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information.