## PRIVACY POLICY

### Date: December 01, 2023

### TABLE OF CONTENTS

- ### 1.PURPOSE OF THIS POLICY

- ### 2.CONTACT DETAILS

- ### 3.CONTROLLER

- ### 4.PRIVACY POLICY

- ### 5.THE DATA WE COLLECT

- ### 6.HOW IS YOUR PERSONAL DATA COLLECTED

- ### 7.PURPOSES FOR WICH WE WILL USE YOUR PERSONAL DATA

- ### 8.INTERNATIONAL TRANSFERS

- ### 9.RETENTION PERIOD

- ### 10.YOUR LEGAL RIGHTS

- ### 11.SAFETY MEASURES

### 1. PURPOSE OF THIS POLICY

1.1. This Privacy Policy sets out how we collect and use your personal information when you use our AENO kitchen robot ( the “Robot”), and the choices available to you in relation to the use of your personal information (the Privacy Policy).

This Policy is designed to help you understand our privacy practices, including what personal data we collect, why we collect it, what we do with it and how we protect it, as well as your individual rights. It also describes how you may contact us to learn more about our data practices or to exercise your rights.

1.2. This Policy is designed to help you understand our privacy practices, including what personal data we collect, why we collect it, what we do with it and how we protect it, as well as your individual rights. It also describes how you may contact us to learn more about our data practices or to exercise your rights.

1.3. It is important that any data we collect, and store is accurate. Therefore, if anything changes regarding your personal data during your relationship with us, please keep us informed.

1.4. We may change this Policy from time to time, to reflect how we are processing your data, and if we make changes, we will notify you by revising the effective date at the top of this Policy. If we make significant changes that materially affect your privacy rights, we will provide advanced notice and make that clear on the robot, or by some other means of contact such as email, so that you are able to review the changes before you continue using the Services. If you do not agree with the modified Policy, please discontinue the use of the Services or do not consent to the updates.

1.5. If you have any questions about this privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below.

### 2. CONTACT DETAILS

1 Iapetou, Agios Athanasios, 4101, Limassol, Cyprus

Email: dpo@asbis.com – Data Protection Officer

### 3. CONTROLLER

3.1. ASBISC ENTERPRISES PLC, a company registered under the legislation of the Republic of Cyprus, with registered number HE 75069, registered address: 1 Iapetou,4101, Agios Athanasios, Limassol, Cyprus, (“the Company”, “We”, “Us” “Our”), and its affiliated companies, are the Data Controllers and responsible for your personal data. For the purposes of this policy an affiliated company, means an entity which, directly or indirectly, owns or controls, is owned or is controlled by or is under common ownership or control with another entity. As used herein, “control” means the power to direct the management or affairs of an entity, and “ownership” means the beneficial ownership of fifty percent (50%) or more of the voting equity securities or other equivalent voting interests of the entity.

### 4. PRIVACY POLICY

4.1 In making the robot available to you, we act reasonably and believe that:

- you have all necessary rights to register and use the robot.
- you are at least 18 years of age or older.
- provide true information about yourself to the extent necessary to use the robot.
- you understand that by posting your personal information you have apparently made that information public and that information may become available to the Company.
- you understand that certain types of information transmitted by you to other users of the robot cannot be deleted by you or the Company.
- you understand and accept the provisions of this Privacy Policy.

4.2. We do not review the user information we receive from you unless such review is necessary for the Company to fulfil its obligations to you.

4.3. This Privacy Policy applies to EU citizens only.

### 5. THE DATA WE COLLECT

5.1 When using the term “Personal Data” in our Privacy Policy, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold. We collect, use, store and transfer different kinds of personal data grouped together as follows:

a) Identity Data

Includes: name/middle name/last name, nickname or similar identifiers

b) Contact Data

Includes: email address

c) Account data:

Includes: age, gender, recipes, notes on recipes

d) Technical Data

Includes: Information about your technical devices, history activity on the robot technical interaction with the robot.

e) Usage Data

Includes: information on how you use the robot.

f) Aggregated Data

Includes: We collect, use, and share Aggregated Data. This kind of data, result from processing personal data for statistical purposes (output data). Aggregated data are derived from your personal data but are not considered personal data as they do not reveal your identity directly or indirectly.

g) Special Category Data

We DO NOT collect any Special Category Personal Data. Meaning details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, genetic, biometric data. Nor do we collect any information about criminal convictions or offences.

### 6. HOW IS YOUR PERSONAL DATA COLLECTED

6.1 We collect your data through different methods:

1.Direct interactions

You provide us with your Identity, Contact data and Account Data.

This includes personal data you provide when you:

- Register as a user and use the robot

2. Automated technologies or interactions | When you interact with the robot, we automatically collect Technical Data.

### 7. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

Purpose/ Activity | Type of data | Legal basis for processing
We use these data so we can provide our services to you. | Identity data Contact data Account data | Consent

7.1. Your personal information may also be processed if required by law enforcement or a regulatory authority, body or agency or for the defence or exercise of legal claims. We will not delete personal information if it is related to an investigation or dispute. They will continue to be stored until these issues are fully resolved and/or during the period required and/or permitted under applicable/relevant law.

7.2. Please note that if you do not want us to process sensitive and special categories of data about you (including data related to your health, racial or ethnic origin, political opinions, religious or philosophical beliefs, sex life and sexual orientation) you should take care not to publish this information or share this data through the robot. Once you provide this data, it will be accessible by us and third-party partners.

7.3. Please note that you have the right to withdraw your consent at any time. If you withdraw your consent to processing or do not register as a user you may continue using the robot.

7.4. If we intend to further process your data for any purpose other than those set out in this Privacy Policy, we will provide you with details of that purpose before we start processing.

### 8.INTERNATIONAL TRANSFERS

8.1. We may transfer and maintain some of your personal information on our servers or databases outside the European Union.

8.2. Countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or apply standard contractual clauses (e.g., Standard Clauses, Data Processing Agreement/Addendum) to ensure that your data is adequately protected.

### 9. RETENTION PERIOD

9.1. We will retain your personal data for as long as necessary to carry out the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or if additional legal/regulatory obligations require us to retain your personal data in during the period required and/or permitted under applicable/relevant legislation.

9.2. You can delete your personal data by removing the data from your account. Alternatively, you can remove your page using the Remove My Profile feature available.

9.3 We may remove your account or the information you post on your account if there are reasons provided by applicable law or as provided by the terms.

### 10. YOUR LEGAL RIGHTS

10.1. Under certain circumstances, you have rights under data protection laws in relation to your personal data.

10.2. Access. Request access to your personal data (commonly known as “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

10.3. Rectification, Portability, and Deletion of your Personal Information. You have the right to correct or update your personal data, object to the processing of your personal data, ask us to restrict processing of your personal data, or request the portability of your personal data. To protect the privacy and the security of your personal data, we may request data from you to enable us to confirm your identity and your right to access such data, as well as to search for and provide you with the personal data we maintain upon your request. There are instances where applicable laws or regulatory requirements allow or require from us to refuse to provide or delete some or all the personal information that we maintain.

10.4. Request erasure of your personal data. This enables you to request the deletion or removal of your personal data when there is no good reason for us to continue processing it. You also have the right to request for deletion or removal of your personal data when you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be communicated to you, if applicable, at the time of your request.

10.5. Object to processing of your personal data when we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object when we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

10.6. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to the use of your data but we need to verify whether we have overriding legitimate grounds to use it.

10.7. Request the transfer of your personal data to you or to a third party. We will provide to you, or to a third party of your choice, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

10.8. Withdraw consent at any time when we rely on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

10.9. Object to the receipt of advertising brochures via traditional mail. If you no longer wish for us to use your postal address to send you marketing brochures by means of traditional mail, please contact us or (via the return address provided with each advertising brochure), to submit your request to unsubscribe from further postal advertising.

10.10. You also have the right to independently remove your account, the information in your account, and make changes and corrections to your account.

10.11. Lodging Complaints. If you believe we have infringed or violated your privacy rights, please contact us so that we may attempt to resolve any issues to your satisfaction. Notwithstanding the approaches of exercising your rights stated above, this is without prejudice to your right to lodge a claim or complaint to your data protection authority (more details on data protection authorities and their contact info can be found at https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en ).

10.12. If you wish to exercise any of the rights set out above, please contact us either through support or by using the contact details provided in section 2. We will aim to respond to you within 30 days from receipt of request. We will need to verify your identity before we are able to disclose any personal information to you.

### 11. SAFETY MEASURES

11.1. We take technical, organizational and legal measures, including encryption where appropriate, to ensure that your personal data is protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.

11.2. Access to your account is authorized using your login details (e-mail address) and password. You are responsible for keeping this information confidential. You should not share your credentials with third parties and we recommend that you take steps to ensure that this information remains confidential.